Privacy Policy

WOOSH5 Privacy Policy Last Updated: January 18, 2024

This privacy policy describes how WOOSH5 Holding B.V., WOOSH5 B.V., WOOSH5 Inc (“WOOSH5,” “we,” “us,” or “our”) collects, uses, and shares information about you and the choices you have regarding this information. This privacy policy applies to the information we collect when you access or use our products, services, and technology platforms (including, but not limited to, our websites, mobile applications, and other WOOSH5-controlled applications that refer to this privacy policy) (collectively, the “services”). Please note that this privacy policy does not apply to your use of third-party sites, services, or applications that you access through our services. We recommend consulting the privacy policy of these third parties for more information about their privacy practices.

CHANGES TO THIS PRIVACY POLICY

We may change this privacy policy from time to time. If we make changes, we will notify you by revising the date at the top of this document. In some cases, we may add an additional notice, such as adding a statement to our homepage or sending an email notification. We recommend reviewing the privacy policy when you access our services to stay informed about any changes and the choices available.

INFORMATION COLLECTION

Information You Provide to Us

We collect information directly from you when you use our services. For example, we collect information when you download our (mobile) application(s), register for our services, sign up for an account, complete an exercise, questionnaire, or other form, participate in interactive features of our services, including video or audio features we offer, apply for a job or to become a coach, request customer support, or otherwise communicate with us. The types of information we may collect include your name, email address, mailing and billing address, user ID, work experience and education, payment information, and any other information you choose to provide.

Information About Interactions with the Services

In addition to the information above, you may provide us additional information to help us identify the best coach for you or in conjunction with your coaching sessions. For example, you may provide information about your title, employment details, language, gender, marital status, nationality, or other information about you and your personal or professional experiences. We also collect information about your use of the Services such as how often you use the coaching services, development programs planned and attended, engagement status, and session ratings.

Information We Collect Automatically When You Use the Services

In addition to the above information, you provide us with additional information to help us identify the right coach for you or in combination with your resilience profile. For example, you provide information about your title, employment details, language, gender, marital status, nationality, or other information about you and your personal or professional experiences. We also collect information about your use of our services, such as how often you use the coaching services, development programs, engagement status, and session ratings.

Information We Automatically Collect When You Use Our Services

When you access and use our services, we automatically collect information about you, including the following:

-Log information: We log information about your use of our services, including the type of browser you use, access times, viewed pages and the exercises you finished.

-Information about the device: we collect data about the computer or mobile device you use to get access to our services.

USE OF INFORMATION

We may use the information we collect to provide, maintain, and improve our services, including assessing and enhancing the quality of coaching services. We may also use the information we collect to:

-Provide products and services you request, process transactions, and send related information.

-Verify your identity and, where applicable, authorize you to use our services (such as when your employer has paid for our services).

-If you are a coach, determine your compensation.

-Respond to your comments, questions, and requests.

-Send you technical notices and other administrative messages.

-Communicate with you about products, services, offers, promotions, rewards, and events offered by us or others, and provide news and information we think may be of interest to you.

-Monitor and analyze trends, usage, and activities related to our services.

-Conduct research, analysis, and surveys.

-Personalize and improve our services and provide content or features that match your user profiles or interests.

-Perform any other purpose for which the information was collected.

SHARING OF INFORMATION

When you use our services, we may share information about you with our coaches so they can provide services to you. With your permission we may also share information regarding your use of our services with the employer or another entity that has sponsored your use of our services, such as the program you selected and how you’ve used our services (such as the number of sessions attended). We will not share information about the content of your sessions with your employer or other sponsoring entity unless we have your permission to do so or if necessary to protect the rights, property, or safety of others. We may also share or transfer information about you as follows or as otherwise described in this privacy policy:

-With vendors, consultants, and other service providers who need access to such information to perform work on our behalf.

-In response to a request for information if we believe disclosure is in accordance with any applicable law or regulation, legal process, or as otherwise required by any applicable law, rule, or regulation.

-If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property, and safety of you, us, or others.

-In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company.

-With your consent or at your direction, including if we notify you through our services that certain information you provide will be shared in a specific manner and you provide this information yourself.

We may also share aggregated or de-identified information that reasonably cannot be used to identify you.

ANALYTICS SERVICES

We may permit others to provide Analytics Services on our behalf. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our services and other websites and applications, including your IP address, web browser, mobile network information, viewed pages, time spent on pages or in apps, links clicked, and conversion data. This information may be used by WOOSH5 and others to, among other things, analyze and track data and gain a better understanding of your online activity.

INSPECTION and TRANSFER

You have the right to request the information we hold about you at any time. You also have the right to transfer this information to third parties. And of course you have the right to have this information amended or deleted if this is not correct. If a data breach occurs, WOOSH5 will immediately report this to the police and the Dutch Data Protection Authority.

TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES

We are based in Europe and the United States, and the information we collect is governed by respective laws. In Europe, we are governed by the GDPR laws
since 2018.
Regarding the processing of all personal data we receive from the EU or Switzerland (‘European data’), we adhere to the EU-U.S. Privacy Shield Framework Principles and the Swiss-U.S. Privacy Shield Framework Principles issued by the U.S. Department of Commerce (together, the ‘Principles’). For more information about the Principles, you can visit the Department of Commerce Privacy Shield website.

The General Data Protection Regulation (GDPR) is a set of laws established in the EU in 2018.

Privacy Shield is an agreement between the EU and the US that allows the transfer of personal data from the EU to the US.
The GDPR has specific requirements regarding data transfer from the EU. One of these requirements is that the transfer should only occur to countries considered to have adequate data protection legislation.

In general, the EU doesn’t have a list where the US is considered to meet this requirement. Privacy Shield is designed to create a program where participating companies are deemed to provide adequate protection, thus facilitating the transfer of information. In summary, Privacy Shield allows US companies or EU companies working with US companies to comply with this GDPR requirement.

Please direct any questions or complaints about our adherence to the Principles directly to us. If we share European data with an external service provider processing the data solely for us, we will be liable for the processing of European data by third parties in violation of the Principles unless we can demonstrate that we are not responsible for the event giving rise to the damage.

DATA RETENTION

We store the information we have collected about you for as long as necessary for the purpose(s) for which we originally collected this information or for other legitimate business purposes, including our legal, regulatory, or other compliance obligations. After a year we will ask you whether you want us to keep your information or store it anonymously for research purposes only. Should a data breach occur, WOOSH5 will immediately report this to the police and the Dutch Data Protection Authority.

YOUR CHOICES

Your Information

You can update, correct, or delete information about yourself at any time by contacting us at support@dev-woosh5-ondev.com. Please note that we may retain certain

information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period.

Promotional Communication

You can opt-out of receiving promotional communication from us by following the instructions in this notification or by emailing us at support@dev-woosh5-ondev.com. If you opt out, we may still send you non-promotional communication, such as messages about your account or our ongoing business relationship.

Mobile Push Notifications/Alerts

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

EUROPEAN RESIDENTS

If you are a European resident, resident of the European Economic Area, and the European Free Trade Association, you have certain rights and protections under the law regarding the processing of your personal data.

Legal Basis for Processing

If you are a European resident, when we process your personal data, we will only do so in the following situations:

-We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the services you have requested).

-We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes in our services, and to deliver, secure, and improve our services.

-You have given us consent to process your personal data.

-If you are a resident of Europe, you have the right to access personal data we hold about you and to request that your personal data be corrected, deleted, or transferred.

-You also have the right to object, or you can request that we restrict certain processing activities.
-You have the right to request deletion of your personal data.
-You have the right to inspect the information we have recorded about you.

-If you wish to exercise any of these rights, you can log into your account or contact us as indicated below.”

Questions or Complaints

If you’re a European resident and have complaints about how we handle your personal data that we can’t resolve, you have the right to file a complaint with the privacy authority in the country where you live. For contact information for your local
data protection authority, please refer to http://ec.Europa.EU/Justice/Data-Protection/Article- 29/structure/Data-Protection-Authorities/index_en.htm “

Contact Information

If you have questions or complaints about our Privacy Policy you may mail us on:
support@dev-woosh5-ondev.com

WOOSH5 Holding BV, Bergschot, 69B, 4817PA Breda, The NetherlandsWOOSH5, Inc.

2330 Vinemead Ct Katy TX 77450, USA