Privacy Policy – CHES Protocol

1. General Information
   This Privacy Policy applies to the services offered under the name CHES Protocol, operated by PRFORM Management & Coaching, a sole proprietorship registered with the Dutch Chamber of Commerce (KvK). In this Policy, “we,” “our,” or “us” refers to PRFORM Management & Coaching.

We are committed to protecting your personal data and handling it in a lawful, fair, and transparent manner.

2. Data We Collect
   We may collect the following categories of personal data:

• Identification data: name, email address, contact details.
• Payment data: billing information processed securely through Stripe.
• Account and usage data: subscription type, login activity, preferences, and interactions with our platform.
• Communication data: messages or requests you send through our contact form or email.

3. How We Use Your Data
   We process your data for the following purposes:

• To provide and manage your subscription and access to training programs.
• To process payments and handle billing through Stripe.
• To communicate with you regarding your subscription, updates, or support inquiries.
• To improve our services by analyzing anonymous or aggregated usage data.
• To comply with legal obligations, including tax and accounting requirements.

4. Legal Basis for Processing
   We process personal data only when one of the following legal bases applies:

• Performance of a contract (e.g., providing your subscription).
• Legal obligations (e.g., bookkeeping requirements).
• Legitimate interests (e.g., improving services, preventing misuse).
• Consent (e.g., if you sign up for a newsletter).

5. Sharing of Data

• We do not sell or rent personal data to third parties.
• We may share data with trusted service providers strictly necessary to deliver our services, including:
  • Stripe (payment processing).
  • Hosting providers and technical partners who help operate our platform.
• We ensure that such parties process data in compliance with applicable privacy laws.

6. Data Retention

• Personal data is stored only as long as necessary for the purposes stated above.
• Payment records are kept for the legally required period under Dutch tax law (usually 7 years).
• When no longer required, data will be deleted or anonymized.

7. International Data Transfers
   As our users may be located worldwide, data may be processed outside the EU. In such cases, we ensure that transfers comply with applicable data protection rules (e.g., EU Standard Contractual Clauses).
8. Your Rights
   As a user, you have the following rights under applicable data protection laws:

• Right of access – obtain confirmation and a copy of your personal data.
• Right to rectification – request correction of inaccurate data.
• Right to erasure – request deletion of your data, subject to legal retention obligations.
• Right to restriction – limit processing of your data under certain circumstances.
• Right to data portability – request transfer of your data to another provider.
• Right to object – object to processing based on legitimate interests or direct marketing.

Requests can be sent to the contact details listed below. We may ask for proof of identity before fulfilling requests.

9. Security
   We take appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or alteration.
10. Updates to This Policy
    We may update this Privacy Policy from time to time. The most recent version will always be published on our website. Material changes will be communicated clearly to subscribers.
11. Governing Law
    This Privacy Policy is governed by Dutch law. Any disputes will be submitted to a competent court in the Netherlands.
12. Contact
    For questions regarding this Privacy Policy or to exercise your rights, please contact:
    PRFORM Management & Coaching – CHES Protocol