PRIVACY POLICY

Effective Date: January 19, 2026

Last Updated: January 19, 2026

1. INTRODUCTION

René van de Schraaf ("we," "us," "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you engage our executive performance optimization services ("Services").

By using our Services, you consent to the data practices described in this policy. If you do not agree with this policy, please do not use our Services.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

When you engage our Services, we collect information you voluntarily provide, including:

Contact Information: Name, email address, phone number, physical address
Professional Information: Job title, company, industry, work demands
Health Information: Medical history, current health status, medications, biomarker data, sleep patterns, energy levels, stress indicators
Lifestyle Information: Exercise habits, nutrition patterns, travel schedules, work patterns
Program Information: Goals, preferences, progress tracking, consultation notes
Payment Information: Billing address, payment method details (processed securely through third-party payment processors)

2.2 Information Collected Automatically

When you access our website or use our Services, we may automatically collect:

Device Information: IP address, browser type, operating system
Usage Information: Pages visited, time spent, links clicked
Cookies and Tracking: We use cookies and similar technologies to enhance your experience and analyze usage patterns

2.3 Information from Third Parties

We may receive information from:

Healthcare Providers: With your explicit consent, lab results or medical records relevant to your optimization program
Wearable Devices: If you choose to integrate data from fitness trackers, sleep monitors, or health apps
Referral Sources: Limited information from referral partners (e.g., ASMALLWORLD, professional networks)

3. HOW WE USE YOUR INFORMATION

We use collected information for the following purposes:

3.1 Service Delivery

Provide personalized optimization protocols and consultations
Monitor progress and adjust strategies
Communicate about your program and provide support
Schedule consultations and send reminders

3.2 Service Improvement

Analyze effectiveness of protocols and methodologies
Develop new optimization strategies
Improve user experience and service quality
Conduct research using anonymized, aggregated data

3.3 Business Operations

Process payments and maintain financial records
Send administrative information and updates
Respond to inquiries and provide customer support
Enforce our Terms of Service

3.4 Marketing (With Consent)

Send newsletters or promotional materials (you may opt out anytime)
Share success stories or case studies (only with explicit consent and anonymization)

4. HOW WE SHARE YOUR INFORMATION

4.1 We Do NOT Sell Your Information

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

4.2 Service Providers

We may share information with trusted third-party service providers who assist in:

Payment Processing: Secure payment gateways (e.g., Stripe, PayPal)
Communication Tools: Email services, messaging platforms, video conferencing
Data Storage: Cloud storage providers with encryption and security measures
Analytics: Website analytics tools (e.g., Google Analytics)

These providers are contractually obligated to protect your information and use it only for the purposes we specify.

4.3 Supplement Affiliate Disclosure

We recommend Protandim Nrf2 Synergizer supplements and have an affiliate relationship with LifeVantage. When you purchase through our recommendation:

We may receive a commission (disclosed transparently)
Your purchase information is shared with LifeVantage for fulfillment
LifeVantage's privacy policy applies to their handling of your data

4.4 Legal Requirements

We may disclose your information if required by law or in response to:

Court orders, subpoenas, or legal processes
Requests from law enforcement or government authorities
Protection of our rights, property, or safety
Investigation of fraud or security issues

4.5 Business Transfers

If we undergo a merger, acquisition, or sale of assets, your information may be transferred to the new entity. You will be notified of any such change.

5. DATA SECURITY

5.1 Security Measures

We implement reasonable security measures to protect your information, including:

Encryption: Data transmitted via secure SSL/TLS protocols
Access Controls: Limited access to authorized personnel only
Secure Storage: Encrypted databases and secure cloud storage
Regular Audits: Periodic security assessments and updates

5.2 Limitations

While we strive to protect your information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

5.3 Your Responsibility

You are responsible for:

Maintaining the confidentiality of your login credentials
Using secure networks when accessing our Services
Notifying us immediately of any unauthorized access

6. DATA RETENTION

We retain your information for as long as necessary to:

Provide our Services and maintain your account
Comply with legal obligations (e.g., tax, accounting requirements)
Resolve disputes and enforce our agreements
Conduct legitimate business operations

Retention Periods:

Active Clients: Duration of engagement plus 7 years (legal requirement)
Inactive Clients: 7 years after last interaction
Marketing Data: Until you opt out or request deletion
Financial Records: 7 years (Dutch legal requirement)

7. YOUR RIGHTS

Under GDPR and Dutch law, you have the following rights regarding your personal data:

7.1 Right to Access

Request a copy of the personal information we hold about you.

7.2 Right to Rectification

Request correction of inaccurate or incomplete information.

7.3 Right to Erasure ("Right to be Forgotten")

Request deletion of your personal information, subject to legal retention requirements.

7.4 Right to Restriction

Request limitation on how we process your information.

7.5 Right to Data Portability

Request transfer of your data to another service provider in a structured, machine-readable format.

7.6 Right to Object

Object to processing of your information for direct marketing or legitimate interests.

7.7 Right to Withdraw Consent

Withdraw consent for processing at any time (does not affect prior lawful processing).

7.8 How to Exercise Your Rights

To exercise any of these rights, contact us at:

Email: rene@executiveactivation.com
Subject Line: "Privacy Rights Request"

We will respond within 30 days of receiving your request.

8. COOKIES AND TRACKING TECHNOLOGIES

8.1 Types of Cookies We Use

Essential Cookies: Required for website functionality
Analytics Cookies: Help us understand how visitors use our site
Preference Cookies: Remember your settings and preferences

8.2 Managing Cookies

You can control cookies through your browser settings. Note that disabling cookies may affect website functionality.

9. INTERNATIONAL DATA TRANSFERS

We are based in the Netherlands (European Union). If you access our Services from outside the EU:

Your information may be transferred to and processed in the EU
We ensure appropriate safeguards are in place for international transfers
By using our Services, you consent to such transfers

10. CHILDREN'S PRIVACY

Our Services are NOT intended for individuals under 18 years of age. We do not knowingly collect information from children. If you believe we have inadvertently collected information from a child, please contact us immediately.

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically. Changes will be:

Posted on our website with the updated "Last Updated" date
Communicated to active clients via email for material changes
Effective immediately upon posting (unless otherwise stated)

Your continued use of our Services after changes constitutes acceptance of the updated policy.

12. CONTACT US

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:

René van de Schraaf
Email: rene@executiveactivation.com
Website: https://executiveactivation.com
Location: Brielle, Netherlands

13. SUPERVISORY AUTHORITY

If you believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):

Autoriteit Persoonsgegevens
Website: autoriteitpersoonsgegevens.nl
Phone: +31 (0)70 888 8500

By using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.