emmanuelle.coach is operated by Emmanuelle Verhagen who is registered to business from Belgium with license number BE0670.558.714. We are specialised in delivering leadership & inclusion coaching, training and consulting to individual clients or client teams, both in the private as in the corporate domain.

The delivery of our services includes in-person meetings, team facilitation meetings, tailor-made adult learning program development and delivery such as workshops and retreats as well as the dissemination of information relevant to leadership, diversity and inclusion via the website emmanuelle.coach and our newsletter.

We take the privacy of our clients seriously and only use the personal information we collect about our clients for the sake of delivering the described services and to stay in touch with our client base.

In line with the GDPR (General Data Protection Regulation (EU) 2016/679) we have fully updated our Privacy Policy which is outlined below, covering the following topics:

1. What information do we collect about our clients, how do we collect it and how is it used?
2. Who has access to this data and for how long is the data held?
3. How can a client access, correct or request to delete their data?
4. What about data collected through access to our website: emmanuelle.coach?
   Please note that the GDPR covers the collection, storage and processing of personal data such as client name, address, e-mail address, phone numbers, organisation and job title. In the course of and for the benefit of delivering our services to our clients, we also gather other personal information such as personality profiles, feedback reports, session notes and, at times, personal e-mail content. We have added an additional provision to our Privacy Policy to cover the accountability for and protection of this information which is usually of a confidential nature
5. How do we store and protect other personal and confidential information we have collected in the course of a coaching assignment?
6. Changes to our Privacy Policy and How to contact us?

Details

(1) What information do we collect about our clients, how do we collect it and how is it used?

How? We collect personal data about our clients in one of the following ways:

• Potential clients: when we are approached by or approach a new client for a proposal to deliver coaching services or when we are referred by a third party to approach a client for a possible proposal to deliver coaching services.
• Contracted clients: at time of contracting a new client we complete and verify personal data in order to deliver our coaching services over the course of the contracted period.
• Past clients: we update past client data whenever possible in order to stay in touch with our client base.
• Other interested parties: we collect personal data from visitors to our website who have indicated their interest in our services via the ‘contact us’ page or via subscription to our newsletter.

What? The data we collect includes: client name, e-mail address, phone numbers, office mailing address, title, organisation and, at times, PA name, email and number (if applicable).

Why? We use the personal data for one or more of the following purposes – different throughout the ‘lifecycle’ of a client.

(2) Who has access to this data and for how long is the data held?

	Potential Client	Contracted Client	Past Client	Other interested parties
Data collected	First name, last name, e-mail address	First name, last name, e-mail address, phone number, job title, organization, address	All data that was gathered in the previous 2 stages	First name, last name, e-mail address, phone number
	At times: Phone number, organisation name, job title	At times: PA data: name, number, e-mail address
Who has access	Partners at emmanuelle.coach	Partners at emmanuelle.coach and additional coach(es) agreed through the contract	Partners at emmanuelle.coach	Partners at emmanuelle.coach and contracted marketing agency
Purpose of the data	To exchange requests and proposals for coaching services	To complete contracting To enable direct communication throughout the coaching mandate To invoice for our services	To stay in touch after a mandate has ended (contract fully served)	To provide requested information about our services To send out our quarterly newsletter
Length of storage	12 months from the last contact unless explicitly agreed to retain.		12 months from the conclusion of the mandate unless explicitly agreed to retain.	Retained on an on-going basis. Data deleted within one month of opt out or request to delete.

We do not share our client’s personal data with any other parties than the ones mentioned above. In case we would consider to share the data with a new party, the client’s explicit consent will be requested.

We operate a data minimalisation policy, meaning that data that reaches the end of the retention period (outlined above) will be deleted throughout our systems, unless explicit permission has been requested and received from the client to further retain the data.

(3) How can a client access, correct or request to delete their data?

At any time, clients have the right to request a copy of the information we hold about them by sending an e-mail or by mail.

At any time, clients have the right to stop us from contacting them by requesting to delete their information by e-mail or mail.

From time to time we may check the accuracy of our clients’ data by using the retained e-mail address. Also, clients can advise us about any changes or corrections in the data we hold by e-mail or mail.

Our e-mail address: hello@emmanuelle.coach
Our mailing address: Quinten Metsijslaan 12, 1861 Wolvertem, Belgium

(4) What about data collected through access to our website: emmanuelle.coach?

The two ways we collect personal data via our website are as follows:

1. Personal data given by website visitors through either or both the ‘contact us’ form and the form to subscribe to our newsletter OpenHouse. The type of data we collect and how we handle this data is outlined in points 1 to 3 above.
2. Cookies – cookies are text files placed on your computer to collect standard internet log information and website visitor behavior information. This information is used for analytical purposes to help us optimise our website. For our detailed cookie policy follow this link: https://emmanuelle.coach/cookie-policy.

(5) How do we store and protect other personal and confidential information we have collected in the course of a coaching assignment?

The DPA and GDPR cover the collection, storage and processing of personal data such as client name, address, e-mail address, phone numbers, organisation and job title.

In the course of and for the benefit of delivering our coaching services to our clients, we also gather other personal information such as personality profiles, feedback reports, session notes and, at times, personal e-mail content.

We strictly follow the International Coach Federation (ICF) Code of Ethics. Section 4 of the Code covers the confidentiality of the information we collect in the course of a coaching assignment. For more detailed information about this Code of Ethics, follow this link: https://coachfederation.org/code-of-ethics.

This ‘other personal and confidential’ information described above is collected, stored and retained ONLY by the coach assigned to the client by contract.

All electronic documents are securely stored in a password protected DropBox file.

All e-mail accounts are also password protected and only accessible by the individual coach.

All hand-written documents (session notes e.g.) are filed at the emmanuelle.coach offices in locked filing cabinets to which only the assigned coach has access or are destroyed.

The files described above are kept for 5 years after the assignment is completed for reasons of intellectual property and future reference – only accessible by the assigned coach.

In the event a emmanuelle.coach coach wishes to share any of the above information with another coach or partner or with a professional coach-supervisor, this can be done on an anonymous basis ONLY or by explicit consent from the client.

In the event a client wishes to delete the files, this can be requested at any time after the assignment has been concluded by e-mail or mail.

Our e-mail address: hello@emmanuelle.coach
Our mailing address: Quinten Metsijslaan 12, 1861 Wolvertem, Belgium

(6) Changes to our Privacy Policy and How to contact us?

We regularly review our Privacy Policy to remain up to date with best practice and legal requirements. Any changes will be posted on the website. This Privacy Policy was last updated on August 1st, 2018.

Clients can contact us with any queries regarding our policy and the data we hold by e-mail or mail:

Our e-mail address: hello@emmanuelle.coach
Our mailing address: Quinten Metsijslaan 12, 1861 Wolvertem, Belgium