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Privacy Policy

1. Introduction
 

Onward and Upward Coaching ("we", "us", "our"), registered at Bestevâerstraat 96-3, 1056 HR Amsterdam, the Netherlands with registration number KVK 92019986, is committed to protecting your personal data. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, with whom we share it, and what rights you have.

This policy applies to:

We act as data controller in respect of the personal data described in this policy.

Our data protection contact is: Melinda Heilman, reachable at melinda@onwardandupwardcoaching.com.

2. Personal Data We Collect
 

We collect the following categories of personal data:

Identity and contact data: name, e-mail address, telephone number, country of residence, and any other details you provide when registering or contacting us.

Booking and session data: session dates, attendance records, coaching hours log (maintained for ICF credentialing purposes with your consent), session notes where you have agreed to this.

Payment data: transaction reference, payment status, and invoice information. We do not receive or store your full payment card number. Payment card data is processed exclusively by our payment provider, Wix Payments, under their own privacy policy.

Communications data: content of e-mails and messages you send to us.

Technical and website data: IP address, browser type, pages visited, and session duration, collected automatically when you visit our website.

Special category data: we may incidentally receive information about your health or wellbeing in the course of coaching sessions. We process such data only to the extent strictly necessary for the delivery of coaching, on the basis of your explicit consent, and subject to enhanced confidentiality obligations. We do not ask for or retain clinical or medical records.

3. Purposes and Legal Bases for Processing​

Legal basis

Performance of contract

Performance of contract

Performance of contract / legal obligation

Consent

Legitimate interest / pre-contractual measures

Legitimate interest

Legal obligation

Consent

Purpose

Providing coaching services​

Processing payments

Sending booking confirmations and invoices

Maintaining coaching hours log for ICF credentialing

Responding to enquiries

Improving our services and website

Complying with legal obligations

Marketing communications (only with consent)

4. Third-Party Tools and Processors​

Transfer mechanism

N/A (EEA-based)

Adequacy decision (Israel)

Standard Contractual Clauses

Standard Contractual Clauses

Adequacy decision (Israel)

Standard Contractual Clauses

Tool

Wix​

Google Calendar and Wix Booking System

Google Meet

Google Workspace

Wix Payments

Gmail (Google Workspace)

​

Purpose

Website hosting

Session scheduling

Video coaching sessions

Signing agreements

Payment processing

Client communications

Location

Netherlands (EEA)

United States

United States

United States

United States

United States

Tool

Wix​

Google Calendar and Wix Booking System

Google Meet

Google Workspace

Wix Payments

Gmail (Google Workspace)​

5. International Transfers
 

Some of our tools involve the transfer of personal data to countries outside the European Economic Area. Where this occurs, we ensure that appropriate safeguards are in place, which may include:

  • standard contractual clauses approved by the European Commission;

  • an adequacy decision by the European Commission; or

  • another appropriate transfer mechanism under applicable data protection law.

You may request details of the specific safeguards in place by contacting us at melinda@onwardandupwardcoaching.com.

6. Retention Periods

​

We retain personal data only for as long as necessary for the purposes for which it was collected:

table tbd.

Retention period

Duration of relationship + 5 years

7 years (tax and accounting obligation)

Duration of relationship + 1 year, unless longer retention is agreed

As required by ICF credentialing rules, currently 5 years

Until consent is withdrawn

13 months

Category

Client account and booking data​

Invoice and payment records

Session notes (where agreed)

Coaching hours log (ICF)

Marketing communications

Website technical data

7. Cookies
 

Our website uses cookies. Strictly necessary cookies are placed automatically to ensure the website functions properly. All other cookies — including analytics and marketing cookies — are placed only with your prior, freely given consent via our cookie banner.

A full overview of the cookies we use, their purpose, and how to manage your preferences is set out in our Cookie Policy at https://www.onwardandupwardcoaching.com.

8. Your Rights

​

Under applicable data protection law, you have the right to:

  • access your personal data;

  • rectify inaccurate data;

  • erasure of your data ("right to be forgotten"), subject to legal retention obligations;

  • restriction of processing;

  • data portability;

  • object to processing based on legitimate interest;

  • withdraw consent at any time, without affecting the lawfulness of processing prior to withdrawal.

To exercise any of these rights, please contact us at melinda@onwardandupwardcoaching.com. We will respond within one month. In complex cases we may extend this by a further two months, of which we will notify you.

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) viawww.autoriteitpersoonsgegevens.nl, or with the supervisory authority in your country of residence.

9. Security

​

We take appropriate technical and organisational measures to protect your personal data against accidental or unlawful loss, alteration, unauthorised disclosure or access. These include encrypted connections (HTTPS), access controls on all stored data, and regular review of data held.

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay.

10. Changes to This Policy


We may update this Privacy Policy from time to time. We will notify you of material changes by e-mail before the changes take effect. The current version is always available at https://www.onwardandupwardcoaching.com.

Onward and Upward Coaching | Bestevâerstraat 96-3, 1056 HR Amsterdam, the Netherlands | melinda@onwardandupwardcoaching.com | https://www.onwardandupwardcoaching.com

Last updated: 15 July 2026

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