Privacy policy

1. Controller

The controller for data processing on coachelsea.com is Ichii GmbH, Kollwitzstraße 76, 10435 Berlin, Germany, represented by its managing director Kunichi Kisaki. Email: info@ichii.de.

No data protection officer has been appointed.

2. Overview

We only process personal data where this is necessary to operate the website, answer enquiries and provide coaching sessions you have booked.

Without your consent this website sets no cookies and loads no analytics or marketing services. We use no advertising services or tracking pixels and embed no third-party content such as videos, maps or social media plugins. Fonts are served from our own server.

If statistics are offered, we store your choice (“allowed” or “declined”) in your browser’s local storage (entry “coachelsea-analytics-consent”) so that we do not ask again on every visit. This entry is necessary for the function you requested (§ 25(2) no. 2 TDDDG), is not transmitted to us and remains until you delete it in your browser.

What you share in coaching sessions is treated as confidential. It is not recorded on or transmitted through this website.

3. Hosting and server log files

The website is hosted by Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. Vercel delivers pages through a global content delivery network; server-side functions (such as booking and payment) run in a data centre in Frankfurt am Main, Germany.

When you visit the website, Vercel processes technically necessary data, in particular IP address, date and time, requested URL, amount of data transferred, referrer and browser and operating system information. This data is stored in server log files to deliver the website securely and reliably and to detect errors or abuse. We do not combine it with other data or use it for analytics.

The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is the secure and error-free provision of the website. Vercel is certified under the EU-US Data Privacy Framework; transfers to the USA are based on the European Commission’s adequacy decision (Art. 45 GDPR) and additionally on standard contractual clauses (Art. 46 GDPR).

4. Contact by email

If you write to hi@coachelsea.com, we process your email address, your name if you give it, and the content of your message in order to answer you and, where you wish, to arrange coaching. The website has no contact form.

The legal basis is Art. 6(1)(b) GDPR (steps prior to a contract at your request) and otherwise Art. 6(1)(f) GDPR (legitimate interest in answering messages). Our mailbox is provided by Google Workspace (Google Cloud EMEA Limited, Ireland); Google may transfer data to the USA and is certified under the EU-US Data Privacy Framework.

Every reply is written personally. We delete correspondence once it is no longer needed; if a contract is concluded, it is retained as far as commercial and tax retention obligations apply.

5. Spam and abuse protection

To protect the booking, payment and withdrawal functions we only use our own mechanisms, without third parties and without cookies: a field invisible to humans on the withdrawal form, a check of the request’s origin and a limit on the number of requests per IP address. For this limit your IP address is kept in the server’s memory for at most 10 minutes and is not stored permanently. The legal basis is Art. 6(1)(f) GDPR.

6. Payment of the Private Clarity Session (Stripe)

When you continue to payment, you are taken to a checkout page operated by Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland (“Stripe”). Stripe processes your name, email address, billing address, payment details and the transaction data and, if you buy for a company, the company name and VAT ID, in order to carry out the payment, determine the applicable tax, prevent fraud and issue your receipt and invoice. VAT IDs from the EU may be checked against the European Commission’s VIES system. We do not receive your full card or account details.

Before the checkout opens, we record your two confirmations (terms and withdrawal information read; request that the session may take place within the withdrawal period) together with the time and the version of the terms. This record is stored with the payment at Stripe and repeated in your order confirmation.

The legal basis is Art. 6(1)(b) GDPR (performance of the contract) and Art. 6(1)(c) GDPR (statutory retention obligations under commercial and tax law, for which invoices and payment records are kept for the statutory periods). Stripe may transfer data to Stripe, Inc. in the USA, which is certified under the EU-US Data Privacy Framework. Stripe’s privacy policy applies to its checkout page.

7. Choosing your time

After a verified payment you choose your time on our own booking page; no third-party content is loaded and no cookies are set. To save you retyping, your name and email address from the payment are filled in, and you can correct them. Your browser’s time zone is used to show the times in your local time.

When you book, we store your first and last name, email address, time zone, the time of the session, a reference to your payment, the booking status and the identifiers of the calendar event and the Zoom meeting. This booking record is kept in a database operated by Neon Inc. (USA) on servers in Frankfurt am Main, Germany. If you reschedule or cancel, the record is updated. We keep it for as long as needed to provide the session and to meet statutory retention obligations under commercial and tax law. The optional answer to “What would make this conversation valuable for you?” is sent only to the coach by email and is not stored in the booking database.

To show only free times and to create the session, we use Google Calendar, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). For availability we only read busy and free times of the coach’s calendar, never the content of other appointments. For your booking we create a calendar event with your name and email address as the invited guest; Google then sends you the calendar invitation, and any change or cancellation, by email. The invitation shows the email address of the coach’s Google account.

The legal basis is Art. 6(1)(b) GDPR. Neon and Google may transfer data to the USA; both are certified under the EU-US Data Privacy Framework. The privacy policies of Neon and Google apply.

8. Order confirmation and transactional emails

After payment we send you an order confirmation with the contract details, your recorded confirmations, the terms and the withdrawal information, and a link to choose your time. When you book, reschedule or cancel, we send you a confirmation with the session details and a personal link for changes. If you use the withdrawal function, we send a confirmation of receipt. These emails are sent via Resend (Plus Five Five, Inc., USA), which is certified under the EU-US Data Privacy Framework. The legal basis is Art. 6(1)(b) and (c) GDPR.

9. Withdrawal function

If you withdraw using the form on this website, we process your name, email address, the details identifying your contract, any note and the time of receipt, in order to handle your withdrawal, refund your payment and document it. The data is stored in non-public storage (Vercel Blob, Frankfurt am Main). The legal basis is Art. 6(1)(c) GDPR, and Art. 6(1)(b) GDPR for processing the refund.

10. Sessions on Zoom

Coaching sessions take place on Zoom, a service of Zoom Communications, Inc., 55 Almaden Boulevard, Suite 600, San Jose, CA 95113, USA (“Zoom”). When you book, we create a separate Zoom meeting for your session through Zoom’s interface; it contains the session title and time, but not your name or email address. The link to the meeting is added to your calendar invitation and your booking confirmation. When you join, Zoom processes in particular the name you enter, audio and video data and technical connection data.

Sessions are not recorded, and no transcripts or AI meeting summaries or notes are created: automatic recording and Zoom’s AI Companion features are switched off for these meetings. The legal basis is Art. 6(1)(b) GDPR. Zoom is certified under the EU-US Data Privacy Framework; details can be found in Zoom’s privacy statement.

11. Web analytics with Google Analytics 4 (only with consent)

If you choose “Allow” in the statistics notice, we use Google Analytics 4, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Before that, no Google script is loaded and no data is sent to Google.

After your consent, the following data is processed in particular: pages visited, time, referring page, language, device, browser, operating system and screen information, and an approximate location derived from your IP address. Google sets cookies (“_ga” and “_ga_<ID>”) containing a pseudonymous identifier, valid for up to two years by default. If you send an enquiry, an event without any form content is recorded. Google Signals and ad personalisation are disabled.

The legal basis is your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG). Data may be transferred to Google LLC in the USA, which is certified under the EU-US Data Privacy Framework. You can withdraw your consent at any time via “Privacy settings” in the website footer; we then disable Google Analytics, delete its cookies for this website and reload the page.

12. Contact by email

If you write to us by email, we process your email address and the content of your message to handle your request (Art. 6(1)(b) or (f) GDPR).

13. Links to other websites

This website links to external websites, for example Amazon (book listings) and Credly (credential verification). Data is only transferred to their operators once you follow such a link; their privacy policies apply there.

14. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on Art. 6(1)(f) GDPR on grounds relating to your particular situation (Art. 21). Please contact info@ichii.de.

You also have the right to lodge a complaint with a data protection supervisory authority, for example the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit), Alt-Moabit 59–61, 10555 Berlin.

No automated decision-making, including profiling, takes place.