Privacy Policy

1. Who We Are

Data Controller: Dr. Sara Hegry, trading as GenX Leadership Academy
Address: Klosterstraße 3, 13581 Berlin, Germany
Email: [email protected]
Phone: +49 176 3538 1191

If you have questions about how we handle your data, contact us at the above details. We will respond within 30 days.

2. What Data We Collect

We collect information you provide directly and information gathered automatically when you use our site:

• Contact details — name, email address, phone number from inquiry or booking forms.
• Coaching intake data — professional background, goals, and session notes shared during the coaching relationship.
• Newsletter subscription — email address when you subscribe to Leadership Insights.
• Payment information — billing details processed by our third-party payment providers. We do not store full card numbers.
• Usage & analytics data — pages visited, time spent, browser type, device, and IP address collected via cookies and analytics tools.
• Communications — emails, messages, and feedback you send to us.

3. How We Use Your Information

• Deliver, personalise, and improve coaching services and programmes.
• Respond to enquiries and communicate about sessions or services.
• Process bookings and send confirmation emails.
• Send newsletters and leadership resources — only where you have opted in.
• Analyse website usage to improve user experience and content.
• Comply with legal and regulatory obligations.

4. Legal Basis for Processing (GDPR)

• Contract performance — processing necessary to deliver coaching services you engaged us for (Art. 6(1)(b) GDPR).
• Legitimate interests — improving services, website analytics, and business communications (Art. 6(1)(f) GDPR).
• Consent — newsletter subscriptions and non-essential cookies, where you actively opted in (Art. 6(1)(a) GDPR).
• Legal obligation — where processing is required by EU or German law (Art. 6(1)(c) GDPR).

5. Sharing Your Information

We do not sell, rent, or trade your personal data. We may share it only as necessary with:

• Service providers — email platforms, scheduling tools, payment processors, CRM, and website hosting.
• Professional advisors — lawyers, accountants, or auditors bound by confidentiality obligations.
• Legal authorities — where disclosure is required by law, court order, or regulatory authority.

All third-party processors are contractually required to keep your data secure and use it only for the purpose of providing services to us.

6. Cookies & Tracking

We use cookies to enhance your experience and collect analytics:

• Essential cookies — required for the website to function. Cannot be disabled.
• Analytics cookies — help us understand visitor behaviour (e.g. Google Analytics). Anonymised where possible.
• Preference cookies — remember your settings such as language or display preferences.
• Marketing cookies — only set with your explicit consent.

You can manage or disable non-essential cookies through your browser settings or our cookie consent tool.

7. Data Retention

• Coaching records: minimum 7 years (German professional standards).
• Newsletter subscribers: until you unsubscribe.
• Analytics data: 26 months (anonymised).
• Inquiry data: 2 years from last contact if no engagement followed.

You may request deletion of your data at any time (see Section 9).

8. International Data Transfers

Some of our service providers operate outside the EEA. Where transfers occur, we ensure appropriate safeguards are in place — such as EU Standard Contractual Clauses (SCCs) — to protect your data to EEA standards.

9. Your Rights Under GDPR

1. Right of access — request a copy of the data we hold about you (Art. 15).
2. Right to rectification — ask us to correct inaccurate or incomplete data (Art. 16).
3. Right to erasure — request deletion of your data (Art. 17).
4. Right to restriction — ask us to limit how we use your data (Art. 18).
5. Right to data portability — receive your data in a machine-readable format (Art. 20).
6. Right to object — object to processing based on legitimate interests or for direct marketing (Art. 21).
7. Right to withdraw consent — withdraw consent at any time without affecting prior lawful processing (Art. 7(3)).

To exercise any right, email [email protected]. We will respond within 30 days.

10. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal or similarly significant effects on you (Art. 22 GDPR).

11. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include encrypted connections (HTTPS) and restricted access controls. In the event of a data breach affecting your rights, we will notify you and the competent supervisory authority as required by law.

12. Children's Privacy

Our services are intended for adults (18+). We do not knowingly collect personal data from individuals under 16. If you believe a minor has shared data with us, contact us immediately and we will delete it.

13. Third-Party Links

Our website may contain links to external sites. This policy applies only to our site. We are not responsible for the privacy practices of third-party websites.

14. Right to Lodge a Complaint

If you believe we have not handled your data lawfully, you have the right to lodge a complaint with your local data protection authority. In Germany:

Berliner Beauftragte für Datenschutz und Informationsfreiheit
Alt-Moabit 59–61, 10555 Berlin — www.datenschutz-berlin.de

15. Changes to This Policy

We may update this policy from time to time. The updated policy will be posted here with a revised effective date. Where changes are material, we will notify you by email or a prominent notice on our website.

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