Enablers Association Privacy Policy

Version: 1.0
Effective Date: 1 January 2026
Last Updated: 1 January 2026
Data Controller: Enablers Association, 5 Route du Village, 1884 Villars sur Ollon, Switzerland
Privacy Contact: [email protected]

  1. Introduction

This Privacy Policy explains how Enablers Association (“we,” “us,” “our,” “Association”) collects, uses, protects, and shares your personal data. This policy applies to:

  • Active Members and Associates of the Association
  • Website visitors (enablersnetwork.com)
  • Newsletter subscribers
  • Prospective members

What this policy does NOT cover: Personal data of client project participants (coaching participants, workshop attendees) is handled under separate joint controller arrangements with our clients and is governed by specific data protection agreements for each client engagement.

We are committed to protecting your privacy and complying with the EU General Data Protection Regulation (GDPR), Swiss Federal Act on Data Protection (FADP), and other applicable privacy laws.

  1. Personal Data We Collect

2.1 Member Information (Active Members & Associates)

Identity & Contact Data:

  • Full name and preferred name
  • Email address(es) – both Enablers email and personal email
  • Phone number(s)
  • Mailing address
  • LinkedIn profile and other professional social media links

Professional Information:

  • Professional credentials and qualifications
  • Work history and curriculum vitae
  • Areas of expertise and specialization
  • Languages spoken
  • Professional biography for website and client presentations
  • Professional headshot photo

Financial & Legal Data:

  • Bank account details (for payment processing)
  • Professional liability insurance certificates and coverage details
  • Tax identification number (where required)
  • Signed membership agreements and policy acknowledgments

Project & Performance Data:

  • Client project assignments and roles
  • Availability and scheduling information
  • Internal feedback and professional development notes
  • Training and certification records

2.2 Website Visitors

Technical Data:

  • IP address
  • Browser type and version
  • Operating system
  • Pages visited and time spent on pages
  • Referring website
  • Geographic location (country/city level)

Cookie Data:

  • Google Analytics cookies (performance tracking)
  • reCAPTCHA cookies (security/spam prevention)

2.3 Newsletter Subscribers

  • Email address
  • Name (if provided)
  • Subscription preferences
  • Email engagement data (opens, clicks) via Brevo

2.4 Prospective Members

  • Contact information provided during inquiry
  • Professional background shared during application process
  • Communications exchanged during membership evaluation
  1. Legal Basis and Purpose for Processing

We process your personal data under the following legal bases:

Contract Performance (GDPR Art. 6(1)(b)):

  • Managing membership relationships
  • Coordinating client project assignments
  • Processing payments and financial administration
  • Providing member benefits and services

Legitimate Interests (GDPR Art. 6(1)(f)):

  • Marketing the Association to prospective clients (showing member profiles)
  • Internal member directory and networking
  • Website analytics to improve user experience
  • Fraud prevention and security
  • Legal compliance and record-keeping

Consent (GDPR Art. 6(1)(a)):

  • Newsletter subscriptions
  • Non-essential cookies
  • Use of member photos/bios for marketing purposes

Legal Obligation (GDPR Art. 6(1)(c)):

  • Tax and accounting record retention
  • Insurance compliance verification
  • Anti-money laundering checks where applicable

4. How We Use Your Personal Data

4.1 Membership Management

  • Maintaining member records and contact information
  • Facilitating participation in Association circles and activities
  • Processing annual membership fees
  • Tracking insurance coverage and compliance requirements
  • Distributing Association communications and updates

4.2 Project Staffing

  • Matching members to client project opportunities
  • Presenting member profiles to prospective clients
  • Coordinating project teams and schedules
  • Managing client relationships and project delivery

4.3 Financial Administration

  • Processing payments to members for project work
  • Collecting annual membership fees
  • Managing development commissions (10% to Association)
  • Tax reporting and compliance
  • Accounting and bookkeeping

4.4 Website Operations

  • Analyzing website traffic and user behavior
  • Improving website functionality and user experience
  • Security and spam prevention
  • Providing requested information to visitors

4.5 Communications

  • Sending newsletters about Association activities and industry insights
  • Internal member communications and updates
  • Responding to inquiries and providing support
  1. Data Sharing and Disclosure

5.1 Within the Association

All Active Members have access to:

  • Member directory (names, contact info, expertise areas, photos)
  • Member profiles and professional backgrounds
  • Project assignments and availability

Purpose: Facilitate networking, collaboration, and peer-to-peer project opportunities.

5.2 With Clients

We share member information with prospective and current clients including:

  • Professional profiles, credentials, and experience
  • Photos and biographies
  • Areas of expertise relevant to client needs
  • Insurance coverage confirmation

Purpose: Enable clients to evaluate and select appropriate members for their projects.

5.3 With Service Providers

We share data with trusted third parties who provide services to us:

  • Google Workspace/Drive (USA/EU): Member data storage, email, document management
  • Brevo (EU): Newsletter distribution and email marketing
  • Google Analytics (USA/EU): Website analytics
  • Miro (EU/USA): Collaborative workspace and document storage
  • Website Hosting Provider (EU): Website hosting and maintenance
  • Accountant (Switzerland): Financial administration, tax compliance, bookkeeping

All service providers are contractually required to protect your data and may only use it to provide services to us.

5.4 Legal Requirements

We may disclose your personal data if required by law, court order, or government authority, or to protect the Association’s legal rights.

5.5 We Do NOT:

  • Sell or rent personal data to third parties
  • Share data for third-party marketing purposes
  • Transfer data to countries outside EU/EEA/Switzerland without appropriate safeguards
  1. International Data Transfers

Some of our service providers (Google, Miro) have servers in the USA. When we transfer data outside Switzerland/EU/EEA, we ensure appropriate safeguards:

  • Google: EU-US Data Privacy Framework certification and Standard Contractual Clauses
  • Miro: Standard Contractual Clauses
  • Brevo: EU-based, no transfer outside EU

Your data remains protected to the same standards regardless of location.

  1. Data Security

We implement appropriate technical and organizational measures to protect personal data:

Technical Measures:

  • Encrypted data transmission (TLS/SSL)
  • Password-protected documents for sensitive information
  • Access controls and authentication
  • Regular security updates and patches
  • Device encryption for laptops and mobile devices

Organizational Measures:

  • Information Security Policy and mandatory compliance
  • Confidentiality obligations for all members
  • Regular security training
  • Incident response procedures
  • Access limited to authorized personnel only

For full details, see our Information Security Policy.

  1. Data Retention

During Active Membership: We retain your personal data for as long as you are an Active Member or Associate.

After Membership Ends:

  • Financial records: 10 years (Swiss tax law requirement)
  • Contracts and legal documents: 6 years (Swiss Code of Obligations)
  • Insurance certificates: 6 years after expiry
  • Contact information and professional data: 3 years (for potential future collaboration)
  • Photos and marketing materials: Deleted within 30 days unless you consent to continued use

Newsletter Subscribers: Until you unsubscribe, then deleted within 30 days.

Website Analytics: Google Analytics data is automatically deleted after 26 months.

  1. Your Rights

Under GDPR and Swiss FADP, you have the following rights:

Right to Access (Art. 15 GDPR): Request a copy of the personal data we hold about you.

Right to Rectification (Art. 16 GDPR): Request correction of inaccurate or incomplete data.

Right to Erasure / “Right to be Forgotten” (Art. 17 GDPR): Request deletion of your personal data, subject to legal retention obligations.

Right to Restriction of Processing (Art. 18 GDPR): Request limitation on how we use your data in certain circumstances.

Right to Data Portability (Art. 20 GDPR): Receive your data in a structured, commonly used format for transfer to another controller.

Right to Object (Art. 21 GDPR): Object to processing based on legitimate interests or for direct marketing.

Right to Withdraw Consent (Art. 7(3) GDPR): Withdraw consent for newsletter or marketing communications at any time.

Right to Lodge a Complaint: Contact the Swiss Federal Data Protection and Information Commissioner (FDPIC) or your local supervisory authority.

How to Exercise Your Rights

Email: [email protected]
Subject: Data Privacy Request – [Your Name]
Include:

  • Your full name and contact information
  • Description of your request
  • Verification of identity (we may ask for additional information to confirm your identity)

Response Time: We will respond within 30 days of receiving a valid request.

  1. Cookies and Website Tracking

10.1 Cookies We Use

Essential Cookies (always active):

  • Session management
  • Security and authentication
  • reCAPTCHA (spam prevention)

Analytics Cookies (optional, can be disabled):

  • Google Analytics: tracks website usage, page views, user behavior

10.2 Managing Cookie Preferences

Browser Settings: You can disable cookies through your browser settings. Note that some website features may not function properly without cookies.

Google Analytics Opt-Out: Install Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout

Newsletter Opt-Out: Click “unsubscribe” in any newsletter email.

  1. Children’s Privacy

Our services are intended for professionals and are not directed at individuals under 18 years of age. We do not knowingly collect personal data from children.

  1. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. Significant changes will be communicated via:

  • Email notification to members
  • Notice on website homepage
  • Updated “Last Updated” date above

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

  1. Client Project Participant Data (Separate Arrangements)

Important Note: When we deliver coaching, facilitation, or leadership development services to client organizations, we process personal data of participants (e.g., names, feedback, assessment results).

This data is handled differently:

  • We act as joint controller with the client organization
  • The client provides privacy notices to their employees/participants
  • Data processing is governed by specific data protection agreements for each client engagement
  • Participants should direct privacy questions to their organization’s HR or data protection officer

This Privacy Policy does not cover client project participant data.

  1. Contact Information

Data Controller:
Enablers Association
5 Route du Village
1884 Villars sur Ollon
Switzerland

Privacy Questions:
[email protected]

Supervisory Authority (Switzerland):
Federal Data Protection and Information Commissioner (FDPIC)
Feldeggweg 1
3003 Bern
Switzerland
Website: www.edoeb.admin.ch

 

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