Privacy Policy

Enjoy Brussels | Website, advertising and coaching services

Effective date: 20 August 2026

Your privacy in plain language

This notice explains which personal data Enjoy Brussels uses, why it is used, which service providers may receive it, how long it is kept and how you can exercise your rights. Personal data is not sold. Advertising contacts are not added to the newsletter automatically.

Who is responsible for your data

Bettina Neukam, trading as ENJOY BRUSSELS, is the controller for the processing described in this notice.

Controller: Bettina Neukam, ENJOY BRUSSELS

Enterprise number: 0840.504.604

Address: Avenue Englebert 31, 1331 Rixensart, Belgium

Privacy contact: learninbrussels@gmail.com

Website: www.learninbrussels.com

No data protection officer has been appointed because Enjoy Brussels is not legally required to appoint one. Privacy questions and requests can be sent to the email address above.

Scope of this notice

This notice applies when you visit the Enjoy Brussels website or a landing page, respond to an advertisement, contact Enjoy Brussels through Messenger, Instagram, Facebook, LinkedIn, WhatsApp, email or a form, book a call, subscribe to a newsletter, request or purchase coaching, join an individual or group session, make a payment, or provide a testimonial.

Third-party platforms also process data for their own purposes. Their own privacy notices apply to that processing. This policy describes what Enjoy Brussels does with the data it receives or controls.

Personal data we may collect

Contact and identity data. Name, email address, telephone number, postal or invoicing address, preferred language, time zone, social-media username, profile image and platform identifier.

Coaching and enquiry data. German level, learning goals, availability, location, professional role, employer or commissioning organisation, career plans, relevant previous learning experience, and the content of messages, forms and discovery calls.

Learning content. Documents, written work, voice messages, exercises, feedback, session notes, chat contributions and other material you choose to share for coaching.

Session data. Display name, voice, video, chat, attendance, shared screen, and - only after advance notice and an appropriate legal basis - a recording, transcript or AI-generated meeting summary.

Transaction and administration data. Contract and programme information, invoice data, company and VAT information where relevant, payment amount, date, bank reference and status. Full payment-card details are collected directly by Stripe and are not available to Enjoy Brussels.

Website and device data. IP address, browser and device type, operating system, referral page, pages viewed, interactions, date and time, approximate location, cookie identifiers and consent preferences.

Marketing and testimonial data. Newsletter preferences, delivery/opening/click information where enabled, consent records, testimonial text, professional title, name, photograph and links to a public professional profile.

Enjoy Brussels does not ask for special-category data such as health, political or religious information. Please do not send such information unless it is genuinely necessary. If it must be processed, an appropriate legal basis and additional safeguards will be used.

Where the data comes from

Most data is obtained directly from you. Data may also come from Meta or another platform when you message or interact with an Enjoy Brussels page; from a Calendly booking; from an employer, institution or training provider that arranges your coaching; from a payment provider; or from public professional information that you ask Enjoy Brussels to use.

If an employer, institution or training provider commissions the coaching, it may provide your name, business contact details, level, timetable and agreed learning objectives. Enjoy Brussels may return attendance or agreed progress information to that organisation, but does not disclose confidential coaching content unless this has been clearly agreed or is legally required.

Why we use personal data and our legal bases

Enquiries, discovery calls and proposals. Data is used to answer you, assess your needs, arrange a call and prepare a suitable offer. The legal basis is taking steps at your request before entering into a contract (Article 6(1)(b) GDPR) and, where applicable, the legitimate interest in managing genuine business enquiries (Article 6(1)(f)).

Coaching and customer administration. Data is used to deliver individual or group coaching, personalise materials, communicate about sessions, provide support, manage changes and fulfil the agreed programme. The legal basis is performance of the contract (Article 6(1)(b)).

Corporate or institution-sponsored coaching. Data is used to organise and document a commissioned course. The bases are the legitimate interests of Enjoy Brussels and the commissioning organisation in delivering the agreed training (Article 6(1)(f)), contractual steps where applicable, and consent for optional disclosures.

Payments, invoices and accounting. Data is used to process payment, issue invoices, maintain accounts and comply with Belgian tax and accounting requirements. The bases are the contract and legal obligations (Article 6(1)(b) and (c)).

Newsletter and promotional messages. Newsletters and marketing by email or WhatsApp are sent only on the basis of a separate consent (Article 6(1)(a)), unless the law permits a narrowly defined communication to an existing customer. Consent can be withdrawn at any time. Service messages about a booking or active programme are not marketing.

Website analytics, embedded media and non-essential cookies. These are used only after consent where required (Article 6(1)(a)). Consent can be changed through Cookie Settings.

Testimonials, name, image and professional profile. Publication is based on specific consent (Article 6(1)(a)). Consent can be withdrawn for future use, without affecting lawful publication before withdrawal.

Security and legal claims. Limited data may be used to prevent misuse, protect accounts and systems, establish or defend legal claims, and respond to lawful requests. The bases are legitimate interests and legal obligations (Article 6(1)(f) and (c)).

Meta advertising, Messenger and social media

Enjoy Brussels uses business pages and advertisements on Facebook and Instagram. Current advertising may open a conversation in Messenger or Instagram Direct. When you send a message, Enjoy Brussels receives the account name, profile information made available by the platform, the date and time, and the content and attachments you choose to send. These data are used to respond to the enquiry and, if you request it, to arrange a call or coaching proposal.

A Messenger or social-media contact is not automatically subscribed to the Brevo newsletter. A separate opt-in is required. Enquiry data may be copied into email, scheduling or customer notes when this is necessary to follow up your request.

Meta Platforms Ireland Limited also processes data under its own terms. For Page and account insights, Enjoy Brussels and Meta may act as joint controllers within the scope defined by Meta. Enjoy Brussels uses aggregated insights to understand reach and improve communications, based on its legitimate interest. Meta remains responsible for the platform-level processing and for the obligations allocated to it in its Controller Addendum.

Meta: Facebook, Instagram, Messenger, advertisements and page insights. Meta Privacy Policy.

LinkedIn: professional-page interactions, messages and public recommendations. LinkedIn Privacy Policy.

WhatsApp: optional customer communication and voice-message exercises at the user's request. WhatsApp EEA Privacy Policy.

Website, scheduling, newsletter and communication providers

systeme.io (ITACWT Limited): website and landing-page delivery, forms and related automation. Privacy Policy.

SiteGround: domain and hosting services where used for the website infrastructure. Privacy Policy.

Calendly, LLC: appointment scheduling; it may receive your name, contact details, time zone, selected time and answers entered in the booking form. Privacy Notice.

Google: Gmail or Google Workspace for email and files, Google Analytics for consent-based website statistics, and YouTube for embedded videos. Google Privacy Policy.

Brevo: newsletter subscriptions, dispatch, unsubscribe management and, where enabled, delivery/open/click statistics. Brevo Privacy Policy.

Canva: forms, hosted pages and visual or teaching materials. Depending on the feature, Canva may act as a processor or an independent/joint controller. Canva Privacy Policy.

Microsoft Teams and Zoom: online calls, coaching sessions, chat and file sharing. Microsoft Privacy Statement.

Zoom's separate notice is available here: Zoom Privacy Statement.

Fathom: meeting assistant used, when agreed, to record, transcribe and summarise online sessions. Fathom Privacy Policy.

Vimeo: embedded video content where used. Vimeo Privacy Policy.

Online sessions, Fathom and group coaching

A session is not recorded or transcribed without advance notice. Where Fathom or a platform recording feature is proposed, participants are told before recording begins. Consent can be refused without losing access to the core coaching service; an unrecorded alternative will be used. Recording indicators shown by Teams or Zoom should also be observed.

In a group session, other participants can see or hear your display name, voice, video, chat contributions and any material you choose to share. Participants are expected not to record, copy or disclose another participant's contributions without permission. Enjoy Brussels takes reasonable organisational steps to reinforce confidentiality but cannot guarantee another participant's conduct.

Payments, invoices and professional administration

Stripe: online card and payment processing. Stripe receives payment and transaction data directly and may act as a processor and an independent controller for fraud prevention and legal compliance. Stripe Privacy Policy.

ING Belgium. For bank transfers or ING QR payments, Enjoy Brussels receives the payer name, account reference, amount, date and payment reference. ING processes banking data under its own legal obligations and privacy information.

Clearfacts / Wolters Kluwer Belgium: invoice and pre-accounting administration, with access by authorised accounting professionals where necessary. Privacy and Cookie Notice.

Cookies, analytics and embedded content

Strictly necessary technologies. These are used to deliver the website, maintain security, remember consent choices and provide functions requested by you. They do not require consent where they are genuinely necessary.

Google Analytics. If you consent, Google Analytics measures visits and interactions using identifiers and technical data such as IP address, device/browser information, pages viewed, source and approximate location. Enjoy Brussels uses these statistics to improve the website. Analytics data under Enjoy Brussels' control is configured for a retention period of up to 14 months where the platform setting permits.

YouTube and Vimeo. Embedded videos can allow the provider to receive technical and usage data and to place cookies. Non-essential embeds should load only after your consent or active choice.

Meta advertising tools. Ads may be delivered and optimised within Meta's platforms. Any separate website-based Meta tracking or similar marketing technology, if enabled, must be reflected in the live Cookie Settings and activated only after consent where required.

The site's Cookie Settings should show the current list of active cookies, providers, purposes and durations. You can withdraw or change a non-essential cookie choice at any time. Withdrawal does not affect processing already carried out lawfully.

Who may receive the data

Personal data may be available to Bettina Neukam; contracted service providers listed in this notice; authorised accounting or professional advisers; a commissioning employer, institution or training provider within the limits explained above; other group participants for the visible elements of a group session; and public authorities where disclosure is legally required.

Providers receive only the data reasonably necessary for their role. Processing agreements and confidentiality obligations are used where required. Enjoy Brussels does not sell personal data.

International data transfers

Some providers or their subprocessors operate outside the European Economic Area, including in the United States. Where personal data is transferred internationally, the transfer is based, as applicable, on an adequacy decision such as the EU-US Data Privacy Framework for certified recipients, the European Commission's Standard Contractual Clauses, or another lawful safeguard. Provider privacy notices contain more information about their locations and transfer mechanisms.

How long we keep personal data

Enquiries and Messenger/social-media leads. Up to 24 months after the last meaningful contact, unless you become a customer, ask for earlier deletion, or a longer period is needed for a legal claim.

Customer and coaching files. Operational correspondence, needs analyses, teaching materials, feedback and summaries are generally kept during the programme and for up to 24 months after the final session, unless a different period is agreed or necessary for a dispute.

Recordings and transcripts. Where created with proper notice and consent, recordings and transcripts are kept for no longer than six months after the relevant programme ends, unless earlier deletion is requested or a longer period is specifically agreed. Useful written summaries may form part of the coaching file described above.

Newsletter data. Until you unsubscribe or withdraw consent. A limited suppression record may then be retained for as long as necessary to ensure that no further marketing is sent and to demonstrate compliance.

Invoices, payments and accounting records. Ten years from 1 January following the relevant accounting or tax period, or any longer period required by Belgian law.

Testimonials. While the testimonial is published or until consent is withdrawn. A limited consent record may be kept as necessary to demonstrate that publication was authorised.

Technical logs and backups. For the provider's normal security and backup cycles, then deletion or anonymisation. Provider-controlled copies may follow the retention periods stated in their own policies.

Your choices and rights

Under the GDPR, depending on the circumstances, you may request access to your data, correction, deletion, restriction of processing and data portability. You may object to processing based on legitimate interests, including direct marketing. Where processing is based on consent, you may withdraw consent at any time without affecting earlier lawful processing.

To exercise a right, contact learninbrussels@gmail.com. Enough information may be requested to verify your identity. Enjoy Brussels normally responds within one month; the GDPR permits an extension for complex or numerous requests, in which case you will be informed.

You may also lodge a complaint with the Belgian Data Protection Authority: Rue de la Presse 35, 1000 Brussels, Belgium; contact@apd-gba.be; www.dataprotectionauthority.be. You may contact another competent EEA supervisory authority if appropriate.

Security

Enjoy Brussels uses reasonable technical and organisational measures appropriate to a small coaching business, including access controls, account security, restricted sharing, reputable service providers and secure payment channels. No method of transmission or storage is completely risk-free. If a personal-data breach creates a risk requiring notification, the applicable legal procedure will be followed.

Minors

Enjoy Brussels services are primarily intended for adults. If coaching is arranged for a minor, a parent, guardian, school or commissioning organisation must be appropriately involved, and only data necessary for the coaching and administration will be used. Enjoy Brussels does not knowingly use minors' data for behavioural advertising.

Automated decisions and profiling

Enjoy Brussels does not make solely automated decisions that produce legal or similarly significant effects concerning you. Advertising platforms may use profiling to select or optimise audiences under their own policies. Enjoy Brussels may choose broad campaign criteria and review aggregate performance, but access to coaching and pricing are not decided solely by an automated system.

Changes to this notice

This notice may be updated when services, tools or legal requirements change. The current version and effective date will be published on the website. Material changes affecting an active customer relationship will be communicated where appropriate.

Last reviewed: 20 August 2026.