How we handle your data

1. Who we are

De Adempauze is a sole proprietorship of Sjoerd Righolt, based in Zandvoort, the Netherlands.

• Chamber of Commerce (KVK): 42030226
• VAT: NL005443419B25
• Email: sjoerd@deadempauze.nl

2. What data we collect

We only process data you provide to us yourself:

• Name and first name
• Phone number (for guidance via WhatsApp)
• Email address
• Payment information (via Mollie, see section 6)
• Content of messages you send via WhatsApp or the contact form

3. What we use your data for

Your data is used exclusively for:

• Providing the coaching via WhatsApp (daily guidance)
• Handling payments
• Answering questions via the contact form or email
• Scheduling appointments you book through this site

We never use your data for marketing purposes without explicit consent and never sell it to third parties.

4. Ada: AI coaching via WhatsApp

The daily coaching is provided by Ada, an AI assistant that uses technology from Anthropic (Claude). Ada processes your messages to offer personal guidance based on your goal, notes and conversation history. As breath coach, Sjoerd Righolt supervises the system and is always present in the background. You never chat with a computer alone. Ada only speaks Dutch for now, but will be speaking English soon.

By taking part in the coaching programme, you consent to the processing of health-related information you share yourself (such as sleep, stress or breathing) via these AI systems.

5. Legal basis for processing

We process ordinary personal data on the basis of performance of the contract (Art. 6(1)(b) GDPR). For health-related information you share yourself during the coaching, we rely on your explicit consent (Art. 9(2)(a) GDPR).

6. Third parties (processors)

To deliver our service we use the parties below. They only process your data for that purpose.

• Meta (WhatsApp Business API): sending and receiving coaching messages. Based in the US (Standard Contractual Clauses).
• Anthropic: processing messages for AI coaching via Ada (Claude). Your messages are processed to generate a reply and are not used for other purposes. Based in the US (Standard Contractual Clauses).
• Notion: storage of your coaching file (name, goal, weekly plan, conversation notes). Based in the US (Standard Contractual Clauses).
• Hostinger: hosting of the server our automation runs on (routing messages, creating weekly plans). The server is in Germany, the backups in Lithuania (both EU).
• Mollie: payment processing. PCI-DSS certified, based in the Netherlands.
• Google (Google Calendar and Google Meet): an appointment you book through this site goes into my calendar with your name, phone number and email address; online appointments take place via Google Meet. Based in the US (EU-US Data Privacy Framework).
• mijn.host: hosting of this website and of the list of booked appointments. Based in the Netherlands.
• Moneybird: invoices and receipts. Based in the Netherlands.
• GitHub (Microsoft): private version control of our internal working documents, in which your name and the progress of your programme may be mentioned. The storage is not public and only accessible to De Adempauze. Based in the US (Standard Contractual Clauses).

7. Retention period

We do not keep your data longer than necessary to deliver the coaching. After the programme ends, personal data is deleted within 12 months, unless a statutory retention obligation applies (such as for financial records: 7 years).

8. Your rights

You have the right to:

• Request access to the data we process about you
• Have incorrect data corrected
• Have your data deleted
• Object to the processing

To do so, send an email to sjoerd@deadempauze.nl. We respond within 30 days. With an access request you receive an overview of all data we have stored about you, including which processors have processed your data.

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) via autoriteitpersoonsgegevens.nl.

9. Contact

For questions about this privacy policy, you can contact us at sjoerd@deadempauze.nl.