Legal
Privacy Policy

1. Who is responsible

("NewCOACH.ES", "we") is the controller for the personal data described in this policy. Contact for privacy questions: hello@smrt.bio

The SMRT.BIO platform is operated by SMRT.BIO Global B.V., Mierloseweg 134, 5707 AS Helmond, Netherlands. When we use the platform to deliver NewCOACH.ES services, SMRT.BIO processes data on our behalf under a data processing agreement. For personal SMRT.BIO accounts that exist independently of NewCOACH.ES, SMRT.BIO is the controller and its own privacy policy applies (SMRT.BIO Privacy Policy).

2. Whose data we process

  • Coaches: people who enrol in or hold a NewCOACH certification.
  • Coachees: people supported by a NewCOACH on SMRT.BIO.
  • Licence customers: organisations and their contact persons and employees.
  • Website visitors and people who contact us.

3. What we collect, why, and on what legal basis

  • Coaches
    • Data: Name, contact details, country, organisation, payment and invoice data
    • Purpose: Enrolment, payment, invoicing, applying the country-tier price
    • Legal basis (GDPR): Contract (6(1)(b)); legal obligation for invoices (6(1)(c))
  • Coaches
    • Data: Training attendance, portfolio, pitch recording , assessment scores and feedback
    • Purpose: Running and assessing the certification
    • Legal basis (GDPR): Contract
  • Coaches
    • Data: Directory profile: name, photo, coach type, city, organisation, specialisms, profile link
    • Purpose: Publishing the coach directory
    • Legal basis (GDPR): Contract; you control what is shown
  • Coaches
    • Data: Licence sales linked to you, commission statements, bank details
    • Purpose: Paying commission
    • Legal basis (GDPR): Contract; legal obligation
  • Coachees
    • Data: Account data; Passion, Strength and Skill test results; job profiles; Business Model Canvas; business plan; financing application
    • Purpose: Providing the coaching tools; letting the coach see what the coachee chooses to share
    • Legal basis (GDPR): Contract with the coachee (6(1)(b)); consent for sharing with a coach (6(1)(a))
  • Licence customers
    • Data: Organisation details, admin contacts, list of employees with a licence
    • Purpose: Providing and billing licences
    • Legal basis (GDPR): Contract; legitimate interest in managing the account (6(1)(f))
  • Everyone
    • Data: Messages, support requests, complaints
    • Purpose: Answering you
    • Legal basis (GDPR): Legitimate interest; contract
  • Website visitors
    • Data: IP address, device and browser data, cookie data
    • Purpose: Security, essential site functions,
    • Legal basis (GDPR): Legitimate interest; consent for non-essential cookies
  • Everyone
    • Data: Email address
    • Purpose: Newsletters and updates about NewCOACH.ES
    • Legal basis (GDPR): Consent; existing customers: legitimate interest, with an opt-out in every message

We do not ask for special categories of personal data (such as health, religion or ethnic origin). Please do not enter such data in free-text fields. Test results describe interests, strengths and skills; they are not psychological diagnoses.

4. How coachee data is shared with a coach

A coach sees a coachee's data only after the coachee has linked to that coach, and only the parts the coachee has chosen to share in their SMRT.BIO sharing settings. The coachee can change or withdraw this at any time, after which the coach no longer has access. Coaches are bound by our Terms and Code of Conduct to use this data only for coaching that person.

5. Automated assessments

SMRT.BIO calculates test profiles and suggests matching jobs and courses automatically. These are suggestions to support a decision that the coachee makes, with their coach. We do not make decisions based solely on automated processing that have legal or similarly significant effects on you. Financing decisions are taken by the financing parties, not by us.

6. Who receives your data

  • SMRT.BIO Global B.V., as platform provider (processor).

  • Hosting and IT providers: [● name, location].

  • Payment provider: Mollie, which processes card and bank data under its own responsibility.

  • Your coach, only as described in section 4.

  • Financing parties, only when you submit an application through the Apply for Financing module, and only the data in that application.

  • Accountants, auditors and legal advisers, where needed.

  • Authorities, where the law requires it.

We do not sell personal data.

7. Transfers outside the EEA

The SMRT.BIO group has companies in South Africa and Pakistan, and coaches and coachees may be based outside the EEA. Where personal data is transferred to a country without an EU adequacy decision, we use the European Commission's Standard Contractual Clauses and additional safeguards where needed. You can request a copy via hello@smrt.bio. When a coach outside the EEA views data a coachee has chosen to share with them, that transfer happens at the coachee's request.

8. How long we keep data

  • Coach account, directory profile
    • Retention: While the certification is valid, plus 12 months (so you can renew); then deleted or anonymised. The directory listing is removed when certification ends.
  • Assessment results and certificates
    • Retention: 5 years after the certification ends, so the certification can be verified.
  • Invoices, payment and commission records
    • Retention: 7 years (Dutch tax law).
  • Coachee data held on the platform
    • Retention: While the coachee's account exists. Coachees can delete their account at any time.
  • Support messages and complaints
    • Retention: 2 years after the case is closed.
  • Marketing consent
    • Retention: Until you withdraw it.

9. Security

We and SMRT.BIO use technical and organisational measures appropriate to the risk, including encrypted connections, access controls based on role, logging, and confidentiality obligations for staff and trainers. If a personal data breach is likely to cause you a high risk, we will tell you without undue delay.

10. Your rights

You have the right to access your data, to have it corrected or deleted, to restrict or object to processing, to data portability, and to withdraw consent at any time (without affecting processing before withdrawal). Send your request to hello@smrt.bio. We respond within one month; we may ask you to confirm your identity.

You can also complain to a data protection authority, in particular in the EU country where you live or work. In the Netherlands this is the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl); in Spain the Agencia Española de Protección de Datos (aepd.es).

11. Children

Our services are intended for people aged 16 and over. Where an educational institution uses SMRT.BIO with younger pupils, the institution is responsible for obtaining parental consent.

12. Changes

We may update this policy. The date at the top shows the current version. We will notify account holders of material changes by email.