("NewCOACH.ES", "we") is the controller for the personal data described in this policy. Contact for privacy questions: hello@smrt.bio
The SMRT.BIO platform is operated by SMRT.BIO Global B.V., Mierloseweg 134, 5707 AS Helmond, Netherlands. When we use the platform to deliver NewCOACH.ES services, SMRT.BIO processes data on our behalf under a data processing agreement. For personal SMRT.BIO accounts that exist independently of NewCOACH.ES, SMRT.BIO is the controller and its own privacy policy applies (SMRT.BIO Privacy Policy).
We do not ask for special categories of personal data (such as health, religion or ethnic origin). Please do not enter such data in free-text fields. Test results describe interests, strengths and skills; they are not psychological diagnoses.
A coach sees a coachee's data only after the coachee has linked to that coach, and only the parts the coachee has chosen to share in their SMRT.BIO sharing settings. The coachee can change or withdraw this at any time, after which the coach no longer has access. Coaches are bound by our Terms and Code of Conduct to use this data only for coaching that person.
SMRT.BIO calculates test profiles and suggests matching jobs and courses automatically. These are suggestions to support a decision that the coachee makes, with their coach. We do not make decisions based solely on automated processing that have legal or similarly significant effects on you. Financing decisions are taken by the financing parties, not by us.
SMRT.BIO Global B.V., as platform provider (processor).
Hosting and IT providers: [● name, location].
Payment provider: Mollie, which processes card and bank data under its own responsibility.
Your coach, only as described in section 4.
Financing parties, only when you submit an application through the Apply for Financing module, and only the data in that application.
Accountants, auditors and legal advisers, where needed.
Authorities, where the law requires it.
We do not sell personal data.
The SMRT.BIO group has companies in South Africa and Pakistan, and coaches and coachees may be based outside the EEA. Where personal data is transferred to a country without an EU adequacy decision, we use the European Commission's Standard Contractual Clauses and additional safeguards where needed. You can request a copy via hello@smrt.bio. When a coach outside the EEA views data a coachee has chosen to share with them, that transfer happens at the coachee's request.
We and SMRT.BIO use technical and organisational measures appropriate to the risk, including encrypted connections, access controls based on role, logging, and confidentiality obligations for staff and trainers. If a personal data breach is likely to cause you a high risk, we will tell you without undue delay.
You have the right to access your data, to have it corrected or deleted, to restrict or object to processing, to data portability, and to withdraw consent at any time (without affecting processing before withdrawal). Send your request to hello@smrt.bio. We respond within one month; we may ask you to confirm your identity.
You can also complain to a data protection authority, in particular in the EU country where you live or work. In the Netherlands this is the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl); in Spain the Agencia Española de Protección de Datos (aepd.es).
Our services are intended for people aged 16 and over. Where an educational institution uses SMRT.BIO with younger pupils, the institution is responsible for obtaining parental consent.
We may update this policy. The date at the top shows the current version. We will notify account holders of material changes by email.