Version 2.2, last updated on 12 October 2026

1. Who we are

CoachX is the trade name of Fabian Polak, located at Noordeindseweg 9, 2645 AK Delfgauw, the Netherlands, registered with the Dutch Chamber of Commerce (KvK) under number 67018815. CoachX offers online health and fitness coaches an ecosystem to set up, grow and manage their coaching business: a website, a payment environment, a coaching app, business coaching, sales support (including the AI Setter) and advertising. CoachX is also developing the consumer platform YourCoachX. For privacy questions, please contact legal@coachxlifestyle.com. CoachX has not appointed a data protection officer, as the law does not require one for our activities.

2. Who this policy applies to

This privacy policy applies to:

• visitors of our websites, including coachxlifestyle.com;
• coaches who work with CoachX or are in discussion with us about doing so, and the persons acting on their behalf;
• clients and leads of coaches, insofar as CoachX processes their data. A specific allocation of roles applies to them, explained in section 5;
• visitors of YourCoachX and people who post a review there (section 6);
• coaches who use the AI Setter and anyone who sends a coach a message on Instagram or responds to the coach’s messages (section 7).

For the data described in sections 3, 4 and 6 and the data of coaches in section 7, CoachX is the controller. For the data described in section 5 and the data of coaches’ contacts in section 7, CoachX generally acts as a processor on behalf of the coach.

3. Visitors of our website

When you visit our website, we process technical data such as your IP address, browser, device and the pages you visit. We do this to keep the website working properly and securely (legitimate interest) and, if you consent, to analyse website use and measure advertising. Our cookie policy explains which cookies and similar technologies we use and how to adjust your preferences. If you fill in a form, for example to request an introductory call, we process your name, email address, phone number, company name and anything else you share with us, in order to handle your request and contact you. This is necessary to take steps at your request prior to entering into an agreement. We keep this data for up to 12 months after the last contact, unless a collaboration follows.

4. Coaches and prospective coaches

4.1 Which data

• contact and business details: name, address, email address, phone number, company name, Chamber of Commerce number, VAT number and VAT status;
• data you provide during onboarding, such as your profile, brand identity, offer, prices and images;
• financial data: the Stripe Connected Account in your name, your clients’ payments, the fees CoachX withholds, invoices, monthly statements and your IBAN;
• data we must collect and report to the Dutch Tax Administration under the DAC7 rules: name, address, date of birth (if you are a natural person), Chamber of Commerce number, VAT number, tax identification number (for a sole proprietorship this is the BSN), IBAN and the revenue earned through CoachX;
• communication with your business coach, sales support and the Meta Ads Expert, including in ClickUp and by email, and the plans and tasks resulting from it;
• recordings, transcripts and summaries of online calls (section 4.3);
• usage data of the CoachX Dashboard and the coaching app, such as login details and activity;
• images you provide for your website, YourCoachX and promotion;
• if you use the AI Setter: the data of your connected Instagram account and your settings (section 7).

4.2 Purposes and legal bases

• Performing the collaboration agreement: onboarding, building and hosting your website, access to the dashboard and the coaching app, business coaching, sales support (including the AI Setter), advertising, payments and settlement (performance of a contract).
• Our administration, invoicing and statutory tax retention obligation, and reporting to the Dutch Tax Administration under DAC7 (legal obligation).
• Recording, transcribing and summarising calls to capture knowledge and agreements, create tasks and build a file we use to support you (legitimate interest; see 4.3).
• Using AI to draft monthly, quarterly and content plans and through AI agents in ClickUp (performance of a contract and legitimate interest; see 4.4).
• Using images you provide to promote you and CoachX, on our website, YourCoachX, social media and in advertising, as agreed in the collaboration agreement (performance of a contract).
• Sending updates about the CoachX Ecosystem and offers for similar services to coaches we work with (legitimate interest). You can unsubscribe at any time via the link in the message or via legal@coachxlifestyle.com. We only send newsletters to people we do not work with if they have given consent.
• Securing our systems, preventing misuse and establishing, exercising or defending legal claims (legitimate interest).

4.3 Call recordings

Online calls between you and CoachX, such as onboarding calls, strategy calls and calls with your business coach, may be recorded and transcribed and summarised using software (currently Fathom). We use the recordings solely to perform our collaboration: recording agreements, creating tasks and building a file your business coach uses to support you. We treat recordings as confidential and do not share them with other coaches. You can object to a recording before or during the call; we will then look for an alternative, such as written minutes.

4.4 Use of AI

We use AI tools to draft plans, analyse data and answer questions, including through AI agents in ClickUp and the AI Setter (section 7). When you communicate with an AI agent, this is made recognisable. AI output is reviewed by a team member before any decisions are based on it. We do not make decisions with legal effects for you based solely on automated processing. Where possible, we choose settings under which your data is not used to train AI models.

4.5 Who within CoachX has access

Employees and independent contractors working for CoachX, such as business coaches, high-ticket closers, appointment setters, Meta Ads Experts and developers, have access to your data insofar as needed for their work. They are bound by confidentiality.

5. Clients and leads of coaches

If you are a client or lead of a coach who works with CoachX, that coach is the controller of your data, such as your sign-up, contact details, goals, training and nutrition data, check-ins and payments. CoachX processes this data as a processor, on behalf of your coach, within the CoachX Dashboard, your coach’s website, the coaching app, sales support (including the AI Setter) and advertising. Your coach’s privacy policy describes how your coach handles your data and what role CoachX plays. If you wish to exercise any of your rights, please contact your coach. If we receive a request from you, we will forward it to your coach. For requests to delete data from the AI Setter, you can also contact us directly (section 7.7). In a limited number of cases, CoachX is itself the controller of data of coaches’ clients:

• for images in which you appear and which we use for promotion with your explicit consent;
• for inviting clients to post a review on YourCoachX and publishing those reviews (section 6);
• for data we anonymise to improve our services; that data can then no longer be traced back to you;
• for data we must retain or disclose under a legal obligation.

If you pay your coach via a CoachX payment page, the payment is handled by Stripe. Stripe processes your payment data under its own privacy policy.

6. YourCoachX

YourCoachX is the CoachX platform where consumers can compare coaches and are redirected to the website of the coach they choose. YourCoachX is under development. Once the platform is available, CoachX, as controller, will process visitors’ visit, search and click data to operate and improve the platform (legitimate interest and, for non-essential cookies, consent). If you choose a coach on YourCoachX, your data is processed on behalf of that coach from that moment on (section 5). CoachX may invite a coach’s clients to post a review of that coach. If you post a review, we publish your first name and your review on YourCoachX. You can have your review removed via legal@coachxlifestyle.com. We verify that a review comes from a client who actually completed a programme with the coach.

7. Instagram and the AI Setter

Coaches who work with CoachX can connect their Instagram account to the CoachX AI Setter. The AI Setter replies to Instagram messages on the coach’s behalf, asks questions to determine whether a coaching programme is a good fit, and schedules introductory calls. This section applies to coaches who use the AI Setter and to anyone who sends a coach a message on Instagram or responds to the coach’s messages. Messages from the AI Setter are generated with the help of AI. We always make this known at the start of the conversation, and the AI Setter never denies being an AI when asked. The coach can take over a conversation at any time. If you indicate that you do not want to receive any more messages, the AI Setter stops replying. If you appear to be under 18, the conversation is handed over to the coach. The AI Setter does not make decisions that produce legal effects for you or similarly significantly affect you.

7.1 Roles

CoachX is the controller of the coach’s data. For the data of people who message the coach, the coach is the controller and CoachX processes the data as a processor on the coach’s behalf (see also section 5). Because the Instagram connection runs through CoachX, you can also send a request to delete your data directly to CoachX (section 7.7).

7.2 Which data we process

From the coach:

• the Instagram account ID and username;
• an encrypted access token;
• the AI Setter settings and the information the coach provides about their offer and way of working.

From people who message the coach:

• Instagram ID, name, username and profile picture;
• the number of followers and whether you and the coach follow each other, as provided by Instagram after you have sent the coach a message;
• the content of messages and attachments, including the replies sent by the coach and the AI Setter;
• comments and replies to the coach’s messages and posts;
• timestamps of messages;
• answers to questions about goals, situation, timing and budget;
• details of a booked call: name, email address and time;
• notes and AI-generated summaries of the conversation.

7.3 Health data

Sometimes people share something about their health on their own initiative, for example an injury. The AI Setter does not ask for this, and you do not need to share such information to schedule an introductory call. Conversations in which someone shares health information are handed over to the coach. We do not use this information for any other purpose.

7.4 Purposes and legal bases

We use this data only to reply to messages on the coach’s behalf, determine whether a programme is a good fit, schedule introductory calls and make the conversations visible to the coach in the CoachX Dashboard. The data of a coach and their contacts is used only for that coach, not for other coaches and not for CoachX’s own marketing. For the coach’s data, the legal basis is the performance of the collaboration agreement. For the data of people who message the coach, the processing is necessary to take steps at their request prior to a possible agreement with the coach, and is based on the coach’s legitimate interest in replying to messages quickly and carefully.

7.5 How long we keep data

• We keep conversations and related data for as long as the coach uses the AI Setter, up to a maximum of 12 months after the last message in a conversation.
• If a coach disconnects their Instagram account, we delete the access token immediately and the data of the coach’s contacts within 30 days, unless the coach reconnects the same Instagram account within that period.
• We keep technical log files for a maximum of 30 days. Backups are overwritten within 7 days.
• If someone becomes a client of the coach, the arrangements in section 5 apply to the data needed for the coaching programme.

7.6 Who processes the data

For the AI Setter we work with Meta (Instagram), Hetzner (servers in the EU), Anthropic (generating replies), Cal.com (scheduling calls) and Bubble (the CoachX Dashboard). Anthropic does not use the data it receives through our integration to train its models. Anthropic, Cal.com and Bubble may process data outside the EU. Data processing agreements and the safeguards described in section 9 apply to this. Meta also processes messages sent via Instagram under its own privacy policy.

7.7 Deleting your data

You can request deletion of your data at any time by sending an email to legal@coachxlifestyle.com, stating your Instagram username and the coach you were in contact with. We will then delete your data from our database and the CoachX Dashboard within 30 days and let you know once this has been done. Coaches can delete the data of their AI Setter at any time by disconnecting Instagram in the CoachX Dashboard, or by removing the CoachX app in Instagram under Settings, Apps and websites. The access token and the data processed through the AI Setter are then deleted automatically, within the periods set out in section 7.5.

8. Who we share data with

We share data with parties that help us deliver our services, only to the extent necessary for that purpose:

• Everfit (coaching app), Bubble (CoachX Dashboard and YourCoachX), mijn.host and WordPress (websites) and Hetzner (servers in the EU);
• Stripe (payments) and Meta (advertising and the AI Setter’s Instagram connection);
• Anthropic (AI models for the AI Setter);
• ClickUp (project management, communication and AI agents), Google Workspace (email, calendar and documents), Postmark (email), Zapier and similar services (automations), Cal.com (scheduling) and Fathom (recordings and transcriptions);
• independent contractors working for CoachX as business coach, sales support, Meta Ads Expert or developer;
• our accountant and advisers, insofar as necessary for our administration and legal matters.

We enter into data processing agreements with our processors. We also provide data to the Dutch Tax Administration (DAC7 and tax obligations) and to other authorities where required by law. In the event of a transfer of our business, for example to a company that continues the activities of CoachX, data may form part of that transfer; we will inform you about this. We do not sell personal data.

9. Transfers outside the EEA

Several of our suppliers, including Everfit, Bubble, ClickUp, Fathom, Google, Stripe, Anthropic and Cal.com, process data in the United States or other countries outside the European Economic Area. We ensure that such transfers take place on the basis of an adequacy decision of the European Commission, such as the EU-US Data Privacy Framework, or on the basis of the European Commission’s standard contractual clauses, supplemented by appropriate measures. People working for CoachX may also work remotely from countries outside the EEA; they access data only through secure access and, where required, on the basis of standard contractual clauses. On request, we will provide more information about the safeguards used.

10. Retention periods

• Data of prospective coaches: up to 12 months after the last contact.
• Data from the collaboration agreement, invoices, monthly statements and payment data: 7 years after the end of the financial year in which the collaboration ended (statutory tax retention obligation).
• DAC7 data: 10 years after the end of the year to which the report relates, as required by law.
• Recordings, transcripts and summaries of calls and the coaching file: during the collaboration and up to 12 months thereafter.
• Communication in ClickUp and by email: up to 24 months after the end of the collaboration, unless a longer period is needed for administration or a legal dispute.
• Images for promotion: up to 12 months after the end of the collaboration, or earlier on request.
• Data processed through the AI Setter: see section 7.5.
• Data of coaches’ clients that we process as a processor: after the collaboration with the coach ends, this data is returned or deleted at the coach’s request, as agreed in the data processing agreement.

11. Security

We take appropriate technical and organisational measures to protect data, including access control and two-factor authentication where available, encryption of data in transit, encrypted storage of access tokens, logging, regular backups of systems under our control, and limiting access to people who need the data for their tasks.

12. Your rights

You have the right to access, rectify or erase your data, to restrict processing, to object to processing based on legitimate interest, and to receive your data in a common, machine-readable format. Where processing is based on your consent, you can withdraw that consent at any time; this does not affect processing carried out before the withdrawal. You can send a request to legal@coachxlifestyle.com. We respond within one month and may ask you to verify your identity. If you disagree with how we handle your data, you can lodge a complaint with the Dutch Data Protection Authority, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl), or with the supervisory authority in your country.

13. Minors

Our services for coaches are intended for persons aged 18 and over. Coaches who coach minors are themselves responsible for obtaining the consent of parents or guardians.

14. Changes

We may amend this privacy policy, for example when we introduce new services or the law changes. The current version is always available on coachxlifestyle.com. In the event of significant changes, we will inform the coaches we work with by email or via the CoachX Dashboard.

15. Contact

CoachX (Fabian Polak) Noordeindseweg 9, 2645 AK Delfgauw, the Netherlands Chamber of Commerce (KvK) 67018815 Email: legal@coachxlifestyle.com