Privacy Statement

22 August 2026. This version replaces the privacy notice dated 7 April 2022.

In2Coaching supports people in developing their personal leadership skills. During these sessions, personal matters almost always come up: how someone reacts under pressure, what’s going on at work, and sometimes what’s going on outside of work. We believe you should know exactly what happens to that information. This statement explains that, in plain language.

This statement applies to all our services, not just our website. It also covers coaching programmes, training courses and leadership programmes, as well as any recordings we make in connection with these.

Who is responsible?

In2Coaching, registered with the Chamber of Commerce under number 59040238, with its registered office at Boechorsthof 25, 2201 XM Noordwijk. We are the data controller for the data set out in this statement.

If In2Coaching is running a programme on behalf of your employer, your employer is responsible for the participant details it provides. In2Coaching remains responsible for the content of your coaching sessions, and that content is not shared with your employer.

For enquiries regarding privacy: info@in2coaching.nl or 085 303 5386.

What we process and why

For each type of service, the information below sets out what data we use, why we are permitted to do so, and how long we retain it.

Data on health and wellbeing

Coaching often touches on issues such as tension, stress, energy levels and personal circumstances. These are special categories of personal data, and are subject to additional rules. We will only process them with your explicit consent, which we will record in writing in advance and which you may withdraw at any time.

We never share this information with your employer. If we are working on behalf of your employer, they will only receive a general update on progress and, where agreed, group-level averages. We will never disclose the content of your conversations or your individual scores, unless you have given your separate and demonstrable consent to do so.

Recordings and the use of AI

We record coaching sessions, both online and on-site, and then process the recordings automatically. Here’s how it works:

• the recording is automatically transcribed into a verbatim transcript
• that transcript is fed into an AI model, which generates a summary, an analysis of patterns and a draft for the follow-up email
• The coach always reads and edits the results themselves before anything is done with them

No decisions are made about you based solely on automated processing. Whenever you are speaking to an In2Coaching AI assistant, for example in a chat window, we will indicate this on the screen itself.

Recording will only take place with your consent. If you do not give your consent, or if you withdraw it, we will not record the call and no automatic processing or analysis will take place. This will not affect your case and will not incur any additional costs.

Who we share your data with

We do not sell your data or share it with parties that do not play a role in the provision of our services. However, in order to carry out our work, we do engage service providers who act as data processors on our behalf. We enter into a data processing agreement with them.

Transfer outside Europe

As you can see from the table, several of our service providers are based in the United States. If your data is transferred there, we ensure that appropriate safeguards are in place, such as the European Commission’s Standard Contractual Clauses or the EU-US Data Privacy Framework. If you would like to know which safeguard applies to which party, we will send you that overview.

How we protect your data

We take security seriously and review it regularly. In practical terms, this means, amongst other things:

• Only the coach has access to coaching files and recordings, and everything is stored in a business environment set up specifically for this purpose
• Interfaces between systems are protected by a key, and these keys are replaced periodically
• Our database is set up in such a way that no one from outside can access it, not even via our own applications
• We keep a record of which service providers have access and review this twice a year

If, despite everything, something does go wrong, we will report any data breach to the Dutch Data Protection Authority within 72 hours and will inform you directly if the breach poses a high risk to you.

Cookies and website visits

Our website uses cookies in three categories. Our full cookie policy can be found at In2Coaching.nl and contains the up-to-date list.

• Functional cookies. These are necessary for the site to function, for example for booking appointments via Calendly and for securing forms. These are always enabled and do not require consent.
• Analytical cookies. We use Google Analytics to measure how the site is used, so that we can improve it. This includes information such as which pages you view, how long you stay on the site, and how you arrived there.
• Marketing and tracking cookies. These are set by Google Ads, Facebook, LinkedIn and ActiveCampaign, as well as by embedded content such as videos from Vimeo. They may track your behaviour across different websites and thereby tailor adverts to you. These organisations are largely based in the United States.

For analytical and marketing cookies, we ask for your consent in advance via the cookie banner. If you do not give your consent, these cookies will not be set and nothing will be stored on your device. You can change or withdraw your consent at any time via the same banner. We have entered into a data processing agreement with Google. The measurement data from Analytics is not retained for longer than the retention period set in our account.

There is one thing we would like to make explicitly clear. We use Google’s consent mode. This means that the tracking script is already on the page before you make your choice, and it sends a single message to Google without using cookies: the time, a general location, your browser type and a random number that is generated anew for each page view. This does not allow you to be identified, and it is used solely to estimate the total number of visitors. Only once you have given your consent are cookies placed and is your visit actually tracked. Our cookie policy explains this in more detail.

The organisations behind the marketing cookies decide, to some extent, what exactly they do with your data. We recommend that you read their own privacy policy if you would like to find out more about this.

Your rights

You have the following rights, and we will help you to exercise them. Please send any requests to info@in2coaching.nl. We will respond within one month.

• Right of access: requesting details of the personal data we hold about you
• Correction: having incorrect information corrected or supplemented
• Deletion: having your data deleted, unless we are legally required to retain it, such as in the case of invoices
• Restriction: temporarily suspending processing
• Objection: objecting to processing on the grounds of our legitimate interest
• Data portability: receiving your data in a usable file or having it transferred
• Withdrawing consent: at any time, without giving a reason. This applies in particular to recordings

To ensure that we do not amend the details of the wrong person, we may ask you to prove your identity.

Filing a complaint

If you are not satisfied with the way we handle your data, please let us know first, and we will sort it out together. You also always have the right to lodge a complaint with the Dutch Data Protection Authority via autoriteitpersoonsgegevens.nl.

Changes

We update this statement whenever our working practices change. The date of the last update is shown at the top. In the event of significant changes, we will actively inform you.

Contact

In2Coaching

Boechorsthof 25, 2201 XM Noordwijk

info@in2coaching.nl | 085 303 5386 | In2Coaching.nl