Excellera Legal

Privacy Policy

Version: 20 October 2026

This policy explains what personal data Excellera holds, why we hold it and what you can ask us to do about it. It covers visitors to this website, people who contact us or book a Discovery Call, professionals coached inside an Excellera programme, the sponsors and coordinators we work with, and people quoted on this website.

1. Who we are

Excellera provides the People Development Programme: coaching beyond the executive suite, with organisational insight. It is operated by Filipe Teixeira from Groningen, the Netherlands. For the processing described here we are the controller, unless a section below says otherwise.

  • Excellera is the name under which Filipe Teixeira works as an independent professional in the Netherlands. In November 2026 it will be registered with the Netherlands Chamber of Commerce (KvK) as a sole trader (eenmanszaak). The registration details will then be published here and this policy reissued.
  • For any question about this policy, or to exercise the rights in section 8, write to us at the address at the bottom of this page.

2. Visitors to this website

This website does not track you.

  • There are no analytics, no advertising tags and no tracking scripts anywhere on the site.
  • The only form on the site is the contact form, described in section 3. Every other contact route is an email link, a phone link, a WhatsApp link or the external booking page.
  • No cookies are set for analytics or marketing.
  • Our hosting provider processes technical request data, such as your IP address and browser type, for the ordinary purpose of serving the site and keeping it secure.
  • Some pages link to other sites, such as our LinkedIn page. Those sites have their own privacy policies.

3. Contacting us and booking a Discovery Call

You can write to us through the contact form on this website, or book a call on our booking page. The booking page is a Microsoft Bookings page, not part of this website, and the details you enter there reach us through that service.

  • If you use the contact form, we receive your name, your work email address, your organisation if you give it, your message and the language of the page you sent it from. The message is emailed to our inbox and is not stored on this website.
  • If you book a call, we receive your name, your email address and anything you write in the booking form.
  • We use these details to answer you, to hold the conversation and to follow up on it.
  • Our lawful basis is our legitimate interest in responding to an enquiry about our services, and, where you are acting for an organisation considering an engagement, the steps taken at your request before entering a contract.
  • If the enquiry does not become an engagement, we delete the record no later than twelve months after our last contact with you.
  • If your enquiry comes from an organisation, we handle it as described in section 4A.

4. If you are coached in a programme

Your employer decides that you take part. We decide how the coaching itself is run. Which of us is responsible for a given activity is assessed for each activity, and where we act on your employer's behalf we do so under a data processing agreement with them.

What we hold

Your name and work contact details, your attendance, the goals you set, your answers to any forms, your input on the programme's business indicator (collected before coaching starts, after it ends and six months later), and the notes we make to prepare for and follow up on sessions.

Why we process it

Our lawful basis is our legitimate interest, shared with your employer, in delivering the programme your employer has commissioned. We do not rely on your consent for the coaching itself, because your employer arranges your participation.

We do not ask about your health, religion, politics or other sensitive matters. If you choose to raise them, we keep them confidential and never include them in a report.

Confidential

What you say in a session is not passed to your employer in a form that identifies you. Sessions may be transcribed so that coaching notes can be prepared. Transcripts stay inside our own controlled environment. The limits to confidentiality are the ordinary ones: a serious risk to someone's safety, or a legal obligation to disclose.

Anonymised

Where we use an AI service to summarise coaching material, we first remove identifying details by automated de-identification. A person then checks the result for any remaining risk of re-identification, and only anonymised material is sent. We never send an identifiable transcript to an AI service. Preparing anonymised material from your data is itself processing, and the protections in this section apply while we do it.

Aggregated

Your sponsor receives your attendance and participation status by name, for programme administration only. It also receives a monthly Status Report and an end-of-programme Organisational Insights Report, both at group level.

In those reports:

  • we report only groups of at least five participants, and a theme appears only if it arises in the coaching of at least three participants;
  • we do not break results down by function, site, level or tenure unless each resulting group is large enough that no individual can be singled out;
  • we include no direct quotation unless it is relevant, anonymised and you have approved it in advance;
  • if fewer than five people take part, we report only participation and programme-level observations.

Our agreement with your employer does not allow it to try to identify participants, or to use coaching content, reports or insights for decisions about you, including performance evaluation, promotion, compensation, disciplinary action, redundancy selection or dismissal.

4A. If you are a sponsor or coordinator at an organisation

If you act for an organisation that is considering or running a programme with us, we hold your name, work contact details, role, and the correspondence, proposals, contracts and invoices that follow. We use them to prepare and run the programme, to report to you and to keep our business records. Our lawful basis is the steps taken at your request before entering a contract, performing the contract with your organisation, and our legitimate interest in running that relationship. We keep this information for the periods in section 7.

4B. If you are quoted on this website

With your permission, we publish a testimonial together with your name, your role, the sector you work in and where you are based. Our lawful basis is your consent. You can withdraw it at any time by writing to us, and we will remove the testimonial from the website within ten working days. Withdrawing does not affect anything published before you withdrew. We keep a record of your permission for as long as the testimonial is published.

5. Who processes data for us

We use a small number of established providers to run the practice. They act on our instructions.

  • Microsoft 365, including Teams (with its recordings and transcripts), Outlook, OneDrive, Bookings and Forms, for sessions, correspondence, scheduling and storage.
  • WhatsApp Business, if you choose to contact us that way.
  • Our website hosting provider, for serving this site.
  • Resend, an email delivery service, for sending messages from the contact form to our inbox.
  • An AI service, for summarising coaching material that has been de-identified as described in section 4.
  • We do not sell personal data, and we do not share it for advertising.

6. Where your data is held

We use providers that offer processing within the European Economic Area where that option is available. Where a provider transfers personal data outside the EEA, that transfer relies on a lawful transfer mechanism, such as the European Commission's standard contractual clauses.

7. How long we keep it

We keep personal data only for as long as it is needed for the purpose it was collected for.

  • Programme data, such as coaching notes, transcripts, form responses and business indicator tracking information: one year after the programme ends, unless a longer period is needed to establish or defend a legal claim.
  • Anonymised reports, such as monthly reports and the Organisational Insights Report: kept as business records and for the client relationship, with no set retention period.
  • Sponsor and coordinator records: for the length of the relationship. After it ends, contracts and invoices are kept as financial and administrative records (next item) and the rest is deleted within twelve months.
  • Financial and administrative records: seven years, the retention period required of businesses under Dutch law.
  • Enquiries that do not become an engagement: no longer than twelve months after our last contact.
  • Testimonials: for as long as they are published. The record of your permission is kept for the same period.

8. Your rights

You can ask us for a copy of the personal data we hold about you, ask us to correct it or delete it, ask us to restrict how we use it, object to processing we base on legitimate interest, and ask to receive it in a portable form.

  • Write to us and we will respond within one month.
  • Where we hold the data on your employer's behalf, we will pass your request to them or handle it together with them, and we will tell you which.
  • Where we rely on your consent, for example to publish a testimonial, you can withdraw it at any time.
  • If you are not satisfied with how we handle it, you can complain to the Dutch supervisory authority, the Autoriteit Persoonsgegevens, at autoriteitpersoonsgegevens.nl.

9. Changes to this policy

We update this policy when the way we work changes. The version date at the top of this page tells you which version you are reading. If we make a material change that affects people in a running programme, we will tell their sponsor so that participants can be informed.

Questions about this policy

Write to us and we will answer.

filipe.teixeira@excelleracoaching.com