Privacy Policy

1. Controller

Velvet Life Coaching, IJburglaan 864, 1087 GE Amsterdam, the Netherlands, KVK 42008236, VAT NL003648716B09

Represented by Hartmut Samtleben, email: hartsamt@velvetlifecoaching.com, telephone: +31 6 3975 2218

We are the controller for the personal data described in this statement. We have not appointed a data protection officer; we are not required to do so.

2. Overview of what we process

We process:

• from prospective clients: name, contact details and the enquiry itself, in order to respond to your enquiry and prepare an offer;
  
• from clients: name, contact details, invoicing and payment data, appointment data and session notes, in order to perform the coaching agreement, to invoice, and to meet our tax obligations;
  
• from website visitors: technical data (IP address, browser, operating system, referrer, pages visited), in order to operate and secure the website;
  
• from platform leads: name, contact details and profile information passed to us by a relocation platform, in order to respond to your expression of interest.

We do not use your data for automated decision-making or profiling.

3. Purposes and legal bases

Responding to enquiries. When you contact us by email, telephone, or our website form, we process the data you give us in order to answer. Legal basis: performance of a contract or steps prior to a contract (Art. 6(1)(b) GDPR), or our legitimate interest in answering enquiries (Art. 6(1)(f) GDPR).

Delivering coaching. To hold sessions, schedule appointments, keep notes and communicate between sessions. Legal basis: performance of the contract (Art. 6(1)(b) GDPR).

Invoicing and administration. To issue invoices, process payments and keep our accounts. Legal basis: performance of the contract (Art. 6(1)(b)) and compliance with a legal obligation under Dutch tax law (Art. 6(1)(c) GDPR).

Accreditation verification. ICF, EMCC/NOBCO and AC require coaches to be able to evidence their coaching hours. If you consent, we share your name, contact details and the start date, end date and total duration of the coaching relationship with those bodies solely for verification. No session content and no personal notes are shared. Legal basis: your consent (Art. 6(1)(a) GDPR). You may refuse without any consequence for the coaching, and may withdraw consent at any time with effect for the future.

Website operation and security. Legal basis: our legitimate interest in a functioning and secure website (Art. 6(1)(f) GDPR).

Establishing, exercising or defending legal claims. Legal basis: our legitimate interest (Art. 6(1)(f) GDPR).

4. Data we receive from a relocation platform

We are listed as a service partner on Home.Made Navigator, a relocation platform operated by Home.Made Bespoke Relocators B.V. in Amsterdam.

If you express interest in our services through that platform, the platform passes us your name and contact details, and may pass profile information relevant to the service — for example nationality, visa route, housing status, and what you are looking for. The platform does this on the basis of your request or consent.

We and the platform each act as an independent controller: we are not responsible for how the platform processes your data, and the platform's privacy statement applies to your use of the platform.

We use data received this way only to contact you about your expression of interest and, if you become a client, to deliver the coaching. We do not use it for marketing unless you have separately consented. If you do not become a client, we delete your data within six months.

When we contact you for the first time, we tell you that we received your details through the platform, and point you to this statement.

Where a relocatee who reached us through Home.Made Navigator raises a matter with the platform, or where something arises that is likely to affect their experience of our services, we respond to Home.Made Bespoke Relocators B.V. We pass on only what is necessary — typically the fact and the date of a step — and withhold the content of coaching conversations, anything covered by our duty of confidence, and any special category of personal data. We and Home.Made each act as independent controllers for this exchange. Legal basis: our and Home.Made’s legitimate interest in a single point of accountability for a referral (Art. 6(1)(f) GDPR). You may object at any time under Art. 21 GDPR; in that case we confirm only the fact and the date of the step concerned.

5. Session notes and sensitive topics

Coaching conversations can touch on health, wellbeing or other personal matters. We do not set out to collect special categories of personal data as defined in Art. 9 GDPR, and we ask you not to share more than the coaching requires.

Notes on session content are kept pseudonymised — without your name or other identifying details — in a paper notebook or an encrypted digital notebook. Records relating to the commercial relationship (name, contact details, invoices) are kept separately on an encrypted drive and in our accounting system.

If you wish, we can agree not to keep written session notes at all.

6. Recipients and processors

We share personal data only where necessary, and only with:

• Snelstart, for invoicing and bookkeeping — processor agreement in place;
  
• Zoom, for holding online sessions — processor agreement in place;
  
• All-Inkl, for email and website operation — processor agreement in place;
  
• JVE Financieel, for statutory obligations — legal obligation;
  
• ICF, EMCC/NOBCO and AC, for accreditation verification — on the basis of your consent only.
  

We have concluded processor agreements under Art. 28 GDPR with each processor. We do not sell personal data and do not share it for advertising purposes.

7. Transfers outside the EEA

We seek to use providers that process data within the EU or EEA. Where a provider processes data in a third country, this is based on an adequacy decision of the European Commission or on EU Standard Contractual Clauses with supplementary measures as required under Chapter V GDPR.

We use Zoom for online sessions. Zoom Video Communications may process data outside the EEA; transfers are based on the EU–US Data Privacy Framework and EU Standard Contractual Clauses. Where available, we use Zoom's EU data residency option.

8. How long we keep data

• Enquiries that do not lead to an agreement: 6 months after the last contact.
  
• Invoices, contracts and accounting records: 7 years from the end of the financial year, as required by Dutch tax law.
  
• Contact and appointment data of clients: 2 years after the coaching relationship ends.
  
• Pseudonymised session notes: 2 years after the coaching relationship ends.
  
• Accreditation verification data: until you withdraw consent, or until the relevant accreditation cycle ends.
  
• Website server logs: 30 days.
  

After these periods, data is deleted or irreversibly anonymised.

9. Security

We store data on devices with encrypted drives, use strong and unique passwords with two-factor authentication where available, and keep session content separate from identifying information. Where notes are kept on paper, they are stored in a locked place and contain no identifying details.

10. Your rights

You have the right to:

• access the personal data we hold about you, and to receive a copy;
• rectification of inaccurate or incomplete data;
• erasure of your data, where one of the grounds in Art. 17 GDPR applies;
• restriction of processing in the circumstances set out in Art. 18 GDPR;
• data portability — to receive data you provided in a structured, commonly used, machine-readable format;
• object at any time to processing based on our legitimate interest, on grounds relating to your particular situation (Art. 21 GDPR);
• withdraw consent at any time, with effect for the future, where processing is based on consent.

To exercise any of these rights, email hartsamt@velvetlifecoaching.com. We respond within one month.

You also have the right to lodge a complaint with a supervisory authority — in the Netherlands, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl) — or with the authority in your country of residence or workplace.

11. Is providing data obligatory?

Providing your name, contact details and invoicing data is necessary in order for us to enter into and perform a coaching agreement; without it we cannot deliver the service. Everything else — including what you choose to share in a session — is entirely voluntary.

12. Website

Server logs. Our hosting provider, all-inkl.com - Neue Medien Münnich, automatically records technical data when the site is accessed: IP address, date and time of access, the page requested, the website you came from (referrer), browser type and version, operating system, and your internet service provider. This is necessary to operate and secure the site, and to identify attacks on it. Legal basis: our legitimate interest in a functioning and secure website (Art. 6(1)(f) GDPR). Logs are deleted after 30 days.

Cookies. This website does not use cookies, and does not store anything in your browser. We use no analytics, tracking or advertising services. No consent banner is therefore required.

Contact form. Data you enter in the contact form is transmitted to us and stored for as long as needed to handle your enquiry. Legal basis: Art. 6(1)(b) or (f) GDPR.

13. Changes to this statement

We may update this statement to reflect changes in our services or in the law. The current version always applies; the version date is shown at the top.