Privacy Policy

1. Introduction

Imfiy BV ("we," "our," or "us") operates the Ask Us Here platform. We are committed to protecting your personal data and respecting your privacy in accordance with the General Data Protection Regulation (GDPR) and Dutch data protection laws.

Data Controller:
Imfiy BV
Raamplein 1
1016 XK Amsterdam
Netherlands
KVK: 67058094
Email: [email protected]

2. Data We Collect

2.1 Account Information

• Name: For identification and personalization
• Email address: For account creation, login, and communication
• Password: Encrypted and stored securely for account access
• Role: Whether you're a client or coach

2.2 Session Data

• Chat messages: All messages exchanged during coaching sessions
• Session duration: Start time, end time, and total minutes
• Session ratings: Feedback and ratings you provide
• Billing information: Per-minute rates and charges incurred

2.3 Payment Information

• Wallet balance: Current credit balance in your account
• Transaction history: Top-ups, session charges, and refunds
• PayPal data: We do NOT store PayPal account details or credit card numbers. Payment processing is handled entirely by PayPal.

2.4 Technical Data

• IP address: For security and fraud prevention
• Browser type and version: To optimize platform performance
• Device information: To ensure compatibility
• Cookies: For session management and preferences (see Section 8)

3. How We Use Your Data

We use your personal data for the following purposes:

3.1 Service Delivery

• To create and manage your account
• To facilitate coaching sessions between clients and coaches
• To process payments and maintain wallet balances
• To send session confirmations and receipts

3.2 Communication

• To respond to your inquiries and support requests
• To send important updates about your account or sessions
• To notify you of changes to our Terms or Privacy Policy

3.3 Quality Assurance

• To monitor session quality and coach performance
• To resolve disputes or billing issues
• To improve our platform and services

3.4 Legal Compliance

• To comply with legal obligations
• To prevent fraud and ensure platform security
• To enforce our Terms of Service

3.5 Marketing (With Consent)

We will only send you promotional emails if you have explicitly opted in. You can unsubscribe at any time.

4. Legal Basis for Processing (GDPR)

Under GDPR, we process your data based on:

• Contract performance: To provide coaching services you've requested
• Legitimate interest: To improve our services and prevent fraud
• Legal obligation: To comply with tax and financial regulations
• Consent: For marketing communications (you can withdraw anytime)

5. Data Sharing and Third Parties

We share your data only with trusted third parties necessary for service delivery:

5.1 Payment Processor

PayPal: Processes wallet top-ups securely. PayPal has its own privacy policy governing payment data.

5.2 Real-Time Messaging

Pusher: Enables real-time chat functionality. Session messages are transmitted through Pusher's secure channels but are stored in our database.

5.3 Infrastructure Providers

Our platform is hosted on secure cloud infrastructure. These providers have access to server data but are contractually obligated to protect it.

5.4 Legal Authorities

We may disclose data if required by law, court order, or to protect our rights and safety.

We do NOT sell your personal data to third parties for marketing purposes.

6. Data Retention

We retain your data for the following periods:

• Active accounts: Data retained while your account is active
• Session data: Chat messages and session details retained for 12 months after session ends
• Financial records: Transaction history retained for 7 years (Dutch tax law requirement)
• Deleted accounts: Personal data deleted within 30 days of account deletion, except where legally required to retain

7. Your Rights Under GDPR

As a user in the EU, you have the following rights:

7.1 Right to Access

Request a copy of all personal data we hold about you.

7.2 Right to Rectification

Request correction of inaccurate or incomplete data.

7.3 Right to Erasure ("Right to be Forgotten")

Request deletion of your personal data, subject to legal retention requirements (e.g., financial records).

7.4 Right to Restrict Processing

Request limitation on how we process your data.

7.5 Right to Data Portability

Receive your data in a structured, machine-readable format.

7.6 Right to Object

Object to processing based on legitimate interest.

7.7 Right to Withdraw Consent

If processing is based on consent (e.g., marketing emails), you can withdraw at any time.

To exercise these rights, contact us at: [email protected]

We will respond within 30 days. If you're unsatisfied, you can file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

8. Cookies and Tracking

We use the following types of cookies:

8.1 Essential Cookies

Required for login, session management, and platform functionality. These cannot be disabled.

8.2 Analytics Cookies (If Applicable)

Help us understand how users interact with the platform to improve performance. You can opt out via browser settings.

For more information on managing cookies, see your browser's help documentation.

9. Data Security

We implement industry-standard security measures to protect your data:

• Encryption: Passwords are encrypted using bcrypt hashing
• HTTPS: All data transmitted over secure SSL/TLS connections
• Access controls: Limited employee access to personal data
• Regular backups: To prevent data loss

However, no system is 100% secure. You are responsible for keeping your password confidential.

10. International Data Transfers

Your data is primarily stored within the European Union. If we transfer data outside the EU, we ensure adequate safeguards are in place (e.g., Standard Contractual Clauses or services certified under EU-US Data Privacy Framework).

11. Children's Privacy

Ask Us Here is not intended for users under 18 years of age. We do not knowingly collect data from children. If we discover a user is under 18, we will delete their account immediately.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last Updated" date. Significant changes will be communicated via email.

13. Contact Us

For privacy-related questions or to exercise your GDPR rights, contact:

Data Protection Officer
Imfiy BV
Email: [email protected]
Address: Raamplein 1, 1016 XK Amsterdam, Netherlands
KVK: 67058094