Privacy policy

Last updated: 19 October 2026

1. Introduction

Thank you for visiting www.simonbowen.com. I take data protection seriously and handle your personal data in accordance with the General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), and the Telecommunications Digital Services Data Protection Act (TDDDG).

This Privacy Policy informs you about how your personal data is processed when you visit my website or work with me as a coaching or mentoring client.

2. Data Controller

Name: Simon Bowen
Role: Freelance coach and mentor (Freiberufler)
Address: Weitzgrunder Allee 3, 14806 Bad Belzig, Germany
Email: privacy@simonbowen.com

I am the controller for the personal data described in this policy. As a freelancer, I am not legally required to appoint a Data Protection Officer.

3. Types of Personal Data Processed

Website Visitors:

  • IP address, browser information and device type, held in the hosting provider’s server logs

Via the enquiry form:

  • Name, email address and anything you write, including who referred you if you choose to say

Clients and Prospective Clients:

  • Contact and billing details
  • Coaching session notes
  • Communication history
  • Files or data shared as part of coaching
  • CRM records

4. Legal Basis for Processing

Your personal data is processed under the following lawful bases:

  • Consent (Art. 6(1)(a) GDPR): for enquiries via the enquiry form
  • Contractual necessity (Art. 6(1)(b) GDPR): for arranging a first conversation at your request, coaching sessions and client onboarding
  • Legal obligation (Art. 6(1)(c) GDPR): for accounting and tax purposes
  • Legitimate interests (Art. 6(1)(f) GDPR): for server logs that keep the website secure and working, and for running my business

5. Data Retention

  • Client data: Retained for up to 12 months after contract expiry
  • Website enquiries: Retained for 12 months
  • Invoices and financial records: Retained for the periods German tax law sets in §147 AO, which run from 6 to 10 years depending on the type of document

6. Cookies and Similar Technologies

This website sets no cookies and uses no analytics, advertising or tracking tools, so it has no cookie banner. The pages store nothing on your device and read nothing from it.

7. Services Behind This Website

This website loads no third-party scripts, fonts, maps, videos or trackers. The fonts are served from this site’s own server, and nothing on the pages is embedded from another company. Links to other sites, such as the Luma page for Make the Cut, send data to that site only once you click them.

These services process personal data when you visit the site or use its enquiry form:

  • Vercel (Vercel Inc., USA) hosts the website. When a page loads, it receives your IP address and browser details in its server logs. Vercel is certified under the EU–U.S. Data Privacy Framework and offers a data processing agreement with Standard Contractual Clauses. It keeps these logs only for the limited period its service sets.
  • Enquiry form. What you enter is sent to me as an email and arrives in my mailbox at my email host in Germany. I do not keep it in a database on this website.
  • Google Search Console shows me, in aggregate, how this site appears in Google search. It is verified by a DNS record, puts nothing on your device and receives nothing from your visit. Google acts as a separate controller for its own search data.

Where data goes to the USA, I rely on the EU–U.S. Data Privacy Framework if the provider is certified, and otherwise on Standard Contractual Clauses.

8. Other Third-Party Services

As part of my coaching services, I collect and process personal data in compliance with the General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).

a. Types of Data Collected

  • Full name
  • Email address, phone number
  • Invoicing and payment details
  • Appointment and communication history
  • Coaching session notes and reflections
  • Uploaded documents or assessments (if applicable)
  • Voluntary feedback or testimonials

b. Purpose of Processing

  • To deliver coaching sessions
  • To organise and manage appointments
  • To issue invoices and maintain financial records
  • To document the coaching process
  • For optional feedback and testimonials
  • For digital tools that support your own reflection between sessions

c. Legal Basis for Processing (Article 6 GDPR)

  • Art. 6(1)(b): Performance of a contract (coaching agreement)
  • Art. 6(1)(a): Consent (e.g. testimonials or optional communication channels)
  • Art. 6(1)(c): Legal obligation (e.g. record-keeping)
  • Art. 6(1)(f): Legitimate interest (e.g. efficient service delivery)

d. Who Else Receives Your Data

I use a small number of service providers to run my practice. They fall into these groups:

  • Email hosting and mailboxes, in Germany.
  • Email and file storage with Google (Gmail and Google Drive, USA), where emails, notes and files from our work together can be stored.
  • Accounting and invoicing software, in Germany, and my tax adviser.
  • Video calls, task and note management, and electronic signing of coaching agreements.
  • AI-supported note-taking: I may use Granola AI (USA) to take notes of a session, only with your explicit permission.
  • Messaging apps, only if you choose one: WhatsApp or Telegram. Please use them for non-sensitive messages only. I am happy to use another channel you prefer.

Where a provider is based in the USA, I rely on the EU–U.S. Data Privacy Framework if it is certified, and otherwise on Standard Contractual Clauses. If you would like to know which providers hold your data, ask me at privacy@simonbowen.com and I will tell you.

9. Your Rights under the GDPR

a. Your Rights
You have the right to:

  • Access your personal data (Art. 15 GDPR)
  • Rectify inaccurate data (Art. 16 GDPR)
  • Erase your data (“right to be forgotten”, Art. 17 GDPR)
  • Restrict or object to processing (Art. 18, 21 GDPR)
  • Data portability (Art. 20 GDPR)
  • Withdraw consent at any time (Art. 7(3) GDPR)

To exercise any of these rights, contact me at privacy@simonbowen.com.

You also have the right to lodge a complaint with a supervisory authority. For my place of business in Brandenburg, this is the Landesbeauftragte für den Datenschutz und für das Recht auf Akteneinsicht Brandenburg (https://www.lda.brandenburg.de/).

b. Response Time for Data Subject Requests

In accordance with Article 12(3) of the GDPR, I aim to respond to all valid data subject requests (e.g. access, rectification, erasure, objection) within 30 days of receipt. In cases where the request is particularly complex or if I receive multiple requests from the same individual, this period may be extended by up to an additional 60 days. In such cases, I will inform you of the extension and the reasons for the delay.

c. Automated Decision-Making

I do not use automated decision-making or profiling as part of my coaching or website services.

10. Data Security

I use industry-standard security measures (e.g. SSL encryption, secure backups, and limited access control) to protect your data. External service providers are chosen carefully and bound by data processing agreements where applicable.

11. Changes to this Privacy Policy

This Privacy Policy may be updated occasionally to reflect legal or operational changes. The date of the last update will always be indicated at the top of this page.

12. Contact

If you have questions about this Privacy Policy or how your data is handled, please contact:

Simon Bowen
privacy@simonbowen.com