Privacy Policy

This Privacy Policy explains how I, Ineke Vermeulen, process personal data in accordance with the EU General Data Protection Regulation (GDPR) and other applicable data protection laws. It also includes our Cookie Policy.

Name and Contact Details of the Controller

Ineke Vermeulen

Schleißheimer Str. 189
80797 Munich, Germany

Phone number: +49 162-1510511
Email: ineke@inekevermeulen.com
Website: https://inekevermeulen.com

General Principles of Data Processing

I process your personal data only when necessary to:

  • Provide my services and digital products
  • Comply with legal obligations
  • Improve my website and user experience
  • Communicate with you based on your consent or a legitimate interest

Categories of Data Processed

Depending on how you interact with my website, I may collect:

  • Identification data (name, email address, postal address)
  • Payment details (via secure payment providers)
  • Technical data (IP address, browser type, operating system, pages visited)
  • Communication data (messages via contact forms, emails)

Purposes and Legal Bases

I process your data based on:

  • Art. 6(1)(b) GDPR – Performance of a contract (e.g., coaching bookings, course purchases)
  • Art. 6(1)(a) GDPR – Consent (e.g., newsletter subscription, cookies)
  • Art. 6(1)(f) GDPR – Legitimate interest (e.g., website analytics, security)

Hosting

My website is hosted by ALL-INKL.COM – Neue Medien Münnich (Germany), which processes data on my behalf under a data processing agreement.

Analytics and Tracking

We use Matomo Analytics, an open-source web analytics platform, to analyze and improve the use of our website.

Matomo is hosted directly on our own server. This means that all analytics data is stored exclusively on our infrastructure and is not shared with third parties.

We have configured Matomo in cookieless mode, so no cookies are set, and no personally identifiable information is stored. The following information may be collected:

  • pages visited and actions performed
  • time of visit and duration of visit
  • type of device, operating system and browser used
  • anonymized IP address (used only to determine approximate location)

The processing of this data is based on our legitimate interest in analyzing and improving our website (Art. 6(1)(f) GDPR).

Cookies

I use Borlabs Cookie – Operated by Borlabs GmbH, Germany. GDPR-compliant cookie consent management tool.

Types of cookies used:

  • Essential cookies: Required for website functionality
  • Functional cookies: Remember preferences
  • Analytics cookies: Only if you consent (e.g., plausible events if configured)
  • Marketing cookies: For embedded videos or social media content

Payment Providers

When you make a purchase, payment data is processed directly by:

  • Tentary – Operated by Tentary GmbH, Germany. GDPR-compliant.
  • PayPal – Operated by PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxembourg. GDPR-compliant; transfers possible to the USA based on Standard Contractual Clauses.
  • Stripe – Operated by Stripe Payments Europe Ltd., Ireland. GDPR-compliant; transfers possible to the USA based on Standard Contractual Clauses.

I do not store full payment details; only transaction confirmations are retained.

Email Marketing

Brevo – Operated by Sendinblue SAS, France (EU). GDPR-compliant email marketing service. Your data is processed exclusively on servers located in the EU. Consent is required before sending you marketing emails.

Appointment Booking for First Calls

Brevo – Operated by Sendinblue SAS, France (EU). GDPR-compliant. Used exclusively for scheduling initial consultation calls via secure online forms.

Appointment Booking and Mentoring Sessions

For scheduling initial consultation calls and mentoring sessions, we use Brevo (Sendinblue SAS, France/EU). Brevo is GDPR-compliant and processes data exclusively within the EU. Your information is used solely for the purpose of managing appointments via secure online forms.

For the actual coaching sessions, we use Google Meet (Google LLC) and Microsoft Teams (Microsoft Corporation) as video conferencing tools.

  • Google Meet: Google LLC, Googleplex, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
  • Microsoft Teams: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.

For customers within the EU, data processing with both services is carried out under the EU Standard Contractual Clauses (SCCs) to ensure GDPR compliance.

Google Meet and Microsoft Teams are used exclusively to conduct online mentoring and consultation sessions via secure meetings. Data processing is based on Art. 6(1)(b) GDPR (performance of a contract) and Art. 6(1)(f) GDPR (legitimate interest in effective and secure communication).

Clients may choose whether their coaching session will be held via Google Meet or Microsoft Teams.

Further information on data processing:

Embedded Content and Media

YouTube – Operated by Google Ireland Ltd., Ireland. GDPR-compliant; transfers possible to the USA based on Standard Contractual Clauses.

Social Media Plugins and Sharing

My website includes share buttons and may embed content from:

  • Instagram – Operated by Meta Platforms Ireland Ltd., Ireland. GDPR-compliant; transfers possible to the USA.
  • LinkedIn – Operated by LinkedIn Ireland Unlimited Company, Ireland. GDPR-compliant; transfers possible to the USA.
  • YouTube – See section Embedded Content and Media.

Data Transfers to Third Countries

Some services (e.g., YouTube, PayPal, Stripe, Instagram, LinkedIn) may process data in the USA. Transfers are based on Standard Contractual Clauses or your consent.

Retention Period

I store personal data only as long as necessary for the stated purposes or as required by law.

Your Rights

Under the GDPR, you have the right to:

  • Access your data
  • Rectify inaccurate data
  • Request your data be erased
  • Restrict processing
  • Data portability
  • Withdraw consent at any time
  • Lodge a complaint with a supervisory authority

Security Measures

This website uses SSL encryption and technical safeguards to protect your data.

Updates to This Privacy Policy

This Privacy Policy may be updated from time to time. Please check back regularly.