Privacy Policy

Consent to AI-Assisted Transcription & Summarization

By working with me, you acknowledge that:

• I may, with your explicit verbal or written consent, use secure AI-powered tools (such as Fathom for transcription and ChatGPT for summarization) to help create transcripts and summaries of our coaching sessions.
• These tools are used only to improve accuracy and impact of the coaching process.
• You always have the right to refuse or withdraw consent, and coaching will continue without these tools if you prefer.
• Any data processed via these tools is handled in accordance with the GDPR (AVG) and my Privacy Policy below.

Privacy Policy
Victoria Onken Coaching
 (“I”, “me”, “my”)

1. Introduction
This Privacy Policy explains how I handle your personal data when you use my coaching services, website, and related offerings. I am based in the Netherlands and comply with the General Data Protection Regulation (GDPR/AVG). Since I work with clients worldwide, this policy is also designed to meet international best practices.

2. Data Controller
Victoria Onken Coaching
Registered in the Netherlands as sole proprietor (ZZP)
Contact: hello@victoriaonken.com

3. Personal Data I Collect
I may collect the following information:

• Identification & contact details (name, email, phone number, address)
• Billing details (invoices, payments)
• Coaching session information (notes, summaries, transcripts, recordings if explicitly agreed)
• Communications (emails, messages, intake forms)
• Website usage data (cookies, analytics, IP address)

4. Purposes of Processing
I process your personal data to:

• Deliver coaching sessions
• Prepare and maintain client session summaries and analysis
• With your explicit verbal or written consent, use secure AI-powered tools (such as transcription and summarization software, e.g., Fathom and ChatGPT) to support accurate records and create more impactful outcomes
• Schedule and manage appointments
• Administer billing and bookkeeping
• Improve and personalize services (with anonymized or aggregated data where possible)
• Send marketing or newsletters (only with your explicit consent)
• Comply with Dutch and EU legal obligations

5. Legal Basis for Processing (GDPR)

• Contract performance (to provide coaching)
• Legal obligation (tax, bookkeeping)
• Legitimate interest (service quality, communication)
• Consent (marketing, optional transcripts/recordings, AI-based processing)

6. Retention of Data

• Coaching notes & summaries: up to 7 years, unless you request earlier deletion (except where law requires retention).
• Invoices & bookkeeping: 7 years (per Dutch tax law).
• Communications: up to 2 years after last contact.
• Marketing data: until consent is withdrawn.

7. Sharing & Transfers

• With your explicit consent, session transcripts and notes may be processed by trusted external service providers, including AI-based transcription and summarization tools (e.g., Fathom, ChatGPT).
• These providers may operate outside the EU. In such cases, transfers are subject to GDPR safeguards (such as EU Standard Contractual Clauses).
• I do not otherwise share or sell your data.

8. Your Rights

• You have the right to:
• Access your data
• Correct inaccuracies
• Request deletion (“right to be forgotten”)
• Restrict or object to processing
• Request data portability
• Withdraw consent at any time
• File a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens)

9. Cookies
My website may use cookies for functionality and analytics. You can control cookies through your browser settings.

10. Contact
For questions about this policy or your data rights: hello@victoriaonken.com