Comfort B.V. — Communication Skills Training for Italy

Comfort B.V. respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal data when you visit our website, request enrollment, or communicate with us about our education programs available across Italy. Comfort B.V. is established in the Netherlands and processes personal data in accordance with the EU General Data Protection Regulation (GDPR) and applicable Dutch data protection laws.

Who we are

Controller: Comfort B.V.
Registered address: Grutto 2, 5296 MB Esch, Netherlands
Email: [email protected]

Scope

This policy covers personal data processed through this website and related communication about our programs (including email correspondence and enrollment requests).

Data we collect

Identification and contact details: name, email address, phone number.
Enrollment information: selected course(s), comments or learning goals, consent choices, and preferred schedule.
Communication records: messages you send to us by email or through web forms and our replies.
Usage and device data: pages visited, time spent, referring pages, approximate location (country/region), browser and device type, and similar diagnostics generated by cookies or similar technologies.
Training-related records (if you enroll): attendance, assignments, feedback, and requested certificates or confirmations.
Technical logs: IP address and event logs recorded by our hosting environment for security, performance, and fraud prevention.

Purposes and legal bases

Responding to inquiries and processing enrollment requests (GDPR Art. 6(1)(b) contract or pre-contractual steps).
Delivering programs, managing participation, issuing confirmations, and handling support (GDPR Art. 6(1)(b)).
Operating, securing, and improving our website and services, including analytics and performance measurement (GDPR Art. 6(1)(f) legitimate interests).
Sending service communications related to your request or enrollment (GDPR Art. 6(1)(b) and/or Art. 6(1)(f)).
Sending optional updates or information you specifically request or consent to receive (GDPR Art. 6(1)(a) consent; you may withdraw at any time).
Complying with legal obligations, including Dutch accounting and tax laws (GDPR Art. 6(1)(c)).

Cookies and similar technologies

We use cookies to improve site performance and analyze traffic. Details about categories, purposes, and your choices are described in our Cookies Policy. You can manage your preferences in your browser and, where offered, through on-site controls.

Data sharing

We may share personal data with:

Service providers acting on our instructions (e.g., hosting, security, email delivery, form processing, and—where applicable—payment processing).
Invited specialists who participate in educational delivery, only where necessary to facilitate specific sessions and with appropriate confidentiality safeguards.
Public authorities or other parties when required by law or to protect our rights, safety, or users.

We do not sell personal data.

International transfers

We seek to process and store personal data within the European Economic Area (EEA). If transfers outside the EEA are necessary, we will implement appropriate safeguards such as the European Commission’s Standard Contractual Clauses or rely on another lawful transfer mechanism, and will take steps to ensure an adequate level of protection.

Retention

Inquiry and enrollment requests: up to 24 months after the last interaction, unless you enroll or request earlier deletion.
Training and service records: for the duration of the program and up to 7 years where required by Dutch legal obligations (e.g., accounting and tax).
Technical logs and security data: typically up to 12 months, unless needed longer for security or legal reasons.
Marketing communications based on consent: until you withdraw consent or the purpose is fulfilled.

We may retain data longer if necessary to establish, exercise, or defend legal claims.

Your rights

Subject to conditions and exceptions under applicable law, you have the right to:

Access your personal data and obtain a copy.
Request rectification of inaccurate or incomplete data.
Request erasure of your data (“right to be forgotten”).
Request restriction of processing.
Object to processing based on our legitimate interests.
Receive your data in a portable format and transmit it to another controller (data portability).
Withdraw consent at any time where processing is based on consent (this does not affect prior lawful processing).

To exercise your rights, contact us at [email protected]. We may need to verify your identity before responding.

Supervisory authority

If you believe your rights have been infringed, you may lodge a complaint with a data protection authority. Our lead authority in the Netherlands is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). You can also contact your local EU authority.

Security

We implement technical and organizational measures designed to protect personal data, including secure transmission (HTTPS), access controls, and security monitoring. No system is entirely secure; if we detect a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant authority as required by law.

Children

Our services are intended for adults. We do not knowingly collect personal data from children under 16. If you believe a child provided personal data to us, please contact us so we can take appropriate action.

Third-party links

Our website may reference resources or platforms operated by third parties. Their processing is governed by their own privacy policies. We encourage you to review those policies when you leave our website.

How to contact us

Comfort B.V.
Grutto 2, 5296 MB Esch, Netherlands
Email: [email protected]

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The “Last updated” date at the top indicates the most recent revision. We encourage you to review this page periodically.