Privacy Policy
Last Updated: January 8, 2025
1. Who We Are
NOWHERE Coaching (operated by Article 19 LLC) is a Florida-based company providing global coaching services. We act as a data controller under GDPR for all personal data processed in connection with our coaching services. We prioritize the privacy and security of our clients' data while delivering professional coaching services worldwide.
2. Data Collection and Processing
2.1 What Data We Collect and Why
We collect and process the following types of information:
Contact Information (name, email, phone number)
Purpose: To communicate with you and schedule coaching sessions
Legal basis: Contract performance
Session Scheduling Details
Purpose: To organize and manage coaching sessions
Legal basis: Contract performance
Coaching Documentation
Purpose: To provide tailored coaching services and track progress
Legal basis: Contract performance
Payment Information
Purpose: To process payments for services
Legal basis: Contract performance and legal obligations
2.2 How We Collect Data
We collect data through:
Direct submission via contact forms, Email communications, Video calls, Calendar, Payment processing systems, Document storage, Forms
2.3 Data Retention
Coaching records: 10 years (as specified in our coaching agreement)
Payment records: 7 years (legal requirement)
Email communications: 10 years
After these periods, data is securely deleted unless required by law.
3. Data Protection and Security
3.1 Technical Measures
Industry-standard encryption for data in transit and at rest
Google Workspace enterprise-grade security
Two-factor authentication mandatory
Regular security updates and monitoring
3.2 Access Controls
Access limited to the business owner only
No third-party access except where necessary for service provision
All access is logged and monitored
3.3 Service Providers
We use the following GDPR-compliant service providers:
Google Workspace (email, document storage)
WISE (payment processing)
WIX (website hosting)
All providers have signed Data Processing Agreements (DPAs).
4. International Data Transfers
4.1 Data Storage and Transfers
Primary business operations: United States
Data storage: Google Workspace infrastructure
International transfers protected by:
Standard Contractual Clauses (SCCs)
Google Workspace's GDPR compliance framework
4.2 Legal Basis for Processing
We process data under the following GDPR legal bases:
Contract performance (Article 6(1)(b))
Legal obligations (Article 6(1)(c))
Legitimate interests (Article 6(1)(f))
Explicit consent where required
5. Your Rights and How to Exercise Them
5.1 Your Rights
You have the right to:
Access your personal data
Request corrections
Request deletion
Data portability
Withdraw consent
Lodge complaints with supervisory authorities
5.2 How to Exercise Your Rights
Email: admin@now-here.coach
Response time: Within one month
Identification required: We may need to verify your identity
No fee charged (except for manifestly unfounded or excessive requests)
5.3 Limitations
Certain data may not be deleted if required for legal obligations
Access to third-party data may be restricted
Requests affecting others' privacy may be limited
6. Website and Cookies
6.1 Cookie Usage
We use two types of cookies on our website:
Essential Cookies (Required)
Purpose: Enable core website functionality
Usage: Power our booking system, Enable contact form submissions, Maintain basic security
These cookies are strictly necessary and cannot be disabled
Analytics Cookies (Optional)
Purpose: Basic website analytics
Usage: Basic website analytics through Wix's built-in analytics system, Track general visitor patterns, Measure website effectiveness
These cookies are optional and can be disabled
No personal information is collected through analytics
Data is anonymized and used only for website improvement
6.2 Managing Cookie Preferences
You can accept or decline optional cookies via our cookie banner
Browser settings can be used to manage or delete cookies
Declining optional cookies won't affect core website functionality
Essential cookies cannot be disabled as they are required for website operation
6.3 Cookie Retention
Essential cookies: Deleted when you close your browser
Analytics cookies: Stored for up to 12 months
You can clear cookies anytime through your browser settings
6.4 Website Forms
When you submit forms on our website:
Data is encrypted in transit
Stored securely in our systems
Used only for the purpose specified on the form
7. Special Categories of Data
We do not routinely collect or process special categories of personal data.
If coaching sessions reveal sensitive information:
It is treated with strict confidentiality
Stored securely with enhanced protection
Processed only with explicit consent or as legally permitted
8. Data Breaches
In the unlikely event of a data breach:
We will notify affected individuals within 72 hours
Provide details of the breach and mitigation measures
Report to relevant supervisory authorities if required
9. Contact Information
For privacy-related inquiries:
Email: admin@now-here.coach
Address: Article 19 LLC, 3833 Powerline Road, Suite 101, Fort Lauderdale, FL 33309
Response time: Within 2 business days
10. Updates to This Policy
We review this policy annually and update it as needed.
Material changes will be communicated directly to active clients.
Last reviewed: January 17, 2025
Next scheduled review: January 17, 2026
ICF Code of Ethics
I have completed an ICF-accredited coach training program through the Irish Lifecoach Institute. This training adheres to the high standards set by the International Coaching Federation (ICF), the leading global organization for professional coaching.
As a coach trained in an ICF-accredited program, I follow the ICF Code of Ethics in all my coaching relationships, ensuring:
Transparent communication about coaching services
Strict confidentiality and clear boundaries
Professional excellence and integrity in all coaching relationship
Continuous professional development
Non-discriminatory practices and respect for diversity
The complete ICF Code of Ethics can be found on the official ICF website.