Privacy Policy

PRIVACY POLICY PRO COACH MASTERY (PCM) Version 1.0 – December 30, 2025 Company: ICA Netherlands B.V. KvK: 98840126 VAT-id: NL868665691B01 Address: Tasmanstraat 131, 2518VM Den Haag, Netherlands Email: info@procoachmastery.com Website/Platform: procoachmastery.com and/or the associated learning platform This privacy policy describes how Pro Coach Mastery (PCM) collects, uses and protects personal data in accordance with the General Data Protection Regulation (GDPR). 1. Data Controller ICA Netherlands B.V., operating under the name Pro Coach Mastery, is the data controller for the processing of personal data. 2. What personal data do we collect? We collect and process the following categories of personal data: 2.1 Data you provide to us: Name and email address (via contact form and waitlist form) Messages you send via the contact form Account data (when registering for the training) Payment data (via Stripe) Consent for marketing communications 2.2 Data collected automatically: Technical logs (IP address, browser type, operating system) Usage data (page views, click behavior) Progress and scores within the learning platform (Parts of) transcript/AI interactions Feedback summaries 2.3 Anonymized data about clients: If you as a participant apply the training with real clients, anonymized data about coaching conversations may be stored in the platform for learning purposes. 3. Purpose and legal basis for processing We process your personal data for the following purposes: 3.1 Performance of contract (Art. 6(1)(b) GDPR): Delivering the online coach training Account management and access to the platform Processing payments Education, assessment and certification Support and communication 3.2 Consent (Art. 6(1)(a) GDPR): Marketing communications by email (if you have given consent for this) Newsletters and updates 3.3 Legal obligation (Art. 6(1)(c) GDPR): Retention of data for tax and administrative purposes Compliance with applicable laws and regulations 3.4 Legitimate interest (Art. 6(1)(f) GDPR): Improving our services and platform Security and fraud prevention Analytics and statistics (with anonymized data where possible) 4. Who do we share your data with? We share your personal data with the following parties: 4.1 Service providers: Supabase (EU): Database and data storage Vercel (EU): Website hosting Hostinger (EU): Hosting and infrastructure Stripe (EU): Payment processing OpenAI (EU): AI functionalities and processing of interactions Brevo: Email marketing and newsletters Google Analytics: Website analytics and statistics 4.2 Data processing: All these parties process data as processors on behalf of PCM and are contractually obligated to protect your data and only use it for the purposes for which they are engaged. 4.3 Legal obligations: We may share your data if this is legally required or upon request from competent authorities. 5. International transfers Your personal data is processed and stored within the European Union (EU). All service providers we use process data within the EU or have implemented appropriate safeguards in accordance with the GDPR. 6. Retention periods We do not retain your personal data longer than necessary: Account and training data: Minimum 3 years and maximum 5 years after termination of the agreement Payment data: In accordance with legal retention obligations (usually 7 years) Marketing consent: Until you withdraw your consent Technical logs: Maximum 2 years Analytics data: Maximum 26 months (Google Analytics default) Longer retention may be necessary for disputes, claims or legal obligations. 7. Cookies and tracking We use cookies and similar technologies for: 7.1 Functional cookies: Login functionality Platform functionality 7.2 Analytical cookies: Google Analytics: For analyzing website usage and improving our services Tracking pixels for analytics You can manage cookies through your browser settings. Note: disabling cookies may limit the functionality of the platform. 8. Data security We take appropriate technical and organizational measures to protect your personal data: Encryption of data in transit and at rest Access restrictions and password protection for the login portal Regular security audits Limited access to personal data (only for employees who need it) 9. Your rights You have the following rights regarding your personal data: 9.1 Right of access (Art. 15 GDPR): You can request which data we process about you. 9.2 Right to rectification (Art. 16 GDPR): You can have incorrect data corrected. 9.3 Right to erasure (Art. 17 GDPR): You can request deletion of your data, unless we must retain it for legal purposes. 9.4 Right to restriction of processing (Art. 18 GDPR): You can request restriction of the processing of your data. 9.5 Right to data portability (Art. 20 GDPR): You can receive your data in a structured format. 9.6 Right to object (Art. 21 GDPR): You can object to processing based on legitimate interest. 9.7 Right to withdraw consent: You can withdraw your consent for marketing communications at any time via the unsubscribe link in emails or by contacting us. 10. Exercising your rights To exercise your rights, you can contact us via: Email: info@procoachmastery.com Post: ICA Netherlands B.V., Tasmanstraat 131, 2518VM Den Haag, Netherlands We respond within 1 month to your request. In complex cases, this may be extended by a maximum of 2 months. 11. Right to lodge a complaint If you believe that we do not process your personal data correctly, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens): Autoriteit Persoonsgegevens P.O. Box 93374 2509 AJ Den Haag The Netherlands Phone: +31 88 - 1805 250 Website: www.autoriteitpersoonsgegevens.nl 12. Automated decision-making Within the platform, assessments and evaluations can (largely) take place automatically. You have the right to request a human reassessment within 14 days after the result (as described in the Terms and Conditions, Article 12). 13. Changes to this privacy policy We may adjust this privacy policy from time to time. Changes will be published on this page with indication of the date of the last change. In case of significant changes, we will inform you by email. 14. Contact For questions about this privacy policy or the processing of your personal data, you can contact us: ICA Netherlands B.V. Tasmanstraat 131 2518VM Den Haag Netherlands Email: info@procoachmastery.com Last updated: December 30, 2025