Privacy Policy

1. Introduction

Onder watersport vereniging Scyllus ("we," "us," or "our") is committed to protecting the privacy and personal data of individuals who visit our website and use our services. This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you interact with our website, contact us, or participate in our coaching and personal development education programs.

We operate in compliance with the General Data Protection Regulation (GDPR) — Regulation (EU) 2016/679 — as well as the Dutch Implementation Act of the GDPR (Uitvoeringswet Algemene verordening gegevensbescherming, UAVG), and other applicable data protection laws in the Netherlands and the European Union.

By using our website or submitting personal information to us, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller

The data controller responsible for processing your personal data is:

If you have any questions or concerns about this Privacy Policy or the processing of your personal data, you may contact us at the email address listed above.

3. What Personal Data We Collect

We may collect and process the following categories of personal data:

3.1 Information You Provide Directly

• Contact Information: Full name, email address, phone number
• Inquiry Details: Selected program, preferred learning format, and any message or comment you include when submitting a contact form
• Consent Records: Records of the consents you provide when submitting forms on our website

3.2 Information Collected Automatically

• Technical Data: IP address, browser type and version, operating system, device type, screen resolution
• Usage Data: Pages visited, time spent on pages, referring website URL, date and time of access
• Cookie Data: Information collected through cookies and similar tracking technologies (see our Cookie Policy for details)

4. How We Use Your Personal Data

We process your personal data for the following purposes:

• Responding to Inquiries: To respond to your contact form submissions, questions, and requests for information about our coaching and personal development education programs
• Providing Services: To facilitate your participation in educational programs, send program-related communications, and provide relevant learning materials
• Website Operation: To operate, maintain, and improve our website, ensure technical functionality, and analyze how visitors use our website
• Legal Compliance: To comply with applicable legal obligations under Dutch and European Union law
• Security: To protect our website against unauthorized access, fraud, and other security threats

5. Legal Basis for Processing

Under the GDPR, we process personal data based on one or more of the following legal bases:

• Consent (Article 6(1)(a) GDPR): When you have given clear, explicit consent for us to process your personal data for a specific purpose, such as submitting a contact form
• Contractual Necessity (Article 6(1)(b) GDPR): When processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract
• Legitimate Interest (Article 6(1)(f) GDPR): When processing is necessary for our legitimate interests, such as improving our website, ensuring security, and analyzing website usage, provided that such interests are not overridden by your fundamental rights and freedoms
• Legal Obligation (Article 6(1)(c) GDPR): When processing is necessary for compliance with a legal obligation to which we are subject under Dutch or European Union law

6. Data Sharing and Disclosure

We do not sell, rent, or trade your personal data to third parties. We may share your personal data in the following limited circumstances:

• Service Providers: We may share data with trusted third-party service providers who perform services on our behalf, such as website hosting, email communication, and technical support. These providers are contractually obligated to protect your data and process it only on our instructions
• Legal Requirements: We may disclose personal data if required to do so by law, regulation, court order, or other governmental authority in the Netherlands or the European Union
• Protection of Rights: We may disclose personal data if we believe in good faith that such action is necessary to protect our rights, your safety, the safety of others, or to investigate fraud

7. International Data Transfers

Our organization is based in the Netherlands. If your personal data is transferred outside the European Economic Area (EEA), we will ensure that appropriate safeguards are in place in accordance with the GDPR, such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions by the European Commission for the receiving country
• Other legally recognized transfer mechanisms under the GDPR

8. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Specifically:

• Contact form submissions: Retained for up to 24 months after your last interaction with us, unless a longer retention period is required by law or necessary for the establishment, exercise, or defense of legal claims
• Technical and usage data: Retained for up to 12 months
• Cookie data: Retained in accordance with the durations described in our Cookie Policy

When personal data is no longer required, we will securely delete or anonymize it.

9. Your Rights Under the GDPR

As a data subject, you have the following rights under the GDPR and Dutch data protection law:

• Right of Access (Article 15): You have the right to request a copy of the personal data we hold about you
• Right to Rectification (Article 16): You have the right to request correction of inaccurate or incomplete personal data
• Right to Erasure (Article 17): You have the right to request deletion of your personal data, subject to certain legal exceptions
• Right to Restriction of Processing (Article 18): You have the right to request that we restrict the processing of your personal data in certain circumstances
• Right to Data Portability (Article 20): You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller
• Right to Object (Article 21): You have the right to object to the processing of your personal data based on legitimate interests or for direct marketing purposes
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days, as required by the GDPR.

10. Right to Lodge a Complaint

If you believe that the processing of your personal data infringes the GDPR or applicable Dutch data protection law, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):

We encourage you to contact us first so that we can address your concerns directly.

11. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance user experience, analyze website traffic, and support website functionality. For detailed information about the types of cookies we use, their purposes, and how to manage your cookie preferences, please refer to our Cookie Policy.

12. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include, but are not limited to:

• SSL/TLS encryption for all data transmitted between your browser and our website
• Secure storage of personal data with access limited to authorized personnel only
• Regular review and updating of security practices
• Server-side validation and spam protection for form submissions

While we take reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, but we are committed to maintaining a high standard of data protection.

13. Third-Party Links

Our website may contain links to third-party websites or services. We are not responsible for the privacy practices or content of such third-party websites. We encourage you to read the privacy policies of any third-party website before providing them with your personal data.

14. Children's Privacy

Our website and educational programs are designed for adults. We do not knowingly collect personal data from individuals under the age of 16. If we become aware that we have inadvertently collected personal data from a child under 16, we will take steps to delete such data as soon as possible. If you believe that we may have collected data from a child under 16, please contact us at [email protected].

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. When we make significant changes, we will update the "Last updated" date at the top of this page. We encourage you to review this Privacy Policy periodically.

Continued use of our website after any changes to this Privacy Policy constitutes your acknowledgment of the changes and your consent to the updated terms.

16. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Netherlands and the European Union, including the General Data Protection Regulation (GDPR) and the Dutch Implementation Act of the GDPR (UAVG). Any disputes arising from or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the competent courts in the Netherlands.

17. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us: