We are pleased that you are visiting our website at www.temboni.com. Data protection and data security when using our website are very important to us. We would therefore like to inform you which of your personal data we collect when you visit our website and for what purposes it is used.

Who is responsible? The person responsible in the sense of the Dutch GDPR Implementation Act (Uitvoeringswet Algemene Verordening gegevensbescherming) (“UAVG”) and the EU’s General Data Protection Regulation (“GDPR”) is The Makers Barn B.V., KvK 87855801, Duisterensijk 2 Wijhe 8131RA, (“Temboni”, “we”, “us”, “our”).
Please direct any questions you may have to info@temboni.com or use our Contact Form

Principles of data processing a) Personal data Personal data is any information relating to an identified or identifiable natural person. This includes, for example, information such as your name, age, address, telephone number, date of birth, e-mail address, IP address or user behavior.

b) Processing The processing of personal data (e.g. collection, retrieval, use, storage or transmission) always requires a legal basis.

c) Legal basis In accordance with the UAVG and the GDPR, we have to have at least one of the following legal bases to process your Personal Data: i) you have given your consent, ii) the data is necessary for the fulfillment of a contract / pre-contractual measures, iii) the data is necessary for the fulfillment of a legal obligation, or iv) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

d) Retention and storage We process and store your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period exists (in particular commercial and tax law in accordance with the Dutch Commercial and Fiscal Code. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

In general, your data is saved and stored using the services of Amazon (AWS) (410 Terry Ave N, Seattle 98109, WA and Marcel-Breuer-Straße 12, 80807 München, Germany) in their Stockholm server location and an Heroku Server provided by Salesforce Inc (Salesforce Tower, 3rd Floor, 415 Mission Street, San Francisco, California, 94105, USA) for our backend and your service data. In addition, for optimal data management and support, we store the data related to your contract with us in our Customer Relations Management System (CRM) provided by Zoho Corporation B.V., (Beneluxlaan 4B, 3527 HT Utrecht, Netherlands).

Data we collect a) Provision and use of the website When you call up and use our website, we collect the personal data that your browser automatically transmits to our server. This is technically necessary for us to display our website and to ensure its stability and security. In this sense, we collect the following data: i) IP address of the requesting computer, ii) Date and time of access, iii)name and URL of the file accessed, iv) website from which the access was made (referrer URL), v) browser used and, if applicable, the operating system of your computer as well as the name of your access provider. The legal basis is our legitimate interest.

b) Hosting The hosting services used by us for the purpose of operating our website is Vercel Inc (440 N Barranca Ave Pmb 4133 Covina, CA, 91723-1722 United States). In doing so Vercel processes inventory data, contact data, content data, usage data, meta data and communication data of customers, interested parties and visitors of our website and services, on the basis of our legitimate interests.

c) Cookies We use cookies on our website. In accordance with the Dutch Telecommunications Act (Wet van 4 februari 2015 tot wijziging van de Telecommunicatiewet) (“TA”) and the EU`s Privacy and Electronic Communications Directive (“PECD”) we are required to obtain your consent before placing so-called Non-Essential Cookies (Functional cookies, Analysis and Performance Cookies, Advertising Cookies or Targeting Cookies). For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

d) Contacting Us We offer you the opportunity to contact us using various methods. We collect the data you submit such as your name, email address, telephone number and your message in order to process your enquiry and respond to you. The legal basis is both your consent and contract.

e) Registration As part of the registration process, users provide their Full Name, Email address, and their chosen password. The data provided will be used for the purposes of creating and using the account and providing and/or using our services. In the context of the use of our registration and the use of your account, the legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as consent. . f) Contractual Services We process the Personal Data involved when you enter into a contract with us in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, fulfillment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.

g) When using our advanced coaching analytics platform We process the Personal Data involved in your use of our services (AI-Powered Summaries and Insights, in order to be able to provide our services. We recognize that you own your service data. We provide you complete control of your service data by providing you the ability to (i) access your service data, (ii) share your service data through supported third-party integrations, and (iii) request export or deletion of your service data.

We process various service data in the context of the provision of add-ins. In principle, you become the data controller and we become the data processor. Where we process Personal Data as data processor or in other words on behalf of you, we will process the Personal Data involved in your use of our services in accordance with your instructions and shall use it only for the purposes agreed between you and us.

We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly.

Some jurisdictions may require you to disclose your use of our services as your processor in your privacy policy and/or data processing agreement as applicable. For this purpose all Personal Data processed by us will be processed using Vonage Inc. (Holmdel, Bell Labs Holmdel Complex, 101 Crawfords Corner Rd #2416, United States), Gladia SAS (38 Rue de la Tremblaie, 35510 Cesson-Sevigne, France), OpenAI (OpenAI OpCo, LLC, 575 Florida Street, San Francisco, CA 94110, United States), as sub processor and take appropriate legal precautions and corresponding technical and organizational measures to ensure the protection of service data and Personal Data in accordance with the UAVG and GDPR.

Further and if you are providing us with Personal Data relating to a third party, you agree a) that you have in place all necessary appropriate consents and b) that such third party has read this Privacy Policy. You agree to indemnify us in relation to all and any liabilities, penalties, fines, awards, or costs arising from your non-compliance with these requirements.

h) Support ticket If you create a support ticket, we will request Personal Data and, where applicable, non-Personal Data in accordance with your request, this may include your name, email address and other order related data you voluntarily provide. The data provided is not shared with third parties and cannot read your data when it is entered. If you submit a support ticket, we process the data for the purpose of processing and handling your ticket.

Our employees will also have access to data that you knowingly share with us for technical support or to import data into our services. We communicate our privacy and security guidelines to our employees and enforce privacy safeguards strictly. The legal basis of the data processing is our obligation to fulfill the contract and/or our legitimate interest in processing your support ticket.

i) Administration, financial accounting, office organization, contact management We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

j) Social Media When you visit our social media profiles on Facebook, and Instagram (Meta Platforms 1601 Willow Road Menlo Park, CA 94025 and 4 Grand Canal Square Grand Canal Harbour Dublin 2 Ireland), we process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account.The legal basis is our legitimate interest and your consent.

k) Marketing For our marketing we also use Zoho and if you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out. The legal basis for processing is the initiation of a contract, our legitimate interest and your consent.

l) Newsletter If you have consented to receive our newsletter(s), we will use your email address and, if applicable, your name to send you information about us, our promotions, and news. You can revoke your consent to receive the newsletter(s) at any time with effect for the future. You will find the unsubscribe link at the end of each newsletter. The revocation leads to the deletion of the collected user data. Our newsletter is sent as part of processing on our behalf by Zoho to whom we pass on your email address for this purpose.

Data Security We undertake to protect your privacy and to treat your personal data confidentiality. In order to prevent manipulation or loss or misuse of your data stored with us, we take extensive technical and organizational security precautions which are regularly reviewed and adapted to technological progress. These include, among other things, the use of recognised encryption procedures (SSL or TLS).


However, we would like to point out that, due to the structure of the Internet, it is possible that the rules of data protection and the above-mentioned security measures are not observed by other persons or institutions that are not in our area of responsibility. We have no technical influence on this. It is the user's responsibility to protect the data he or she provides against misuse by encrypting it or in any other way.

International transfers We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.

How we may share your Personal Data We may share your Personal Data with our Business Partners for the purposes described in this Privacy Policy, including (but not limited to) conducting the services you request, or customizing our business to better meet your needs. We share your Personal Data only with Business Partners who agree to protect and use your Personal Data solely for the purposes specified by us.

We may also disclose your Personal Data for any purpose with your consent or for law enforcement, fraud prevention or other legal actions as required by law or regulation, or if we reasonably believe that we must protect us, our customers or other business interests. Except as described above of which you will be informed in advance, we will not disclose your Personal Data.

What we do not do We do not request Personal Data from minors and children; We do not use Automated decision-making including profiling; and We do not sell your Personal Data.

Privacy rights Under the UAVG and the GDPR, you can exercise the following rights: Right to information Right to rectification Right to deletion Right to data portability Right of objection Right to withdraw consent Right to complain to a supervisory authority Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

Updating your information and withdrawing your consent If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing or want to withdraw any consents you have given us, please contact us.

Access Request In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

Complaint to a supervisory authority The Autoriteit Persoonsgegevens is the relevant data protection supervisory authority in the Netherlands. The Autoriteit Persoonsgegevens can be contacted as follows: Autoriteit Persoonsgegevens, PO Box 93374, 2509 AJ DEN HAAG, Telephone number: (+31) - (0)70-888 85 00, Fax: (+31) - (0)70 - 888 85 01, www.autoriteitpersoonsgegevens.nl. We would, however, appreciate the chance to deal with your concerns before you approach the Autoriteit Persoonsgegevens.

Validity This Privacy Policy was last updated on Friday, 05th January 2024, and is the current and valid version. However, from time to time changes or a revision to this policy may be necessary. Please direct any questions you may have to info@temboni.com or use our Contact Form