The Breakthrough Club Privacy Statement

Personal data must be processed in a lawful and transparent manner, ensuring fairness towards the individuals whose personal data is being processed (‘lawfulness, fairness and transparency’).

What is personal data?

The General Data Protection Regulation (GDPR) states that personal data is any information about an identified or identifiable natural person. This means that information is either directly about someone or can be traced back to this person.

About us

Breakthrough Club B.V. (hereafter “Breakthrough Club”), Adres, Amsterdam is responsible for the processing of personal data as set out in this privacy statement as a data controller.  

For what purposes do we process personal data?

Your personal data is exclusively processed for well-defined purposes. As part of your participation in our Breakthrough Club program and in compliance with the Dutch GDPR law, we obtain personal data from you, which is deemed necessary for the preparation or execution of the agreement between us. It is important to understand that without processing this data, we would be unable to deliver our services to you effectively.

Additionally, we utilize your personal data for marketing activities, a practice recognized as processing for our legitimate interests as per legal requirements. Below, we provide further details regarding the various objectives involved.

1. To provide the Breakthrough Club Program

We process personal data for the execution of our agreement in two steps. The first step is to determine if you meet the inclusion criteria for participating in the Breakthrough Club. Based on a medical screening, your answers provided in the questionnaires and (online) interview, we make sure you are mentally and physically healthy. The personal data we process during the first step includes medical data. We kindly ask you to provide your consent for using this data to determine if you are suitable to join the BreakTrough Club Program. During the screening you will provide personal data regarding, among other things:

  • Your name and date of birth;
  • General screening of your mental and physical health (current and history);
  • two short psychiatric screening tests (PHQ9 - Depression, GAD7 - Anxiety);
  • Your previous experience(s) with psychedelic substances (if you have any);
  • current and previous drug/substances use. (We will ask participants if they are open to refrain from drug/substances during the course of the program and/or (depending on the person) to be very conscious with the usage of it (for example, alcohol maximum of two units per week prior to the ceremony);
  • current and history of medication.

During the second step (the Breakthrough Club Coaching Program) we process personal data you provide to us regarding: Your life-story, your strengths and pitfalls, what your future dream-life looks and feels like, your core values, your intention for the BreakThroughClub Coaching Program, Information about your Thoughts, Emotions and Behaviours, ect.

This purpose is necessary for the conclusion or performance of an agreement (Article 6 paragraph 1 sub b GDPR) and consent, which you give when you sign up for our Breakthrough Club Coaching Program (Article 6 paragraph 1 sub a GDPR).

2. For Scientific Research  

We use aggregated, anonymized and/or pseudonymized data for scientific research purposes in order to improve our services and to empirically research the effectiveness of the BreakThrough Club. This is based on our legitimate interest to improve our services and conduct empirical research on the effectiveness of our services (Article 6 (1) (f) GDPR).

3. For Customer Service: handling questions / comments / complaints

You can call and email us. To ensure that we can help you immediately we use the data available in our customer relationship management system, which includes your contact information, questions, used services, et cetera. This is necessary for the conclusion or performance of a contract (Article 6 (1) (b) GDPR) and / or our legitimate interest (Article 6 (1) (f) GDPR).

4. Sending News and Promotions by Email

You can sign up for the newsletter via our site. You will only receive marketing messages from us if you have given us permission to do so, or if you have enrolled in the BreakTrough Club (or other) services from us and have not indicated that you do not wish to receive the marketing messages.  

Would you rather not receive a newsletter anymore? Unsubscribe via the email itself by clicking on "unsubscribe" or by emailing us at privacy@breakthroughclub.org with this request. The legal basis is our legitimate interest (Article 6 (1) f GDPR) and consent, which you give when you sign up for our newsletter (Article 6 paragraph 1 sub a GDPR).

Who do we share your data with?

In a number of cases, we provide your data to external parties. For example, the external service providers that help us process your personal data. However, we will never sell your data to other parties.  

Processors who help us process your personal data may only use your data on our instructions and to perform the relevant services they provide to us. They may not use or pass on your data independently.  

In some cases, we might be legally obliged to provide your data. For example, to governmental bodies. In all cases, we only share strictly necessary data. Furthermore, we could share your data with:

  • Website visitors when we share your review(s)  

    We ask you to leave a review on our website to help inform other future BreakTrough Club Participants. By adding a review we share your: (nick)name and review. After posting, the review is public. Please use a nickname and not your real name if you prefer not to have your real name visible on our website.
  • Service providers

    We can use the services of third parties to process your data in accordance with this privacy statement. These third parties act as processors for us. This includes the party that hosts our website, suppliers who help us with marketing activities and suppliers who help us with a customer relationship management service.
  • Third parties who act as processors for us have entered into a processor agreement with us which, among other things, states that they will only process your data in accordance with our instructions, treat the data confidentially and secure it properly. [We also share order and financial information that could contain personal data in specific circumstances within our group for administrative purposes.]

How long do we keep your data?

We keep this data for as long as is necessary for the purpose for which we use your data. And as long as the law obliges us to keep your data. Exactly how long that is differs. From a few months to many years, for example because that is necessary for our accounting.  

We will store your data in any case as long as necessary, unless you ask us to delete data or your account via info@breakthroughclub.org. In case we have no further legal obligation to maintain your data, then we will delete your data within 30 days after your request.

    How we protect your data?

    Pursuant to Article 32 of the GDPR, we are obliged to take appropriate technical and organizational measures to prevent the loss of personal data or unlawful processing.

      5. Security

      We pay a lot of attention to properly securing personal data. For example, the (personal) data that you enter on the website during transmission is encrypted and the (personal) data is sent via a secure connection.

      6. Confidentiality

      All our employees and external service providers have signed a confidentiality agreement. We handle information that you entrust to us with care. That is why only certain employees get access to your data.  

      We apply a high level of security for your data. The data is stored on a secure server, among other things. This server is only accessible to persons who are expressly authorized to do so. The building where the server is located is also well secured.

      Where do we store your data?

      We work with various applications to obtain and store certain data. To guarantee your privacy, we choose our suppliers carefully and these applications are bound by strict rules. Most data are stored within the European Union.  

      For the data that is sent outside the EU, we only work with parties that offer sufficient protection according to European rules. If we (possibly via our external service providers) process your data outside the EU, we will ensure adequate protection of your personal data. For example, by using special contacts to ensure this (for example, EU Standard Contractual Clauses).

      Your rights

      You have the right to be well informed about what we do with your data and why we need your data. We do this by means of this privacy statement. In addition to the right to be informed transparently, you have the following rights:  

      • Right of access (if you want to know what data we collect from you);
      • Right to rectification (we are happy to adjust all data that are no longer correct);
      • Right to be forgotten (in some cases you can ask us to delete your data);
      • Right to restriction of processing (in some cases you may ask us to limit the processing of your data);
      • Right to data portability (if you wish, we can pass on your data to another party or give you a copy of your data);
      • Right to object (in some cases you may object to the use of your data).

      YIf you want to exercise one of your rights, you can contact us (see contact). We will respond to your request within one month.

      If we need your consent

      If we process your data on the basis of consent, you always have the right to withdraw your consent. You can easily do this by emailing privacy@Breakthroughclub.org. If we have no other basis for the data that we process on the basis of consent, we will no longer use this data and delete it.

        Complaints

        In case of complaints, for example about the way in which we use your data or how we respond to your privacy-related questions, you can submit a complaint to the Dutch Data Protection Authority.

          Contact

          If you have any questions about this Privacy Statement or want to exercise your rights as data subjects, you can contact us at info@breakthroughclub.org

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