Data Protection Policy

Last updated: April 7, 2025

Henriquez E-Commerce & Leadership Training, operating under the brand Optimize Your Vibe, is committed to protecting the personal data of everyone we work with. This policy describes how personal data is collected, handled, and stored to meet our data protection standards and comply with applicable law — including the EU General Data Protection Regulation (GDPR), which applies to individuals located in the European Economic Area (EEA).

Nevin Henriquez Henriquez E-Commerce & Leadership Training Savaneta 177 E, Aruba Email: connect@optimizeyourvibe.com International: +31 6 1446 0094 Local: +297 593 7547

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1. Why This Policy Exists

This Data Protection Policy ensures that Henriquez E-Commerce & Leadership Training:

• Complies with data protection law and follows industry best practices

• Protects the rights of clients, affiliates, partners, and staff

• Is open and transparent about how it stores and processes personal data

• Protects itself and the individuals it works with from the risks of a data breach

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2. The Law — EU GDPR

The EU General Data Protection Regulation (GDPR) describes how organizations that conduct business with individuals or entities located in EU/EEA nations must collect, handle, and store personal information. These rules apply regardless of whether data is stored electronically, on paper, or in any other format.

To comply with the law, personal information must be collected and used fairly, stored safely, and not disclosed unlawfully. The GDPR is underpinned by eight core principles. Personal data must:

• Be processed fairly, lawfully, and in a transparent manner

• Be obtained only for specific, lawful purposes

• Be adequate, relevant, and not excessive

• Be accurate and kept up to date

• Not be held for any longer than necessary

• Be processed in accordance with the rights of data subjects

• Be protected in appropriate ways against unauthorized or unlawful processing and against accidental loss, destruction, or damage

• Not be transferred outside the European Economic Area (EEA) unless that country or territory also ensures an adequate level of protection

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3. Policy Statement

Every day our business receives, uses, and stores personal information about our clients, affiliates, partners, and colleagues. It is important that this information is handled lawfully and appropriately, in line with applicable data protection requirements.

We take our data protection duties seriously because we respect the trust placed in us to use personal information responsibly. This policy sets out the basis on which we process any personal data that we collect or handle. It may be amended at any time and does not form part of any employment contract.

The company as a whole is responsible for ensuring compliance with applicable data protection law. Any questions about this policy or concerns that it has not been followed should be directed in the first instance to our Data Protection contact at connect@optimizeyourvibe.com.

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4. What Is Personal Data?

Personal data is any data — whether stored electronically or in paper format — relating to a living individual who can be identified directly or indirectly from that data.

Processing means any activity that involves the use of personal data. This includes obtaining, recording, holding, organizing, amending, retrieving, using, disclosing, erasing, or destroying data, as well as transferring personal data to third parties under privacy control conditions.

Sensitive personal data includes contact information, address, session activity on our platform, and IP location. Sensitive personal data may only be processed under strict conditions and only for the express purpose for which it was collected.

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5. Data Protection Principles

Anyone within our organization who processes personal data must ensure that data is:

• Processed fairly, lawfully, and in a transparent manner

• Collected for specified, explicit, and legitimate purposes, with any further processing completed only for a compatible purpose

• Adequate, relevant, and limited to what is necessary for the intended purposes

• Accurate and, where necessary, kept up to date

• Kept in a form that permits identification for no longer than necessary for the intended purposes

• Processed in line with the individual's rights and with appropriate security measures — including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage

• Not transferred to people or organizations in countries without adequate data protection, without first advising the individual

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6. Fair and Lawful Processing

We will only process personal data where it is required for a lawful purpose. Lawful purposes include: the individual's consent, the performance of a contract with the individual, compliance with a legal obligation, or the legitimate interests of the business. When sensitive personal data is processed, additional conditions must be met.

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7. Collection of Information

Information you provide us

We collect information you provide directly, including your name, email address, postal address, payment method, and telephone number. We collect this information when you use our services, interact with our customer support, participate in surveys or promotions, provide reviews or ratings, or otherwise provide information to us through our Site or elsewhere.

Information we collect automatically

We collect information about you and your use of our services, including:

• Your activity on our platform, such as course progress and search queries

• Details of your interactions with customer service, including date, time, and reason for contact

• Transcripts of any chat conversations initiated on our platforms

• Device IDs or unique identifiers, device and software characteristics

• Connection information, page view statistics, referral URLs, and IP address

• Information collected via cookies, web beacons, and other tracking technologies, including advertising data

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8. Use of Information

We use the information we collect to provide, analyze, administer, enhance, and personalize our services and marketing efforts, and to process registrations, orders, payments, and communications.

Our primary aim is always to enhance the user experience. We use data to understand how our platform is being used, identify difficulties users may be facing, and take action to improve the experience. We also use data such as most visited links and most watched content to understand user preferences and create additional content aligned with our clients' needs.

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9. Processing for Limited Purposes

In the course of our business, we may collect and process personal data received directly from individuals and from other sources, including business partners, sub-contractors, and payment service providers.

We will only process personal data for the specific purposes for which it was collected or for any other purposes specifically permitted by applicable data protection law. We will notify individuals of those purposes at the point of collection or as soon as reasonably practicable thereafter.

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10. Notifying Individuals

When we collect personal data directly from an individual, we will inform them of:

• The purpose or purposes for which we intend to process their personal data, and the legal basis for processing

• The types of third parties, if any, with whom we will share their personal data

• Any intended transfers of personal data to a country outside the EEA, and the safeguards in place

• How individuals can limit our use and disclosure of their personal data

• The period for which their data will be stored, or the criteria used to determine that period

• Their rights to access, correct, erase, restrict, port, and object to the processing of their data

• Their right to withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal

• Their right to lodge a complaint with a relevant data protection authority

If we receive personal data about an individual from other sources, we will provide them with this information as soon as possible and at the latest within one month.

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11. Accurate Data

We will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of personal data at the point of collection and at regular intervals thereafter. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data promptly.

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12. Timely Processing

We will not keep personal data longer than is necessary for the purpose or purposes for which it was collected. We will take all reasonable steps to destroy or erase from our systems all data that is no longer required.

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13. Processing in Line With Individual Rights

We will process all personal data in line with data subjects' rights, including their right to:

• Confirmation as to whether or not personal data concerning them is being processed

• Access any data held about them

• Request rectification, erasure, or restriction of processing

• Lodge a complaint with a supervisory authority

• Data portability

• Object to processing, including for direct marketing

• Not be subject to automated decision-making, including profiling, in certain circumstances

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14. Data Security

We will take appropriate security measures against unlawful or unauthorized processing of personal data and against accidental or unlawful destruction, damage, loss, alteration, or unauthorized disclosure.

We maintain data security by protecting the confidentiality, integrity, and availability of personal data:

Confidentiality – only people authorized to use the data can access it.

Integrity – personal data is accurate and suitable for the purpose for which it is processed.

Availability – authorized users can access the data when they need it for authorized purposes.

Our security procedures include:

• Data minimization practices

• Pseudonymization and encryption of data where appropriate

• Restricted access controls — only staff with a legitimate business need may access personal data

• Secure disposal of paper documents and physical destruction of digital storage devices when no longer required

• Electronic data deleted once its intended purpose is fulfilled

• Staff ensuring that screens displaying personal data are not visible to unauthorized persons, and that devices are locked when left unattended

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15. International Transfers

We may transfer personal data to countries outside the European Economic Area (EEA). We will only do so where:

• The destination country ensures an adequate level of protection for data subjects' rights and freedoms

• The data subject has given their consent

• The transfer is necessary for the performance of a contract with the data subject or is required on important public interest grounds

• The transfer is authorized by the relevant data protection authority and appropriate safeguards are in place

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16. Disclosure and Sharing of Personal Data

We may share personal data with sub-processors and third-party service providers who assist us in delivering our services. We require all such parties to respect the security of personal data and treat it in accordance with applicable law.

We may also share personal data in the event of a business sale, merger, or restructuring, in which case the new owner may use personal data in the same way as set out in this policy.

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17. Subject Access Requests

Individuals have the right to request access to the personal data we hold about them. All such requests should be submitted in writing to connect@optimizeyourvibe.com.

Upon receiving a request, we will verify the identity of the requester before disclosing any information. We will respond to all legitimate requests within one month. If a request is particularly complex, we will notify the individual and keep them updated. We will not charge a fee for reasonable requests.

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18. Data Breach Procedures

We have procedures in place to detect, report, and investigate personal data breaches. In the event of a confirmed breach, we will notify affected individuals and any applicable regulatory authority without undue delay, and in accordance with our legal obligations.

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19. Changes to This Policy

We may modify this Data Protection Policy at any time. Any changes will be posted on this page with a revised "Last updated" date. If you have any questions or concerns, please contact us at connect@optimizeyourvibe.com.