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 separate, explicit consent, use Fathom and ChatGPT to prepare session transcripts, written summaries and reviews of recurring themes across sessions, as explained above.
• 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)
• Where information shared in coaching concerns your health, sex life, sexual orientation or other specially protected personal information, I obtain explicit consent for its use in the agreed coaching and record-keeping process. Permission for optional recording, transcription and AI-assisted processing is requested separately.

6. Retention of Data

• Session recordings: Any recording saved in Fathom is deleted from my account once the written summary has been completed and checked.
• Working transcripts: I review whether full transcripts are still needed after each review across several sessions. Material that remains necessary for ongoing coaching may be retained during the agreed programme, including in ChatGPT conversations and uploaded files. Remaining working transcripts are deleted from my accounts and working files within 30 days after the programme ends. For an extended pause, we agree when this material will be reviewed or deleted.
• Reviewed coaching records: Final summaries, pattern reviews and essential coaching notes may be retained for up to seven years after coaching ends, but are deleted sooner when no longer necessary.
• Financial records: Invoices and bookkeeping records are retained for seven years.
• Other communications: Emails and messages are retained for up to two years after our last contact, unless they are deleted sooner or relevant extracts form part of the essential coaching record.
• Marketing information: Information used for newsletters is retained until you unsubscribe or withdraw consent.
• You may request earlier deletion, subject to any applicable legal requirements. Deletion from my accounts initiates the providers’ own deletion processes; removal from their backup systems may take additional time.

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: victoria@victoriaonken.com