CLIENT PRIVACY NOTICE
Divergent Empowerment - ADHD & Neurodivergent Coaching Services
Last updated: 15 October 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:
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)
- For group coaching: written session recaps shared with your group, and, if all members of your group consent, transcripts and summaries of group sessions produced with Zoom AI Companion (see Section 11)
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 session recaps to participants in group coaching, and, where all group members consent, to transcribe and summarise group sessions with Zoom AI Companion to help me draft those recaps
- 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, sending group session recaps, 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), and for transcribing and summarising group sessions with Zoom AI Companion, 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:
- Forms and coaching agreements are collected and stored through Tally, based in Belgium (within the EU). If you ask to complete a form as a Word document instead, you can return it to me by email, and it will be stored in Proton Mail or Proton Drive. Upon your request, this can be done through a password-protected message.
- 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
- Emails exchanged between Proton Mail and other email providers are encrypted in transit and on my side on Proton, but are not end-to-end encrypted, so your own email provider may keep a readable copy of what you send. If you would prefer end-to-end encryption, for example when returning a completed form, I can send you a password-protected email for your reply
- Coaching information (session notes, intake forms, questionnaires and anything relating to your health or neurodivergence) is accessible to me only. My virtual assistant supports me with administrative tasks and has access only to the information described in Section 7.1. She cannot access my own mailbox (roberta@divergentempowerment.com) or any coaching information
- Emails sent to assistant@divergentempowerment.com are read by my virtual assistant. Please do not send sensitive information to that address; write to roberta@divergentempowerment.com instead
- Where relevant, anonymised information may be shared in supervision
- Video sessions are conducted via secure platforms; I do not record sessions unless explicitly agreed. In group coaching, Zoom AI Companion is used to transcribe and summarise sessions only if all members of the group have given their explicit consent (see Section 11)
- Any note I take during sessions 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
- Website forms (Squarespace) for enquiries and marketing preferences
- Forms and agreements: Tally, based in Belgium
- Email communications: Proton Mail, based in Switzerland
- Document storage: Proton Drive, based in Switzerland
- Invoicing and accounting software: Accountable
- Payment processing: Stripe
- Video conferencing provider (Zoom) for online sessions, and Zoom AI Companion for transcribing and summarising group sessions where all group members have consented
- Community platform (Discord) — optional, and only used by clients who choose to opt into a group's private community; not used in individual coaching
- My virtual assistant, based in South Africa, who helps me with administrative tasks. She has access only to invoicing records (name, contact and invoicing details, amounts and payment status), to first enquiries and marketing preferences submitted through my website forms, and to emails sent to assistant@divergentempowerment.com. She has no access to my own mailbox, session notes, intake forms or any coaching information
These providers and my virtual assistant process data on my behalf and are bound by data processing agreements to protect your information.
7.2 Tax Adviser
My tax adviser receives invoicing and payment records where necessary to prepare my tax returns. Tax advisers are bound by professional confidentiality.
7.3 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.
7.4 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.
7.5 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, including intake forms: deleted within 30 days of 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)
- Transcripts and summaries of group sessions produced with Zoom AI Companion: these will be deleted as soon as possible after summaries are shared and no later than three months after being recorded
- Consent records: 5 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.
Please note that group session recaps, once sent, are also held in the email accounts of the other group participants, and I cannot delete those copies.
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
Some processing takes place in countries that do not have blanket adequacy status:
- 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
- My virtual assistant is based in South Africa and accesses the administrative information described in Section 7.1 from there
Where this applies, I rely on appropriate safeguards:
- Standard Contractual Clauses (SCCs) approved by the European Commission, which I have signed with my virtual assistant
- EU-US Data Privacy Framework certification where applicable
You can ask me for a copy of the safeguards in place.
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
- After sessions, I send a written recap by email to the participants of your group. To make the recap useful, it may refer to you by first name and summarise what you worked on in the session, such as a goal, a challenge or a strategy you discussed. Recaps go only to the members of your group. I do not include health information or other sensitive personal details in recaps. You can ask me at any time not to be named in recaps, or to leave out or correct anything about you
- Provided that all members of your group explicitly consent, I use Zoom AI Companion to transcribe and summarise group sessions, solely to help me draft the session recaps. You are asked for this consent separately in the Group Coaching Agreement. If any member of the group does not consent, these features are not used for that group. Please be aware that a transcript records everything said in the session, including anything participants choose to share about their health. You can withdraw your consent at any time by emailing me, and the features will then no longer be used from the following session onwards
- 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:
- Session recaps shared with the members of your group, as described in Section 11
- 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:
Roberta Locatelli
Email: roberta@divergentempowerment.com
Phone: +49 157 37288068