top of page

PRIVacy policy

Last updated: October 26, 2025

 

This Privacy Policy describes how we collect, use and disclose Your personal  information when You use Our Service, and informs You of Your privacy rights and the protections afforded under applicable law.

We process Your Personal Data in accordance with the General Data Protection Regulation (GDPR – Regulation (EU) 2016/679) and the German Federal Data Protection Act (BDSG).

By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

 

Interpretation and Definitions

 

Interpretation

The words with initial capital letters have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

 

Definitions

For the purposes of this Privacy Policy:

Company (referred to as either «the Company», «We», «Us», «Our», or «the Coach») refers to Sensitive Coaching Practice.

Cookies are small files that are placed on Your computer, mobile device, or any other device by a website, containing details of Your browsing history among other uses.

Country refers to: Nordrhein-Westfalen, Germany

Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.

Personal Data is any information relating to an identified or identifiable individual.

Service refers to the Website and the coaching services offered (including online sessions via Google Meet or Zoom and in-person sessions).

Service Provider means any natural or legal person who processes data on behalf of the Company (e.g., hosting providers, email services, online platforms such as Google and Zoom).

Usage Data refers to data collected automatically, generated by the use of the Service, or from the Service infrastructure itself (e.g.,  duration of a page visit).

Website refers to Sensitive Coaching Practice, accessible from www.sensitive-coaching.com

You (also referred to as either “the Client”) means the individual accessing or using the Service, or the company/legal entity on whose behalf such individual is accessing or using the Service.

 

Collecting and Using Your Personal Data

 

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information. Personally identifiable information may include, but is not limited to:

  • Email address

  • First name and last name

  • Payment details (for invoicing)

  • Usage Data

 

Usage Data

Collected automatically when using the Service. May include:

  • IP address, browser type, browser version

  • Pages visited, time/date of visit, time spent on pages

  • device identifiers, operating system, diagnostic data

  • For mobile devices: device type, unique ID, IP address, operating system, browser type

 

Tracking Technologies and Cookies

Our website uses cookies and similar technologies. Some of these are technically necessary (essential cookies) to ensure the proper functioning of our website. Others (such as for analysis or marketing) are only used with your consent, which you can give via our cookie banner when you first visit our site. You can withdraw your consent at any time.

 

Cookies can be “Session Cookies” (deleted when you close your browser) or “Persistent Cookies” (remain on your device until they expire or you delete them manually).

We use the following types of cookies:

  • Essential Cookies (always active, no consent needed) – necessary to provide basic website functions. Legal basis: Art. 6(1)(f) GDPR in conjunction with § 25 TTDSG.

  • Analytics/Performance Cookies (require your consent) – help us understand how visitors use our website so we can improve it. Legal basis: Art. 6(1)(a) GDPR in conjunction with § 25 TTDSG.

  • Functionality Cookies (require your consent) – allow us to remember preferences (e.g., language settings). Legal basis: Art. 6(1)(a) GDPR in conjunction with § 25 TTDSG.

  • Marketing Cookies (if used, require your consent) – allow personalized advertising. Legal basis: Art. 6(1)(a) GDPR in conjunction with § 25 TTDSG.

 

You can configure your browser to block or delete cookies. You may also change or withdraw your consent through the cookie banner at any time.

 

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain Our Service (legal basis: Art. 6(1)(b) GDPR - contract)

  • To contact You about sessions, updates or security notices (Art. 6(1)(b), (f) GDPR)

  • To send You newsletters or promotional offers only with prior consent (Art. 6(1)(a) GDPR)

  • To manage Your requests

  • For invoicing, accounting, and tax compliance (Art. 6(1)(c) GDPR)

  • For analysis and service improvement (Art. 6(1)(f) GDPR)

 

We may share Your Personal Data in the following cases:

  • With Service Providers: (e.g., Google Meet, Zoom, email providers)

  • For business transfers: (e.g., sale or merger)

  • With Your consent

 

Retention of Your Personal Data

We will retain Your Personal Data only for as long as necessary for the purposes set out in this Privacy Policy:

  • Contract data: kept for (ten) 10 years to comply with German tax and commercial law (mandatory under HGB & AO)

  • Communication data: deleted after three (3) years (statutory limitation period).

  • Usage Data: shorter retention, unless used for security or legal compliance.

After the respective retention periods expire, personal data will be securely deleted or anonymised in accordance with Article 17 GDPR (“Right to erasure”)

 

Transfer of Your Personal Data

Your data may be transferred to and processed in countries outside the EU/EEA.

Where this occurs, We ensure appropriate safeguards under Art. 44–49 GDPR (e.g., EU Commission adequacy decisions, Standard Contractual Clauses).

 

Your Data Protection Rights

Under the GDPR, You have the following rights:

  • Right of access (Art. 15 GDPR)

  • Right to rectification (Art. 16 GDPR)

  • Right to erasure (“Right to be Forgotten”) (Art. 17 GDPR)

  • Right to restriction of processing (Art. 18 GDPR)

  • Right to data portability (Art. 20 GDPR)

  • Right to object (Art. 21 GDPR)

  • Right to withdraw consent at any time (Art. 7(3) GDPR)

 

You also have the right to lodge a complaint with a supervisory authority, in particular the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW).

 

Deletion of Your Personal Data

You may request deletion of your Personal Data at any time, unless legal obligations (e.g., tax retention)  require us to keep it.

 

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred.

 

Law enforcement

We may disclose data if required by law.

 

Other legal requirements

We may disclose Data if is necessary to:

  • comply with a legal obligation,

  • protect rights or property,

  • investigate wrongdoing,

  • protect safety,

  • protect against liability.

 

Security of Your Personal Data

We implement technical and organizational measures (TOMs) according to Art. 32 GDPR to protect Your Data.

Note: No transmission over the internet is 100% secure.

 

Children's Privacy

Our Service is not directed at children under 16.

We do not knowingly collect data from minors. If discovered, data will be deleted.

 

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party’s site. Please note that this Privacy Policy does not apply to such external sites, and We have no control over their content or practices. We strongly encourage You to review the Privacy Policy of every site You visit.

 

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time.

We will inform You of material changes in advance, via email or website notice, in compliance with Art. 13(3) GDPR.

 

Contact Us

If you have any questions about this Privacy Policy, You can contact us by

bottom of page