Version: 1.1
Last updated: 12 November 2025
Participants in our training programmes, courses, masterclasses and exams;
Coaching and mentoring clients;
Individuals completing (online) assessments or voice intakes;
Visitors of our websites and our online hub (GHL environment);
Newsletter subscribers and other business contacts.
3.1 Basic and contact details
Name and initials;
Address, postal code, city, country;
E-mail address and phone number(s);
Organization name and job title/role.
3.2 Training and examination
Training programs, modules and sessions you attend;
Attendance/participation records;
Test and exam data, assessments, marks/grades and pass/fail decisions;
Certificates and diplomas issued (including registrations).
3.3 Coaching, mentoring and assessments
Notes on sessions, objectives and progress;
Completed worksheets and formats (for example around work-life balance, Ikigai, 24-hour schedule, etc.);
(Voice) recordings of intakes and sessions, and related transcripts;
Results of (AI-supported) analyses and reflections, insofar as necessary for the trajectory.
3.4 Financial and administrative data
Billing address and invoice history;
Payment data (such as payment status and references via a payment provider).
3.5 Online usage and communication
IP address, device and browser information;
Usage data of our website and hub (for example pages visited, forms submitted);
Cookie IDs and preferences (where applicable);
Newsletter preferences and open/click statistics (if you receive our mailings).
As a rule, we do not require special categories of personal data (such as health data) as a mandatory part of our services. If you voluntarily share such information with us, we will handle it carefully and limit the processing to what is strictly necessary for the trajectory.
4.1 Training, education and examinations
Registering you and handling administration;
Preparing and delivering classes, assignments and exams;
Assessing performance, recording results and issuing certificates/diplomas;
Meeting (tax) retention requirements and audit obligations (e.g. in the context of CRKBO).
Legal basis: performance of a contract, legal obligation, legitimate interest (quality assurance).
4.2 Coaching, mentoring and (AI-supported) assessments
Carrying out coaching and mentoring trajectories;
Mapping your situation, goals and progress;
Analysing (voice) intakes and sessions using transcription and analysis tools (including AI tools);
Preparing reports, advice and personal learning and development plans.
Legal basis: performance of a contract and, where necessary, your explicit consent (especially where you share sensitive information or where voice recordings are made).
4.3 Relationship management and communication
Responding to your questions and requests;
Scheduling appointments, sessions and (online) events;
Improving our services based on feedback.
Legal basis: performance of a contract, legitimate interest (effective communication).
4.4 Marketing, newsletters and events
Sending newsletters, updates, invitations and relevant content;
Making our communication more relevant where permitted;
Managing registrations and attendance for (online) events.
Legal basis: your consent (opt-in) or our legitimate interest in maintaining customer relationships. You can unsubscribe at any time.
4.5 Website, hub and cookies
Ensuring the technical functioning of our website and online hub;
Compiling basic usage statistics (e.g. which pages are visited);
Using marketing and tracking cookies where applicable (only with consent).
Legal basis: legitimate interest (functional and strictly necessary cookies) and consent (analytical/marketing cookies where required).
Transcribe and structure voice intakes and sessions;
Analyze answers and patterns in order to better tailor our coaching and training;
Generate (anonymized) insights regarding themes and learning needs.
Educational partners, such as the Arnhem and Nijmegen University of Applied Sciences, if a programme or certification is delivered in cooperation (for example for examinations and issuing diplomas).
Service providers (processors) who provide services on our behalf, such as hosting and IT service providers, CRM and marketing automation systems (such as our GHL environment), e-mail and newsletter providers, online learning platforms and videoconferencing services, payment service providers and external bookkeeping/accountancy services.
We conclude data processing agreements with these parties, requiring them to process your data solely on our instructions and to ensure adequate security.
Training and examination data: for the duration of the programmed and, in principle, up to a maximum of 10 years after completion;
Financial administration (invoices, payments): 7 years after the end of the financial year (statutory tax retention period);
Coaching and mentoring files: up to a maximum of 5 years after the end of the trajectory, unless a different period is agreed with you;
(Voice) recordings and transcripts: in principle up to a maximum of 2 years after the relevant session, unless they become part of an ongoing trajectory;
Newsletter and marketing data: as long as you remain subscribed; when you unsubscribe, we anonymize or delete your data for this purpose;
Website and cookie data: in line with the periods set out in our cookie statement.
Right of access: you can request information about the personal data we process about you;
Right to rectification: you can ask us to correct inaccurate or incomplete data;
Right to erasure (“right to be forgotten”): in certain cases you can ask us to delete your data;
Right to restriction of processing: in specific situations you can request us to limit the processing of your data;
Right to data portability: you can request to receive your data in a structured, commonly used and machine-readable format, or to have it transmitted to another controller;
Right to object to processing based on our legitimate interests;
Right to object at any time to the use of your data for direct marketing
Right to withdraw consent where processing is based on your consent.
You can submit your request or objection by contacting [email protected] (subject: “Privacy / GDPR”). We may ask you to provide sufficient identification. In principle, you will receive a response within one month.


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