Privacy Policy

Updated on April 25th, 2024

ARTICLE 0 - PREAMBULE

This privacy policy governs the collection and processing of personal data (hereinafter "Personal Data") of users (hereinafter "User") of the website joffreyberti.com and its subdomains empowerscore.com and redirected domain (hereinafter "Site").

The collection and processing of data are carried out by the company Empower Up LLC, license 2323589.01 located in Sharjah Media City - PO-BOX 515000 - Sharjah, United Arab Emirates and represented by Mr. Joffrey Berti, Managing director (hereinafter the "Provider").

This Privacy Policy applies to any use of the Site and all services provided by the Provider and must be read in conjunction with the Terms & Conditions of the Provider.

ARTICLE 1 – DATA

The Provider will use all means at its disposal to ensure the security and confidentiality of the personal data entrusted to it, in compliance with the laws and regulations in force.

Data may be collected for explicit, legitimate, and specific purposes to ensure:

- the proper functioning and continuous improvement of the Site, services, and features

- the management of the User's subscription to the Site's services such as Quiz, Newsletter, Subscriptions of services

- the provision of a secure Online Mentoring platform space

- the preparation of documentation resulting from the mentoring and for the User

- the organisation of events by the Provider such as calls, online Group Coaching, Webinars, etc

- the development of commercial statistics based on site traffic

ARTICLE 2 - DATA CONTROL

The General Data Protection Regulation (GDPR) / applicable Data Privacy laws took effect on 25th May 2018. All User information is always entirely confidential unless permission is given otherwise. The Provider is the data controller of the Personal Data processed through the Site or directly with the User.

For any questions regarding the management and use of the User's personal data, the Provider can be contacted by mail at the address mentioned above and by email at the following address: support@joffreyberti.com

ARTICLE 3 – COLLECTION AND PROCESSING OF PERSONAL DATA

The Personal Data provided by the User to the Provider are subject to computer processing and are stored and used by the latter for the purposes described in the aforementioned article and concern:

- Personal data : Name, first name, email, telephone number, emergency contact, postal address.

This data is considered “identifying information”, as it can personally identify you. The provider only requests personal information relevant to providing you with a service and only uses it to help provide or improve this service.

- Registrations : registration and management of subscriptions if the User subscribe to a service and the provision of corresponding services

- Communications : Video calls: group calls can be recorded in case required to provide the service. All calls are encrypted.

- Session notes: The provider will keep brief notes of the sessions in accordance with the Terms & Conditions.

- Appointment scheduling: All appointments are to be made using the Calendly platform. Calendly does not provide encryption.

- Connection Data and Cookies (IP addresses, connection logs)

- Management of claims and potential disputes

When the User visits the Site, browsing data may be collected and processed by the Provider or any provider of their choice for statistical purposes, in order to improve the use of the Site, and in particular to measure the number of page views, the number of visits, and the User's journey on the Site.

ARTICLE 4 - SECURITY OF PERSONAL DATA

The Provider takes all appropriate technical and organizational measures to ensure the security of the User's Personal Data, in particular, against loss, alteration, dissemination, or illegal use of their data. In particular, the Provider uses a cloud-based tool to store your personal information and case notes securely.

ARTICLE 5 - LEGAL BASIS FOR PROCESSING

Processing carried out by the Provider in accordance with the purposes set out above is necessary to enable the Provider to:

fulfil its contractual obligations towards Users

comply with the legal obligations incumbent upon it as per Terms & Conditions and Working Together Agreement signed when a User buys the relevant service from the Provider.

ARTICLE 6 - RECIPIENTS OF PERSONAL DATA

The User's Personal Data is not subject to communication or transfer to third parties for commercial or promotional purposes unless expressly agreed upon by the User.

In certain cases, the Provider may be required to disclose the User's Personal Data to any administrative or judicial authority that requests it, in accordance with applicable legislation.

In particular by using this website or the Provider Services, the Provider may have release information to a relevant individual or agency if it has been determined that a child or adult is at risk of or is currently being abused; or if the User is at imminent danger to him/herself or others; or if a subpoena of records or any other requirement to share information by law has been requested.

All contacts, including sessions, telephone conversations and emails, will be conducted in confidence and may be recorded (coaching call for example). Prior to any recording, the User agreement will be sought. All conversations, notes, recording will remain confidential, except in the following circumstances:

- Where the Client gives permission for confidentiality to be broken

- Where the Provider is compelled by a court of law

- Where the information is of a nature that confidentiality cannot be maintained, for example:

- The possibility of harm exists

- In cases of fraud or crime

- When minors (under 18 years old) are involved

- Where a referring GP or other healthcare professional requires a report. A copy of the report will be available on request.

The User's Personal Data may be disclosed to third-party subcontractors of the Provider to ensure access to and use of the Site and its services. The User's choice to receive offers or commercial prospecting messages from the Provider and/or its partners is subject to their prior and express agreement by ticking a box accessible when they are asked to provide Personal Data. If the User no longer wishes to receive them, they have the option to unsubscribe at any time by making a request to the Provider at the following address: support@joffreyberti.com

ARTICLE 7 - USE OF COOKIES

The Provider uses cookies when the User navigates the Site. A cookie is a file sent by a website when it is visited and stored in web browsers. Generally, cookies are used to measure and evaluate the behaviour of Users who visit a website (site traffic, number of visitors, duration of visits, most viewed elements, etc.). They are aimed at improving the User's experience on the Site.

There are several types of cookies, some of which are non-identifying, and others that are identifying. Some cookies can be associated with other data to personalize the User's experience on a website. When cookies are identified, they allow for the collection and processing of Personal Data. Cookies used by the Provider are stored for a maximum of 13 months from their first deposit on the User's computer. Please note that it is also possible that third parties use cookies to collect data related to the User's navigation. The Provider is in no way responsible for operations related to the use of third-party cookies. The User can configure the operation of cookies installed on their computer by configuring their browser settings. Additional information on how the User can configure their browser and limit the action of cookies can be found online.

ARTICLE 8 - AMENDMENT OF PRIVACY POLICIES

These Privacy Policies may be amended by the Provider at any time. In the event of changes to the privacy policies, the new version in effect will be applicable to the User upon their connection to the Site. In the event of a dispute between the User and the Provider, the privacy policy to be considered will be the one in effect at the time of the facts causing the dispute.

ARTICLE 9 - DURATION OF PERSONAL DATA RETENTION

The Provider will only retain the User's Personal Data for a limited period, determined according to the nature of the data in question and the processing concerned.

- On this basis, the User's Personal Data will be retained for the following durations:

- Identification data: 36 months from the last connection

- Order data: 36 months from the order date

- Once these durations are reached, some of the Personal Data in question may be subject to an archiving procedure for accounting management and dispute management purposes or requests, for a duration not exceeding the legal statutes of limitations in these matters.

- After the relevant retention period, the Provider will destroy any document and data with the User personal information.

ARTICLE 10 - USER RIGHTS

The User has the right to access, rectify, erase or delete all or part of their Personal Data, a right to object, and a right to limit processing and data portability of their Personal Data, which they can exercise by contacting the Provider at support@joffreyberti.com

For processing based on the User's consent, they also have the right to withdraw their consent at any time. Such requests must be made by the User personally and in writing, signed and accompanied by a photocopy of an identity document bearing the holder's signature.

The User is advised that exercising these rights does not affect the validity of the processing operations carried out previously, nor the Provider's right to archive some of the Personal Data in question, in accordance with the principles set out above.

This information will only be processed for the purpose of identifying the User and will not be kept beyond the time required to process the response. The request will specify the email or postal address to which any response should be sent.