Privacy Notice
In line with the General Data Protection Regulation (GDPR), this privacy describes how Dare&Grow S.à r.l. (Dare&Grow) collects and uses personal information about you during and after your relationship with Dare&Grow.
Dare&Grow understands that the information you trust us with is important to you and is committed to protecting your privacy and keep your personal data confidential. The purpose of this document is to be as clear as possible about what will happen with your personal information and why.
Who is responsible for the use of the personal data?
Your personal data will be collected and held by Dare&Grow as a “Controller”. This means that Dare&Grow is responsible for deciding how to hold and use personal data about you.
This privacy notice may be updated at any time.
Which types of personal data are used?
Dare&Grow collects the following personal data:
- Your name
- Your contact data (e.g. e-mail and postal address, phone number)
- The information shared by you to allow Dare&Grow to provide the coaching, training and mentoring services (Services)
How is your information used?
Dare&Grow collects your personal data for the following purposes:
- To communicate with you before, during and after the provision of the Services,
- To send newsletters, where requested by you,
- To provide the requested Services,
- For invoicing purposes,
- For compliance with legal obligations, in particular retention for compliance with the Commercial Code,
- For dealing with legal disputes involving you,
- To maintain a personal log of coaching sessions for the maintenance of the qualification with the International Coaching Federation. No personal data will ever be transferred to the International Coaching Federation. https://coachingfederation.org/experience-requirements
What are the lawful grounds for using your information?
The GDPR specifies that personal data can only be used on the basis of at least one of six lawful grounds. Dare&Grow will only use your personal information when it is necessary to do so. Below are set out the legal grounds upon which the processing is done.
| To communicate with you before, during and after the provision of the Services | To execute the contract between you and Dare&Grow. |
| To send newsletters | Your prior consent. |
| To provide the requested Services | To execute the contract between you and Dare&Grow. |
| For invoicing purposes | To execute the contract between you and Dare&Grow. |
| For compliance with legal obligations | Legal obligation, in particular Article 16 of the Luxembourg Commercial Code. |
| For dealing with legal disputes | Legitimate interest. |
| To maintain a personal log of coaching session for the maintenance of the qualification with the International Coaching Federation. | Legitimate interest. Dare&Grow will not share your personal data with the International Coaching Federation. All logs will be kept confidential by Dare&Grow. You can object to the use of your personal data for this purpose at any time. |
If you do not provide your name and contact details to allow Dare&Grow to send invoices, Dare&Grow will not be able to provide the Services to you.
Please note that providing information about yourself is necessary for Dare&Grow to provide the Services. If you choose to not provide information about yourself to Dare&Grow, it may impact the level of service that Dare&Grow is able to provide.
How Dare&Grow collects, protects and shares your personal data
Dare&Grow collects personal information about you directly from you when you contact Dare&Grow via telephone, email, social media or through this website.
Client and business data is stored on GDPR compliant and secured devices.
Dare&Grow may change the systems in which data is stored to another equivalent system without notification but will ensure the appropriate security of your data and GDPR compliance at all times.
Dare&Grow makes use of service providers, including an accountant and Calendly. For more information about how Calendly processes personal data, click here. Dare&Grow will share with the accountant only the personal data that are necessary to establish invoices and to comply with legal obligations.
How long will Dare&Grow keep your information?
Dare&Grow will retain your personal data for the duration of the provision of the Services and, in principle, for 10 years after the end of the contractual relationship.
Your coaching notes will, in principle, be retained for 5 years following the end of the contractual relationship.
As part of the internal process, personal data held on file is periodically reviewed to ensure that there is a reason for retaining such records. Otherwise Dare&Grow will securely remove the personal data.
Your rights
Unless subject to an exemption by the GDPR or by Luxembourg law, you have the following rights with respect to your personal data:
- Access to your personal data: You have the right to request a copy of your personal data held by Dare&Grow.
- Correcting your personal data: In an effort to ensure that your personal data is accurate, complete and up to date, you may ask that your personal data be amended to meet your standards, if it is incorrect.
- Deletion of your personal data: You have the right to request that your personal data be deleted in certain cases, including where:
- You consider that Dare&Grow no longer requires the data for the purposes for which it was collected or that there is no longer a need for your personal data to be retained for compliance with legal obligations.
- The use of your personal data is contrary to legal obligations.
Dare&Grow wishes to specify that some of your personal data cannot be deleted before the end of the legal retention period.
- Object to how your personal data is used: Where we use your personal data to perform tasks carried out for the legitimate interests of Dare&Grow, you may request to desist from such an action, unless there are overriding legitimate grounds to continue.
- Restrict how your personal data is used: In some cases, you may restrict how Dare&Grow uses your personal data. This right might apply, for example, where Dare&Grow checks the accuracy of your personal data or assesses the validity of any objection you have made to the use of your personal data. This right might also apply where there is no longer a basis for using your personal data but you do not want Dare&Grow to delete it. Where this right is validly exercised, Dare&Grow may only use the relevant personal data with your consent, legal claims or where there are other public interest grounds to do so.
- Withdrawing consent for using your personal data: Where Dare&Grow uses your personal data with your consent, you may withdraw that consent at any time and Dare&Grow will stop using your personal information for the purpose, including for newsletters, for which consent was given.
If you want to exercise any of your rights, please contact Dare&Grow on: elodie.michaud@daregrow.lu.
Data security
Dare&Grow has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
The transmission of information via the internet is not completely secure and Dare&Grow cannot guarantee the security of your data transmitted online and transmission is made at your own risk. If you communicate with Dare&Grow by e-mail, you assume the risks of such communications being intercepted, not received or delivered, or received by individuals other than the intended recipient.
Right to lodge a complaint
You have the right to lodge a complaint with your national data protection authority. In Luxembourg, this is the Commission Nationale pour la Protection des Données (CNPD), which can be contacted here or at the following address:
15, Boulevard du Jazz
L-4370 Belvaux