Privacy for coaches

Please note: this is a courtesy translation. In case of any discrepancy, the German version at /coach-datenschutz prevails.

1. Purpose of this statement

This privacy statement applies in addition to the general ELANUM privacy statement and is addressed exclusively to people who use ELANUM as a coach, therapist, counsellor or astrologer in order to enter and process data about their clients.

The relationship between you and ELANUM is processing on behalf of a controller within the meaning of Art. 9 FADP (Swiss Federal Act on Data Protection). ELANUM processes client data solely on your instructions and on your behalf.

2. Roles

• Coach (you): controller for the client data collected. You are obliged to inform your clients about this processing before entering their birth data and to obtain their consent.
• ELANUM (maind GmbH, Brugg): processor, processes client data solely to provide the agreed calculation and dossier functions.
• Client: data subject with all rights under Swiss data protection law (access, rectification, erasure, data portability).

3. Which client data is processed

Which data is collected depends on the modules you use. The client record is the basis; appointment booking and invoicing are enabled separately and collect additional data.

3.1 Client record (basis of every calculation)

• Personal details: first name, last name, gender, date of birth, time of birth, place of birth
• Geo data: latitude and longitude of the place of birth (for the house calculation)
• Email address: optional, stored if you send your client a self-entry invitation link or if a booking is linked to the record
• Optional partner data: if you prepare a couple analysis for your client, the first name, last name and birth data of the partner are collected as well
• Notes: keywords on the coaching process recorded by you (free text)
• Record of consent: confirmation flag, timestamp and your note on how consent was obtained
• Calculation output: astrological, numerological and Human Design data (profiles, aspects, energy chart) derived from the birth data

3.2 Optional personality instruments

If you use these tools, ELANUM stores the results with the client record: Enneagram type, wing and raw scores, Big Five values (BFI-10), character strengths (VIA), values profile (PVQ), emotional competence (WLEIS), growth mindset, regulatory focus, conflict style and the three scales of the so-called Dark Triad (narcissism, Machiavellianism, psychopathy). In an executive context this is joined by role, industry, team size, your free-text focus and up to three biographical milestones with date and note.

Please treat these values with particular care. Personality scores attached to a named person are sensitive for the person concerned, even where they do not legally qualify as health data. As the controller, you decide whether collecting them is proportionate in the specific case.

3.3 Appointment booking (module "Buchen", only if enabled)

• First name, last name, email address (mandatory) and phone number (optional) of the person booking
• Appointment, duration, service booked, status and payment method
• Free-text message from the booking form, if you offer this field. What your client writes there may contain health information.
• Consent flag and timestamp, cancellation token, reminder timestamp

3.4 Invoices (module "Rechnung", only if enabled)

• Name and full billing address of the paying person, optionally their email address
• Invoice number, amount, currency, deadlines, status, reference for the Swiss QR code
• Invoice line items with description, quantity and price, plus your remarks

4. Health data in the Tarif 590 reimbursement voucher

This section matters. If you enable the Tarif 590 voucher in the invoice settings, ELANUM processes genuine health data on your behalf. This is sensitive personal data under Art. 5 lit. c FADP and a special category of personal data under Art. 9 GDPR.

Specifically, the following is stored for such a voucher:

• The patient's date of birth (mandatory field of the standard form)
• The treatment date (mandatory on the voucher, optionally also per individual treatment line)
• Treatment line items with a tariff code under Tarif 590 for complementary therapy, together with the official designation of that code, the treatment duration and the amount. The code names the treatment method. Combined with name, address and date of birth, this states which treatment a specific person received on a specific day.
• The patient's name and address as invoice recipient
• Your provider identifiers: ZSR number (Swiss payment register number), optionally GLN, EMR and ASCA numbers, and your practice address

Purpose: solely to produce the reimbursement voucher with which your patient can claim treatment costs from their supplementary insurance under the Swiss Insurance Contract Act, plus the associated invoicing and bookkeeping. ELANUM does not analyse this data, does not link it to matching, the dating area or the astrological calculations, and does not pass it on to any insurer. The voucher is created on your side; sending it to the patient or the insurer is entirely up to you.

Opt-in: the Tarif 590 voucher is switched off by default. It requires deliberate activation per practice and a stored ZSR number. As long as you do not activate it, no treatment data arises in ELANUM.

What this means for you: as the controller you need explicit consent from your patient for health data (Art. 6 para. 7 lit. a FADP, in the EU Art. 9 para. 2 GDPR) or another sound basis arising from the treatment relationship. Please also assess whether processing sensitive data obliges you to carry out a data protection impact assessment (Art. 22 FADP, Art. 35 GDPR) and whether your professional secrecy obligations require a written data processing agreement with us. We will provide such an agreement on request.

5. Legal bases

• You as coach: consent of your client or patient (Art. 6 para. 6 FADP, and for health data explicit consent under Art. 6 para. 7 lit. a FADP) and performance of the treatment or counselling contract.
• ELANUM: processing solely on behalf and on instruction under Art. 9 FADP. We do not rely on any legal basis of our own for client data and pursue no purposes of our own with it.
• Your invoices: invoices and bookings that you create in ELANUM for your clients are your data; we process them on your behalf. The statutory retention duty (Art. 958f of the Swiss Code of Obligations) for them lies with you.

6. Retention periods

The periods differ by data category. There is no single erasure rule across all modules.

• Client record: 90 days since last access. Every time the record is opened (view, edit, dossier) the last_accessed_at timestamp is updated. If the record is not opened for 90 days it is deleted automatically and irreversibly, including birth data, partner data and test results. A daily clean-up run and a check each time the client list is opened enforce this.
• Your own session notes survive this clean-up. They are your work product. Before the record is deleted, the first name is preserved as an archive label on the session so that you can still assign your notes. If you do not want this, delete the notes yourself.
• Invoices and accounting records: as long as your account exists. They are not deleted automatically. This includes Tarif 590 vouchers with date of birth, treatment date and tariff codes. You can delete drafts yourself; issued invoices cannot be deleted. When you delete your account, we delete them (section 13). The ten-year retention duty under Art. 958f of the Swiss Code of Obligations lies with you; please download your invoices before you delete your account.
• Bookings: remain as appointment history and have no automatic erasure period. You can cancel individual bookings.
• You can delete any client record manually at any time.

Generated PDF dossiers are held in your personal library and are subject to their own retention period (see the coach terms).

7. Your duties as a coach

• Informing the client: before entering data you inform your clients that their birth data will be processed on an external platform (ELANUM).
• Obtaining consent: you obtain the explicit consent of your client. Consent must be freely given, informed and capable of being documented.
• Professional secrecy: professional confidentiality duties (for example under FSP, ASCA or SBAP standards or cantonal professional law) remain entirely your responsibility. Through this processing ELANUM becomes your auxiliary person within the meaning of those duties.
• Health data: if you use the Tarif 590 voucher, obtain explicit consent for processing health data and assess the need for a data protection impact assessment (see section 4).
• Client requests: requests from your clients regarding access, rectification or erasure are to be forwarded to ELANUM without delay (contacts‍m‍a‍r‍t@maind.ch).
• No disclosure: you do not pass client data to unauthorised third parties, neither directly nor via screenshots or exports from ELANUM.
• PDF security: you treat generated client dossiers as confidential documents and hand them only to the respective client.

8. Who has access to the data

• You. Every query of client, booking and invoice data is bound to your coach account. Other coaches cannot see your data.
• The operator, technically. As operator, maind GmbH has access to the database and the backups and can therefore technically view client data as well. This happens only for troubleshooting, for restoring data or at your explicit request.
• Account impersonation. An account with SUPERADMIN permission can enter a user account for support purposes and then also sees that account's coach area. This function can be switched off platform-wide, is limited to five operations per hour and is logged (section 9).
• Nobody else. There is no disclosure to advertising partners, no evaluation for training purposes and no transfer to insurers.

9. Technical and organisational measures

ELANUM protects client data through:

• Encrypted transmission via HTTPS/TLS
• Server location exclusively in Switzerland (Infomaniak, Geneva)
• Optional 2FA (TOTP), confirmed with a code by email when switched on, and passkey/WebAuthn for coach accounts
• Access log under Art. 4 DPO: every access to client data (store, read, change, delete, disclose), by you as well as by our team, including every account impersonation; recorded are the time, the acting person, the role, the type of access, the type of data and the identifier of the record, without content. Kept for one year and additionally stored separately from the database
• Logging of other security-relevant events in the security log (90 days, deleted thereafter)
• Watermarking of all PDF dossiers with coach ID and timestamp
• Optional PDF protection (PROTECTED mode with edit protection)
• Automatic deletion of the client record after 90 days without access
• Separation of coach data from the platform's dating and discovery data

10. Sub-processors

ELANUM uses the following sub-processors for its operations:

• Infomaniak Network SA (Geneva, Switzerland), hosting, SMTP delivery, backup. All client data stored in ELANUM resides there.
• Stripe Payments Europe Ltd. (Dublin, Ireland), payment processing for the coach setup fee, dossier purchases and, if you offer online payment, for your clients' appointment bookings.
• Functional Software, Inc. (Sentry) (USA, EU data region in Frankfurt, Germany), error reports. When a technical error occurs, Sentry receives the error message, the technical trace, the requested address, browser and operating system. The requested address may contain the internal identifier of a client record, a session or an invoice, but no names. We do not transmit account identifiers, cookies, form input or session recordings. For visits from the EU, the EEA or an unknown country, we send error reports from the browser only with the consent of the person currently using ELANUM.

Abroad: Stripe is based in Ireland and Sentry's data is stored in Germany; both countries provide adequate data protection. The parent companies of Stripe and Sentry are based in the USA; for access from there, the safeguards named in section 9 of the general privacy statement apply.

What Stripe receives: for your own payments, exclusively coach-related payment and identification data. If you enable online payment for appointment bookings, your client's email address and the name of the booked service are additionally transmitted to Stripe so that the payment page and the receipt can be created. The payment runs through your own Stripe Connect account. Choose service names that do not reveal a diagnosis or a treatment method if you wish to avoid this.

Not transmitted to Stripe: birth data, calculation results, your notes, test results and all Tarif 590 data including treatment date and tariff codes.

11. Data export for clients

Upon request by an affected client, mediated through you as the coach, ELANUM makes the stored data available in a machine-readable format (JSON) within 30 days. Please send such requests to contacts‍m‍a‍r‍t@maind.ch.

12. Reporting data breaches

If you suspect a data breach (unauthorised access, data loss) you are obliged to inform ELANUM without delay, so that a report to the Swiss Federal Data Protection and Information Commissioner can be made within the statutory deadline (Art. 24 FADP). Where health data is affected, notification of the data subjects must also be assessed.

13. End of the collaboration

If your coach status ends, your branding and your client records are deleted within 30 days. We keep your purchases from us (dossiers, team reports) as accounting records for ten years (Art. 958f of the Swiss Code of Obligations), without any reference to your clients.

Invoices and bookings are your data and remain in your account, including the Tarif 590 vouchers. If you delete your account, we delete them as well. Because the retention duty under Art. 958f of the Swiss Code of Obligations lies with you, we offer you the download of your invoices on the page for deleting your account; please download them beforehand.

No backup copy is kept beyond that. Deleted data may remain in our backups for up to 365 days; we use backups only to restore after a failure.

14. Applicable law and authoritative version

This coach privacy statement is governed by Swiss law (Federal Act on Data Protection, FADP). The place of jurisdiction is the seat of the operator in Switzerland.

The German version is the authoritative one. This English text is a translation provided for convenience. Where the two differ, the German wording applies.

15. Contact

For questions about this coach privacy statement please contact:

Email: contacts‍m‍a‍r‍t@maind.ch