Last updated: 07.07.2026
Purposeful Pathways Coaching — Privacy Policy
1. Who We Are
Nicole Gupta, trading as “Purposeful Pathways Coaching” (“we”, “us”, “our”) is a coaching practice established in Portugal, operating the website https://purposefulpathwayscoaching.com/ (the “Website”). Nicole Gupta, as the individual operating this business, is the data controller responsible for the personal data described in this Privacy Policy.
Contact details:
- Controller: Nicole Gupta, trading as Purposeful Pathways Coaching
- Website: https://purposefulpathwayscoaching.com/
- Address: Figueiró dos Vinhos, Portugal
- Email: nicolegupta.coaching@gmail.com
- Data protection contact: Nicole Gupta, nicolegupta.coaching@gmail.com
If you are located in the EU, EEA, or UK, you have the right to lodge a complaint with a supervisory authority. In Portugal, this is the Comissão Nacional de Proteção de Dados (CNPD), www.cnpd.pt. UK residents may also contact the Information Commissioner’s Office (ICO), www.ico.org.uk.
2. Scope of This Policy
This Policy applies to personal data we collect through the Website, through email or phone correspondence, through video coaching sessions, and through the coaching and contracting relationship, from:
- Visitors browsing the Website
- Newsletter subscribers
- People who contact us through a form, email, or phone
- People who book or attend a coaching session or discovery call
- Clients under a signed coaching agreement
We primarily serve clients in the European Union and United Kingdom, and also accept clients located elsewhere, including the United States. Where local law provides additional or different rights, we honour those rights for the relevant individuals.
3. What Personal Data We Collect
3.1 Data you provide directly
- Name, email address, phone number
- Messages you send via contact forms or email
- Newsletter sign-up details (name, email address)
- Booking details (appointment time, session topic if provided)
- Information shared during coaching sessions, discovery calls, or in your coaching agreement, which may include details about your career, health, wellbeing, or personal circumstances
- Payment and billing details necessary to invoice you (processed via Stripe or banks)
3.2 Data collected automatically
- IP address, browser type, device and operating system
- Pages visited, time on page, click and scroll behaviour, referring website
- Cookies and similar tracking identifiers (see our separate Cookie Policy)
3.3 Special category data
Coaching conversations may occasionally touch on health, mental health, or other sensitive topics. We only process such special category data where you have voluntarily shared it and, where required by law, with your explicit consent. We do not seek out or require special category data to provide coaching services.
4. How and Why We Use Your Data
| Purpose | Data used | Legal basis (GDPR) |
|---|---|---|
| Respond to enquiries sent via contact form or email | Name, email, message content | Consent / steps prior to entering a contract (Art. 6(1)(b)/(a)) |
| Send the newsletter | Name, email address | Consent (Art. 6(1)(a)) — withdrawable at any time |
| Schedule and conduct coaching sessions or discovery calls | Name, email, booking details, session content | Performance of a contract (Art. 6(1)(b)) |
| Deliver coaching services and manage the client relationship | Contract details, session notes, payment info | Performance of a contract (Art. 6(1)(b)) |
| Send relevant offers to existing clients | Name, email, service history | Legitimate interest (Art. 6(1)(f)) — soft opt-in, with opt-out on every email |
| Website analytics and performance improvement | Usage data via Google Analytics, Microsoft Clarity | Consent (Art. 6(1)(a)) via cookie banner |
| Advertising measurement | Usage/interaction data via Meta Pixel | Consent (Art. 6(1)(a)) via cookie banner |
| Recording sessions for ICF training / mentor coaching / certification | Audio recording and transcript of the session | Explicit, separate consent (Art. 9(2)(a) where special category data is involved) |
| Accounting, invoicing, and legal compliance | Contract, invoice, and billing records | Legal obligation (Art. 6(1)(c)) |
We do not sell your personal data. We do not use your data for any purpose incompatible with those listed above without asking for your consent first.
5. Cookies and Tracking Tools
The Website uses the following third-party tools, which may place cookies or similar technologies on your device and transmit data to the tool provider:
| Tool | Provider | Purpose | Data shared |
|---|---|---|---|
| Meta Pixel | Meta Platforms, Inc. (USA) | Ad measurement and targeting | IP address, device data, pages visited, on-site actions |
| Google Analytics | Google LLC (USA) | Website traffic and usage analytics | IP address (may be truncated), device data, browsing behaviour |
| Microsoft Clarity | Microsoft Corporation (USA) | Session recording, heatmaps, UX analysis | Click/scroll behaviour, device data; form field inputs are masked by default |
Meta, in particular, acts as a joint controller (not merely a processor) for certain data collected via the Pixel, and independently determines how it uses that data for its own advertising purposes, in addition to providing measurement data to us. Full details of cookies used, their duration, and how to manage your preferences are set out in our separate Cookie Policy.
These tools only load after you have given consent via our cookie banner, where required by applicable law.
6. Other Service Providers (Processors) We Use
We share personal data with the following processors, each acting under our instructions and, where required, a Data Processing Agreement (DPA):
| Service | Provider | Purpose | Location / transfer safeguard |
|---|---|---|---|
| MailerLite | MailerLite Limited | Newsletter sending and subscriber management | EU-based provider; DPA in place |
| Zoom | Zoom Video Communications, Inc. (USA) | Video coaching sessions, scheduling, recordings | EU-US Data Privacy Framework / SCCs; DPA in place |
| Gmail / Google Workspace | Google LLC (USA) | Email correspondence | EU-US Data Privacy Framework / SCCs; DPA in place |
| Local device / drive storage | N/A (stored by us directly) | Storage of signed contracts and client records | Portugal; access-controlled, encrypted, regularly backed up |
We only work with processors who provide sufficient guarantees to protect your data and who are contractually bound to use it solely for the purposes we specify.
7. International Data Transfers
Some of the providers listed above are based in, or transfer data to, the United States. Where this occurs, we rely on one or more of the following safeguards:
- The provider’s certification under the EU-US Data Privacy Framework (DPF), where applicable
- European Commission-approved Standard Contractual Clauses (SCCs)
- Other adequacy mechanisms recognised under GDPR / UK GDPR
You may request further information about the specific safeguard used for a given transfer by contacting us using the details in Section 1.
8. Session Recordings for ICF Training and Certification
As part of maintaining or pursuing International Coaching Federation (ICF) credentials, we may record the audio (and generate a transcript) of a coaching session for mentor coaching, supervision, or credentialing review.
- This is a distinct purpose from general service delivery, marketing, or analytics, and requires your separate, explicit, opt-in consent before any recording begins.
- Recordings and transcripts may be shared only with the specific ICF-recognised mentor coach, assessor, or supervisor involved in the review, under confidentiality obligations.
- Recordings are retained only as long as necessary for the relevant training or credentialing cycle, and are deleted securely afterwards (see retention table in Section 9).
- You may decline to be recorded, or withdraw consent before a session starts, without any effect on the coaching service itself.
- Where a recording touches on special category data (e.g. health information you choose to share), we treat your consent to recording as also covering that data, and you may ask us to pause or exclude specific topics from recording at any time.
9. How Long We Keep Your Data
| Data category | Retention period |
|---|---|
| Newsletter subscriber data | Until you unsubscribe, plus up to 30 days to process the request |
| Contact form / enquiry data that does not become a client relationship | Up to 12 months from last contact, then deleted |
| Client coaching agreements, contracts, and invoices | 10 years, as required under Portuguese commercial and tax law |
| Session notes and client records (non-financial) | Duration of the coaching relationship plus 5 years, unless you request earlier deletion and no legal obligation requires retention |
| ICF training/certification recordings and transcripts | Only for the duration of the relevant training or credentialing cycle, then securely deleted |
| Website analytics data (Google Analytics, Clarity) | As configured in each tool, typically 14–26 months, per that tool’s default or configured retention setting |
| Meta Pixel data | Retained by Meta per its own data policy; not separately stored by us |
After the applicable period, data is securely deleted or anonymised, unless a longer period is required by law or necessary to establish, exercise, or defend legal claims.
10. Data Security
We take reasonable technical and organisational measures to protect your personal data, including:
- Access to client files and recordings limited to Nicole Gupta, trading as Purposeful Pathways Coaching.
- Encryption of locally stored files and password protection of devices
- Regular backups
- Use of reputable service providers with their own security safeguards and, where applicable, data processing agreements
No method of transmission or storage is completely secure. If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the CNPD within 72 hours where legally required, and will notify affected individuals without undue delay where the breach is likely to result in a high risk to them.
11. Your Rights
Under the GDPR (and, where applicable, UK GDPR), you have the right to:
- Access the personal data we hold about you
- Correct inaccurate or incomplete data
- Request erasure of your data (“right to be forgotten”), subject to legal retention obligations
- Restrict or object to certain processing, including direct marketing at any time
- Request a portable copy of data you provided to us
- Withdraw consent at any time, without affecting the lawfulness of processing before withdrawal
- Lodge a complaint with the CNPD (Portugal), the ICO (UK), or your local supervisory authority
To exercise any of these rights, contact Nicole Gupta at nicolegupta.coaching@gmail.com. We will respond within one month, as required by GDPR.
12. Marketing and Newsletters
We only send newsletter marketing to people who have actively opted in. If you become a client, we may send you information about related services and offers based on our legitimate interest in maintaining that relationship, and every such email includes an easy way to opt out. You can unsubscribe from any marketing email at any time using the link provided, or by contacting us directly.
13. Children’s Data
Our services are directed at adults. We do not knowingly collect personal data from individuals under the age of 18. If you believe a minor has provided us with personal data, please contact us so we can delete it.
14. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, tools, or legal requirements. The “Last updated” date at the top of this page indicates when it was last revised. Material changes will be highlighted on the Website or communicated directly where appropriate.
15. Contact Us
If you have questions about this Privacy Policy or how we handle your personal data, please contact:
- Nicole Gupta, trading as Purposeful Pathways Coaching
- Website: https://purposefulpathwayscoaching.com/
- Figueiró dos Vinhos, Portugal
- Email: nicolegupta.coaching@gmail.com