CLIENT PRIVACY NOTICE

Divergent Empowerment - ADHD & Neurodivergent Coaching Services

Last updated: September 2026

1. Introduction

This Client Privacy Notice explains how Dr. Roberta Locatelli, trading as Divergent Empowerment ("I", "me", "my"), collects, uses, stores, and protects your personal information when you engage with my coaching services.

This notice is separate from my website privacy policy and specifically covers the personal information processed in the context of our coaching relationship, including individual and group coaching sessions.

I take your privacy seriously and am committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR) and German data protection law (BDSG).

2. Data Controller

The data controller responsible for your personal information is:

Dr. Roberta Locatelli

Im Winkelrain 18

72076 Tübingen, Germany

Email: roberta@divergentempowerment.com

Phone: +49 157 37288068

3. What Personal Information I Collect

In the course of our coaching relationship, I may collect and process the following categories of personal information:

3.1 Contact and Identification Information

- Full name

- Email address

- Phone number

- Postal address (if relevant for invoicing)

- Time zone and preferred contact methods

3.2 Coaching-Related Information

- Information shared during discovery calls and intake processes

- Goals, challenges, and areas you wish to work on

- Session notes and observations from our coaching sessions

- Progress notes and action items agreed upon

- Questionnaires, assessments, and self-reflection exercises you complete

- Communications between sessions (emails, messages)

3.3 Special Category Data

Given the nature of ADHD and neurodivergent coaching, you may choose to share information that constitutes special category data under GDPR, including:

- Information about ADHD diagnosis, symptoms, or experiences

- Mental health information you choose to disclose

- Information about neurodivergent traits or other diagnoses

- Health-related information that affects your coaching goals

I only process this sensitive information with your explicit consent and solely for the purpose of providing effective coaching support.

3.4 Payment and Administrative Information

- Invoicing details

- Payment records

- Appointment history and scheduling information

- Coaching agreement and consent records

4. How I Use Your Information

I use your personal information for the following purposes:

- To provide coaching services and support your goals

- To prepare for and conduct coaching sessions effectively

- To track your progress and tailor my approach to your needs

- To communicate with you about appointments and follow-ups

- To send invoices and manage payment records

- To comply with legal and professional obligations

- For my own professional development through supervision (in an anonymised form)

5. Legal Basis for Processing

I process your personal information based on the following legal grounds under GDPR:

5.1 Contract Performance (Art. 6(1)(b) GDPR)

Processing necessary to fulfil our coaching agreement, including scheduling sessions, providing coaching services, and managing payments.

5.2 Explicit Consent (Art. 6(1)(a) and Art. 9(2)(a) GDPR)

For processing special category data (health and neurodivergence-related information), I rely on your explicit consent. You may withdraw this consent at any time without affecting the lawfulness of processing before withdrawal.

5.3 Legitimate Interests (Art. 6(1)(f) GDPR)

For certain processing activities such as maintaining professional records, improving my services, and participating in supervision to maintain professional standards.

5.4 Legal Obligations (Art. 6(1)(c) GDPR)

For record-keeping required by tax law and professional obligations.

6. How I Store and Protect Your Data

I take appropriate technical and organisational measures to protect your personal information:

- All forms and coaching agreements are collected and stored through Tally, based in Belgium (within the EU)

- Email correspondence with you takes place through Proton Mail, and other documents are stored on Proton Drive, both based in Switzerland and offering encrypted storage

- Access to your information is limited to me only (and, where relevant, anonymised information may be shared in supervision)

- Video sessions are conducted via secure platforms; I do not record sessions unless explicitly agreed

- Any paper documents identify you by first name only, rather than full contact details, and are destroyed securely as soon as our coaching relationship ends, or whenever you ask me to

7. Who I Share Your Data With

I treat all information shared in coaching as confidential. However, I may share limited information in the following circumstances:

7.1 Service Providers

- Scheduling platform (Acuity Scheduling / Squarespace) for appointment booking

- Forms and agreements: Tally, based in Belgium

- Email communications: Proton Mail, based in Switzerland

- Document storage: Proton Drive, based in Switzerland

- Video conferencing provider (e.g., Zoom) for online sessions

- Community platform (Discord) — optional, and only used by clients who choose to opt into a group's private community; not used in individual coaching

- Payment processors for handling transactions

These providers process data on my behalf and are bound by data processing agreements to protect your information.

7.2 Professional Supervision

As part of my professional development and to maintain coaching standards, I may discuss coaching work in supervision. In these discussions, your information is anonymised so you cannot be identified.

7.3 Legal Requirements

I may be required to disclose information if compelled by law or court order, or if there is a serious risk of harm to yourself or others.

7.4 With Your Consent

I will only share identifiable information with third parties (such as healthcare providers or employers) with your explicit written consent.

8. How Long I Keep Your Data

I retain your personal information for the following periods:

- Coaching records and session notes: deleted immediately after the end of the coaching relationship, or earlier upon your request

- Financial records and invoices: 8 years (as required by German tax law)

- Business correspondence and contracts: 6 years (as required by German commercial law)

- Consent records: 3 years after the end of the coaching relationship

- Discovery call notes (non-clients): 6 months after last contact

After these periods, your data will be securely deleted or anonymised.

9. International Data Transfers

Most of the tools I use to store your data stay within, or are treated as equivalent to, the European Economic Area (EEA):

- Tally, which stores all forms and coaching agreements, is based in Belgium — within the EU, so no international transfer is involved

- Proton Mail and Proton Drive are based in Switzerland. Switzerland has held a valid EU adequacy decision since 2000, most recently reconfirmed by the European Commission in January 2024, meaning data can be transferred there without any additional safeguards being required

Other tools I use, such as Zoom (video conferencing) and Discord (the optional group coaching community platform, used only by those who choose to opt in), are based in the United States, which does not have blanket adequacy status. Where this applies, I rely on appropriate safeguards such as:

- Standard Contractual Clauses (SCCs) approved by the European Commission

- EU-US Data Privacy Framework certification where applicable

10. Your Rights

Under GDPR, you have the following rights regarding your personal data:

- Right of access: Request a copy of the personal data I hold about you

- Right to rectification: Request correction of inaccurate or incomplete data

- Right to erasure: Request deletion of your data in certain circumstances

- Right to restrict processing: Request limitation of how I use your data

- Right to data portability: Receive your data in a structured, machine-readable format

- Right to object: Object to processing based on legitimate interests

- Right to withdraw consent: Withdraw consent at any time for processing based on consent

To exercise any of these rights, please contact me at roberta@divergentempowerment.com. I will respond to your request within one month.

You also have the right to lodge a complaint with a supervisory authority. In Germany, this is the data protection authority of Baden-Württemberg (Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg).

11. Special Considerations for Group Coaching

This section applies only if you take part in group coaching. If you're working with me one-to-one, it doesn't apply to you.

If you participate in group coaching sessions, please note:

- Other participants may see and hear information you share during sessions

- All group members are asked to maintain confidentiality about what is shared in sessions

- I cannot guarantee that other participants will maintain confidentiality, and I am not responsible for a breach of confidentiality by another participant

- You are encouraged to share only what you feel comfortable discussing in a group setting

- Any written materials I create about group sessions will not identify individual participants

- Some groups offer an optional private Discord community as a supplementary space between sessions. Joining it is entirely your choice, is never required to take part in the group coaching itself, and requires you to actively opt in. If you do join, messages you post remain visible to other group members, including after you leave, unless you delete them yourself beforehand (see the Group Coaching Agreement for details)

12. Confidentiality Boundaries

Everything discussed in coaching is treated as confidential, with the following exceptions:

- If you provide written consent for me to share specific information with a named third party

- If I am legally compelled to disclose information (e.g., by court order)

- If I believe there is a serious and imminent risk of harm to yourself or others

- Anonymised information shared in professional supervision

If I ever need to break confidentiality for safety reasons, I will, wherever possible, discuss this with you first.

13. Changes to This Notice

I may update this privacy notice from time to time. If I make significant changes, I will inform you directly. The current version will always be available upon request.

14. Contact Me

If you have any questions about this privacy notice or how I handle your personal data, please contact me:

Dr. Roberta Locatelli

Email: roberta@divergentempowerment.com

Phone: +49 157 37288068