Privacy Policy

INTRODUCTION
 
Wide Circle Performance Solutions bvba (the “Company”) respects the privacy concerns of the users of its website, www.WideCircle.eu and the services provided therein (the “Site”). The Company thus provides this privacy statement to explain what information is gathered during a visit to the Site and how such information is stored and may be used.
All persons working for, or contracted, by Wide Circle Performance Solutions are governed by this privacy policy and appropriate non-disclosure documents have been signed. Therefore, we may reference the Company as ‘we’ and ‘our’ because it’s relevant to how ‘we’ process and use your data.
 
Please also review the Terms of Use, which also govern use of this Site.
 
This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.WideCircle.eu or through your contact with us via other channels.
 
By providing us with your data, you warrant to us that you are over 13 years of age. Please see section below. 
 
Wide Circle Performance Solutions is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). We are also act as a data processor specifically when we process your Harrison Assessment questionnaire data to produce reports. 
 
Contact Details
 
Full name of legal entity: Wide Circle Performance Solutions bvba
Email address: [email protected]
Postal address: Rue Victor Philipsstraat 7, 3040 Huldenberg, Belgium
 
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at  [email protected].
 
We will ensure that all personal information supplied is held securely in accordance with the General Data Protection Regulation (EU) 2016/679, commonly known as "GDPR”.
Under the GDPR law we must inform you of how we use your data as you interact with www.WideCircle.eu. We will try to keep the ‘jargon’ to a minimum so it is clear what it all means.
 
However, just so you know we take this seriously, please understand that we will never sell, rent, distribute or do anything illegal with any of the data that you may provide either directly through this site or in direct contact with us, or indirectly through the use of cookies (for information, please see our "Use of Cookies" below).
 
As a general policy, no personally identifiable information, such as your name, address, or e-mail address, is automatically collected from your visit to the Site. However, certain non-personal information is recorded by the standard operation of the Company’s internet servers. Information such as the type of browser being used, its operating system, and your IP address is gathered in order to enhance your online experience.
The Site’s various mailing lists, downloads, special offers, contests, registration forms, and surveys may request that you give us contact information such as your name, mailing and/or e-mail address, demographic information such as your age and gender, and personal preference information such as your preferred software and interests. Information submitted at the time of submission will be used by the Company only as necessary for our legitimate business interests, including without limitation the improvement of our products, services and the contents of the Site. Personally identifiable information is never sold or leased to any third parties. With your permission, we may use your contact information to send you information about our company and products. You may always opt-out of receiving future mailings as provided below.
 
The Company does not store any credit card information it may receive in regard to a specific transaction and/or billing arrangement except as necessary to complete and satisfy its rights and obligations with regard to such transaction, billing arrangement, and/or as otherwise authorized by a user.
 
The Company may disclose user information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with the Company’s rights or property, other users of the Site, or anyone else that could be harmed by such activities. 
 
WHAT PERSONAL DATA WE COLLECT
 
We may collect and process the following types of data from you:
  • Identity and contact data such as email address, first name, last name, title, address, telephone numbers, business name, username and date of birth
  • Additional personal data when necessary to fulfil a service or contract with you e.g. to generate a Harrison Assessment report
  • Transaction data such as purchase details but excluding financial data
  • Technical and usage data such as IP address, your browsing history on our sites and device information
 
HOW WE COLLECT PERSONAL DATA
 
We collect data from and about you when you:
  • Subscribe to our services or newsletter
  • Correspond with us by post, phone email or otherwise
  • Fill in forms
  • Order our products or services
  • Provide feedback to us
  • Use our websites
  • Complete a Harrison Questionnaire
 
HOW WE USE AND PROCESS YOUR PERSONAL DATA
 
We only use your personal data when we have a valid reason. The legal bases for processing your data are generally consent that you have clearly given, to fulfil a contract with you or our legitimate interests. We may use your data when we are legally obliged in order to fulfil statutory requirements.
We store your personal data for a minimum of 2 years, except where you have requested us not to. Under Belgian law, we are legally required to retain financial and accounting data, which we will retain for 10 years.
We use your data to:
Fulfil a contract between us
  • To provide a service requested by you
  • To send marketing communications via email
  • To provide content relevant to you and measure the effectiveness of our advertising
  • To improve our websites, products and services
  • To comply with a legal obligation
  • To protect your vital interests
  • To protect our legitimate interests or the legitimate interests of a third party
 
WHERE WE STORE YOUR PERSONAL DATA
 
We use software platforms and payment gateways to store and process your information  including: Harrison Assessments, Kajabi, Mailchimp, Dropbox, Paypal, Stripe,  Google Analytics.
 
Where these sites are based in the United States, we will only transfer your personal data to them if they are part of the EU-US Privacy Shield.
 
Links to our social media accounts and other platforms on our websites –  Facebook, Twitter, Instagram, YouTube, Harrison Assessments. When viewing content or engaging with these sites, be aware that your use is subject to the Privacy, Cookie and Terms of Use policies set by those platforms. We encourage you to read these policies.
 
DISCLOSURE OF YOUR PERSONAL DATA
 
We may disclose your information to members of our Company to enable us to carry out the delivery of our products and services. We will only disclose your information externally where we have a duty to comply with a legal or regulatory obligation, or in the case where we we may sell any part of the businesses or assets.
 
YOUR RIGHTS
 
You have the right to:
  • Access, correction, erasure of your personal data
  • Objection to and restriction of processing of your personal data
  • Transfer of your personal data
  • Withdrawal of your consent where provided
To exercise any of these rights, please contact us at [email protected]. We aim to respond as soon as possible and in any case, within 30 days of your request.
Unless specifically requested, we do not delete your data if you unsubscribe from direct marketing, but hold your information as ‘suppressed’ within our data processing platforms.
 
CHILDREN AGED 13 AND UNDER 
 
The Company recognizes the special obligation to protect personally identifiable information obtained from children age 13 and under. AS SUCH, IF YOU ARE 13 YEARS OLD OR YOUNGER, THE COMPANY REQUESTS THAT YOU NOT SUBMIT ANY PERSONAL INFORMATION TO THE SITE OR TO THE COMPANY. If the Company discovers that a child age 13 or younger has signed up on the Site or provided us with personally identifiable information, we will delete that child’s identifiable information from our records.
The Company nonetheless encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer:
  • Teach kids never to give personal information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc.
  • Know the sites your kids are visiting and which sites are appropriate.
  • Look for Website privacy policies. Know how your child’s information is treated.
  • Check out appropriate websites for more tips on protecting children's privacy online
 
USE OF COOKIES 
 
Cookies are pieces of information that a website transfers to an individual’s computer hard drive for record keeping purposes. Cookies make using our Site easier by, among other things, saving your passwords and preferences for you. These cookies are restricted for use only on our Site, and do not transfer any personal information to any other party. Most browsers are initially set up to accept cookies. You can, however, reset your browser to refuse all cookies or indicate when a cookie is being sent. Please consult the technical information relevant to your browser for instructions. If you choose to disable your cookies setting or refuse to accept a cookie, some parts of the Site may not function properly or may be considerably slower.
 
The Company uses the following cookies on the Site:
Cookie
Name
Purpose
_kjb_session
Kajabi session cookie
Tracks your active admin session so you don't need to re-login
kjba
Kajabi affiliate token
Tracks which affiliate has referred an offer purchase
_abv
Admin bar hidden
Tracks whether the user wishes their admin previewing bar to be hidden
Malware/Spyware/Viruses: Neither the Company nor the Site knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.
 
LINKS TO EXTERNAL SITES 
 
The Company is not responsible for the content or practices of third party websites that may be linked to the Site. The Company is also not responsible for any information that you might share with such linked websites. You should refer to each website’s respective privacy policy and practices prior to disclosing any information.
 
BULLETIN BOARDS AND CHAT AREAS 
 
Guests of the Site are solely responsible for the content of messages they post on the Company’s forums, such as chat rooms and bulletin boards. Users should be aware that when they voluntarily disclose personal information (e.g., user name, e-mail address, phone number) on the bulletin boards or in the chat areas, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features. 
 
CHOICE/OPT-OUT
 
The Site may provide you the opportunity to opt-in to receive communications from us at the point where we request information about you. You always have the option of removing your name from any e-mail list in order to discontinue any such future communications. In order to ensure immediate removal from any list, please follow the specific instructions set forth within the communications you receive from the Company which you no longer wish to receive. If you are unsuccessful in completing the instructions specified in any such communication, please e-mail us at [email protected], including a copy of the undesired email attached to the request, and state you wish to be removed from the mailing list.
 
CONTACT INFORMATION FOR COMPLAINTS OR CONCERNS
 
If you have any complaints or concerns about the Company or about this privacy statement, please contact:
Via email: [email protected]
 
Information provided by you via general e-mail inquiries to the Company such as your e-mail address is used only to respond to your inquiries in the ordinary course of business, and is never shared with third parties.
 
SECURITY 
 
Security for all personally identifiable information is extremely important to us. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, The Company cannot ensure or warrant the security of any information you transmit via the internet. By transmitting any such information to the Company, you accept that you do so at your own risk.
 
YOUR ACCEPTANCE OF THESE TERMS 
 
By using the Site, you accept the policies and restrictions set forth in this Privacy Policy. If you do not agree to this policy, please do not use the Site. 
 
CHANGES TO PRIVACY POLICY
 
We  may update this policy from time to time. This Privacy Policy may be revised from time to time by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the then current Privacy Policy to which you are bound.Material changes or changes that affect your rights will be notified via email and/or a notification on our website.
 
This policy is effective as of 25th May 2018.
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