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, 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.
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
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 published and maintained on our website.
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 ensure security, fraud prevention, and service quality (logging/analytics in aggregated or pseudonymized form).
- To comply with legal obligations.
4. Sharing Your Data
4.1 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) 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.
4.2 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).
- Where legally required or with your consent for specific shared integrations.
5. 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. After you delete your account, we remove your personal data within a reasonable period unless a legal retention duty applies.
6. 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.
7. Your Rights
7.1 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).
7.2 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.
8. 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.
9. 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.
10. 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, September 26, 2025 at 5:03 AM
