Effective Date: January 2026

1. Introduction

Welcome to Mme Bianca SAS. Led by a Certified Executive & Professional Coach operating under Master Coach ICI and ICF frameworks, we are committed to maintaining the highest level of confidentiality and protecting the personal data of our clients. This policy outlines how your information is collected, used, and protected, as well as your rights regarding your personal data under the General Data Protection Regulation (GDPR) and the guidelines set forth by the French Data Protection Authority (CNIL - Commission Nationale de l'Informatique et des Libertés).

2. Information We Collect

To provide an effective and secure coaching experience, we collect the following types of information:

• Identity & Contact Data: Name, email address, phone number, and professional title.

• Intake & Assessment Data: Information provided during the Discovery Call, pre-session questionnaires, and details regarding your professional or personal situation.

• Session Notes: Confidential notes taken during our individual coaching programmes to track progress and design resilience strategies.

• Financial Data: Billing information necessary for regulatory compliance and invoicing through our financial and enterprise systems.

3. How We Use Your Information

Your data is strictly used to facilitate a premium coaching experience. Specifically, we use your information to:

• Deliver personalised coaching interventions.

• Manage booking scheduling and administrative workflows.

• Process payments and maintain accurate financial governance.

• Fulfil legal, tax, and statutory requirements under French law.

4. The ICF Code of Ethics & Confidentiality

Confidentiality is the cornerstone of the coaching relationship. In alignment with the strict ethical standards of the International Coaching Federation (ICF), all information shared during coaching sessions is strictly confidential.

• Sponsor vs. Client: If your coaching is sponsored by your employer (the Sponsor), they will only receive high-level updates regarding attendance and general themes. Specific session details, personal bottlenecks, and private discussions remain exclusively between the coach and the individual client.

• Exceptions to Confidentiality: Confidentiality may only be broken if there is a legal obligation to do so (such as a court subpoena) or if the coach has reasonable cause to believe there is an imminent risk of serious harm to the client or others, as dictated by ICF regulations and French law.

5. Third-Party Data Processors

We utilise secure, industry-standard third-party systems to operate the practice. These platforms act as data processors and are governed by their own stringent privacy policies:

• TidyCal: Utilised for appointment scheduling and calendar management.

• Google Workspace: Utilised for secure email communication and document collaboration.

• Financial Platforms: Customised billing platforms for secure invoicing and statutory tax compliance.

6. Data Retention

We retain client data only for as long as necessary to fulfil the purposes outlined in this policy, including satisfying any legal, accounting, or reporting requirements mandated by the CNIL. Session notes are kept securely and are destroyed after a standard period following the conclusion of the coaching engagement, in strict accordance with standard ICF practices.

7. Your GDPR Rights

Under the GDPR and French data protection laws, you possess specific rights regarding your personal data:

• Right to Access: You may request a copy of the personal data we hold about you.

• Right to Rectification: You may request that we correct any inaccurate or incomplete data.

• Right to Erasure: You may request the deletion of your personal data (the "right to be forgotten"), subject to our legal retention requirements.

• Right to Restrict Processing: You may ask us to suspend the processing of your data under certain circumstances.

• Right to Lodge a Complaint: If you believe your data rights have been breached, you have the right to lodge a formal complaint with the French Data Protection Authority (CNIL).

8. Contact Information

For any questions regarding this privacy policy, or to exercise your GDPR rights, please contact the Data Controller:

• Company: Mme Bianca SAS

• Email: legal@mmebianca.com

• Location: France