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Privacy policy

What is collected when you use this site or book a conversation, why, and what you can do about it.

What is collected when you use this site or book a conversation, why, and what you can do about it.

What is collected when you use this site or book a conversation, why, and what you can do about it.

Last updated: 15.10.2026

01

Who We Are

This Privacy Policy explains how I collect, use, store and protect personal data when you visit my website, contact me or engage my coaching services.

The data controller responsible for your personal data is:

Iryna Klochko
Business form: sole proprietor
Registered in: Ukraine
Registration number: 2010350000000591955
Business address: 15 Instytutska Street, Khmelnytskyi, Ukraine, 29016
Email: klochkocoach@gmail.com
Website: [Website URL]

In this Policy, “I”, “me” and “my” refer to the data controller identified above.

I aim to process personal data lawfully, fairly and transparently in accordance with applicable data protection legislation, including the EU General Data Protection Regulation (GDPR) where applicable.

This Privacy Policy explains how I collect, use, store and protect personal data when you visit my website, contact me or engage my coaching services.

The data controller responsible for your personal data is:

Iryna Klochko
Business form: sole proprietor
Registered in: Ukraine
Registration number: 2010350000000591955
Business address: 15 Instytutska Street, Khmelnytskyi, Ukraine, 29016
Email: klochkocoach@gmail.com
Website: [Website URL]

In this Policy, “I”, “me” and “my” refer to the data controller identified above.

I aim to process personal data lawfully, fairly and transparently in accordance with applicable data protection legislation, including the EU General Data Protection Regulation (GDPR) where applicable.

02

Personal Data I Collect

The information I collect depends on how you interact with my website and coaching services.

2.1. Website Visits

When you visit my website, certain technical information may be processed by the website hosting platform or other services enabled on the site. Depending on the configuration, this may include your IP address, browser and device information, pages visited, approximate location derived from technical data, and information about website usage.

If website analytics, embedded content or other third-party technologies are enabled, additional information may be collected as described in the relevant sections of this Policy.

2.2. Enquiries and Contact Forms

If you contact me by email or submit a form, I may collect your name, email address, the information you include in your message, and any other details you voluntarily provide.

I use Google Forms for selected forms, such as enquiries or feedback. Please provide only information relevant to the purpose of the form. Avoid including detailed sensitive personal information in initial enquiries.

2.3. Scheduling and Appointments

I use Google Calendar and may use Calendly to arrange introductory conversations and coaching sessions.

Depending on the booking method, information processed may include your name, email address, selected appointment time, time zone, appointment details and related communications.

Calendly and Google may process personal data according to their own privacy documentation and the arrangements applicable to the services I use.

2.4. Coaching Services and Client Records

When you engage my coaching services, I may process information necessary to establish and manage our professional relationship, including:

  • contact details and correspondence;

  • the Coaching Agreement and agreed service arrangements;

  • session dates and administrative records;

  • information you choose to share about your professional circumstances, goals, priorities and experiences;

  • limited working notes, where I consider them necessary to support the coaching process;

  • information relating to payments, invoices and contractual obligations.

Coaching conversations may involve personal or sensitive information. I do not request sensitive information unless it is relevant to the agreed work. Please share only what you consider appropriate for the coaching process.

2.5. Payments

When you pay for coaching, I may process information such as the amount paid, currency, payment date, transaction reference, invoice details and payment status.

If I use a third-party payment provider, that provider may process payment information under its own privacy terms. I will identify the relevant provider in the applicable payment information once the payment method has been selected.

Where payment is handled by a provider, I do not intend to collect or store full payment card details myself.

2.6. Feedback and Testimonials

If you provide feedback or a testimonial, I may process the text you submit and any associated correspondence.

I will seek separate, explicit permission before publishing an identifiable testimonial. The permission will specify the text approved for publication and the intended channels. Providing feedback does not automatically mean that you agree to its publication.

03

Why I Use Your Personal Data

I use personal data for the following purposes:

  • to respond to enquiries and determine whether coaching is appropriate for your needs;

  • to arrange introductory conversations and coaching sessions;

  • to provide and administer coaching services;

  • to manage the Coaching Agreement, payments and invoicing;

  • to maintain appropriate business, accounting and tax records;

  • to maintain the security and functionality of my website and communications;

  • to understand website usage and improve the site, where relevant analytics tools are enabled and their use is lawful;

  • to publish testimonials where you have provided the required permission;

  • to meet legal obligations and establish, exercise or defend legal claims where necessary.

I do not sell your personal data.

I use personal data for the following purposes:

  • to respond to enquiries and determine whether coaching is appropriate for your needs;

  • to arrange introductory conversations and coaching sessions;

  • to provide and administer coaching services;

  • to manage the Coaching Agreement, payments and invoicing;

  • to maintain appropriate business, accounting and tax records;

  • to maintain the security and functionality of my website and communications;

  • to understand website usage and improve the site, where relevant analytics tools are enabled and their use is lawful;

  • to publish testimonials where you have provided the required permission;

  • to meet legal obligations and establish, exercise or defend legal claims where necessary.

I do not sell your personal data.

04

Legal Bases for Processing

Where the GDPR applies, I rely on the legal basis appropriate to each processing activity:

  • Contract or pre-contractual steps: to respond to requests about coaching, arrange sessions and provide agreed services.

  • Legal obligation: to comply with applicable accounting, tax and other legal requirements.

  • Legitimate interests: where appropriate, to manage my practice, maintain website security, handle routine correspondence and protect legal rights, provided those interests do not override your rights and freedoms.

  • Consent: where required, for certain cookies or tracking technologies, optional marketing communications, publication of testimonials or other activities for which consent is the appropriate legal basis.

Where consent is used as the legal basis, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

If processing involves special categories of personal data under the GDPR, I will rely on an applicable additional legal condition where required.

Where the GDPR applies, I rely on the legal basis appropriate to each processing activity:

  • Contract or pre-contractual steps: to respond to requests about coaching, arrange sessions and provide agreed services.

  • Legal obligation: to comply with applicable accounting, tax and other legal requirements.

  • Legitimate interests: where appropriate, to manage my practice, maintain website security, handle routine correspondence and protect legal rights, provided those interests do not override your rights and freedoms.

  • Consent: where required, for certain cookies or tracking technologies, optional marketing communications, publication of testimonials or other activities for which consent is the appropriate legal basis.

Where consent is used as the legal basis, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

If processing involves special categories of personal data under the GDPR, I will rely on an applicable additional legal condition where required.

05

Confidentiality of Coaching Information

I treat information shared during coaching as confidential in accordance with my Coaching Agreement and applicable law.

I do not publish coaching conversations or identify clients in public materials without appropriate permission.

Confidentiality may be subject to limited exceptions, including where disclosure is required by law or another lawful exception applies.

Where I discuss my professional practice in supervision or professional consultation, I take reasonable steps to protect your identity and confidential information.

The Coaching Agreement provides further information about confidentiality and its limits.

I treat information shared during coaching as confidential in accordance with my Coaching Agreement and applicable law.

I do not publish coaching conversations or identify clients in public materials without appropriate permission.

Confidentiality may be subject to limited exceptions, including where disclosure is required by law or another lawful exception applies.

Where I discuss my professional practice in supervision or professional consultation, I take reasonable steps to protect your identity and confidential information.

The Coaching Agreement provides further information about confidentiality and its limits.

06

Services and Third-Party Providers

To operate my website and provide coaching services, I use or may use the following services:

Framer for website hosting and operation. This service may process technical website data and information submitted through website forms or integrations, where applicable.

Google Forms for enquiries, feedback or other forms. It processes form responses and the contact details requested by the form.

Gmail for email communication. It processes email addresses, message content, attachments and related correspondence.

Google Calendar for appointment booking and scheduling. It processes appointment dates, times, invitees and event details.

Calendly for appointment booking, where used. It processes contact details, booking preferences and appointment information.

Zoom for online coaching sessions, where used. It processes account or meeting details and information processed during online meetings.

Google Meet for online coaching sessions, where used. It processes meeting and participant information and, if enabled, related features such as chat, transcripts or recordings.

WhatsApp for urgent or time-sensitive practical communication. It processes phone numbers, profile information, message content and associated metadata.

A payment provider, once selected, for payment processing. It processes the transaction and payment information required by the provider.

This list describes the services I use or intend to use. The actual data processed depends on the configuration and features enabled in each service.

These providers may process personal data on my behalf or independently for purposes described in their own privacy documentation. Where required by applicable law, I take appropriate steps to establish the necessary contractual and data protection arrangements with providers processing personal data on my behalf.

You can review the relevant providers’ privacy information on their official websites:

Framer: https://www.framer.com/legal/privacy-statement/
Google: https://policies.google.com/privacy
Calendly: https://calendly.com/legal/privacy-notice
Zoom: https://www.zoom.com/en/trust/privacy/
WhatsApp: https://www.whatsapp.com/legal/privacy-policy

The applicable privacy documentation may differ depending on the particular product, account type and service configuration.

To operate my website and provide coaching services, I use or may use the following services:

Framer for website hosting and operation. This service may process technical website data and information submitted through website forms or integrations, where applicable.

Google Forms for enquiries, feedback or other forms. It processes form responses and the contact details requested by the form.

Gmail for email communication. It processes email addresses, message content, attachments and related correspondence.

Google Calendar for appointment booking and scheduling. It processes appointment dates, times, invitees and event details.

Calendly for appointment booking, where used. It processes contact details, booking preferences and appointment information.

Zoom for online coaching sessions, where used. It processes account or meeting details and information processed during online meetings.

Google Meet for online coaching sessions, where used. It processes meeting and participant information and, if enabled, related features such as chat, transcripts or recordings.

WhatsApp for urgent or time-sensitive practical communication. It processes phone numbers, profile information, message content and associated metadata.

A payment provider, once selected, for payment processing. It processes the transaction and payment information required by the provider.

This list describes the services I use or intend to use. The actual data processed depends on the configuration and features enabled in each service.

These providers may process personal data on my behalf or independently for purposes described in their own privacy documentation. Where required by applicable law, I take appropriate steps to establish the necessary contractual and data protection arrangements with providers processing personal data on my behalf.

You can review the relevant providers’ privacy information on their official websites:

Framer: https://www.framer.com/legal/privacy-statement/
Google: https://policies.google.com/privacy
Calendly: https://calendly.com/legal/privacy-notice
Zoom: https://www.zoom.com/en/trust/privacy/
WhatsApp: https://www.whatsapp.com/legal/privacy-policy

The applicable privacy documentation may differ depending on the particular product, account type and service configuration.

07

Online Sessions, Recording and AI Tools

Coaching sessions are conducted online using Zoom or Google Meet, as agreed.

I do not routinely record or transcribe coaching sessions. I will not record or transcribe a session, or use AI tools to record or transcribe it, without appropriate prior disclosure and consent or another lawful basis where applicable.

Some platforms offer features involving AI assistance, transcription, summaries or meeting notes. I will not assume that these features may be used for coaching sessions simply because they are available in the platform.

If I propose to use a tool that processes identifiable client information, I will assess its purpose, privacy implications and applicable legal requirements before using it.

Please do not send highly sensitive information through ordinary messaging channels unless it is necessary and you understand the relevant privacy considerations.

Coaching sessions are conducted online using Zoom or Google Meet, as agreed.

I do not routinely record or transcribe coaching sessions. I will not record or transcribe a session, or use AI tools to record or transcribe it, without appropriate prior disclosure and consent or another lawful basis where applicable.

Some platforms offer features involving AI assistance, transcription, summaries or meeting notes. I will not assume that these features may be used for coaching sessions simply because they are available in the platform.

If I propose to use a tool that processes identifiable client information, I will assess its purpose, privacy implications and applicable legal requirements before using it.

Please do not send highly sensitive information through ordinary messaging channels unless it is necessary and you understand the relevant privacy considerations.

08

WhatsApp and Email Communication

Email is the primary channel for administrative communication relating to coaching, including scheduling and contractual matters.

WhatsApp may be used for urgent or time-sensitive practical messages, such as notifying me of a delay or an immediate scheduling issue.

WhatsApp is not an emergency service, a crisis-support channel or a substitute for appropriate professional assistance.

Please avoid sharing detailed sensitive personal information through WhatsApp or ordinary email unless necessary. Information transmitted through these services may be processed by the relevant provider according to its own privacy practices.

Email is the primary channel for administrative communication relating to coaching, including scheduling and contractual matters.

WhatsApp may be used for urgent or time-sensitive practical messages, such as notifying me of a delay or an immediate scheduling issue.

WhatsApp is not an emergency service, a crisis-support channel or a substitute for appropriate professional assistance.

Please avoid sharing detailed sensitive personal information through WhatsApp or ordinary email unless necessary. Information transmitted through these services may be processed by the relevant provider according to its own privacy practices.

09

Cookies and Website Analytics

My website is hosted on Framer. The website may use essential technical technologies and, depending on its configuration, analytics, embedded content or third-party scripts.

Framer's built-in analytics and third-party tracking technologies may operate differently. The use of Google Analytics, advertising pixels, embedded videos or other third-party services may introduce additional data collection and cookie requirements.

Where applicable law requires consent for non-essential cookies or similar technologies, I will obtain that consent before enabling them. You should be able to manage your preferences through the cookie settings provided on the website, where such a mechanism is required.

The actual cookies, providers, purposes and retention periods depend on the technologies enabled on the published website. This information will be reviewed against the website's actual configuration.

You can also manage cookies through your browser settings. Disabling certain cookies may affect website functionality.

My website is hosted on Framer. The website may use essential technical technologies and, depending on its configuration, analytics, embedded content or third-party scripts.

Framer's built-in analytics and third-party tracking technologies may operate differently. The use of Google Analytics, advertising pixels, embedded videos or other third-party services may introduce additional data collection and cookie requirements.

Where applicable law requires consent for non-essential cookies or similar technologies, I will obtain that consent before enabling them. You should be able to manage your preferences through the cookie settings provided on the website, where such a mechanism is required.

The actual cookies, providers, purposes and retention periods depend on the technologies enabled on the published website. This information will be reviewed against the website's actual configuration.

You can also manage cookies through your browser settings. Disabling certain cookies may affect website functionality.

10

International Data Transfers

Where the GDPR applies and personal data is transferred outside the European Economic Area, I will ensure that the transfer complies with applicable requirements. Depending on the circumstances, this may involve an adequacy decision, appropriate safeguards such as Standard Contractual Clauses, or another lawful transfer mechanism.

The actual countries and safeguards involved depend on the services and account configurations used.

Where the GDPR applies and personal data is transferred outside the European Economic Area, I will ensure that the transfer complies with applicable requirements. Depending on the circumstances, this may involve an adequacy decision, appropriate safeguards such as Standard Contractual Clauses, or another lawful transfer mechanism.

The actual countries and safeguards involved depend on the services and account configurations used.

11

How Long I Retain Personal Data

I retain personal data only for as long as reasonably necessary for the purposes described in this Policy, taking into account applicable legal obligations.

The relevant period depends on the type of information:

  • Enquiries that do not lead to coaching: for a limited period necessary to respond, manage follow-up and maintain appropriate business records.

  • Client and contractual records: for the duration of the engagement and any additional period reasonably necessary to manage contractual matters or legal claims.

  • Financial and accounting records: for the period required by applicable law.

  • Coaching notes and related correspondence: for the period necessary for the agreed coaching purpose and any applicable professional or legal obligations.

  • Technical logs: for the period necessary for security, troubleshooting and website administration.

  • Testimonials and permissions: while the testimonial is in use and for a reasonable period afterwards to document the permission and manage any withdrawal request.

I will establish and apply appropriate retention periods for each category of information. When personal data is no longer required, I will delete it, anonymise it or otherwise dispose of it securely unless retention is required by law.

I retain personal data only for as long as reasonably necessary for the purposes described in this Policy, taking into account applicable legal obligations.

The relevant period depends on the type of information:

  • Enquiries that do not lead to coaching: for a limited period necessary to respond, manage follow-up and maintain appropriate business records.

  • Client and contractual records: for the duration of the engagement and any additional period reasonably necessary to manage contractual matters or legal claims.

  • Financial and accounting records: for the period required by applicable law.

  • Coaching notes and related correspondence: for the period necessary for the agreed coaching purpose and any applicable professional or legal obligations.

  • Technical logs: for the period necessary for security, troubleshooting and website administration.

  • Testimonials and permissions: while the testimonial is in use and for a reasonable period afterwards to document the permission and manage any withdrawal request.

I will establish and apply appropriate retention periods for each category of information. When personal data is no longer required, I will delete it, anonymise it or otherwise dispose of it securely unless retention is required by law.

12

Data Security

I take reasonable technical and organisational measures to protect personal data against unauthorised access, accidental loss, alteration, disclosure or destruction.

These measures may include access restrictions, account security, device protection, secure service providers and appropriate handling of client records.

No method of electronic transmission or storage can be guaranteed to be completely secure. I take reasonable steps to reduce risks and respond to potential security incidents in accordance with applicable law.

I take reasonable technical and organisational measures to protect personal data against unauthorised access, accidental loss, alteration, disclosure or destruction.

These measures may include access restrictions, account security, device protection, secure service providers and appropriate handling of client records.

No method of electronic transmission or storage can be guaranteed to be completely secure. I take reasonable steps to reduce risks and respond to potential security incidents in accordance with applicable law.

13

Your Data Protection Rights

Depending on applicable law and the circumstances of the processing, you may have the right to:

  • request access to your personal data;

  • request correction of inaccurate or incomplete information;

  • request deletion of your personal data;

  • request restriction of processing;

  • object to processing based on legitimate interests;

  • request a portable copy of certain personal data;

  • withdraw consent where processing is based on consent;

  • lodge a complaint with a competent data protection authority.

These rights are subject to applicable legal conditions and exceptions. For example, I may need to retain certain records to comply with legal obligations even if you request deletion.

To exercise your rights or ask a question about your personal data, contact me at klochkocoach@gmail.com. I may need to verify your identity before responding.

I will respond within the period required by applicable law.

Depending on applicable law and the circumstances of the processing, you may have the right to:

  • request access to your personal data;

  • request correction of inaccurate or incomplete information;

  • request deletion of your personal data;

  • request restriction of processing;

  • object to processing based on legitimate interests;

  • request a portable copy of certain personal data;

  • withdraw consent where processing is based on consent;

  • lodge a complaint with a competent data protection authority.

These rights are subject to applicable legal conditions and exceptions. For example, I may need to retain certain records to comply with legal obligations even if you request deletion.

To exercise your rights or ask a question about your personal data, contact me at klochkocoach@gmail.com. I may need to verify your identity before responding.

I will respond within the period required by applicable law.

14

Complaints

If you have concerns about how I process your personal data, please contact me at klochkocoach@gmail.com.

Where the GDPR applies, you may also have the right to lodge a complaint with a data protection supervisory authority in your country of habitual residence, place of work or the place of the alleged infringement.

If you have concerns about how I process your personal data, please contact me at klochkocoach@gmail.com.

Where the GDPR applies, you may also have the right to lodge a complaint with a data protection supervisory authority in your country of habitual residence, place of work or the place of the alleged infringement.

15

Children's Privacy

My coaching services are intended for adults. I do not knowingly collect personal data from children in connection with services intended for adults.

If you believe that a child has provided personal data to me inappropriately, please contact me so that I can assess the situation and take appropriate action.

My coaching services are intended for adults. I do not knowingly collect personal data from children in connection with services intended for adults.

If you believe that a child has provided personal data to me inappropriately, please contact me so that I can assess the situation and take appropriate action.

16

Changes to This Privacy Policy

I may update this Privacy Policy to reflect changes in my services, website technology, data processing practices or applicable legal requirements.

The latest version will be published on this website with its revision date. Where required by law, I will provide additional information or seek consent before introducing a new use of personal data.

I may update this Privacy Policy to reflect changes in my services, website technology, data processing practices or applicable legal requirements.

The latest version will be published on this website with its revision date. Where required by law, I will provide additional information or seek consent before introducing a new use of personal data.

17

Contact

For questions, requests or concerns about this Privacy Policy or the processing of your personal data, please contact:

Iryna Klochko
Email: klochkocoach@gmail.com
Business address: 15 Instytutska Street, Khmelnytskyi, Ukraine, 29016
Website: [Website URL]

For questions, requests or concerns about this Privacy Policy or the processing of your personal data, please contact:

Iryna Klochko
Email: klochkocoach@gmail.com
Business address: 15 Instytutska Street, Khmelnytskyi, Ukraine, 29016
Website: [Website URL]

Strategic Thinking Partner for Life & Career Transitions

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© 2026 Iryna Klochko. All rights reserved.

Strategic Thinking Partner for Life & Career Transitions

pcc icf coach

© 2026 Iryna Klochko. All rights reserved.

Strategic Thinking Partner for Life & Career Transitions

pcc icf coach

© 2026 Iryna Klochko. All rights reserved.

Strategic Thinking Partner for Life & Career Transitions

pcc icf coach

© 2026 Iryna Klochko. All rights reserved.