Version 3 · Effective 2026-08-15

This document is a draft and has not yet been reviewed by legal counsel. It is not yet in effect.

Privacy Policy

Effective date: August 15, 2026 · Version: 3

Ladoos Consultancy BV ("Coachstra," "we," "us"), registered in Belgium (company number 0732908541, registered office at Poddegemstraat 112B, 1850 Grimbergen, Belgium), processes personal data in two distinct roles. Reading this section first will make the rest of this policy make sense. Coachstra serves coaches worldwide; the standard described below (rooted in the EU's GDPR) is applied as our baseline regardless of where you are located, with jurisdiction-specific disclosures layered on top where a particular law requires more (see Section 7).

1. Our two roles: controller and processor

We are a data controller for your coach account data — your name, email, billing details, and login activity. We decide why and how this data is processed. We do not currently collect product-usage/telemetry data. If and when we do, our lawful basis will be legitimate interest, backed by a Legitimate Interests Assessment already on file, scoped to usage and error signals — never your clients' data or content — and never used for advertising.

We are a data processor for your clients' data — client profiles, intake forms, session notes, recordings, transcripts, AI-generated summaries, ICF hours, contracts, and messages. You (the coach) are the controller of this data. We process it only on your instructions, as described in our Data Processing Agreement, which is incorporated into your agreement with us automatically when you use the Service.

This means: if your client wants to access, correct, or delete their data, that request should go to you, not to us — we will forward any request that reaches us directly to you and tell the requester who their controller is.

2. What we collect and why

| Data | Role | Purpose | Legal basis (where we are controller) | | ---------------------------------------------------- | ---------- | --------------------------------------------------------- | ----------------------------------------------------------------------------------- | | Coach account, billing, login | Controller | Provide and bill for the Service | Contract necessity | | Product usage/telemetry (planned, not yet collected) | Controller | Reliability, security, product improvement | Legitimate interest (assessment on file) | | Marketing email preferences | Controller | Send you product updates you've opted into | Consent | | Client profiles, intake, notes | Processor | Delivered on your instructions as controller | You determine the basis | | Session recordings, transcripts, AI notes | Processor | Delivered on your instructions, consent-gated per session | You determine the basis; we never process without your consent gate being satisfied |

We do not use your clients' data, recordings, or transcripts to train models, for benchmarking, or for any purpose beyond what you've instructed — doing so would make us a controller of that data, which our Data Processing Agreement commits us not to become.

3. Automated decision-making

Coachstra does not make automated decisions about you or your clients that produce legal effects or similarly significantly affect you, within the meaning of GDPR Article 22. AI-generated session notes and summaries are drafting aids for your own review — they do not automatically determine any outcome about a client (such as eligibility, scoring, or evaluation) without your judgment in between.

4. Sub-processors and international transfers

We use a limited set of sub-processors to run the Service — see the current list at /subprocessors, which names each vendor, its purpose, its location, and its transfer mechanism. Several sub-processors are located in the United States; where that is the case, we rely on EU Standard Contractual Clauses, supported by a Transfer Impact Assessment for each such transfer, rather than solely on Data Privacy Framework certification. We will give notice of any material change to this list per the commitment stated there.

5. Google user data (Gmail and Google Calendar)

Connecting a Google account is optional — Coachstra works without it, and you can disconnect at any time (see the end of this section). This section describes exactly what we access, use, store, and share when you do connect one.

Coachstra's use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements. The same commitment applies to data received from Google Workspace APIs under the Google Workspace user data and developer policy.

What we request, and why

• gmail.readonly — permits reading your mail. This is a broad scope: it covers received, sent and archived mail, not only your inbox. We use it to copy the email conversations you already have with your clients onto that client's timeline, so your record stays complete even when you reply from Gmail instead of from Coachstra. What we actually keep is narrower than what the scope permits — see below.
• gmail.send — permits sending mail as you. We use it so that client email goes out from your own address, and your client receives a message from you rather than from an unfamiliar third party.
• calendar.events — permits reading, creating and managing calendar events. We use it for two things: creating the calendar entry and Google Meet link for sessions you book in Coachstra, and reading your existing calendar so Coachstra can show your real availability rather than only the sessions it already knows about. The second use is why this scope covers more than it might appear — see below.
• userinfo.email — permits reading your email address. We use it to identify which Google account you connected for calendar and video, and to label it in the app so you can confirm the right account is linked.

What we store — and what we deliberately do not

We do not mirror your mailbox. A message is written to our database only when the address on the other side of it already exists as one of your clients in Coachstra. Every other message — personal mail, mail from people who are not your clients, everything else — is read in transit solely to make that determination and is then discarded. This is enforced in our code, not left to configuration.

For the messages that do match a client, we store the subject, the message text, the sender and recipient addresses, the timestamp, and Google's message and thread identifiers (so that a re-delivered message is recognised rather than duplicated). These sit in your practice's own records, visible only to you and to anyone you have granted access to your Coachstra account.

Calendar access is broader than creating your sessions, and you should know exactly how far it reaches. When you connect a calendar, we read your primary calendar across a window around today and store the title, start time and end time of every timed event we find there — not only the sessions booked through Coachstra. Your provider then notifies us of changes and we keep those stored events up to date. This is what allows Coachstra to show your genuine availability instead of only the time it already knows about, and it means personal and unrelated work appointments are stored too.

We store only each event's title and its start and end times. We do not store descriptions, attendee lists, locations or attachments, and we skip all-day events entirely. The same applies to a connected Outlook calendar.

One thing leaves Coachstra rather than arriving in it. When you book a session with a client through Coachstra, we add that client as an attendee on the calendar event, which means we send their email address to Google and Google emails the invitation to them directly. If you would rather your client's address were not passed to Google, do not book that session through a connected Google calendar.

What we never do with Google user data

• We never use it to create, train, or improve any machine learning or artificial intelligence model — foundational or otherwise. Coachstra's AI features operate only on session recordings and transcripts covered by the per-session consent gates described in Section 2, and are kept separate from the email integration: Google user data is never sent to our AI sub-processors.
• We never sell it, and never transfer it for advertising, retargeting, or for assessing creditworthiness or lending.
• We never let humans read it, other than in the narrow circumstances the Limited Use requirements permit: with your explicit, documented prior agreement to view specific messages; where necessary for security purposes such as investigating a bug or abuse; where the data is aggregated and anonymised for internal operations; or to comply with applicable law.
• We never transfer it to third parties, except as necessary to provide the user-facing features described above, for those same security or legal reasons, or as part of a merger or acquisition and only with your explicit prior consent.

Disconnecting and revoking

There are two separate Google connections, and disconnecting one does not disconnect the other. Your Gmail connection is disconnected from the Communication screen; your calendar and video connection is disconnected from the integrations settings. Disconnecting either stops its sync immediately and deletes that connection's stored access and refresh tokens from our systems. To end all Google access, disconnect both.

Disconnecting inside Coachstra does not by itself revoke the grant on Google's side. To withdraw Coachstra's access at Google, visit myaccount.google.com/permissions and remove Coachstra. We state this plainly rather than implying a revocation we do not perform.

Messages already written to a client's timeline remain part of that client record, which you control as its controller; deletion works as described in Section 8.

6. Retention

We retain coach account data for as long as your account is active plus a reasonable period afterward for legal, tax, and dispute-resolution purposes. Client data (as processor) is retained per your own instructions and settings, and deleted or returned to you at the end of your subscription per our Data Processing Agreement, Section 9.

7. Other jurisdictions

Coachstra is marketed and available worldwide. The GDPR standard described in this policy is our floor for everyone, not an EU-only benefit. Where another jurisdiction's law requires an additional disclosure, it is set out below.

California (CCPA/CPRA): we do not sell or share your personal information, and do not expect to meet the thresholds that trigger the CCPA's full obligations. If you are a California-based coach and your own business requires service-provider terms with us for your California clients, contact us and we will provide them.

Other countries: where local law grants rights beyond those described here (for example, additional consumer or employee data protections), we will honor those rights for the residents they protect; contact us at the address in Section 14 to ask about your specific jurisdiction.

8. Your rights

If you are a coach (our direct customer): you may access, correct, export, or request deletion of your account data by contacting us at info@coachstra.com. You are also the controller responsible for handling these requests from your own clients.

If you are a coach's client: Coachstra is not your controller. Please contact your coach directly to exercise your data protection rights. If you contact us directly, we will forward your request to your coach and will not act on it ourselves, consistent with our role as processor.

You also have the right to lodge a complaint with the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit / Autorité de protection des données), or your own country's supervisory authority if you are located elsewhere in the EU.

9. Cookies

Coachstra sets only strictly necessary cookies: session and authentication cookies, short-lived OAuth security (CSRF) cookies used only during a third-party connection flow you initiate, and one preference cookie that remembers your chosen interface theme, set only after you explicitly choose it. We do not set analytics, advertising, or tracking cookies. Because none of our cookies require consent under applicable law, we do not show a cookie banner; if that changes, this policy and our practice will change with it.

10. Security

We rely on our infrastructure providers' security measures (encryption in transit and at rest, access controls) and apply role-based access controls of our own — see our Data Processing Agreement's Technical and Organisational Measures annex for detail.

11. Data Protection Officer

Coachstra has not appointed a dedicated Data Protection Officer at this time. For any data protection question, contact us at the address in Section 14.

12. Children

The Service is intended for use by professional adults (coaches) and is not directed at children. We do not knowingly collect data from children through our own controller-role processing of coach account data.

13. Changes to this policy

We will notify you of material changes and, where required, ask you to re-accept before continuing to use the Service.

14. Contact

info@coachstra.com.

This document is a draft pending review by a Belgian privacy lawyer. It is not yet in effect and must not be relied upon as binding until that review is complete — see Issue #35.