Privacy Policy

Last updated: March 2026

Cohere Co, trading as cohere, values the protection of your personal data. This privacy policy explains how we handle the personal data we collect via our website, when booking appointments and within our coaching practice.

1. Who are we?

Cohere Co is the data controller responsible for the processing of personal data as described in this privacy policy.

Detail	Information
Company name	Cohere Co (trading as cohere)
Chamber of Commerce	54863651
Email	info@cohere.nl

2. What data do we process?

2a. Via the website

When you visit our website, the following data may be processed:

• IP address and browser data (via Google Analytics)
• Cookie preferences
• Data you enter when booking an appointment via Calendly (name, email address, phone number if applicable)

2b. Within coaching

When you participate in a coaching programme, we additionally process:

• Contact details (name, address, email, phone number)
• Billing details
• Coaching file: session notes, intake information, progress and agreements
• Any special personal data you share during sessions (e.g. health-related information)

3. Why do we process your data?

Purpose	Legal basis (GDPR)
Scheduling appointments via Calendly	Performance of contract
Carrying out the coaching programme	Performance of contract
Maintaining coaching files	Performance of contract / legitimate interest
Invoicing and administration	Legal obligation
Website statistics via Google Analytics	Consent (via cookie banner)
Processing special personal data	Explicit consent

4. Coaching files

During a coaching programme we maintain a digital file. This file contains session notes and relevant information that contributes to the quality of the programme. We handle this with care:

• Files are stored digitally and securely.
• Files are retained for up to 5 years after completion of the programme, after which they are destroyed.
• Only the coach has access to the complete file.

5. Sharing with third parties

We do not share your personal data with third parties unless necessary for the performance of our services or when legally required. We do use the following services:

• Calendly — for scheduling appointments. Calendly processes data in accordance with their own privacy policy.
• Google Analytics (via Google Tag Manager) — for website statistics. Only after consent via the cookie banner.
• Supervisor and peer consultation group — for quality assurance we discuss cases with a supervisor and in a peer consultation group. This is always anonymised: your name and identifiable details are never shared.

6. Retention periods

Data	Retention period
Coaching files	5 years after completion
Billing data	7 years (legal requirement)
Contact details (after programme)	2 years, unless you request earlier deletion
Google Analytics data	Per Google settings (default 14 months)

7. Security

We take appropriate measures to protect your personal data against unauthorised access, loss or misuse:

• Digital files are stored in a secure, password-protected environment
• Our website uses an SSL connection (https)
• Access to personal data is restricted to the coach

8. Your rights

Under the GDPR you have the following rights:

• Access — you may request which data we hold about you
• Rectification — you may have incorrect data corrected
• Erasure — you may request deletion of your data
• Restriction — you may request to restrict processing
• Data portability — you may request your data in a common format
• Objection — you may object to the processing

You can submit a request via info@cohere.nl. We will respond within 4 weeks. You also have the right to file a complaint with the Dutch Data Protection Authority (autoriteitpersoonsgegevens.nl).

9. Professional association

cohere is in the process of joining NOBCO (Dutch Order of Professional Coaches). Upon joining we will comply with the professional code and guidelines of NOBCO, including any additional requirements regarding file management and confidentiality.

10. Changes

We may update this privacy policy from time to time. The most current version is always available on our website. In case of significant changes we will actively inform you.