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1. Privacy Statement

Sustainable Wellbeing Solutions · Version 2.0 · Revision date: 14 October 2026 · Effective date: 1 January 2027

1. Who is responsible for your personal data

This Privacy Statement explains how Annick Rogiers, trading as Sustainable Wellbeing Solutions ("we", "us"), processes personal data as controller when you visit our website, contact us, buy our services or join our online programmes.

2. Legal framework

We process personal data in line with Regulation (EU) 2016/679 (GDPR) and the Belgian Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data. This Privacy Statement is part of our transparency obligations under the GDPR. The version on our website is always the current version.

3. What we process, why, and for how long

 
Purpose Personal data Legal basis Retention
Answering enquiries (contact form, email, phone, strategy call) Name, email, phone, company, position, your message Steps at your request before a contract (Art. 6(1)(b)); our legitimate interest in answering business enquiries (Art. 6(1)(f)) Up to 3 years after the last meaningful contact
Concluding and performing agreements (consultancy, training, coaching, keynotes) Identification and contact details, professional data (sector, company, position), order details, communication Performance of a contract (Art. 6(1)(b)) For the duration of the agreement. Invoices and accounting records 10 years. Other contract-related data up to 3 years after the end of the agreement, in line with the limitation period for contractual claims.
Online learning and membership accounts (Academy, Sustainable Wellbeing Platform after Trauma) Name, email, login details, course access dates and progress, membership type, content you post in the community Performance of a contract (Art. 6(1)(b)) During the access or membership period; afterwards up to 10 years after the access ends, unless another retention duty applies.
Payments, invoicing and accounting Billing details, order and payment confirmation (payments are processed through Kajabi's checkout), bank account number for bank transfers Performance of a contract (Art. 6(1)(b)); legal obligation (Art. 6(1)(c)) 10 years (Belgian accounting obligations) 
Newsletter and free resources (for example the free download) Name, email, subscription choices, email interaction Your consent (Art. 6(1)(a)). You can withdraw it at any time Until you withdraw consent; inactive subscribers up to 3 years after the last meaningful contact
Information about similar services to existing customers Name, email, services purchased Legitimate interest (Art. 6(1)(f)); you can opt out at any time, free of charge Up to 3 years after the last meaningful contact
       
Suppliers and business partners Name, contact details, contract and invoice data Performance of a contract; legitimate interest in managing our business; legal obligation Invoices 10 years; other contract data up to 10 years after the end of the relationship (limitation period) 
Legal claims, compliance and security Data needed to establish, exercise or defend legal claims, to answer data-subject requests and to keep our systems secure Legal obligation (Art. 6(1)(c)); legitimate interest (Art. 6(1)(f)) Until the end of the applicable limitation period, or longer if a dispute is ongoing
Statistics and improving our services Aggregated or anonymised usage and customer data Legitimate interest (Art. 6(1)(f)) Data is anonymised or aggregated as early as possible. Personal data is not kept longer than the source data

How we decide retention periods

We use three criteria. Legal obligations come first: Belgian accounting rules require us to keep accounting records for 10 years. Where we rely on your consent, we keep data until you withdraw it. Where we rely on contract or legitimate interest, we keep data only as long as needed for that purpose, including the period in which a legal claim could still be brought. When a period ends, we delete or anonymise the data.

Information we do not ask for

We do not ask for health data or other special categories of personal data. Please do not include such information in forms or messages. If you choose to share such information, for example in a coaching session or in the community, we process it only as far as necessary and on the basis of your explicit consent. We do not make audio or video recordings of our sessions.

4. Where your data comes from

We receive personal data from you directly (forms, emails, calls, purchases, your account). Where an organisation enrols you in a programme, we receive your name and work email from that organisation.

5. Who receives your data

We do not sell your personal data. We share it only where needed, with:

  • Kajabi (technology platform). We use Kajabi for our website, forms, email, online courses, community, checkout and basic analytics. Kajabi acts as our processor under a data processing agreement. Kajabi uses sub-processors, such as cloud hosting, email delivery and payment providers, which Kajabi publishes in its sub-processor list. 
  • Payment providers that process card or online payments through Kajabi. 
  • Professional advisers such as a legal adviser, only as far as necessary.
  • Public authorities, if the law requires it.

6. Transfers outside the European Economic Area

Kajabi and some of its sub-processors are located in the United States. Where your data is transferred outside the EEA, we rely on safeguards required by the GDPR: an adequacy decision (the EU–US Data Privacy Framework, for certified companies) and/or the standard contractual clauses approved by the European Commission, which Kajabi includes in its data processing agreement. You can ask us for more information about these safeguards.

7. Your rights

  • Information: to know how we process your data (this Privacy Statement).
  • Access: to know whether we process data about you and to receive a copy.
  • Rectification: to have incorrect or incomplete data corrected.
  • Erasure: to have your data deleted in the cases the GDPR provides. This right is not absolute. For example, we must keep accounting records for 7 years.
  • Restriction: to ask us to limit the processing of your data.
  • Data portability: to receive data you gave us in a structured, commonly used format, where processing is based on consent or contract and is automated.
  • Withdraw consent: at any time, where processing is based on consent. Withdrawal does not affect processing before the withdrawal. Every marketing email contains an unsubscribe link.
  • Object: to processing based on our legitimate interest, on grounds relating to your situation. You can object to direct marketing at any time, free of charge, and we will stop.

How to exercise your rights

Send an email to [email protected]. Please be as specific as possible. We may ask you to prove your identity so that nobody else can exercise your rights. We answer within one month. If your request is complex, we may extend this period as the GDPR allows, and we will tell you.

Right to lodge a complaint

If you are not satisfied with how we process your data, please contact us first so we can find a solution. You also have the right to lodge a complaint with the Belgian supervisory authority:

You may also complain to the supervisory authority of your country of residence.

 

8. Changes to this Privacy Statement

We update this Privacy Statement when our activities or the law change. The revision date at the top shows the current version.

9. Contact

Questions about privacy: [email protected], or by post at Sustainable Wellbeing Solutions, Hoogveld 10/4, 3550 Heusden-Zolder, Belgium.