Coaching Privacy Notice
Last updated: 31 August 2026
This notice explains what personal data I hold about coaching clients, why I hold it, and what you can ask me to do with it. It applies to coaching clients and to people who contact me about coaching. Data collected through this website is covered by the privacy policy.
Who is responsible
Benjamin Jean Marian Pages, sole trader (OSVČ)
Lazecká 421, Olomouc 77900, Czechia
IČO: 05592020
ben@benpages.com
I am the data controller. Decisions about your data are mine, and questions about it come to me directly.
What I hold and why
- Name, email, phone, address. To arrange and deliver coaching. Basis: performance of the contract.
- Session notes. For continuity between sessions. Basis: performance of the contract.
- Session recordings and transcripts. So you can revisit a session, and so notes can be generated. Basis: your consent.
- Notes and transcripts processed through ChatGPT. For session preparation and quality improvement. Basis: your consent.
- Messages by email, WhatsApp, or Instagram. To answer you and arrange sessions. Basis: performance of the contract.
- Invoices and payment records. To meet Czech tax and accounting obligations. Basis: legal obligation.
- Emergency contact details. Used only where I have a genuine concern for your safety and cannot reach you. Basis: vital interests.
Coaching conversations can touch on health, stress, and other sensitive subjects. Data of that kind receives additional protection under the GDPR, which is why recording and AI processing are separate opt-in permissions in your coaching agreement rather than defaults. Where you give those permissions, the legal basis is your explicit consent.
You can withdraw any of these permissions at any time by emailing me. Withdrawal takes effect immediately, has no bearing on the coaching itself, and does not undo processing that has already taken place.
Recordings, notes, and AI tools
Where you give the permissions in clause 10 of your coaching agreement:
- Sessions are recorded on Zoom.
- Recordings are stored in a private Google Drive folder accessible only to you and me.
- Zoom AI Companion generates session notes from the transcript. Notes are stored in Notion, and I send you a copy.
- Notes and transcripts may be processed through ChatGPT for session preparation and quality improvement. Your name and other directly identifying information are removed first, and the account used has model training disabled.
Any permission you do not give does not take effect.
Who else processes your data
- Zoom Communications for video, transcripts, and AI-generated notes
- Google for storage of recordings in Drive
- Notion Labs for session notes
- OpenAI for session preparation
- My bank and my accountant for invoices and tax records
Each acts as a processor on my instructions, and none uses your data for its own purposes.
I also discuss coaching situations with other coaching professionals for supervision, which is standard practice in the profession. Those discussions are anonymized, and the other professional is bound by the same duty of confidentiality.
Transfers outside the EU
Several of the providers above are established in the United States. Transfers to them rely on the EU standard contractual clauses or on the EU-US Data Privacy Framework.
How long I keep it
- Session recordings. Three months after your final session.
- Session notes and transcripts. Twelve months after your final session.
- Messages. Twelve months after your final session.
- Contact details. Twelve months after your final session.
- Invoices and payment records. As required by Czech tax and accounting law, up to ten years.
Please download anything you want to keep before these periods expire.
Your rights
You have the right to:
- ask for a copy of the data I hold about you;
- have inaccurate data corrected;
- have your data deleted;
- restrict or object to a particular use;
- receive your data in a portable format; and
- withdraw consent for recording or AI processing at any time.
Email me and I will act on your request within thirty days and confirm in writing. The one exception is invoices and payment records, which I am required to retain for the period stated above.
I do not make automated decisions about you, and I do not sell your data or share it for marketing purposes.
Complaints
Please raise any concern with me first. If you remain unhappy with how I have handled your data, you can complain to the Czech Data Protection Authority, Úřad pro ochranu osobních údajů, at uoou.gov.cz.
Changes to this notice
If this notice changes, I will update the date at the top. Where a change materially affects how your data is used, I will tell you directly.