Privacy Policy – Coaching Clients (Busra Kazmir) & Public Content & Social Media

Effective Date: 21 May 2025

Privacy Policy – Coaching Clients (Busra Kazmir)

This Privacy Policy explains how your personal data is collected, used, and protected when engaging with the services of Busra Kazmir, operating under the registered Dutch business Kazmir.

1. Who is the data controller?

Kazmir (Busra Kazmir)
Box D8412 Keurenplein 41
1069CD Amsterdam, Nederland
Dutch Chamber of Commerce (KvK): 88034615
Email: hello@busrakazmir.com

2. What data is collected?

• Name and contact details

• Intake form responses

• Invoice and payment information

• Notes related to sessions

• Communication records (emails, messages)

• Payment processing data

• Technical data (IP addresses, device information when accessing online platforms)

• Community participation data (for Digital Platform members)

3. Why is your data collected?

• To deliver coaching services

• To issue invoices (as legally required)

• To communicate with you

• To ensure safe and personalized sessions

• To provide access to memberships and community platforms

• To comply with legal obligations

• To improve our services

4. Legal basis (GDPR)

• Consent: When you voluntarily provide information

• Contract: For booked sessions and paid services

• Legal obligation: Tax reporting and financial record keeping

• Legitimate interest: Service improvement and communication

5. How long is your data retained?

• Intake/session notes: Up to 12 months after last session

• Invoices and financial records: 7 years (legal obligation)

• Emails and communications: Up to 12 months

• Community platform data: For duration of membership plus 6 months

• Technical logs: Up to 12 months

6. Who has access?

Only Busra Kazmir and authorized third parties contracted by her (such as content creators, technical support, payment processors, or administrative personnel) have access to your personal data. All such parties are bound by confidentiality agreements and GDPR-compliant data protection policies to ensure your information is handled securely and confidentially.

Your data is never sold or shared with unauthorized persons or third parties, except where legally required (e.g., tax office, payment processor, or law enforcement when legally obligated).

7. International data transfers

Some of our service providers may be located outside the European Union. When data is transferred to countries outside the EU/EEA, we ensure adequate protection through:

• Adequacy decisions by the European Commission

• Standard Contractual Clauses (SCCs)

• Other appropriate safeguards as required by GDPR

By using our services, you consent to such transfers under the safeguards described above.

8. Your rights (GDPR)

You may:

• Access: Request a copy of your personal data

• Rectification: Request correction of inaccurate data

• Erasure: Request deletion of your data (subject to legal obligations)

• Restriction: Request limitation of processing

• Portability: Request data in a structured, machine-readable format

• Object: Object to processing based on legitimate interest

• Withdraw consent: Where processing is based on consent

• File a complaint: With the Dutch Data Authority (Autoriteit Persoonsgegevens)

9. Security

Busra Kazmir takes appropriate technical and organizational measures to protect your personal data against loss, theft, misuse, unauthorized access, alteration, or destruction. These measures include:

• Use of encryption (SSL/TLS)

• Secure storage and password-protected access

• Regular updates and security audits

• Access controls and authentication measures

• Staff training on data protection

Important Disclaimer: However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your data using industry-standard measures, Busra Kazmir cannot guarantee that unauthorized third parties will never be able to bypass security measures.

In the event of a security incident or data breach, we will comply with applicable laws including GDPR and notify affected parties as required.

By using our services, you acknowledge and accept the inherent risks related to data security and agree that Busra Kazmir is not liable for damages resulting from unauthorized access, hacking, or security breaches beyond her reasonable control.

10. Cookies and tracking

Our website and online platforms may use cookies and similar tracking technologies to:

• Ensure proper website functionality

• Analyze website traffic and usage patterns

• Improve user experience

• Remember your preferences

You can control cookie settings through your browser. Disabling cookies may affect website functionality.

11. Digital Platform Community

For members of the Digital Platform community, additional data processing includes:

• Participation records: Session attendance, community interactions

• User-generated content: Posts, comments, shared materials (subject to community guidelines)

• Communication data: Messages within the platform

• Technical data: Login times, platform usage analytics

Community Data Responsibility: You are solely responsible for any personal data you choose to share within the Digital Platform community. Other members' compliance with privacy and confidentiality rules cannot be guaranteed.

Privacy Policy – Public Content & Social Media

This section applies to public content shared by Busra Kazmir on platforms such as YouTube, Instagram, TikTok, newsletters, and livestreams.

1. What data may be collected?

When engaging with public content, we may collect:

• Public usernames and comments

• Messages you send via social media

• Replies to public posts or videos

• Analytics data provided by platforms (e.g., YouTube Insights)

• Newsletter subscription data

• Public interaction data (likes, shares, follows)

We do not actively collect or store sensitive personal data from public users unless you voluntarily contact us directly.

2. Purpose of data use

This information may be used to:

• Respond to messages or comments

• Understand general audience engagement

• Improve content or communications

• Send newsletters (with consent)

• Comply with platform policies

Data is not shared with third parties or used for marketing outside of the platform itself, except as described in this policy.

3. Legal basis

We process your public data only:

• With your consent (e.g., when you comment, message, or subscribe)

• When necessary to reply to your request

• To comply with legal obligations (e.g., copyright or reporting misuse)

• Legitimate interest for improving content and engagement

4. Data retention

• Comments and likes: Remain on the platform and are managed by that platform

• Private messages or emails: May be retained for up to 12 months, unless deleted earlier upon request

• Newsletter data: Until you unsubscribe or request deletion

• Analytics data: Retained according to platform policies

5. Security

Direct messages and email replies are stored securely and only accessible to Busra Kazmir and authorized personnel. We do not download or locally store platform analytics beyond what is necessary for business purposes.

6. Platform responsibility

Your use of platforms like YouTube, Instagram, or TikTok is subject to their own privacy policies:

• YouTube Privacy Policy

• Instagram Privacy Policy

• TikTok Privacy Policy

We are not responsible for how third-party platforms handle your data.

7. International viewers

While Kazmir operates under Dutch and EU law (GDPR), viewers from outside the EU (e.g., USA, Canada, India) may be subject to their own local privacy regulations. By engaging with the content, you agree to the terms stated here and acknowledge that data may be processed in countries with different privacy laws.

8. Newsletter and email marketing

If you subscribe to our newsletter:

• Data collected: Email address, name (optional), subscription preferences

• Purpose: Sending updates, content, and promotional materials

• Legal basis: Your explicit consent

• Retention: Until you unsubscribe or request deletion

• Your rights: You can unsubscribe at any time via the unsubscribe link or by contacting us

9. Liability limitations

Busra Kazmir is not liable for:

• Privacy breaches by third-party platforms

• Data shared by users in public comments or posts

• Misuse of publicly available information by other users

• Actions taken by social media platforms regarding your data

Your participation in public content and social media interactions is at your own risk.

General Provisions

10. Data subject requests

To exercise your GDPR rights or make data-related requests:

• Email us at hello@busrakazmir.com with your request

• Include verification of your identity

• Specify the nature of your request

• Response time: We will respond within 30 days (may be extended by 60 days for complex requests)

11. Complaints and disputes

If you believe your privacy rights have been violated:

• Contact us first at hello@busrakazmir.com

• File a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens)

• Legal action may be available under GDPR

12. Changes to this policy

This policy may be updated as needed to reflect:

• Changes in services or business practices

• Legal or regulatory requirements

• Technological developments

Notice of changes: We will notify you of material changes by email (for clients) or through our public channels. Continued use of services constitutes acceptance of the updated policy.

13. Contact information

For any privacy-related concerns:

📧 Email: hello@busrakazmir.com
📍 Address: Box D8412 Keurenplein 41, 1069CD Amsterdam, Nederland
🏢 Business: Kazmir (KvK: 88034615)