Privacy Policy

Last Updated: December 6, 2025

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1. INTRODUCTION & COMMITMENT TO CONFIDENTIALITY

Giuseppe Tempestini (“Coach Tempestini,” “we,” “us,” or “our”) operates coachtempestini.com and provides professional non-directive coaching services internationally. We are deeply committed to protecting your privacy and maintaining the confidentiality of your personal information.

COACHING SESSION CONFIDENTIALITY:
The content of all coaching sessions is treated as highly sensitive and confidential information. We maintain strict professional confidentiality standards in accordance with International Coaching Federation (ICF) ethical guidelines. Session content, discussions, insights, and personal information shared during coaching are never disclosed to third parties without your explicit written consent, except where required by law.

This Privacy Policy explains how we collect, use, store, and protect your personal data in compliance with:

• European Union General Data Protection Regulation (GDPR)
• California Consumer Privacy Act (CCPA) and other US state privacy laws
• Chilean Personal Data Protection Law (Ley 19.628)

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2. WHO WE ARE

Data Controller: Giuseppe Tempestini
Services: Professional Non-Directive Coaching (English, Italian, Spanish)

For privacy-related questions or to exercise your data rights, contact us via the contact form on our website or email giuseppe at website domain.

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3. WHAT INFORMATION WE COLLECT

3.1 INFORMATION YOU PROVIDE DIRECTLY:

Contact Form Information:

• Name
• Email address
• Phone number (if provided)
• Country
• Preferred coaching session language
• Nature of coaching interest (1-to-1, Business Team, Media, Other)
• Any additional information you choose to share in your message

Coaching Session Information (for active clients):

• Session notes and summaries (kept by coach only)
• Goals and objectives you’ve identified
• Action steps and commitments you’ve made
• Progress updates and feedback
• Payment information (processed through secure third-party providers)

3.2 INFORMATION COLLECTED AUTOMATICALLY:

Website Usage Data:

• IP address (anonymized where possible)
• Browser type and version
• Device information
• Pages visited and time spent
• Referring website
• General location (country/city level only)

Cookies and Tracking:

• Essential cookies for website functionality
• Analytics cookies (with your consent) – see Section 9

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4. HOW WE USE YOUR INFORMATION

We use your personal information only for the following legitimate purposes:

4.1 PROVIDING COACHING SERVICES:

• Responding to your initial contact inquiry
• Scheduling and conducting coaching sessions
• Maintaining session notes to support your coaching journey
• Following up on commitments and action steps
• Invoicing and payment processing

4.2 COMMUNICATION:

• Sending appointment confirmations and reminders
• Sharing session summaries or resources when relevant
• Responding to your questions or requests
• Sending occasional updates about our services (with your consent)

4.3 LEGAL & BUSINESS OPERATIONS:

• Complying with legal obligations
• Protecting against fraud or security threats
• Improving our website and services
• Maintaining business records as required by law

4.4 WHAT WE DO NOT DO:

• We DO NOT sell your personal information to third parties
• We DO NOT share coaching session content with anyone
• We DO NOT use your information for advertising purposes
• We DO NOT send unsolicited marketing emails

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5. LEGAL BASIS FOR PROCESSING (GDPR)

For EU/EEA residents, we process your data based on:

• CONTRACT: Processing necessary to provide coaching services you’ve requested
• CONSENT: Where you’ve given explicit permission (e.g., newsletter signup)
• LEGITIMATE INTERESTS: Operating our business, fraud prevention, website improvement
• LEGAL OBLIGATION: Compliance with tax, financial, and professional regulations

You have the right to withdraw consent at any time without affecting prior processing.

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6. HOW WE PROTECT YOUR INFORMATION

SECURITY MEASURES:

• SSL/TLS encryption for all website communications
• Secure, password-protected systems for client records
• Regular security updates and monitoring
• Limited access to personal data
• Secure third-party services with strong privacy commitments

SESSION CONFIDENTIALITY PROTECTIONS:

• Session notes stored in encrypted, password-protected systems
• Physical notes (if any) kept in locked storage
• Strict adherence to ICF ethical guidelines on confidentiality

DATA BREACH PROTOCOL:
In the unlikely event of a data breach affecting your personal information, we will:

• Notify you within 72 hours (GDPR requirement)
• Report to relevant authorities as required
• Take immediate steps to secure affected data
• Provide guidance on protective actions you can take

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7. WHO WE SHARE YOUR INFORMATION WITH

We share your personal information only with:

ESSENTIAL SERVICE PROVIDERS:

• Website hosting: SiteGround (privacy policy: siteground.com/privacy)
• Email services: Google Workspace (privacy policy: google.com/policies/privacy)
• Payment processors: PayPal, Global 66, bank transfers, cryptocurrency exchanges
• Video conferencing: Google Meet (for online sessions)

All service providers are contractually bound to protect your data and use it only for specified purposes.

WE NEVER SHARE:

• Coaching session content or discussions
• Personal details shared during coaching
• Your contact information with marketers or third parties
• Information for advertising or profiling purposes

LEGAL OBLIGATIONS:
We may disclose information if required by law, court order, or to protect rights, safety, or property. However, coaching session content remains privileged and confidential except in rare cases mandated by law (e.g., credible threat of harm).

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8. HOW LONG WE KEEP YOUR INFORMATION

CONTACT INQUIRIES:

• Kept for 2 years if no coaching relationship develops
• Then automatically deleted unless you request otherwise

ACTIVE CLIENT RECORDS:

• Session notes: Kept for duration of coaching relationship + 7 years
• Payment records: Kept for 7 years (tax/legal requirement)
• Contact information: Kept as long as coaching relationship continues

INACTIVE CLIENT RECORDS:

• After coaching ends, we retain basic contact info for 7 years
• Session notes archived securely for 7 years, then permanently deleted
• You may request earlier deletion (see Section 10)

WHY 7 YEARS?
This retention period aligns with:

• Professional liability insurance requirements
• Tax record obligations (most jurisdictions)
• Potential legal disputes or claims
• Professional coaching standards

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9. COOKIES & TRACKING TECHNOLOGIES

ESSENTIAL COOKIES (Always Active):

• Session management
• Security and fraud prevention
• Form submission functionality
• Language preference (English/Italian/Spanish)

ANALYTICS COOKIES (Optional – Requires Consent):

• Google Analytics (anonymized IP)
• Website traffic and usage patterns
• No personally identifiable information tracked

COOKIE MANAGEMENT:

• You can disable cookies through your browser settings
• Disabling essential cookies may affect website functionality
• You can withdraw analytics consent at any time

We DO NOT use:

• Advertising cookies
• Social media tracking pixels
• Cross-site tracking technologies
• Behavioral profiling cookies

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10. YOUR PRIVACY RIGHTS

Depending on your location, you have the following rights:

ALL USERS:
✓ RIGHT TO ACCESS: Request copies of your personal data
✓ RIGHT TO CORRECTION: Update inaccurate or incomplete information
✓ RIGHT TO DELETION: Request deletion of your data (“right to be forgotten”)
✓ RIGHT TO WITHDRAW CONSENT: Opt-out of communications at any time

EU/EEA RESIDENTS (GDPR):
✓ RIGHT TO DATA PORTABILITY: Receive your data in structured format
✓ RIGHT TO RESTRICTION: Limit how we process your data
✓ RIGHT TO OBJECT: Object to processing based on legitimate interests
✓ RIGHT TO LODGE COMPLAINT: File complaint with supervisory authority

CALIFORNIA RESIDENTS (CCPA):
✓ RIGHT TO KNOW: Categories and specific pieces of data collected
✓ RIGHT TO DELETE: Request deletion of personal information
✓ RIGHT TO OPT-OUT: We don’t sell data, so this automatically applies
✓ RIGHT TO NON-DISCRIMINATION: Equal service regardless of rights exercised

CHILEAN RESIDENTS:
✓ RIGHT TO INFORMATION: Know what data is held about you
✓ RIGHT TO MODIFICATION: Correct or update your information
✓ RIGHT TO CANCELLATION: Request deletion of your data
✓ RIGHT TO BLOCK: Prevent certain data uses

HOW TO EXERCISE YOUR RIGHTS:

• Contact form: coachtempestini.com/contact
• We respond within 30 days (GDPR) or 45 days (CCPA)
• No fee unless requests are excessive or unfounded

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11. INTERNATIONAL DATA TRANSFERS

As we serve clients globally and use international service providers, your data may be transferred outside your country of residence.

DATA TRANSFER SAFEGUARDS:

• We use services with strong privacy commitments (Google, SiteGround)
• Standard Contractual Clauses (SCCs) for EU data transfers
• Adequate privacy protections regardless of processing location
• Your rights remain protected under GDPR if you’re in EU/EEA

PRIMARY DATA LOCATIONS:

• Website hosting: European Union servers (SiteGround)
• Email and Session notes: Google Workspace (global infrastructure)

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12. THIRD-PARTY LINKS

Our website may contain links to external resources (coaching articles, tools, etc.). We are not responsible for the privacy practices of third-party websites.

RECOMMENDATION:

• Review privacy policies of any external sites you visit
• We only link to reputable, professional resources
• External links are provided for convenience, not endorsement

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13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy to reflect:

• Changes in legal requirements
• New services or features
• Improvements in data protection practices

NOTIFICATION OF CHANGES:

• “Last Updated” date will change at top of policy
• Significant changes will be announced via email (active clients)
• Continued use after changes constitutes acceptance
• Previous versions available upon request

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14. PROFESSIONAL COACHING ETHICS

In addition to legal privacy requirements, we adhere to:

INTERNATIONAL COACHING FEDERATION (ICF) CODE OF ETHICS:

• Maintaining strict confidentiality of coaching relationship information
• Not disclosing coach-client relationship without permission
• Protecting identity of clients in testimonials or marketing
• Storing and disposing of records in secure manner

CONFIDENTIALITY EXCEPTIONS:
Consistent with ICF standards and legal requirements, confidentiality may be broken only when:

• Client provides explicit written consent
• Required by court order or subpoena
• Mandatory reporting of child abuse or neglect
• Credible threat of imminent harm to self or others
• Professional consultation for coaching supervision (with anonymization)

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By using our website or services, you acknowledge that you have read and understood this Privacy Policy.

Your privacy and the confidentiality of your coaching journey are our highest priorities.

Giuseppe Tempestini
Professional Non-Directive Coach
coachtempestini.com