Privacy Policy

Coaching Toolkit (https://coaching-toolkit.com) is a coaching workspace. A Practice keeps a profile for each client it coaches, assigns them exercises, and prepares its sessions from the client card. Appspire d.o.o. za usluge provides the service.

Appspire d.o.o. za usluge, OIB 85271623476, registered office Savska cesta 32, 10000 Zagreb, Croatia, email [email protected] ("we", "us").

This policy applies to Coaches who hold an account on Coaching Toolkit, to clients whose profiles a Practice keeps in Coaching Toolkit and who use the client portal, and to visitors of the website.

For Coach accounts, Practice billing records, website visits and the security of the service, we decide why and how the information is processed.

Client profiles, exercises, notes and goals are the Practice's own business records. The Practice decides whom to add, what to assign and what to write; we store and process those records on the Practice's behalf to provide the service.

Payments a client makes to a Practice go to the Practice's own Stripe account. The Practice and Stripe process those payments under their own agreement; we never collect payments on a Practice's behalf and have no access to its funds.

Coach accounts: name, email address, Practice, role, and sign-in records, verified through WorkOS.

Client profiles: what a Coach enters about a client - name, email address, and optionally phone, time zone, pronouns, a context line (such as role, company or referral) - with the engagement's status (Active, Paused or Ended), its start date, the assigned Coach and any groups the client belongs to.

Exercises: which tool was assigned and when, the client's answers to each step, the result built from them (for Values Discovery: the client's values with their grades, icons and alignment scores, and the value they chose to focus on), and when the client started, finished or changed an exercise.

Goals and notes: the goals a Coach records for a client and their progress; client notes and session notes.

Portal access: the link sent to a client (stored only in a form that cannot be turned back into the link), when it was used, and the portal session it started.

The audit log: a record of coaching and billing actions on a Practice - who did what, and when. The actor may be a Coach, a client (for example, completing an exercise) or the system.

Email records: which notification or link was sent to which address, and whether it was delivered.

Billing: the Practice's package and subscription status. Payment details are collected and held by Stripe, not by us.

Client payments: when a Practice connects its own Stripe account, we keep the account's identifier and status - its country, default currency and whether it can take payments. For each payment a Practice requests from a client, we keep the client, the offer, the amount and currency, its status and when it was paid, refunded or disputed, with Stripe's references to the checkout and the payment. Clients enter their card or other payment details on Stripe's checkout page; we never see or store them.

Technical data: IP address, browser and device information and request logs, used to run and secure the service.

A client reaches the portal from a link their Coach sends through Coaching Toolkit by email. The link is personal, works for a limited time and opens a portal session bound to that one client. There is no password and no account to create; a client can ask for a new link from the portal page.

In the portal a client sees the exercises assigned to them, open and finished, and their own values wheel. They can return to an exercise and change an answer. They see nothing about other clients and none of their Coach's notes.

The portal tells the client, before they start, that their Coach sees their answers. On the first visit, and again whenever this notice changes, the portal shows a short privacy notice - what the Coach sees, who runs the service and a link to this policy - and records when the client accepted it. Every Coach on the Practice can see the client's exercise results, as described under Who sees what.

When a Practice ends its engagement with a client, the client keeps the portal: they can still sign in, read what they received and did, download their materials and signed agreements, and change an exercise they finished. They cannot book sessions, and nothing new can be sent to them. To remove the client's profile and their portal for good, the client asks the Practice to erase it, as described under Data retention.

A Coach can open a video room for a live session with a client or a group. Video and audio travel between the participants through servers we operate in Germany, hosted by Hetzner. They are relayed, not recorded, transcribed or stored, and no video processor outside the EU is involved.

We keep a record of each session in the audit trail and for usage control: the room, when it started and ended, and how long each participant was connected.

To find out why a call broke up, each participant's browser also reports technical facts about its own connection during the session (a reconnect, a drop, a weak line, a camera or microphone that could not be opened), with the time. No addresses, device names or content are part of it, and these records are deleted after 90 days.

The background blur runs on your own device, in your browser: the picture is processed there before it is sent, and nothing of it is uploaded for that.

Every Coach on a Practice sees that Practice's client profiles, exercise results and values wheels. The assigned Coach and the Practice's Admins can change a profile.

Client notes and session notes are visible only to the Coach who wrote them - not to other Coaches, not to Admins and not to the client. They stay with their author when a client moves to another Coach.

A client sees only their own exercises and values wheel, in the portal.

Practice Admins see their Practice's audit log. No Practice can see another Practice's records.

Our own staff access Practice records only where needed to run, secure or support the service, or where the law requires it.

To provide Coaching Toolkit to a Practice: keeping client profiles, sending exercises and portal links, showing results on the client card, applying the limits of the Practice's package, and keeping the audit log. For Coach accounts and billing, the legal basis is the contract with the Practice; for client records, the Practice determines the basis on which it keeps them.

To send transactional email: portal links to clients, and notices to Coaches about their Practice and clients. We send no marketing email to clients.

To secure and improve the service, on the basis of our legitimate interest in running it reliably: error and performance monitoring, abuse prevention and aggregate website statistics.

To meet legal obligations, such as accounting and tax rules.

We use a small number of service providers, each limited to the information it needs:

A Coach in a Practice on the Studio package can connect an AI assistant, such as Claude or ChatGPT, to their Coaching Toolkit account. Once connected, the assistant can read what that Coach can see in Coaching Toolkit - client profiles, sessions, goals, action items, exercise results, whiteboards, the booking page, landing pages, branding and the Coach's own notes - and, when the Coach asks it to, make the changes that Coach could make. Changes that reach clients or the public (for example a session invitation, an exercise, a published page or the Practice's branding) wait until the Coach confirms them in Coaching Toolkit.

Connecting an assistant is the Practice's decision, made by its Coach. When a Coach connects one, Coaching Toolkit sends client information to that assistant on the Practice's instruction. The provider of the assistant (for example Anthropic or OpenAI) processes that information under its own terms with the Coach or the Practice. Coaching Toolkit is not a party to that agreement and does not control what the provider does with the information. The assistant's provider is not one of our service providers listed above.

The Practice is responsible for having a lawful basis to share its clients' information with the assistant's provider, for choosing an assistant and settings suited to that information, and for telling its clients about it.

We record each connection, each change an assistant makes or proposes, and on which days an assistant read a client's information. Coaches and Practice Admins can see and revoke connected assistants at any time in Settings; revoking stops access at once. Disconnecting does not delete what the assistant's provider already received; that is between the Practice and the provider.

Client profiles, exercises, notes, goals and the audit log are stored in the EU, on our server in Vienna, Austria.

Coaching materials, the PDF files a Coach uploads to hand out to clients, are stored on the same server in Vienna, in private storage that is not reachable from the web. They are never handed to a third party for storage or scanning, and they can only be downloaded through Coaching Toolkit: by a Coach of the Practice, or by a client the material was sent to.

Some providers are established outside the European Economic Area: WorkOS and Cloudflare in the United States. Where information is transferred outside the EEA, we rely on an adequacy decision of the European Commission or on the Standard Contractual Clauses it has approved.

Ending an engagement deletes nothing: the profile, its exercises, results, goals and notes stay in the Practice's workspace until the Practice erases them. A Practice Admin can erase a client in the app, for example to act on the client's request: the profile and everything about the client are deleted for good, including every Coach's notes, and the Practice's audit log keeps its entries with the client named only as "a deleted client". Payment records the Practice's own Stripe account holds are not affected.

A person who asks a Practice for a session through its booking page is kept as a prospect: their name, contact details, the request and any note they left. A prospect has no portal and gets only the emails about their request. If the Practice declines the request or lets it lapse, the person stays a prospect until the Practice takes them on as a client or erases them, which deletes them for good as described above.

A handout, a coaching material sent to a client, is part of that client's record: when the client is erased, their handouts are erased with them, while the material itself stays in the Practice's library. Coaching materials belong to the Practice: a Coach can delete one from the library once it is archived and was never sent, and the files go with the rest of the Practice's records when those are removed.

When a Practice is deleted, its subscription is cancelled, every engagement ends and no Coach can reach the Practice's records again. The records are retained for audit purposes.

The audit log is kept for as long as the Practice exists. Billing records are kept as accounting and tax law requires.

We process personal data in accordance with applicable data protection law, including Regulation (EU) 2016/679, the General Data Protection Regulation ("GDPR"). Subject to that law, you have the right of access, to rectification, to erasure, to restriction of processing, to object to processing and to data portability, and, where processing is based on consent, the right to withdraw it at any time.

Clients: your profile, exercises and the notes about you are kept by the Practice that coaches you. To get a copy, or to have them corrected or erased, ask your coach: Coaches handle these requests in Coaching Toolkit, where they can export your record (your profile, exercises and answers, goals, sessions and payments, with the exporting Coach's own notes) and an Admin of the Practice can erase it. If you cannot reach the Practice, or it does not respond, write to us and we will pass your request on or help it reach the right place.

Coaches and Practices: email [email protected]. We may ask for information needed to verify your identity before acting on a request.

You also have the right to lodge a complaint with a supervisory authority: in Croatia, the Croatian Personal Data Protection Agency (Agencija za zaštitu osobnih podataka, AZOP), or the data protection authority of the EU member state where you live.

We apply reasonable technical and organisational measures to protect the information described in this policy, including encryption in transit, strict separation of each Practice's records, portal sessions bound to a single client, and access controls on our own systems. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

We may update this policy as Coaching Toolkit changes. Material changes will be flagged on this page; continued use of Coaching Toolkit after a change takes effect means you accept the updated policy.

Questions about this policy or our processing of personal data, or requests to exercise your rights, can be sent to Appspire d.o.o. za usluge, Savska cesta 32, 10000 Zagreb, Croatia, email [email protected].

The Contact button on this website, in the coach app and in the client portal sends your message to us with the address to reply to (the one of your account, or the one you type) and technical details collected to help us find the problem: the page, the app version, your device and browser, screen size, language and time zone, and the requests that failed, errors and pages visited shortly before, together with the IP address the message came from. We use them only to answer you and to fix the problem.

This policy is governed by the laws of the Republic of Croatia, without prejudice to the mandatory data protection rights described above.