Introduction
We are committed to serving our clients and customers to the best of our ability, protecting your data and safeguarding your privacy.
This privacy policy (the “Privacy Policy”) details how Alexandra Slack Coaching (“ASC“) collects and processes your personal data when you interact with the ASC website (https://www.alexandraslack.com) and any other domains that it may use (the “ASC Website”), including but not limited to purchasing a product or service, signing-up to our newsletter or taking an assessment or utilising any similar tool, or scheduling a complimentary ‘discovery’ coaching session.
Data Controller
ASC acts as the data controller and is responsible for your personal data. For the purpose of this Privacy Policy, references to “we”, “us” or “our” refers to ASC.
Contact Details
The contact details of the data controller are:
Alexandra Slack, Coaching
31 rue du Village
Schuttrange
L-5370, Luxembourg
Email: alexandra@alexandraslack.com
If you have any questions about this Privacy Policy, please contact us.
Consent
By using our website, you hereby freely consent to the collection and processing of your data as described in this Privacy Policy.
Complaints Procedure
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the National Commission For Data Protection (the Commission Nationale pour la Protection des Donées, “CNPD”), the Luxembourg supervisory authority for data protection issues (https://cnpd.public.lu/en/particuliers/faire-valoir.html).
However, we should be grateful if you would first raise the issue with us do that we can try to resolve it for you.
Collection and Use of Personal Data
Collection
Personal data means any information or data capable of identifying you as an individual. It does not include anonymised data.
We may collect and process the following categories of personal data (with examples per category which are inclusive but not exhaustive in each case):
• Identity Data – your first name, last name, title, username, date of birth and gender
• Contact Data – your email address, billing/delivery address and telephone number
• Financial Data – your bank account details and/or payment card details
• Transaction Data – details of any transactions between us
• Profile Data – as the case may be, your username and password, purchases/order history, your preferences, feedback, survey responses and assessment responses
• Technical Data – as the case may be, your login data, internet protocol addresses, browser type and version, browser plug-in type, time zone setting and location, operating system and platform and other technology on the device(s) you use to access the ASC Website
• Usage Data – which may include information about how you use the ASC Website, products and services
• Marketing and Communications Data – which may include your preferences in receiving marketing communications from us and other third parties and other communication preferences.
Use
We will only process your personal data when legally permitted to do so.
Your personal information may be stored and used by ASC to perform a contract between us or to provide our products or services to you, or to contact you with respect to transactions conducted through the ASC Website. We may also use your personal data where it is necessary for our legitimate interests (or those of a third party) where any your interests and fundamental rights do not override those interests, or where we must comply with a legal or regulatory obligation or we believe, in good faith, that the disclosure is required by law.
We will not sell, rent or, save as set out in this Privacy Policy, disclose your personal information to our business partners, suppliers, vendors or other third parties without notifying you of our intent to share the information and giving you an opportunity to prevent your information from being shared.
Legal Grounds for Processing Your Personal Data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We may process your personal data based on more than one lawful ground, depending on the purpose for which we are processing such data. We have also explained what our legitimate interests are where relevant.
Purpose Type of Data Legal basis
To register and communicate with you as a prospective client or customer following a booking of a complimentary coaching call, completion of a coaching enquiry form, request for a free lead magnet or complimentary resource, registration on our email marketing list or a request to subscribe to our newsletter via our website Identity
Contact
Profile
Marketing & Communications
Technical
Usage
Marketing & Communication Consent of the data subject
Legitimate interest of developing our products/services and to grow the business and serve clients by better understanding the types of our customers
Management of our contact list and our relationship with you, including providing us with a testimonial, take a survey or assessment, or notifying you about changes to our business or this privacy policy Identity
Contact
Profile
Technical
Usage
Marketing & Communication Consent of data subject, performance of a contract with the data subject, necessity to comply with a legal obligation or legitimate interest to keep our records updated and to develop our business and understand how our customers use our current products/services
To process transactions with you or deliver your product or service, including managing fees, charges and payments, and invoicing, collection and recovery of money owing Identity
Contact
Financial
Transaction
Profile
Marketing and Communications Consent of the data subject, performance of a contract with the data subject, or legitimate interest with respect to the recovery of debts owing to us
Completion of an assessment, survey or similar profiling tool Identity
Contact
Profile
Marketing & Communication
Technical
Usage Consent of the data subject
Legitimate interest of developing our products/services and to grow the business and serve clients by better understanding the types of our customers
The use of data analytics to improve our website, products/services, marketing, customer relationships and experiences Technical
Usage Legitimate interest in categorising types of customers for our products and services, to develop our business, inform our marketing strategy and to keep our website updated.
To make suggestions and recommendations to you about goods or services that may be of interest to you Identity
Contact
Profile
Marketing & Communication
Technical
Usage Legitimate interest of developing our products/services and to grow the business and serve clients by better understanding the types of our customers
To administer our website and run and protect the business (including technical aspects such as systems maintenance, data hosting, analysis and testing, and troubleshooting) Identity
Contact
Profile
Technical
Usage Legitimate interest in administering our business, including in the event of a reorganisation or restructuring, or
necessary to comply with a legal obligation
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
Sensitive Data
Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We will only collect sensitive data from you if you explicitly consent to us doing so.
Your Legal Rights As Regards Your Data
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
• Request access to your personal data
• Request correction or rectification of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Withdraw consent to the processing of your personal data.
You can see more about these rights here: https://cnpd.public.lu/en/particuliers/vos-droits.html
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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. We may also contact you to ask you for further information in relation to your request, or to speed up our response.
We aim to respond to all legitimate personal data requests within one month. Occasionally it may take us longer than a month to respond, in particular if you have made more than one request or your request(s) is/are particularly complex. In this case, we will notify you, and keep you updated.
Changes to the Personal Data we hold
It is important that the information we hold on you is accurate and kept up to date. Please contact us by email, at any time, to let us know of any changes and we will update our data accordingly.
Data Retention
We will retain your data for only so long as is necessary to fulfil the purposes for which it was collected, or any legal obligations, or accounting or reporting requirements.
The duration of any data retention period is based on the following:
- the nature of the data collected,
- the sensitivity of the data collected,
- the amount of the data collected,
- the purpose for the which the data was collected and whether the purpose for which the data was collected can achieved by any other means,
- the potential risk of harm from unauthorised use or disclosure, and
- applicable legal requirements.
Typically, for tax and financial reporting purposes, customer transaction data collected through the ASC website is retained for a period of six (6) years from the later of the date of the transaction or the date on which such person ceases to be a customer.
Notwithstanding the above, personal data shall generally be retained for the earlier of: (i) such period as may be deemed necessary in light of applicable statutory limitation / retention periods, and (ii) for so long as the retention of such personal data is deemed necessary for the purposes for which that personal data is being processed.
At the end of the relevant data retention period, personal data shall be securely shredded, disposed of as confidential waste or subject to secure electronic deletion. Any redundant ASC hard drives shall be wiped clean prior to appropriate electronic disposal.
Personal data which has been apporpriately anonymised and through which you can no longer be personally recognised) may be retained for a longer period for statistical and research-based analysis purposes. Our retention of any such properly anonymised and general data does not require further consent from, or notification to, you.
Cookies and tracking technologies
We value your privacy and are committed to being transparent about our use of cookies and other tracking technologies on our website. These technologies play a crucial role in ensuring the smooth operation of our digital platforms, enhancing your user experience, and providing insights that help us improve.
Understanding cookies and tracking tecnologies
Cookies are small electronic, data files that a website may transfer to a user’s computer. A cookie can contain information such as a user identification code that enable us to remember your preferences and collect data abouve your website usage. Tracking technologies, such as web beacons and pixel tags, help a business understand how a user interact with a website and which pages are visited.
How we use these technologies
Cookies may be used throughout the ASC Website to track user traffic patterns, including in the following ways and classifications:
Essential cookies: Necessary for ASC Website functionality, such as authentication and security. They do not require consent.
Performance and analytics cookies: These collect information about how visitors use the ASC Website, which pages are visited most frequently, and if error messages are received from web pages. These cookies help us improve our website.
Functional cookies: Enable the ASC Website to provide enhanced functionality and personalization, like remembering your preferences.
Advertising and targeting cookies: Used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and help measure the effectiveness of the advertising campaign.
Your choices and consent
Most website browsers automatically accept cookies. If, however, you would prefer not to receive cookies, your browser can be set to warn you before accepting cookies and/or to refuse some or all cookies. If you choose to disable or have your browser refuse cookies, it is possible that some areas of the ASC Website will not display, or may become inaccessible or not function properly when you view them.
In order to enable you to make an express choice, upon your first visit, the ASC Website will present you with a cookie consent banner, where you can:
Accept all cookies: Consent to the use of all cookies and tracking technologies.
Reject non-essential cookies: Only essential cookies will be used to provide you with necessary website functions.
Customize your preferences: Choose which categories of cookies you wish to allow.
Whatever your choice, by using the ASC Website, you agree to be bound by this Privacy Policy and any cookie policy in place from time to time.
Changes to our cookie use
We may update our use of cookies and tracking technologies to improve our services or comply with legal requirements. We will notify you of any significant changes and seek your consent where necessary.
Should you have any questions or concerns about our use of cookies and tracking technologies, please do not hesitate to contact us at alexandra@alexandraslack.com. Your privacy and the integrity of your personal data are of utmost importance to us.
Third Party Links and Sites
Links to third party websites or tools may be contained within the ASC website. Clicking on such links or accessing such third party websites or tools may allow such third parties to collect or share your data. The ASC Privacy Policy does not apply to such third party websites or tools and ASC does not control how such third party websites or tools handle your data, nor does ASC control such third party websites’ or tools’ privacy policies, statements or notices. It is best practice to familiarise yourself with the privacy policies, statements or notices of every website you visit or tool you engage with.
ASC does do not necessarily endorse, and is not responsible for, any third party contact that may be made through the the ASC website.
Storage and Transfer of Data Outside of the EU / EEA
ASC uses third party service (business tool) providers based outside the European Economic Area (EEA), so the processing of your personal data may involve a transfer of data outside the EEA. For example, ASC uses the following US-based business tools: Active Campaign for email marketing, Calendly for calendar bookings, and SamCart as a third-party processor for checkout and payment operations.
Countries outside of the EEA do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside the EEA unless the transfer meets certain criteria.
ASC takes reasonable commercial efforts to ensure that it utilises such third party services (business tools) in a manner which is compliant with the letter and intent of the personal data protection regime applicable in the EEA.
Whenever ASC itself transfers your personal data outside of the EEA, we do our best to ensure a similar degree of security of data by ensuring that at least one of the following safeguards is implemented:
• the transfer is to a country that has been deemed by the European Commission to provide an adequate level of protection for personal data; (https://ec.europa.eu/commission/presscorner/detail/pl/ip_24_161)
• the transfer is being made pursuant to specific standard or model contractual clauses, or similar codes of conduct or certification mechanisms approved by the European Commission from time to time;
(https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en);
• where standard or model contractual clauses do not apply in respect of the transfer and the transfer is to a company or organisation established in the U.S., such company or organisation complies with and has been certified as participating in the EU / U.S. Data Privacy Framework (https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_3752).
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You wil have the right to withdraw this consent at any time.
Changes to the Privacy Policy
This Privacy Policy is reviewed once a year.
We may, however, make changes to this Privacy Policy at any time. Any amended privacy policy will be made available on this page of our website and will supersede any previously in-force verison. The version of the Privacy Policy available on our website is the governing version of the Privacy Policy, and your using of the ASC website subsequent to any such changes constitutes consent to the collection and processing of data in accordance with the terms of such modified policy.
Please check back here periodically to review the terms of the current privacy policy.
Policy last updated September 2026