Privacy Policy

1. Who we are

Excellera provides leadership development through coaching, and is operated by Filipe Teixeira from Groningen, the Netherlands. For the processing described here we are the controller, unless a section below says otherwise.

• A Dutch company is being incorporated. Registration details will be published here once that is complete, and this policy will be reissued in the name of that entity.
• 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.
• There are no contact forms. Every contact route on the site 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.

3. Booking a Discovery Call

The booking page is a Microsoft Bookings page, not part of this website. When you book, the details you enter reach us through that service.

• We receive your name, your email address and anything you write in the booking form, and we use it 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.

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 activity by activity, and where we act on your employer's behalf we do so under a data processing agreement with them.

• We hold your name and work contact details, your attendance, the goals you set, and the notes we make to prepare for and follow up on sessions.
• Your sponsor receives programme-level reporting only, using anonymised insights and factual measures such as attendance. 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.
• Where we use an AI service to summarise coaching material, identifying details are removed first by automated de-identification, and a person then checks the result for any remaining risk of re-identification before anything is sent. We do not knowingly send an identifiable transcript to an AI service.
• Coaching content is confidential. The limits are the ordinary ones: a serious risk to someone's safety, or a legal obligation to disclose.

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, 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.
• 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: as a general approach, one year after the programme ends, unless a longer period is needed to establish or defend a legal claim.
• Financial and administrative records: 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.

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.
• 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.