Privacy Policy - FocusCoachee

This Privacy Policy explains how FocusCoachee collects, uses, shares, and protects your data when you use our services. We value your privacy and handle your information with the utmost care.

1. Data We Collect

When you use our services, we may collect the following types of data:

• Personal information: such as your name, email address, phone number, profile photo, and other details you provide when creating an account.
• Usage data: such as your IP address, browser type, pages visited, and the time and duration of your visits.
• Coach data (professional): coach account and practice details, client roster/relationships, sessions and session metadata, coach-added or uploaded materials (e.g., documents, worksheets), custom methods/templates, assigned tasks, coach-created assessments/questionnaires, availability/scheduling, (where applicable) billing/subscription data managed by the coach, and other data and content connected to the coaching process that the coach adds within the platform.
• Coachee data (coaching content): notes, goals, values, reflections/feedback, completed tasks/questionnaires, and other data and content connected to the coaching process added by the coachee and/or the coach within the coaching process.
• AI usage data: when a coach uses the AI method suggestion feature, we log the situation description entered by the coach, the coachee data categories selected (goals, core values, session data, previously used methods), the AI-generated suggestions returned, and token usage counts. This data is retained for operational monitoring and is not shared with third parties beyond what is necessary to deliver the feature. When a coach or coachee uses the AI text improvement feature, the content of the input field is sent temporarily to our AI subprocessor and is not stored or logged by FocusCoachee.

2. Processing Roles

FocusCoachee as Controller

We act as the controller for account and operational data, such as name, contact details, language, time zone, login and usage logs, support information, and (where applicable) invoicing and payment data. We process this data based on performance of a contract and our legal obligations (e.g., tax retention requirements).

FocusCoachee as Processor (on behalf of the coach/organization)

For coaching content (e.g., notes, reflections, goals and any special-category data), we act as a processor. The coach or their organization is the controller and determines the purposes and means of processing. The coach/organization ensures a valid legal basis (where required, explicit consent) and informs the coachee. We sign a Data Processing Agreement (DPA) with coaches/organizations.

Payment Data

Payments are handled via a certified payment service provider. We do not store full payment card details. We retain invoices and transaction data for as long as legally required.

International Transfers and Subprocessors

Our primary infrastructure and data storage are hosted in the Netherlands, within the EU.

Where applicable, we use subprocessors (e.g., hosting, email, payments). We conclude appropriate processor and data transfer provisions (such as EU Standard Contractual Clauses). An up-to-date list of subprocessors is available on our subprocessors page.

For the AI method suggestion feature and the AI text improvement feature, we use Anthropic, PBC (United States) as a subprocessor. Anthropic is certified under the EU-US Data Privacy Framework and uses Standard Contractual Clauses (SCCs) as an additional transfer basis. Personal data transmitted to Anthropic is not used to train AI models. For the text improvement feature, input field content is processed temporarily and is not stored or logged by FocusCoachee. We have concluded a data processing agreement with Anthropic.

3. How We Use Your Data

3.1 For Coachees

• To support your coaching process (display of sessions, tasks, reflections).
• To facilitate communication between you and your coach.
• To provide account functionality (login, language/time zone, notifications).
• To ensure security, fraud prevention, and service quality (logging/analytics in aggregated or pseudonymized form).
• To comply with legal obligations.

3.2 For Coaches (and organization admins)

• To facilitate your practice and client management (sessions, methods, materials, scheduling, and other data and content connected to the coaching process).
• To provide team/organization features (roles/permissions, seats, administration).
• To manage billing/subscriptions (where applicable).
• To provide AI-powered method suggestions and to improve text in method input fields on explicit user request, where the coach or coachee actively activates this feature (see section 4).
• To ensure security, fraud prevention, and service quality (logging/analytics in aggregated or pseudonymized form).
• To comply with legal obligations.

4. Artificial Intelligence

FocusCoachee offers an optional AI-powered feature that suggests suitable coaching methods based on a coachee's situation. This feature is only available to coaches and is never activated automatically.

How it works

When a coach uses the AI method suggestion feature, the following data is sent to our AI subprocessor (Anthropic, PBC):

• A situation description entered by the coach.
• Coachee data categories actively chosen by the coach via checkboxes: goals, core values, session data and/or previously used methods.
• The list of coaching methods available to that coach (method names and optional descriptive hints, containing no personal data).

The coach decides which coachee data categories to include. No coachee data is sent without the coach's explicit selection. Coaches are responsible for informing coachees about the use of this feature in accordance with applicable privacy law.

Anthropic as subprocessor

Anthropic, PBC (United States) processes the above data solely to generate method suggestions. Anthropic is certified under the EU-US Data Privacy Framework and does not use submitted data to train its AI models. We have concluded a data processing agreement with Anthropic.

Logging and limits

Each use of the AI suggestion feature is logged (coach identifier, chosen data categories, token counts, and suggestions returned). Logs are used for operational monitoring and cost management. A daily usage limit per coach applies.

Text improvement

FocusCoachee also offers an optional AI-powered text improvement feature for method input fields. When a coach or coachee clicks the improve button, the content of that field is sent temporarily to Anthropic, PBC for processing. This content is not stored or logged by FocusCoachee. The feature is only activated by an explicit user action and is never triggered automatically.

5. Sharing Your Data

5.1 For Coachees

• With your coach/organization: to manage the coaching process and track progress.
• With our subprocessors: solely to deliver the services (e.g., hosting, email, payments, and where applicable AI features) under contractual safeguards.
• Where legally required: for example, in response to a lawful request from a competent authority.
• With your explicit consent: when you ask us to share data with a third party.

5.2 For Coaches/Organizations

• Within your organization: account and usage information may be available to authorized admins (e.g., seats, activity overview).
• With our subprocessors: to deliver the services (as above), including Anthropic when the AI method suggestion or text improvement feature is used.
• Where legally required or with your consent for specific shared integrations.

6. Data Retention

We retain account and operational data for as long as needed for the purposes described above or as required by law. We retain coaching content on behalf of the coach/organization in line with the DPA and their chosen retention policy. AI usage logs are retained for a maximum of 12 months for operational and monitoring purposes. After you delete your account, we remove your personal data within a reasonable period unless a legal retention duty applies.

7. Data Security

We implement appropriate technical and organizational measures to protect personal data against loss, theft, unauthorized access, or disclosure. While we do our best to secure your information, we cannot guarantee the security of data transmitted over the internet.

8. Your Rights

8.1 Coachees

You have the rights of access, rectification, erasure, restriction, objection, and data portability. Requests regarding coaching content should primarily be addressed to your coach/organization (the controller). We generally respond within 30 days to requests that relate to us (e.g., your account data).

8.2 Coaches/Organizations

You have the same rights regarding your account and operational data with FocusCoachee. For data you control as the controller of your coachees' data, you are responsible for handling data subject requests; we assist you as processor under the DPA.

All data subjects also have the right to lodge a complaint with the Dutch supervisory authority: the Dutch Data Protection Authority.

9. Cookies

Our website uses cookies to improve your user experience and collect statistics. Non-essential cookies are set only with your consent via our cookie banner. See our Cookie Policy for details and preferences.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The most recent version will always be available on our website. We encourage you to review the policy regularly to stay informed about changes.

11. Contact

If you have questions about this Privacy Policy or how we process your data, please contact us via the contact page.

Publication date: Friday, May 15, 2026 at 4:42 AM