1. Introduction
NYAMUGUSHA NGALO ("we," "us," or "our") is committed to protecting the privacy and personal data of all visitors and users of our website. This Privacy Policy explains how we collect, use, store, disclose, and safeguard your personal information when you visit our website or interact with our services.
NYAMUGUSHA NGALO is established at 11 Bd Paul-Emile Victor, 92200 Neuilly-sur-Seine, France. As a data controller based in France, we process personal data in compliance with Regulation (EU) 2016/679 (the General Data Protection Regulation, or "GDPR") and the French Data Protection Act (Loi n° 78-17 du 6 janvier 1978 relative à l'informatique, aux fichiers et aux libertés), as well as any other applicable data protection legislation.
By accessing or using our website, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with this policy, please discontinue use of our website.
2. Data Controller
The data controller responsible for the processing of your personal data is:
If you have any questions or concerns about this Privacy Policy or our data processing activities, please contact us using the information above.
3. Personal Data We Collect
We may collect the following categories of personal data:
3.1 Information You Provide Directly
When you interact with our website, such as by submitting a contact form or requesting information about our programs, you may voluntarily provide us with:
- Identity data: Full name
- Contact data: Email address, phone number
- Inquiry data: Selected program, preferred learning format, and any message or comment you include in a contact form submission
- Consent data: Record of your consent to this Privacy Policy and to being contacted
3.2 Information Collected Automatically
When you visit our website, we may automatically collect certain technical data, including:
- Technical data: IP address, browser type and version, operating system, device type, screen resolution
- Usage data: Pages visited, date and time of visit, time spent on each page, referring website, click patterns
- Cookie data: Information collected through cookies and similar tracking technologies (see our Cookie Policy for details)
3.3 Information We Do Not Collect
We do not knowingly collect sensitive personal data, also known as special categories of personal data under the GDPR, including data related to racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data, health data, or data concerning sexual orientation. We do not knowingly collect personal data from individuals under the age of 18.
4. Legal Bases for Processing
Under the GDPR, we process your personal data based on the following legal grounds:
- Consent (Article 6(1)(a) GDPR): When you submit a contact form and provide explicit consent by checking the consent checkbox, we process your data based on your freely given, specific, informed, and unambiguous consent. You may withdraw your consent at any time by contacting us.
- Legitimate interests (Article 6(1)(f) GDPR): We may process certain technical and usage data based on our legitimate interest in maintaining the security, performance, and functionality of our website, as well as in understanding how visitors use our site to improve the user experience. We ensure that our legitimate interests do not override your fundamental rights and freedoms.
- Legal obligation (Article 6(1)(c) GDPR): We may process personal data where necessary to comply with a legal obligation to which we are subject under French or European Union law.
5. Purposes of Processing
We process your personal data for the following purposes:
- To respond to your inquiries and provide information about our coaching and personal development programs
- To communicate with you regarding your selected program or learning format preferences
- To operate, maintain, and improve our website
- To ensure the security of our website and protect against unauthorized access, fraud, or other malicious activities
- To analyze website traffic and usage patterns in order to improve the user experience
- To comply with applicable legal obligations and to enforce our Terms of Use
- To maintain records of consent as required by applicable data protection legislation
6. Data Sharing and Disclosure
NYAMUGUSHA NGALO does not sell, rent, or trade your personal data to any third parties for marketing purposes.
We may share your personal data with the following categories of recipients, only to the extent necessary for the purposes described in this Privacy Policy:
- Service providers: Trusted third-party service providers who assist us with website hosting, email delivery, analytics, security, and technical support. These providers process data on our behalf and are bound by contractual obligations to protect the confidentiality and security of your data.
- Legal authorities: Competent authorities, law enforcement agencies, or regulatory bodies in France or the European Union, where disclosure is required by law or necessary to protect our legal rights.
- Professional advisors: Legal, accounting, or other professional advisors as necessary for the operation of our business, subject to applicable confidentiality obligations.
In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred to the acquiring entity, provided that the successor entity agrees to honor the commitments made in this Privacy Policy.
7. International Data Transfers
As our organization is based in France, your personal data is primarily processed and stored within the European Economic Area (EEA). If any personal data is transferred outside the EEA, we ensure that appropriate safeguards are in place, such as:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- An adequacy decision by the European Commission for the recipient country
- Other appropriate legal mechanisms recognized under the GDPR
You may request information about the specific safeguards applied to international transfers of your data by contacting us at [email protected].
8. Data Retention
We retain your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our specific retention periods are as follows:
- Contact form submissions: Retained for a maximum of 36 months from the date of submission, unless a longer retention period is required by law or you request earlier deletion.
- Consent records: Retained for the duration required by applicable French and EU law to demonstrate compliance with GDPR consent requirements.
- Technical and usage data: Retained for a maximum of 13 months, in accordance with the recommendations of the Commission Nationale de l'Informatique et des Libertés (CNIL).
After the applicable retention period has expired, your personal data will be securely deleted or anonymized so that it can no longer be associated with you.
9. Your Rights Under the GDPR
As a data subject, you have the following rights under the GDPR and applicable French data protection law:
- Right of access (Article 15 GDPR): You have the right to obtain confirmation of whether we process your personal data, and to request a copy of the personal data we hold about you.
- Right to rectification (Article 16 GDPR): You have the right to request that we correct any inaccurate or incomplete personal data concerning you.
- Right to erasure (Article 17 GDPR): You have the right to request the deletion of your personal data, subject to certain legal exceptions.
- Right to restriction of processing (Article 18 GDPR): You have the right to request that we restrict the processing of your personal data under certain circumstances.
- Right to data portability (Article 20 GDPR): You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
- Right to object (Article 21 GDPR): You have the right to object to the processing of your personal data based on our legitimate interests. We will cease processing your data unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
- Right to withdraw consent (Article 7(3) GDPR): Where we process your data based on consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
- Right to lodge a complaint: You have the right to lodge a complaint with the French supervisory authority, the Commission Nationale de l'Informatique et des Libertés (CNIL), if you believe that your data protection rights have been violated. The CNIL can be contacted at: CNIL, 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France. Website: cnil.fr.
To exercise any of your rights, please contact us at [email protected]. We will respond to your request within one month of receipt. In certain circumstances, as permitted by the GDPR, this period may be extended by two additional months, in which case we will inform you of the extension and the reasons for it.
10. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies to enhance your browsing experience and to analyze website usage. Cookies are small text files stored on your device when you visit our website.
For detailed information about the types of cookies we use, their purposes, and how to manage your cookie preferences, please refer to our Cookie Policy.
In accordance with the CNIL guidelines, we request your consent before placing non-essential cookies on your device. You can manage your cookie preferences through the cookie consent banner displayed when you first visit our website, or by adjusting your browser settings.
11. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:
- SSL/TLS encryption (HTTPS) across all pages of our website
- Secure server infrastructure and access controls
- Regular security assessments and monitoring
- Server-side form validation and spam protection
- Restricted access to personal data on a need-to-know basis
While we take all reasonable steps to protect your personal data, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security, but we are committed to maintaining robust protections and promptly addressing any security incidents.
12. Children's Privacy
Our website and services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child under 18, we will take prompt steps to delete such data. If you believe that we have collected personal data from a child, please contact us immediately at [email protected].
13. Third-Party Links
Our website does not contain links to third-party websites, products, or services that are not under our control. If in the future any such links are added, we will not be responsible for the privacy practices or content of those third-party sites. We encourage you to review the privacy policies of any external websites before providing them with your personal data.
14. Changes to This Privacy Policy
We reserve the right to update or modify this Privacy Policy at any time. Any changes will be effective immediately upon posting the revised Privacy Policy on this page with a new "Last updated" date. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.
If we make material changes to this Privacy Policy that significantly affect how we process your personal data, we will take reasonable steps to notify you, such as by displaying a prominent notice on our website.
15. Governing Law and Jurisdiction
This Privacy Policy shall be governed by and construed in accordance with the laws of France and the applicable legislation of the European Union, including the GDPR. Any disputes arising from or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the competent courts of Nanterre, France.
16. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or the way we process your personal data, please contact us at:
We will make every effort to address your inquiry in a timely and transparent manner.