Privacy Policy

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This Privacy Policy describes how Washrefine, operating at washrefine.world and located at Middenweg 65A, 1098 AE Amsterdam, Netherlands, collects, uses, stores, and protects personal data in connection with our workplace wellness training products and related services, including the Posture & Movement Basics program, Nutrition Awareness Workshop, and Stress Recovery & Mindfulness Lab cohort training.

1. Data Controller

The data controller responsible for your personal data is Washrefine. For privacy-related inquiries, you may contact us at admin@washrefine.world or by phone at +31653114629. Our registered business address is Middenweg 65A, 1098 AE Amsterdam, Netherlands.

2. Scope of This Policy

This policy applies to all personal data processed when you visit our website, inquire about our training programs, book a session, participate in a workshop or cohort program, receive follow-up materials, or otherwise interact with Washrefine. It covers data relating to individual participants, organisational representatives, and website visitors.

3. Personal Data We Collect

We may collect the following categories of personal data depending on your interaction with our products and services:

• Identity and contact data: full name, job title, organisation name, email address, telephone number, and postal address.
• Booking and program data: selected training program, preferred dates, team size, dietary preferences shared voluntarily for nutrition workshops, accessibility requirements, and session attendance records.
• Communication data: messages submitted through our contact form, email correspondence, and feedback provided after training sessions.
• Technical data: IP address, browser type, device information, pages visited on washrefine.world, and cookie identifiers as described in our Cookies Policy.
• Payment-related data: billing contact details and transaction references. Full payment card details are processed by our secure payment provider and are not stored on our servers.

4. How We Collect Data

We collect personal data directly from you when you complete our contact form, register for a program, communicate with us by email or phone, or participate in training sessions. We also collect limited technical data automatically through cookies and similar technologies when you browse our website. In some cases, organisational representatives provide participant lists for group bookings; in such cases, the organisation is responsible for ensuring appropriate consent or legal basis exists for sharing that data with Washrefine.

5. Purposes and Legal Bases for Processing

We process your personal data for the following purposes under the General Data Protection Regulation (GDPR):

• Delivering booked training products and providing session materials, habit trackers, recipe booklets, and guided audio resources (performance of a contract, Article 6(1)(b) GDPR).
• Responding to inquiries about our workplace wellness programs and preparing customised proposals (legitimate interests in operating our business, Article 6(1)(f) GDPR, or pre-contractual steps at your request, Article 6(1)(b) GDPR).
• Managing bookings, invoicing, and refund requests in accordance with our Return Policy (performance of a contract and legal obligations, Articles 6(1)(b) and 6(1)(c) GDPR).
• Improving our training content and website based on aggregated usage patterns (legitimate interests, Article 6(1)(f) GDPR).
• Sending service-related communications about scheduled sessions, venue changes, or program updates (performance of a contract or legitimate interests, Articles 6(1)(b) and 6(1)(f) GDPR).
• Complying with applicable Dutch and EU legal obligations, including tax and accounting requirements (legal obligation, Article 6(1)(c) GDPR).

Where we rely on consent, such as for optional marketing communications or non-essential cookies, you may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6. Data Sharing and Recipients

We do not sell your personal data. We may share data with trusted third parties only when necessary to deliver our products and services:

• Payment processors for secure transaction handling.
• Cloud hosting providers that store our website and booking systems within the European Economic Area or under adequate safeguards.
• Email and communication platforms used to deliver session confirmations and training materials.
• Professional advisers such as accountants or legal counsel when required.
• Public authorities when required by law or court order.

All processors are bound by data processing agreements requiring appropriate technical and organisational security measures.

7. International Data Transfers

Washrefine primarily processes data within the European Economic Area. If any data is transferred outside the EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission or an adequacy decision, in compliance with Chapter V of the GDPR.

8. Data Retention

We retain personal data only as long as necessary for the purposes described in this policy:

• Contact form submissions and inquiry records: up to 24 months after last interaction unless a booking is made.
• Booking and program participation records: duration of the engagement plus 7 years for accounting and legal compliance.
• Training feedback and satisfaction surveys: up to 3 years in anonymised or aggregated form where possible.
• Technical and cookie data: as specified in our Cookies Policy.

After retention periods expire, data is securely deleted or irreversibly anonymised.

9. Your Rights Under the GDPR

As a data subject in the Netherlands and the EU, you have the following rights regarding your personal data processed by Washrefine:

• Right of access: request a copy of the personal data we hold about you.
• Right to rectification: request correction of inaccurate or incomplete data.
• Right to erasure: request deletion of your data where no compelling reason exists for continued processing.
• Right to restriction: request limitation of processing in certain circumstances.
• Right to data portability: receive your data in a structured, machine-readable format where processing is based on consent or contract and carried out by automated means.
• Right to object: object to processing based on legitimate interests, including profiling.
• Right to withdraw consent at any time where processing is consent-based.

To exercise any of these rights, contact us at admin@washrefine.world. We will respond within one month, extendable by two further months where requests are complex. You also have the right to lodge a complaint with the Autoriteit Persoonsgegevens, the Dutch Data Protection Authority.

10. Security Measures

Washrefine implements appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encrypted connections (HTTPS) on washrefine.world, access controls limiting data access to authorised personnel, secure storage of booking records, and regular review of our data handling practices. While we take security seriously, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

11. Children's Data

Our workplace wellness training products are designed for adult employees and organisational clients. We do not knowingly collect personal data from individuals under 16 years of age. If you believe we have inadvertently collected such data, please contact us immediately so we can delete it.

12. Third-Party Links

Our website may contain links to third-party resources, such as Google Maps embeds. Washrefine is not responsible for the privacy practices of external websites. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Policy

We may update this Privacy Policy to reflect changes in our training products, legal requirements, or business practices. The updated version will be posted on washrefine.world with a revised date at the top. Material changes affecting how we process your data will be communicated to active clients where appropriate.

14. Contact

For questions about this Privacy Policy or our handling of personal data related to workplace wellness training programs, contact Washrefine at admin@washrefine.world, call +31653114629, or write to Middenweg 65A, 1098 AE Amsterdam, Netherlands.