1. What is the purpose of this Data Privacy Policy?
Naomi Israel Consulting Ltd.(hereinafter also referred to as ‘she’) offers services in the field of Executive Coaching and Organizational Consulting. In the course of her business activities, she collects and processes personal data, especially personal data about her clients, affiliated individuals, counterparties, visitors to her website, participants in events, recipients of marketing information, and other entities or their respective contact persons and employees (hereinafter also ‘You’). In this Data Privacy Policy, she informs you about these data processing activities. Additionally, she may separately inform you about the processing of your data, for example, in consent forms, contract terms, additional privacy policies (e.g., on her other websites), forms, and notices. If you provide her with data about other individuals (e.g., family members, representatives, counterparties, or other affiliated individuals), she assumes that you are authorized to do so, that the data is correct, and that, if there is a legal obligation to inform these individuals, you have ensured that they are informed about this disclosure (e.g., by providing them with this Data Privacy Policy in advance).
2. Who is responsible for processing your data?
Responsible for the data processing described in this Data Privacy Policy is:
Naomi Israel Consulting Ltd. , Dufourstrasse 49, 8008 Zurich, Switzerland
If you wish to contact her – Naomi Israel Consulting Ltd. – regarding the processing of your data, you can do so via ‘[email protected]’.
3. For what purposes does she process your data?
When you use her services, her website www.naomiisrael.com (hereinafter ‘Website’), or otherwise interact with her, she collects and processes various categories of your personal data. In general, she may collect and process this data, especially for the following purposes:
• Communications: She processes personal data to communicate with you and third parties, such as team members, via email, phone, postal mail, or other means (e.g., for the preparation and execution of Executive Coaching and/or Organizational Consulting). For this purpose, she processes communication content, your contact information, communication metadata, and any image and audio recordings of (video) calls. In the case of audio or video recordings (e.g., in a video conference), she will inform you separately, and you can choose to inform her if you do not wish to be recorded or end the communication. She may also send information about events, news, or similar to her clients and contract partners as well as other interested individuals. This may include emails and other regular contacts (electronically, by mail, by phone). You can decline these communications (which may occur through any communication channels she has) at any time or refuse or withdraw consent for contact for marketing purposes by notifying her (see contact details in Section 2).
• Initiation and Conclusion of Contracts: In the context of entering into a contract (e.g., a contract to establish a mandate relationship) with you or your principal or employer, she may collect and process names, contact information, authorizations, consent declarations, information about third parties (e.g., additional contact persons), contract content, contract date, creditworthiness data, and any other data that you provide to her or that she collects from public sources or third parties (e.g., commercial registers, credit reporting agencies, sanctions lists, media, legal protection insurance, or the internet). She processes these data, especially when you or your principal or employer conclude a contract to establish a mandate relationship with her or when another party does so in cases in which you are involved.
• Management and Execution of Contracts: She collects and processes personal data to fulfill her contractual obligations towards her clients and other contract partners (e.g., suppliers, service providers, project partners) and, in particular, to provide and claim contractual services. This includes data processing for mandate management (e.g., organizational consulting) as well as data processing for contract enforcement (e.g., debt collection), accounting, and public communication (if permitted). For this purpose, she processes the data that she has collected or obtained as part of the initiation, conclusion, and execution of the contract, as well as data that she generates as part of her contractual services or obtains from public sources or other third parties (e.g., counterparties, information services, media, or the internet). These data may include conversation and consulting protocols, notes, internal and external correspondence, contract documents, documents created and received in the context of executive coaching and organizational consulting, image and audio recordings, as well as other mandate-related information, documents, invoices, as well as financial and payment information.
• Operation of Her Website: To operate her website securely and stably, she collects technical data, such as IP address, information about your device’s operating system and settings, as well as the region, time, and type of usage. She also uses cookies and similar technologies. For more information, see Section 8.
• Improvement of Her Offerings: To continuously improve her website and other electronic offerings (e.g., other websites, online tools) as well as her services, she collects data about your behavior and preferences. This includes analyzing how you navigate through her website, how you interact with her social media profiles, or how you use her services or whether you like them. For this purpose, she processes direct or indirect feedback from you regarding her website, social media presence, and tools (e.g., comments, emails, or other statements directed to her or of which she otherwise becomes aware), as well as other feedback on her services, including within the context of mandate relationships or in public statements made by you (e.g., on social media, in the media, or through submissions).
• Registration: To use certain offerings and services (e.g., self-awareness questionnaires, 360-degree feedback), you may need to register (either directly with her or through her external login providers). For this purpose, she processes the data provided during the respective registration. Furthermore, she may collect personal data about you during your use of the offering or service, such as behavioral and preference data or communication data. If necessary, she will provide you with additional information about the processing of this data.
• Security Purposes: She collects and processes personal data to ensure the adequate security of her IT and other infrastructure (e.g., buildings) and to continuously improve it. This includes monitoring and controlling electronic access to her IT systems, as well as physical access to her premises, analysis and testing of her IT infrastructures, system and error checks, and the creation of backups.
• Compliance with Laws, Directives, and Recommendations from Authorities and Internal Regulations (‘Compliance’): She collects and processes personal data to comply with applicable laws (e.g., tax obligations), self-regulations, certifications, industry standards. For this purpose, she collects, in particular, master and behavioral data, financial data, as well as any other data that she deems necessary or useful to comply with her obligations with regard to compliance.
• Risk Management and Corporate Governance: She collects and processes personal data as part of risk management and corporate governance. This includes her operational organization (e.g., resource planning).
• Job Applications: If you apply for a position with her, she collects and processes the relevant data for the purpose of reviewing the application, conducting the application process, and, if applicable, to establish an employment relationship. She may also process your data to fulfill legal or regulatory obligations (e.g., retention of application documents).
4. Where does the data come from?
• From you: You provide her with many of the data she processes yourself (e.g. as part of a client relationship or otherwise in connection with her services, the use of her website or communication with you). You are not obliged to disclose your data, with exceptions in individual cases (e.g. legal obligations). However, if you want to use her services or otherwise conclude contracts with her, you must provide her with certain data. However, it is possible to use her website without data processing (with the exception of the Contact page).
• From third parties: She can also take data from publicly accessible sources (e.g. commercial registers, media or the Internet including social media) or receive them from (i) authorities at home and abroad, (ii) your employer or sponsor, provided that they either communicate with her in a business relationship or have something else to do, as well as (iii) other third parties (e.g. clients, counterparties, contractual partners). This includes, in particular, the data that she processes as part of a client relationship or otherwise when initiating, concluding and processing contracts, as well as data from correspondence and meetings with third parties, but also all other data categories in accordance with Section 3.
5. Who does she share your data with?
In connection with the purposes listed in section 3, she transmits your personal data in particular to the categories of recipients listed below. If necessary, she will obtain your consent for this.
• Within Naomi Israel Consulting Ltd.: Internally, she exchanges your personal data for the purposes described in Section 3 and processes it accordingly.
• Service provider: She works with service providers at home and abroad who (i) process data that they receive from her on her behalf (e.g. IT providers such as Microsoft), (ii) under joint responsibility with her or (iii) on their own responsibility handling data, that they collected from her, or that they collected for her. These service providers include, for example, other executive coaches or consulting companies. As a rule, she agrees contracts with her service providers regarding the use and protection of personal data.
• Clients and other contractual partners: First of all, this refers to clients and other contractual partners for whom the transfer of your data results from the contract (e.g. because you work for a contractual partner or she provides services for you). This category of recipients also includes bodies with which she cooperates, such as other consultancies at home and abroad. The recipients generally process the data under their own responsibility, sometimes alone, sometimes together with the recipient.
• Authorities and courts: She can pass on personal data to official bodies, courts and other authorities at home and abroad if she is entitled or legally obliged to do so or if this appears necessary to protect her interests or those of her clients or third parties. These recipients process the data on their own responsibility.
• Counterparties and people involved: If this is necessary or seems sensible for the fulfillment of her contractual obligations, in particular for managing the mandate, she will also pass on your personal data to counterparties and other people involved (e.g. dedicated project members).
• Other people: This refers to other cases where the involvement of third parties arises from the purposes set out in Section 3. This applies, for example, to delivery addressees or payment recipients specified by you. As part of communication with her competitors, industry organizations, associations, market observers and other committees, data that concerns you may also be exchanged.
All of these categories of recipients can in turn involve third parties so that your data can also become accessible to them. You can restrict processing by certain third parties (e.g. IT providers), but not that of other third parties (e.g. authorities).
6. Does your personal data also go abroad?
She processes and stores personal data mainly in Switzerland and the European Economic Area (EEA), and depending on the medium – for example ZOOM – also in other countries around the world.
7. What rights do you have?
You have certain rights in connection with your data processing. In accordance with applicable law, you can, in particular, request information about the processing of your personal data, have incorrect personal data corrected, request the deletion of personal data, object to data processing, request the release of certain personal data in a common electronic format or its transfer to other responsible persons or request consent revoked with effect for the future, provided that her processing is based on your consent.
If you want to exercise your rights against her, contact her; you can find their contact details in Section 2.
Please note that conditions, exceptions or restrictions apply to these rights (e.g. to protect third parties or trade secrets or due to professional confidentiality). She reserves the right to black out copies or only provide extracts for data protection reasons or reasons of confidentiality.
8. How do your website and other digital services use cookies, similar technologies and social media plug-ins?
When you use her website, data is generated that is stored in logs (particularly technical data). She can also use cookies to recognize website visitors, evaluate their behavior and recognize preferences. A cookie is a small file or code sequence that is transmitted between the server and your system and allows a specific device or browser to be recognized.
You can set your browser to automatically reject, accept or delete cookies. You can also deactivate or delete cookies in individual cases. You can find out how to manage cookies in your browser in the help menu of your browser.
Both the technical data and cookies she collects generally do not contain any personal data. However, personal data that you or third-party providers commissioned by you store about you (e.g. if you have a user account with these providers) may be linked to the technical data or to the information stored in and obtained from cookies and thus possibly to you personally.
She also sometimes uses social media plug-ins, i.e. small software modules that establish a connection between your visit to her website and a third-party provider. The social media plugin tells the third party that you have visited her website and may transmit to the third party cookies that they have previously placed on your web browser. For more information about how these third parties use your personal information collected through their social media plugins, please see their respective privacy policies.
On her website and elsewhere in the digital area, she particularly uses offers from the following service providers, whose contact details and further information on individual data processing can be found in the respective data protection declaration:
• LinkedIn
Provider: LinkedIn Ireland Unlimited Company, Irland
Data protection information:https://de.linkedin.com/legal/privacy-policy?
Where the third-party providers she uses are located outside of Switzerland, you can find information about any data she may disclose abroad under Section 6.
9. How does she process personal data on her social network pages?
She operates pages on social networks, especially LinkedIn, and processes data in this context. She receives data from you (e.g. when you communicate with her or comment on her content) and from the platforms (e.g. statistics). The platform providers may analyze your use and process this data together with other data they have about you. She also processes this data for her own purposes (e.g. marketing and market research purposes and to manage her platforms) and acts as her own controller for this purpose. For further information on processing by the platform operators, please refer to the data protection declarations of the respective platforms.
She currently uses the following platform, whereby the identity and contact details of the platform operator can be found in the data protection declaration:
• LinkedIn: www.linkedin.com/company/naomi-israel-consulting
Provider: LinkedIn Ireland Unlimited Company, Irland
Data protection information: https://de.linkedin.com/legal/privacy-policy?
She is entitled, but not obliged, to check content before or after her publication on her online presence, to delete content without notice and, if necessary, to report it to the provider of the platform in question.
Where the platform operators you use are located outside of Switzerland, you can find information about any data she may disclose abroad under section 6. Accessing their offers directly (e.g. visiting their online presence on social media, see below) , you send your personal data abroad yourself and not her.
10. What else needs to be taken into account?
She does not assume that the EU General Data Protection Regulation (“GDPR”) is applicable in her case. However, if this is the case in exceptional cases for certain data processing, then this section 10 also applies exclusively for the purposes of the GDPR and the data processing subject to it.
The processing of your personal data is based in particular on the fact that:
• it is necessary, as described in Section 3, for the initiation and conclusion of contracts and their administration and enforcement (Art. 6 Para. 1 (b) GDPR);
• it is necessary to protect the legitimate interests of you or third parties, as described in Section 3, namely for communication with you or third parties, to operate her website, to improve her services and to register for certain offers and services, for security purposes, for compliance with Swiss law and internal regulations, for risk management and corporate governance and for other purposes such as training and education, administration, quality assurance, organization, implementation and follow-up of events and other legitimate interests (Art. 6 Para. 1 (f) GDPR);
• it is required or permitted by law due to her mandate or position under the law of the EEA or a member state (Art. 6 Para. 1 (c) GDPR) or is necessary to protect your interests or those of other natural persons (Art. 6 Para. 1 (d) GDPR);
• You have consented to the processing separately, e.g. via a corresponding declaration on her website (Art. 6 Para. 1 (a) and Art. 9 Para. 2 (a) GDPR).
She would like to point out that she will generally process your data for as long as required by its processing purposes (see Section 3), the legal retention periods and her legitimate interests, in particular for documentation and evidence purposes, or for as long as storage is required for technical reasons ( e.g. in the case of backups or document management systems). If there are no legal or contractual obligations or technical reasons to the contrary, she will generally delete or anonymize your data after the storage or processing period has expired as part of her usual processes and in accordance with her retention policy.
If you do not provide certain personal data, this may mean that it is not possible to provide the related services or conclude a contract. She will point out where the personal data she requests is mandatory.
The right to object to the processing of your data as set out in Section 7 applies in particular to data processing for the purpose of direct marketing.
If you do not agree with her handling of your rights or data protection, please let her know (see contact details in Section 2). If you are in the EEA, you also have the right to complain to your country’s data protection supervisory authority. A list of authorities in the EEA can be found here: https://edpb.europa.eu/about-edpb/board/members_de.
11. Can this Data Privacy Policy be changed?
This Data Privacy Policy does not form part of a contract with you. She can adapt this data protection declaration at any time. The version published on this website is the current version.