Privacy Policy

Flourish SDT BV
Last updated: 14 September 2026

Flourish places great importance on the protection of personal data. In this Privacy Policy, we explain which personal data we process, why we process it, with whom we may share it, how long we retain it and which rights you have.

This Privacy Policy applies to the Flourish website and to personal data we process as part of our professional activities.

1. Who is responsible for your personal data?

The data controller is:

Flourish SDT BV
Trading name: Flourish
Bruul
3220 Holsbeek
Belgium

Company number: BE 0774.461.262

For questions about privacy or to exercise your rights, you can contact us via:

info@flourishsdt.be

2. Which personal data do we process?

Depending on how you interact with Flourish, we may process, among other things:

• first and last name;
• job title and organisation;
• email address and telephone number;
• billing and company details;
• information you provide through a contact form, email, Calendly, Typeform or other communication;
• data relating to registrations, appointments, training courses, programmes or events;
• answers or information you provide in the context of a questionnaire, assessment, training course or professional programme;
• newsletter preferences and information about your interaction with our emails;
• technical data relating to the use of our website, such as device and browser information, pages visited and website traffic data.

We only process data that is relevant to the purpose for which it is collected.

3. Why do we process personal data?

3.1 Contact requests and quotations

When you contact us via the website, email, telephone or another channel, we process the data necessary to answer your request, provide information or prepare a quotation.

Legal basis: taking pre-contractual steps and, where applicable, our legitimate interest in following up professional enquiries and commercial contacts.

3.2 Clients and performance of assignments

When you become a Flourish client, we process personal data for purposes including:

• preparing and delivering keynotes, training courses, workshops, coaching, assessments, educational programmes and other programmes;
• planning and communication;
• participant administration;
• contractual follow-up;
• invoicing and accounting.

Legal basis: performance of a contract and compliance with legal obligations.

3.3 Newsletter and marketing communication

Flourish uses MailerLite to send and manage newsletters and other email communications for which you have subscribed.

We may process, among other things, your name, email address, organisation, preferences and information about your interaction with our emails.

Where consent is required for such communication, we only send it after you have given your consent.

You can unsubscribe at any time using the unsubscribe link at the bottom of each newsletter.

Legal basis: consent and, where legally permitted, our legitimate interest in informing existing professional relationships about relevant services and activities.

Withdrawing your consent does not affect the lawfulness of processing carried out before the withdrawal.

3.4 Appointments via Calendly

Flourish may use Calendly to schedule appointments.

When you book an appointment through Calendly, data such as your name, email address, organisation and any information you provide may be processed.

Legal basis: pre-contractual steps, performance of a contract or our legitimate interest in organising appointments efficiently.

3.5 Forms via Typeform

Flourish may use Typeform for questionnaires, registrations, surveys, feedback or other forms.

The personal data collected depends on the specific form. We only request data that is relevant to the purpose of that form.

Legal basis: depending on the purpose, consent, performance of a contract, pre-contractual steps or legitimate interest.

If a form collects additional or sensitive information for which specific information or consent is required, this will be communicated separately.

3.6 Training courses, assessments and professional programmes

When you participate in a training course, coaching session, assessment, questionnaire or other Flourish programme, we may process data that is necessary to organise and deliver that programme.

The nature of such data depends on the specific programme.

Where Flourish processes personal data of employees or participants on behalf of an organisation, additional arrangements may apply between Flourish and that organisation.

3.7 Website analytics

Flourish uses Google Analytics 4 to gain insight into the use of the website, for example which pages are visited and how visitors arrive at the website.

Google Analytics is only used insofar as prior consent has been given where legally required via the cookie settings.

Legal basis: consent.

More information can be found in our Cookie Policy.

4. Cookies

The website uses cookies and similar technologies.

Strictly necessary cookies may be used without prior consent where they are required for the website or for a function explicitly requested by the user.

Non-essential cookies, including analytics cookies, are only placed after consent has been given where legally required.

You can change your cookie preferences at any time.

More information about the cookies used, their purpose and retention period can be found in our separate Cookie Policy.

5. With whom do we share personal data?

Flourish does not sell personal data.

We may share personal data with service providers where this is necessary for our activities. These may include providers of:

• website management and hosting;
• email and IT services;
• website analytics;
• newsletter software;
• online scheduling;
• online forms and surveys;
• administration and accounting;
• other technical support.

Flourish currently uses, among others, SiteManager, Google Analytics, MailerLite, Calendly and Typeform.

Where these parties process personal data on our behalf, we ensure that appropriate data protection arrangements and safeguards are in place.

Personal data may also be disclosed where this is legally required or necessary for the establishment, exercise or defence of legal claims.

6. Processing outside the European Economic Area

Some service providers used by Flourish may process personal data outside the European Economic Area or may make data accessible from outside the EEA.

Where personal data is transferred outside the EEA, this is done only where there is a valid legal basis and appropriate safeguards are in place, such as an adequacy decision by the European Commission or approved Standard Contractual Clauses.

7. How long do we retain personal data?

We do not retain personal data for longer than necessary for the purpose for which it was collected, unless a longer retention period is legally required or justified.

As a general guideline, we apply the following:

• contact requests and prospect data: for as long as reasonably relevant to the request or professional relationship, in principle up to 2 years after the last meaningful contact;
• newsletter data: for as long as you remain subscribed. After unsubscribing, minimal data may be retained to ensure that your opt-out is respected;
• appointments and forms: for as long as necessary for the purpose for which the data was collected;
• client and contractual data: for the duration of the relationship and afterwards for as long as necessary to meet legal, administrative or legal obligations;
• accounting and tax records: for the legally required retention period;
• website and cookie data: in accordance with the periods stated in the Cookie Policy.

8. How do we protect personal data?

Flourish takes appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, disclosure or misuse.

We use, among other things, secure connections and reliable professional service providers and limit access to personal data to those who need it for their work.

However, no digital system can provide an absolute guarantee of security.

9. Automated decision-making

Flourish does not use personal data for decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.

10. What rights do you have?

Depending on the processing and the applicable legal basis, under the GDPR you may have, among others, the right to:

• receive information about the processing of your personal data;
• access your personal data;
• have inaccurate or incomplete data corrected;
• have personal data erased in certain circumstances;
• restrict processing in certain circumstances;
• object to certain processing;
• receive or transfer your personal data in certain circumstances;
• withdraw previously given consent at any time.

If you wish to exercise one of these rights, please email hermina@flourishsdt.be.

We will in principle respond to your request within one month. Where a request is complex or where multiple requests have been made, this period may be extended in accordance with the GDPR. We will inform you in due time if this applies.

If we have reasonable doubts about your identity, we may request additional information to prevent personal data from being disclosed to the wrong person.

11. Complaints

If you have a question or objection concerning the processing of your personal data, we encourage you to first contact Flourish so that we can investigate the matter.

You also have the right to lodge a complaint with:

Belgian Data Protection Authority
Rue de la Presse 35 / Drukpersstraat 35
1000 Brussels
Belgium

12. Changes to this Privacy Policy

This Privacy Policy may be updated if our services, technologies used or applicable legislation change.

The most recent version is always available on our website.

Last updated: 14 September 2026