Privacy Statement - Sales Training

Privacy Policy – Graham Hulsebos Sales Training

1. Privacy at a Glance

The protection of your personal data is important to Graham Hulsebos Sales Training. We process personal data in accordance with applicable data protection legislation, including the General Data Protection Regulation (GDPR).

We only process personal data that is necessary for, among other things, the operation of our website, responding to enquiries, processing registrations and requests, providing sales training and coaching, preparing quotations, and the other purposes described below.

Personal data is not sold to third parties for advertising or other commercial purposes without a valid legal basis.

2. Data Controller

The controller responsible for the processing of personal data is:

Graham Hulsebos Sales Training

Contact person:
Graham Hulsebos

Email: [email protected]

Our current address and other contact details can be found on our website.

3. What Personal Data Do We Process?

Depending on the services you use, we may process the following personal data:

first and last name;
address details;
email address;
telephone number;
company or organisation details;
job title or position;
billing and payment information;
information relating to enquiries, quotations, registrations and agreements;
information relating to training courses, coaching and other services;
contents of contact enquiries;
contents of communications with our AI assistant Sophie;
technical data processed when using our website.

We only process this information insofar as it is necessary for the relevant purpose and where a valid legal basis exists.

4. Enquiries, Registrations and Performance of Agreements

When you request information, register for a sales training course, coaching programme or other service, or enter into an agreement with us, we process the personal data necessary to handle your request or registration and perform our agreement with you.

We may use this information for purposes including:

handling your enquiry or registration;
preparing and sending a quotation;
planning and delivering training courses and coaching;
communicating with you about our services;
invoicing;
fulfilling our contractual obligations.

The processing is primarily based on Article 6(1)(b) GDPR: processing necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract.

Where we are legally required to retain certain information, processing is based on Article 6(1)(c) GDPR.

5. Contacting Graham Hulsebos Sales Training

When you contact us through our website, by email, by telephone or by other means, we process the information you provide in order to handle your question or request.

This information may include:

your name;
email address;
telephone number;
company name;
job title or position;
the content of your question or request.

Where your contact relates to entering into or performing an agreement, processing is based on Article 6(1)(b) GDPR.

For other business enquiries, processing may be based on our legitimate interest in responding appropriately to questions from customers and prospective customers in accordance with Article 6(1)(f) GDPR.

6. AI Assistant “Sophie”

Graham Hulsebos Sales Training uses the AI-powered digital assistant “Sophie”.

Sophie may be used both through the chat function on our website and by telephone.

Sophie assists visitors and callers with questions about our sales training courses, customised training programmes, coaching, e-learning and other services. Sophie may also assist in collecting the information necessary to follow up an enquiry.

You Are Communicating with Artificial Intelligence

Sophie is an AI-powered digital assistant and not a human employee.

This applies both to the chat function on our website and to telephone conversations with Sophie.

At the beginning of the interaction, you will be informed that you are communicating with an AI system.

What Information May Sophie Process?

When communicating with Sophie, the following personal data may be processed:

name;
telephone number;
email address;
company or organisation details;
job title or position;
the contents of your questions and answers;
information about sales training, coaching or other services in which you are interested;
information about your commercial team or training requirements that you voluntarily provide;
other information that you voluntarily provide to Sophie during a chat or telephone conversation;
technical information necessary for the operation and security of the service.

Please do not provide Sophie with sensitive information or special categories of personal data unless this is necessary for handling your request.

Telephone Conversations with Sophie

When you speak to Sophie by telephone, your speech is technically processed so that the AI system can understand and respond to your request.

We do not store the telephone conversation as an audio recording.

The content or a summary of the conversation is processed in text form and may be sent by email to authorised employees of Graham Hulsebos Sales Training so that your enquiry can be personally followed up.

Website Chat with Sophie

When you chat with Sophie through our website, the information you enter is processed so that Sophie can understand and respond to your request.

The content or a summary of the chat may subsequently be sent by email to authorised employees of Graham Hulsebos Sales Training.

Personal Follow-up

Information received through Sophie may be used to:

further process your enquiry;
contact you by telephone or email in connection with your enquiry;
provide information about our training courses or services;
discuss your training requirements;
provide advice about a suitable training course or service;
prepare a quotation at your request;
schedule an appointment, intake meeting, training course or coaching session.

Legal Basis for Processing by Sophie

Where communication with Sophie takes place at your request with a view to entering into or performing an agreement, processing is based on Article 6(1)(b) GDPR.

For general enquiries and the efficient provision of our customer service and AI assistant, processing may be based on our legitimate interests in accordance with Article 6(1)(f) GDPR.

Hosting and Processing within the European Union

Sophie is hosted within the European Union.

Insofar as personal data is processed when using Sophie, according to the information available to us, this processing takes place within the European Union or the European Economic Area.

Retention Period for Communications with Sophie

Personal data and communications stored within the AI system are generally deleted once your enquiry has been handled, the necessary personal contact by telephone or email has been established, and the information is no longer required within the AI system.

Communication data stored within the AI system is deleted no later than 30 days after the relevant communication.

If your enquiry subsequently results in, for example, a quotation, order, agreement, customer relationship, registration or other business communication, the personal data necessary for this purpose may continue to be processed outside the AI system.

The applicable statutory and operational retention periods will then apply to such data.

We do not store an audio recording of your telephone conversation with Sophie.

7. Invoicing and Administration

For our financial administration, we process information necessary for invoicing, payments and compliance with our statutory administrative obligations.

This information may include:

name and company name;
address details;
email address;
invoice details;
information about training courses or services purchased;
payment information.

Processing takes place for the performance of agreements and to comply with statutory tax and administrative obligations.

The legal bases are Article 6(1)(b) and (c) GDPR.

8. Newsletters and Commercial Communications

If you have subscribed to our newsletter, or where another valid legal basis exists for commercial communications, we may use your contact details to inform you about our training courses, services and relevant developments.

Where processing is based on consent, the legal basis is Article 6(1)(a) GDPR.

You may withdraw your consent at any time with effect for the future. Where legally required, our commercial emails provide an option to unsubscribe.

9. Cookies and Similar Technologies

Our website may use cookies and similar technologies.

Functional and technically necessary cookies may be used to ensure the correct and secure operation of our website.

Where cookies or similar technologies are used for analytics, marketing or other non-essential purposes, this is done in accordance with applicable legal requirements and, where required, on the basis of your consent.

You can manage your preferences through the cookie settings on our website.

10. Website Analytics

We may use analytics tools to statistically analyse the use of our website and improve our website and services.

Where consent is legally required, such analytics tools will only be used after you have provided the necessary consent through our cookie settings.

Further information about the cookies actually used, their retention periods and the service providers involved can be found in the cookie settings on our website.

11. Recipients and Service Providers

We may use technical and administrative service providers to deliver our services.

These may include providers of:

website and webshop technology;
hosting;
email services;
financial administration;
payment processing;
e-learning technology;
AI services;
website analytics;
communication and scheduling services.

Personal data is only shared with such parties where this is necessary for the relevant service and where a valid legal basis exists.

Where a service provider processes personal data on our behalf, we make appropriate arrangements regarding the processing and security of personal data where required.

12. Retention Periods

We generally retain personal data for no longer than is necessary for the purpose for which it was collected.

Where statutory retention obligations apply, certain contractual, invoicing, accounting and administrative information may be retained for longer periods.

Communications stored within Sophie's AI system are subject to the maximum retention period of 30 days described above.

13. Your Data Protection Rights

Subject to the applicable statutory requirements, the GDPR provides you with rights including:

the right of access to your personal data;
the right to rectification of inaccurate personal data;
the right to erasure of your personal data;
the right to restriction of processing;
the right to data portability;
the right to object to certain processing;
the right to withdraw consent previously given.

If you wish to exercise any of these rights, you can contact us using the contact details provided above.

You also have the right to lodge a complaint with the competent data protection supervisory authority.

As Graham Hulsebos Sales Training is established in the Netherlands, you may contact the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

14. Security

We take appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access, unauthorised disclosure and unlawful alteration.

Where necessary and technically available, we use secure and encrypted connections.