Privacy & Dataprotection

Privacy & dataprotection policy.


1. Introduction
Privacy and data protection laws protect the integrity and confidentiality of a person’s private information. AFFEXCO global is committed to protecting the privacy rights of our employees and everyone with whom we cooperate or do business. We will only use personal data for appropriate purposes, and personal data will be processed in accordance with applicable data protection regulation.

Within AFFEXCO global, the data controller will be Affiliate Executive Coaches Bouwhuis. Affiliate Executive coaches Bouwhuis operates AFFEXCO.com / AFFEXCO global and is the controller for the processing of personal data generated from using the site, as well as a number of the processes described in clause 2 below.

2. AFFEXCO global’s processing of personal data

2.1. General
AFFEXCO global processes personal data about employees and external consultants. We also process personal data from members and visitors applying for membership.

AFFEXCO global  will always process personal data fairly and lawfully, and only for a specified, explicit and legitimate purpose or as required by law. AFFEXCO global will therefore only process personal data when such processing is necessary for us to manage our operations, provide services or other legitimate (business) interests, comply with legal or contractual obligations or after receiving consent (the latter which can be withdrawn at any time). Withdrawing consent will not affect the lawfulness of the processing based on the consent prior to withdrawing it. Further information on specific legal basis is provided below.

AFFEXCO global will ensure appropriate information security related to confidentiality, integrity and availability. Personal data will be retained only for the period that is required to serve the legitimate purpose.

Third party service providers may process personal data on behalf of AFFEXCO global within various areas. AFFEXCO global has implemented adequate safeguards in accordance with applicable law to protect your personal data processed by third party service providers.

AFFEXCO global processes personal data about data subjects that are not employed or engaged by AFFEXCO global for these various purposes:

2.2. Communication
AFFEXCO global communicates externally and internally with the general public, specific target groups and individual persons. Examples of communication activities that might be performed by AFFEXCO global or third parties are distribution of newsletters, press releases, company reports, optimising websites, organising events, handling user-initiated dialogue, providing information to public authorities, conducting surveys, and communicating in social media networks. The personal data processed includes contact information and communication-related information.  The legal basis is legitimate interest in providing information and ensuring good management of and support for our customers, suppliers and partners, or your consent.

2.3. Website and cookies
AFFEXCO global does not use any cookies or analytic instruments on the site at this point.

3. Categories and collection of personal data
For easier understanding of this privacy policy we have set up the following categories. This does not mean or entail that the processing will always entail all the examples of personal information included in the categories.

The categories of personal data AFFEXCO global may collect and hold about data subjects include:

  • Contact information, such as names and addresses, telephone numbers and email addresses, titles etc.
  • Application information, such as short bios, references, background checks on certification, interviews and assessments.
  • Human resources information such as details about an individual’s work experience and qualifications, date of birth, identification documentation.
  • Communication-related information, such as public political relations, positions, preferences related to marketing and events, and information related to user behavior in own communication-channels (including IP-addresses).

Personal data may be collected in several ways, including:

  • from a third-party service provider or agent, from a source of publicly available information (e.g. websites) or from an employer (e.g. where a supplier or contractor provides personal data about their employees); 
  • through use of AFFEXCO global’s website; or
  • data provided directly by you.

4. Transfer of personal data

AFFEXCO global will ensure that the European rules on trans-border data flows are complied with when personal data are transferred to external processors (outside AFFEXCO global) located outside of EU/EEA or located in a country that is not recognised by the EU Commission as ensuring an adequate level of protection. AFFEXCO global has binding rules to this purpose.

5. How to exercise your rights as a data subject
National and international data protection gives rights to data subjects. The data subjects have, under some circumstances and subject to the laws of the particular jurisdiction, the right to request access, rectification, erasure and/or restriction to processing of their data.

If you have questions or want to exercise your rights as a data subject, please contact us on bbendox@gmail.com. You have a right to complain to the Norwegian or local Data Protection Authority if you consider that we have breached the data protection legislation, but we encourage you to first contact us to see if we can sort out your complaint, before filing one.

6. Notice to California Residents
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, read the aditional text on this subject under point X below.

7. Changes to this privacy policy
We may update this privacy policy from time to time. If such updates are not material, we may make such alterations without posting a specific notice on our website. If the changes are material and affects your rights or the way we process personal data, we will provide a specific notice on our website.
Please review this privacy policy from time to time

X. DATAPROTECTION supplement for California residents.

 PRIVACY NOTICE FOR CALIFORNIA RESIDENTS Last Updated: 20 December 2019 This Privacy Notice for California Residents supplements the information contained in AFFEXCO global’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). AFFEXCO global adopts this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice. Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements. AFFEXCO global collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include: • Publicly available information from government records; • Deidentified or aggregated consumer information; and • Information excluded from the CCPA’s scope. In particular, AFFEXCO global  has collected the following categories of personal information from its consumers within the last twelve (12) months: • Contact information, such as names and addresses, telephone numbers and email addresses, titles etc.; • Recruitment information, such as application, CV, references, background checks of certification, interviews and assessments • Human resources information such as details about an individual’s work experience and qualifications, date of birth. Use of Personal Information AFFEXCO global may use or disclose the personal information we collect for one or more of the following purposes: • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, AFFEXCO global will use that personal information to respond to your inquiry; • To provide, support, personalize, and develop our Website, products, and services; • To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our responses; 2 20494616_1 • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law); • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business, local grievance mechanisms, and emergency response, which are described in the AFFEXCO global Privacy Policy; • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services; • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; • As described to you when collecting your personal information or as otherwise set forth in the CCPA; and • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred. AFFEXCO global will not collect additional categories of personal information or use the personal information AFFEXCO global collected for materially different, unrelated, or incompatible purposes without providing you notice. Sharing personal information AFFEXCO global may disclose your personal information to a third party for a business purpose. When AFFEXCO global discloses personal information for a business purpose, AFFEXCO global enters a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. AFFEXCO global shares your personal information with the following categories of third parties: • Service providers. • Partners. Disclosures of Personal Information for a Business Purpose In the preceding twelve (12) months, AFFEXCO global has not disclosed the following categories of personal information for a business purpose: • Category A: Identifiers. • Category B: California Customer Records personal information categories. • Category C: Commercial information. • Category D: Internet or other similar network activity. Sales of Personal Information In the preceding twelve (12) months, AFFEXCO global has not sold personal information of consumers. 3 20494616_1 Your Rights and Choices The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. Access to Specific Information and Data Portability Rights You have the right to request that AFFEXCO global disclose certain information to you about AFFEXCO global’s collection and use of your personal information over the past 12 months. Once AFFEXCO global receives and confirms your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), AFFEXCO global will disclose to you: • The categories of personal information AFFEXCO global collected about you; • The categories of sources for the personal information AFFEXCO global collected about you; • Our business or commercial purpose for collecting or selling that personal information; • The categories of third parties with whom AFFEXCO global shares that personal information; • The specific pieces of personal information AFFEXCO global collected about you (also called a data portability request); and • If AFFEXCO global disclosed your personal information for a business purpose including, disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. AFFEXCO global does not provide these access and data portability rights for B2B personal information. Deletion Request Rights You have the right to request that AFFEXCO global delete any of your personal information that AFFEXCO global collected from you and retained, subject to certain exceptions. Once AFFEXCO global  receives and confirms your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), AFFEXCO global will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you. 2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 3. Debug products to identify and repair errors that impair existing intended functionality. 4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. 5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). 6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the 4 20494616_1 information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. 7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. 8. Comply with a legal obligation. 9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it. We do not provide these deletion rights for B2B personal information. Exercising Access, Data Portability, and Deletion Rights To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: • Emailing us at bbendox@gmail.com or • Visiting https://www.affexco.com/en/about-us/contact. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your name, employee number, owner number, mailing address, property location, last four digits of the social security number, last-received check number, and/or other data points which AFFEXCO global has in its records and can be used to verify the authenticity of the request. • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. AFFEXCO global cannot respond to your request or provide you with personal information if AFFEXCO global cannot verify your identity or authority to make the request and confirm the personal information relates to you. AFFEXCO global will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Response Timing and Format AFFEXCO global does what it can to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, AFFEXCO global will inform you of the reason and extension period in writing. Any disclosures AFFEXCO global provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response AFFEXCO global provides will also explain the reasons AFFEXCO global cannot comply with a request, if applicable. For data portability requests, AFFEXCO global will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. 5 20494616_1 AFFEXCO global does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If AFFEXCO global determines that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Non-Discrimination AFFEXCO global will not discriminate against you for exercising any of your CCPA rights. Changes to Our Privacy Notice AFFEXCO global reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes. Contact Information If you have any questions or comments about this notice, the ways in which AFFEXCO global collects and uses your information described here [and in the Privacy Policy], your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: Email: bbendox@gmail.com