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PRIVACY POLICY Your coaching journey is private. That’s why we only share the number of human or AI coaching sessions you’ve attended with your employer. Everything else – what you share with your human or AI coach, your goals, your challenges – stays between you and Coachello. Coaching is confidential, and we treat it that way. Coachello Privacy Policy Last updated: 24 August 2026 1. Introduction At Coachello, we take your privacy seriously. This Privacy Policy explains how Coachello SAS (“Coachello”, “we”, “us”) collects, uses, shares and protects your personal data when you visit our website or use our coaching platform, including through integrations such as Microsoft Teams, Slack and our web application. We process personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws. If anything is unclear, please contact us at [email protected]. 2. Who This Policy Applies To This Privacy Policy applies to: Visitors to our website Users of the Coachello platform Participants in human or AI coaching programmes Representatives of our corporate customers When Coachello provides coaching services on behalf of your employer or sponsoring organisation, that organisation generally acts as the data controller and Coachello acts as a data processor on its behalf. For certain activities where Coachello determines how and why personal data is processed, such as website administration, security and direct customer support, Coachello may act as an independent data controller. 3. Privacy by Design Privacy is built into how Coachello designs and operates its services. In practice: We collect only the personal data needed to provide and operate our services. We limit access to personal data to authorised people who need it. We pseudonymise or anonymise personal data where appropriate, particularly for AI processing and reporting. We use privacy-protective settings by default wherever possible. Coaches and service providers that process personal data on our behalf are contractually required to protect it. 4. What Personal Data We Collect When you visit our website We may collect standard technical and usage information such as: IP address Browser and device information Country or approximate location Website usage information Cookie information You can manage non-essential cookies through our cookie settings. When you use the Coachello platform Depending on the services enabled for your programme, we may process: Name and work email address Account or SSO identifier Company and professional information Language and time zone Coaching preferences and objectives Coach selection Session bookings and attendance Assessments, reflections and feedback Platform activity and usage information Information received through integrations such as Microsoft Teams, calendars or identity providers Coaching data During a coaching programme, we may process information such as: Coaching objectives Assessments and self-reflections Session history Action plans Feedback Notes or insights that you choose to record or share AI coaching conversations where you use AI features Session transcripts where you have explicitly opted into transcription Your coaching content is confidential. Your employer does not receive the content of your human or AI coaching conversations, personal coaching notes or transcripts unless you choose to share this information or disclosure is required by law. 5. Why We Use Your Data We never sell your personal data. We process personal data only where necessary to: Provide human and AI coaching services Create and manage your account Match you with a coach Schedule and manage coaching sessions Provide assessments, exercises and development resources Provide customer and technical support Operate and secure the Coachello platform Prevent fraud, abuse and unauthorised access Measure programme usage and effectiveness Improve our services using aggregated or anonymised information Meet our legal and regulatory obligations Where Coachello acts as a processor, your employer or sponsoring organisation determines the applicable legal basis for processing. Where Coachello acts as a controller, we rely on an appropriate legal basis under applicable law, such as contractual necessity, legitimate interests, consent or compliance with a legal obligation. Where consent is required, you may withdraw it at any time. 6. Who We Share Your Data With We only share personal data where necessary to provide our services or meet our legal obligations. This may include: Your coach Your assigned coach receives the information necessary to prepare for and provide coaching, such as your name, company, coaching objectives and other information you choose to share. Your employer or sponsoring organisation Your employer may receive limited information needed to administer the programme, such as licence activation, participation or session usage. Your employer may also receive anonymised or aggregated programme reporting, such as overall participation, satisfaction levels or coaching trends. We do not share the content of your coaching conversations, personal coaching notes, AI conversations or transcripts with your employer. Technology providers Trusted technology providers may process personal data on our behalf for services such as cloud hosting, authentication, communications, analytics, video conferencing and AI functionality. These providers are subject to contractual confidentiality and data protection obligations. Public authorities We may disclose information where required by applicable law, regulation or a binding legal order. 7. International Data Transfers Our primary hosting infrastructure is located within the European Union. Some of our coaches or technology providers may be located outside the European Economic Area (EEA). Where personal data is transferred outside the EEA, we use appropriate safeguards as required by applicable data protection law. These may include: European Commission adequacy decisions Standard Contractual Clauses (SCCs) The EU-U.S. Data Privacy Framework where the recipient is eligible and certified Other legally recognised transfer mechanisms We assess our service providers and apply additional safeguards where appropriate. 8. How Long We Keep Your Data We keep personal data only for as long as necessary to provide our services and meet our contractual, security and legal obligations. Where Coachello processes personal data on behalf of your employer or sponsoring organisation, retention and deletion are also subject to our agreement with that organisation and its documented instructions. Our standard approach is: Account and authentication data: retained while necessary to provide access to the platform. Coaching data: generally retained during the coaching programme and for a limited period afterwards, normally up to 6 months, unless another period has been agreed with the Client. Programme and usage reporting: retained for the period necessary to provide programme reporting and meet contractual or audit requirements. Security and audit logs: retained for a limited period necessary for security, incident management and compliance. Backups: automatically deleted according to our backup retention cycle. Anonymised data: information that has been irreversibly anonymised and can no longer identify an individual may be retained for analytics, research and service improvement. At the end of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Following termination of a corporate agreement, personal data processed on behalf of the Client is returned or deleted in accordance with the applicable Data Processing Agreement and the Client’s documented instructions. 9. AI-Powered Features Coachello provides AI-powered features designed to support learning, reflection and professional development. Depending on your programme, these may include: AI Coaching AI role-plays AI-powered assessments and debriefs Development exercises Session summaries and recommendations Session transcription where explicitly enabled and accepted How we protect your data when using AI When AI services are used: We limit the data sent to AI providers to what is necessary to provide the feature. Direct account identifiers such as your email address are removed or pseudonymised where technically feasible. AI providers process data under contractual confidentiality and data protection obligations. Your data is not used to train the underlying AI models. Access to AI-generated information is subject to the same security and confidentiality principles as the rest of the Coachello platform. Information you voluntarily include in an AI conversation may itself contain personal data, so we encourage users to share only information relevant to their coaching needs. AI limitations AI-generated responses can sometimes be incomplete or inaccurate. Coachello’s AI features are designed for coaching, learning and professional development. They do not provide medical, psychological, legal or financial advice. Coachello does not use AI coaching data to make hiring, promotion, disciplinary or other decisions that produce legal or similarly significant effects for individuals. Users should apply their own judgement to AI-generated recommendations. Responsible AI Coachello is a signatory of the EU AI Pact and supports responsible, transparent and human-centred AI. We continuously review our AI governance, security and privacy practices as technology and regulatory requirements evolve. 10. Security We use organisational and technical safeguards designed to protect personal data against unauthorised access, loss, misuse or disclosure. These include: Encryption Role-based access controls Authentication and access management Security logging and monitoring Vulnerability and security testing Backup and recovery procedures Supplier security assessments Coachello maintains an ISO 27001:2022 certified Information Security Management System and a Microsoft 365 certified platform. Our privacy and security practices are regularly reviewed and updated. 11. Your Privacy Rights Depending on applicable law and the circumstances, you may have the right to: Access your personal data Correct inaccurate or incomplete personal data Request deletion of your personal data Restrict certain processing Object to certain processing Receive certain data in a portable format Withdraw your consent where processing is based on consent To exercise your rights, contact [email protected]. If you participate in an employer-sponsored programme, your employer is generally the data controller. We may therefore forward or coordinate your request with your employer where appropriate. We respond to privacy requests without undue delay and within the timeframes required by applicable data protection law. You also have the right to lodge a complaint with your local data protection authority. In France, the supervisory authority is the CNIL. 12. Cookies We use cookies and similar technologies to: Operate our website and platform Remember preferences Understand how our services are used Improve user experience Where required, non-essential cookies are only used with your consent. You can manage or withdraw your cookie preferences through our cookie settings or your browser. Please refer to our Cookie Policy for more information. 13. California Residents Where the California Consumer Privacy Act (CCPA) or related California privacy laws apply, California residents may have additional rights, including the right to: Know what personal information we collect and use Request access to personal information Request correction of inaccurate personal information Request deletion of personal information Exercise their privacy rights without discrimination Coachello does not sell personal information. To exercise applicable California privacy rights, contact [email protected]. 14. Changes to This Privacy Policy We may update this Privacy Policy from time to time to reflect changes in our services, technology, legal requirements or privacy practices. If we make material changes, we may notify affected users through the platform, by email or through another appropriate communication channel. The latest version of this Privacy Policy will always be available on our website. The “Last updated” date at the top indicates when the policy was most recently revised. 15. Contact Us If you have questions, concerns or requests relating to privacy or personal data, please contact us. General Support [email protected] For platform questions, onboarding and technical support. Privacy & Legal [email protected] For privacy requests, GDPR questions, contracts and complaints. Coachello SAS 103 Rue du Temple 75003 Paris France Corporate customers can also refer to our Data Processing Addendum (DPA), which governs the processing of personal data under our corporate agreements in more detail. 16. Applicable Law This Privacy Policy is governed by applicable French and European data protection law, including the GDPR. Nothing in this Privacy Policy limits any rights or remedies available to you under applicable data protection law. Thank You Thank you for trusting Coachello. We are committed to protecting your personal data and keeping your coaching experience private and confidential. Certified with Enter your email and we’ll send you the brochure