Privacy Policy

Introduction

ApexCadence, UAB ("we," "our," or "us") is committed to protecting your privacy and the security of your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website amberlvanalyticsgroup.com (the "Website") or engage with our executive coaching services.

We process personal data in accordance with the General Data Protection Regulation (GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, and other applicable data protection laws.

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Website or use our services.

Data Controller

The data controller responsible for your personal data is:

ApexCadence, UAB
Registration Number: 123456789
Varpo g. 15, Šiauliai, 76348 Šiaulių m. sav., Lithuania
Email: dpo@amberlvanalyticsgroup.com
Phone: +370 41 596 252

Categories of Personal Data We Collect

We may collect the following categories of personal data:

1. Information You Provide to Us

• Contact Information: Name, email address, phone number, company name, position/title.
• Inquiry Information: Messages, questions, or information you provide through our contact forms, email, or phone.
• Service Information: Information relevant to coaching services, including leadership assessment data, professional goals, and coaching notes.
• Contractual Information: Details necessary for establishing and managing our business relationship.
• Billing Information: Payment information, billing address, and other financial information necessary for processing payments.

2. Information We Collect Automatically

• Usage Data: IP address, browser type, operating system, referring URLs, access times, pages viewed, links clicked, and other actions taken on our Website.
• Device Information: Type of device, unique device identifiers, and mobile network information.
• Cookies and Similar Technologies: Information collected through cookies, web beacons, and similar technologies. For more information, please see our Cookie Policy.

Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Performance of a Contract: Processing necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract.
• Legitimate Interests: Processing necessary for our legitimate interests, provided that these interests are not overridden by your interests or fundamental rights and freedoms.
• Consent: Processing based on your specific, informed, and unambiguous consent.
• Legal Obligation: Processing necessary for compliance with a legal obligation to which we are subject.

The specific legal basis depends on the category of data and the purpose of processing, as detailed below.

Purposes of Processing

We may use your personal data for the following purposes:

• Provide Services: To provide and deliver the executive coaching services you request, including managing your account, processing payments, and fulfilling our contractual obligations.
• Communicate with You: To respond to your inquiries, send service-related communications, and provide customer support.
• Improve Our Services: To analyze usage patterns, conduct research, and develop new features or services.
• Marketing: To send you promotional communications about our services, events, or other information that may be of interest to you, but only if you have consented to receive such communications or if we have a legitimate interest to do so.
• Legal Compliance: To comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
• Security and Fraud Prevention: To protect the security and integrity of our Website, services, and business.

Recipients of Personal Data

We may share your personal data with the following categories of recipients:

• Service Providers: Third-party vendors who perform services on our behalf, such as IT and system administration, hosting, payment processing, analytics, and marketing. These service providers only access your personal data as necessary to perform their functions and are contractually obligated to maintain its confidentiality.
• Professional Advisors: Lawyers, auditors, bankers, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• Authorities: Government bodies, regulators, law enforcement agencies, courts, or other authorities as required by law or to protect our rights.
• Business Partners: In the event of a merger, acquisition, or asset sale, your personal data may be transferred as part of the transaction.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes.

International Transfers

We are based in Lithuania, but some of our service providers may be located outside the European Economic Area (EEA). Whenever we transfer your personal data outside the EEA, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (Standard Contractual Clauses).
• Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield or have implemented equivalent safeguards.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider:

• The amount, nature, and sensitivity of the personal data
• The potential risk of harm from unauthorized use or disclosure
• The purposes for which we process the data
• Whether we can achieve those purposes through other means
• The applicable legal requirements

Typical retention periods:

• Contact Information: For clients, we retain this information for the duration of our business relationship plus 5 years. For non-clients who have contacted us, we retain information for 2 years from the last communication.
• Service Information: We retain coaching-related information for the duration of the coaching engagement plus 3 years.
• Contractual Information: We retain this information for the duration of the contract plus the applicable statute of limitations (typically 10 years in Lithuania).
• Usage Data: We retain this information for up to 26 months.

Your Rights

Under applicable data protection laws, you have the following rights:

• Access: The right to request a copy of the personal data we hold about you.
• Rectification: The right to request that we correct any inaccurate or incomplete personal data.
• Erasure: The right to request that we delete your personal data in certain circumstances.
• Restriction: The right to request that we restrict the processing of your personal data in certain circumstances.
• Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format.
• Object: The right to object to the processing of your personal data in certain circumstances, including for direct marketing purposes.
• Withdraw Consent: The right to withdraw your consent at any time where we rely on consent to process your personal data.
• Lodge a Complaint: The right to lodge a complaint with a supervisory authority, particularly in the country of your habitual residence, place of work, or place of the alleged infringement.

To exercise any of these rights, please contact us using the contact details provided below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Cookies and Similar Technologies

We use cookies and similar technologies to enhance your experience on our Website, analyze usage patterns, and deliver personalized content.

Cookies are small text files that are stored on your device when you visit a website. They are widely used to make websites work more efficiently and provide information to website owners.

For detailed information about the cookies we use, the purposes for which we use them, and how you can control them, please see our Cookie Policy.

Data Security

We have implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

• Encryption of personal data where appropriate
• Regular testing, assessing, and evaluating the effectiveness of our security measures
• Procedures to address potential data breaches
• Access controls and authentication requirements
• Staff training on data protection and security

While we take reasonable steps to protect your personal data, no security system is impenetrable, and we cannot guarantee the absolute security of your information.

Children's Privacy

Our Website and services are not intended for children under the age of 16, and we do not knowingly collect personal data from children under 16. If you are a parent or guardian and believe that your child has provided us with personal data, please contact us, and we will take steps to delete such information.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. The updated version will be indicated by an updated "Last updated" date. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.