The International ADHD Coach Training Center (iACTcenter) Privacy Policy

iACTcenter Privacy Policy

Last Updated: December 21, 2025

Your privacy is essential to us. At the International ADHD Coach Training Center (iACTcenter), we honor the trust you place in us by protecting your personal information with care, transparency, and respect.

This Privacy Policy explains how we collect, use, store, and safeguard your personal data under:

-The UK General Data Protection Regulation (UK GDPR)

-The EU General Data Protection Regulation (EU GDPR)

-The California Consumer Privacy Act (CCPA)

-The California Privacy Rights Act (CPRA)

-Other applicable global privacy laws

It also explains your rights regarding your data and how to exercise them.

If you have any questions, feel free to contact us directly at assist@iACTcenter.com. This Privacy Policy applies to students, prospective students, volunteer clients, and visitors who interact with our website, learning platforms, or training services.

1. Who We Are

The iACTcenter is an international ADHD Life Coach training school that offers International Coaching Federation (ICF) Accredited Level 1 and Level 2 coach training and education programs for the certification and ICF credentialing of ADHD (Attention Deficit Hyperactivity Disorder) Life Coaches.

We act as the Data Controller for the personal data we collect from students, prospective students, volunteer clients, and website/platform users.

2. Key Definitions

To help you understand this policy:

Personal Data: Any information that identifies or can identify you.

Processing: Any use of your data, including collecting, storing, sending, deleting, and analyzing.

Data Controller: The organization that decides why and how data is processed (iACTcenter).

Data Processor: A third party that handles data on our behalf (e.g., Google Workspace, Ontraport, Vimeo).

Data Protection Officer (DPO): A role required only for certain organizations under GDPR. The iACTcenter does not have a formally appointed DPO; however, our Director of Training oversees data protection matters (see Section 22).

Anonymization: Removing all identifying details so no one can tell who the data refers to.

Pseudonymization: Masking identities (e.g., “Student 14”, first name, last initial) but still possible to re-identify internally.

International Transfer: When your data is sent outside your home region (e.g., from the United Kingdom (UK)/European Union (EU) to the United States (U.S.).

3. What Personal Data We Collect

We only collect the information necessary to support your learning, run our programs, deliver the products and services you request, and fulfill certification, accreditation, and legal requirements. We do not gather data that isn’t needed, and we never sell your information.

3.1 Information You Provide Directly

This may include:

-Identity and Contact Information: name, email, mailing address, phone number

-Enrollment, registration, and application details

-Payment and Transaction Information: (encrypted and never visible to staff after processing) Billing details submitted during purchases or tuition payments—processed securely and never visible to staff after completion.

-Participation Records: (attendance, assignments, progress) Attendance, coursework, engagement in coaching labs, mentor coaching activities, and progress toward graduation.

-Mentor coaching recordings: audio/video sessions, transcripts, forms, and written materials that must be pseudonymized or minimized before submission to protect volunteer-client privacy.

–Final Performance Evaluation (FPE) materials: any recordings or written submissions required for program completion.

-Communications with faculty, staff, or administration: Emails, messages, questions, and feedback you share with us throughout your training journey.

We use this information only for its intended purpose—to support you as a student and uphold program, graduation, certification, and credentialing requirements.

3.2 Information Collected Automatically

When you visit our website or learning platforms, we may automatically collect limited data to help us operate securely and improve performance. This includes:

-device information

-cookie data (see our Cookie Policy)

-interaction patterns with our learning platforms

-website activity and page interactions

-website analytics (IP address, browser type, device identifiers, time zone)

This information helps us keep our systems functional, secure, and user-friendly.

3.3 Volunteer Client Information

Students are required to pseudonymize or minimize all volunteer-client information before submitting recordings or forms for mentoring, evaluation, and graduation. We do not knowingly process identifiable volunteer-client data. If identifiable client data is inadvertently submitted, we securely delete it upon discovery and may request resubmission of a pseudonymized/minimized version.

3.4 Sensitive Data

We do not intentionally collect health information or other special-category data. If you voluntarily share sensitive information, we will protect and process it in accordance with applicable data-protection requirements and with deep respect for your privacy.

4. How We Collect Personal Data

We want you to feel informed and confident about where your information comes from. We collect personal information in a few simple and transparent ways. We keep your data only as long as needed for the purpose you submitted it, and then we delete or anonymize it.

Most of the information we collect comes directly from you when you voluntarily share this with us through:

-our website

-enrollment or purchase forms

-program participation

-event registration

-direct communication with faculty or staff

4.1 Information You Provide Directly

You may provide Identity, Contact, Payment, Transaction, Survey, Marketing, or (occasionally) Special Information when you:

-fill out an application, form, or questionnaire

-enroll in a course or training

-purchase a product or digital resource

-participate in surveys

-subscribe to the newsletter

-reach out by email, phone, or other communication

We use this information only for the purpose you intended.

4.2 Newsletter Sign-Up

If you choose to join our newsletter, you provide your email address. You may unsubscribe or request the removal of your personal data at any time by emailing assist@iACTcenter.com. We honor these requests promptly and respectfully.

4.3 Enrollment, Registration, and Purchases

When you register for or purchase programs or services, we may request your:

-name

-email

-billing details

-phone number

-mailing address

All billing information is encrypted, securely processed, and not visible to staff after processing unless you request help updating a payment method.

4.4 Purpose-Based Collection

We use your data only for the purpose it was submitted. For example:

-If you inquire about a program, we answer your question.

-If no further services are requested, inquiry data is deleted after 90 days.

-If you later enroll or subscribe, your data is retained according to those purposes.

This supports clarity, autonomy, and respectful handling of your information.

4.5 Website Cookies and Technical Information

We may collect limited technical information through cookies or similar technologies to support essential functions and improve performance.

Example:
If you leave a comment on our site, you may choose to have your name and email saved so you don’t need to re-enter them next time.

You can manage your cookie preferences through your browser, our Cookie Settings, or by reviewing our Cookie Policy.

4.6 For Visitors in the European Union (EU) /European Economic Area (EEA) /the United Kingdom (UK)

For individuals joining us from these regions, all non-essential cookies are turned off by default. You may accept, reject, or customize them using our Cookie Banner.

4.7 Publicly Available Sources

We may receive limited identity or contact information from publicly available sources (such as the U.S. Securities and Exchange Commission), but only when appropriate and proportionate.

4.8 Third-Party Services

We may receive information from trusted service providers that support our educational and business operations, including:

-Website analytics tools (e.g., Google Analytics)

-Client Relationship Management (CRM) systems (e.g., Ontraport—billing and communication data)

-Course delivery, enrollment, communication, or support platforms (e.g., Vimeo)

All third-party providers are vetted for GDPR alignment, and Data Processing Agreements (DPAs) are maintained whenever required.

We do not share, sell, or rent your personal data.

5. Lawful Bases for Processing Your Personal Data

We process your personal information only when we have a clear and legally valid reason to do so. Under GDPR, these reasons—called lawful bases—help ensure that your data is handled responsibly, transparently, and in ways that support your relationship with the iACTcenter.

Our lawful bases include:

5.1Contractual Necessity

We use your information when it is necessary to provide what you have requested—your training, mentoring, evaluations, courses, services, certification support, or access to our learning community. Without this information, we cannot deliver the program you enrolled in.

5.2 Legitimate Interests

We may process specific data to support internal operations that help us maintain a safe, effective, and continually improving training environment. These interests include:

-program improvement and curriculum development

-internal administration

-maintaining security, fraud prevention, and platform integrity

We always balance these interests against your rights and reasonable expectations.

5.3 Consent

-For optional communications—such as newsletters, marketing updates, or invitations—you choose whether to receive them.

-If you give consent, you may withdraw it at any time by clicking unsubscribe or emailing assist@iACTcenter.com.

5.4 Legal Obligations

We may process data when required to comply with laws, accreditation standards, or regulatory requirements, including:

-financial and tax recordkeeping

-accreditation and audit requirements

-documentation required by coaching education standards

-responding to lawful requests

5.5 Anonymized and Aggregated Data

Sometimes we remove all identifying details from your information so it cannot be linked to you. Once data is anonymized, it is no longer considered personal data under GDPR.

We may use anonymized or aggregated data to:

-understand program trends

-strengthen curriculum and learning design

-improve services and student experience

-generate statistical reports

We use anonymized data respectfully and only to enhance our programs and support our learners.

5.6 Table: Lawful Bases for Processing Your Personal Data, Examples, and Retention Period

Lawful Basis (GDPR)	Types of Personal Data Processed	Examples of Processing Activities	Retention Period
Contract (Art. 6(1)(b))	Information required to deliver your program, coaching labs, mentor coaching, RaeNotes evaluations, training services, and certificates	• Payment details to enroll in iACTcenter programs • Student name, email, address, time zone for enrollment • Sending login links, class schedules, practicum details, and coaching lab reminders • Maintaining enrollment, participation, and training completion records • Scheduling mentoring sessions • Providing certificates, transcripts, and evaluation feedback • Participating in recorded curriculum components (classes, meetings, coaching labs) where recording is part of program delivery • Submitting mentor coaching and Final Performance Evaluation (FPE) recordings and evaluation materials required for program completion and accreditation	• 7 years unless otherwise required for accreditation
Consent (Art. 6(1)(a))	Information you choose to give voluntarily	• Opting into newsletters or event updates • Completing optional surveys, testimonials, or research participation • Agreeing to marketing communications • Allowing cookies (EU/UK visitors) • Optional replay access or optional recordings not required for training delivery (where offered)	• Until you withdraw consent, or if inactive for: • 24 months (industry) • Up to 6 years (iACTcenter)
Legitimate Interests (Art. 6(1)(f))	Information processed for expected educational, operational, and security purposes	• Using anonymized feedback for program improvement • Monitoring attendance for program completion • Evaluating coaching competency using RaeNotes • Fraud prevention and security monitoring • Protecting curriculum and intellectual property • Minimal archival records to verify past enrollment	• 7 years (iACTcenter) unless anonymized sooner
Legal Obligation (Art. 6(1)(c))	Information required for financial, tax, legal, or accreditation compliance	• Retaining financial and tax records • Maintaining invoices and bookkeeping files • Responding to regulatory or legal requests • Keeping documentation required for accreditation audits	• 7 years (U.S. & UK accounting regulations)
Vital Interests (Art. 6(1)(d))	Emergency contact details or information needed to protect someone’s life or safety	• Using a stored emergency contact if a student becomes unwell during a live session • Sharing limited information with emergency services if immediate harm is suspected	• Only as long as necessary for safety; deleted or returned afterward
Public Task (Art. 6(1)(e))	Not applicable to the iACTcenter (private organization)	• Used only by governmental or public-interest institutions; not relevant.	• N/A
Account Information	Username, login credentials, LMS profile details	• Setting up your school account • Managing your learning dashboard	• 7 years
Payment or Billing Information	Credit card, Stripe/PayPal transaction details, payment dates	• Processing tuition payments • Responding to payment disputes	• 7 years (legal requirement)
General Student Transaction Information	Details of sign-ups for programs, digital content, webinars, downloads	• Managing orders for digital content • Confirming program enrollment	• 6 years
Survey, Assessment & Quiz Information	Feedback, summative assessments, quizzes	• Improving curriculum and quality • Internal program review	• 7 years
Marketing Information	Communication preferences, opt-in history	• Sending newsletters, marketing updates	• Until you unsubscribe, or 36 months of inactivity
Website, Device & Technical Information	IP address, browser type, operating system, device settings, time zone, cookies	• Website analytics, troubleshooting, improving site navigation	• Up to 3 years

6. How We Use Your Personal Data

We use your data to:

-Provide and manage your training program

-Deliver mentor coaching and evaluations

-Support your iACTcenter certification and International Coaching Federation (ICF) credentialing pathway

-Monitor attendance, participation, and assessment records

-Communicate with you about your program

-Improve our curriculum, website, and student experience

-Ensure program integrity, safety, and confidentiality

-Meet accreditation and auditing requirements

6.1 Marketing, Outreach, Visibility

We may use limited personal information—such as your name, email address, or program engagement history—to better understand the reach and impact of our advertising and marketing efforts. This helps us improve the visibility of our programs, increase the accuracy of our outreach, and help reduce stigma around ADHD. We do not sell your personal data, and any marketing activities are based on the lawful basis of legitimate interest under the UK GDPR, carefully balanced with your right to opt out at any time. You may opt out of marketing-related communications at any time, and this will not affect your enrollment or required program communications.

This includes:

-Sharing program updates and educational information

We may communicate with you about your enrollment, upcoming classes, mentor coaching, evaluations, and relevant program updates. These communications are considered part of your training experience and are sent in accordance with our contractual obligation to support your participation.

– Providing optional newsletters, resources, and ADHD-related offerings

With your permission, we may send you newsletters, announcements, and information about ADHD resources, tools, or services that we believe may benefit you or your community. You will only receive these promotional communications where you have opted in, and you may unsubscribe at any time.

– Responsible marketing of our programs

With your consent (where required by law), we may use limited contact information to share updates about new programs, training opportunities, or events that may support your growth as a coach. These communications are always optional, and you may withdraw consent at any time by clicking “unsubscribe” or emailing assist@iACTcenter.com.

– Supporting our mission of reducing stigma and increasing global ADHD awareness

As part of our commitment to providing accurate and supportive ADHD education, we may use aggregated and anonymized data to better understand community needs, enhance our outreach, and increase the visibility and clarity of ADHD coaching worldwide. This is in pursuit of our legitimate interest in advancing our public educational mission and is never intended to identify you personally.

– As otherwise described in this Privacy Policy

We may also use your information for other purposes detailed in this Privacy Notice, always in alignment with GDPR and only when there is a clear, lawful basis.

7. Training Recording Policy & Coaching Demonstrations

Quick Summary

As part of our accredited ADHD Life Coach training programs, certain activities—such as mentor coaching, coaching demonstrations, and Final Performance Evaluations (FPE)—require reviewing recorded coaching sessions. These recordings support accurate, competency-based feedback, skill development, and compliance with International Coaching Federation (ICF) accreditation and audit requirements.

To support this process, the iACTcenter uses RaeNotes, a secure coaching-evaluation platform that enables structured competency scoring, timed transcripts, and evaluator feedback. RaeNotes operates on Amazon Web Services (AWS) using System and Organization Controls-2 (SOC-2) certified infrastructure, with encryption in transit and at rest.

We take privacy seriously. Only pseudonymized or minimized recordings are uploaded for evaluation, access is restricted to authorized faculty and evaluators, and recordings are retained only as long as necessary for training, evaluation, and accreditation purposes. Recordings are never used for marketing or public distribution without your explicit, separate permission.

When recordings involve volunteer clients, students are responsible for obtaining written permission and ensuring all identifying information is removed before submission. The iACTcenter does not knowingly process identifiable volunteer-client data.

International transfers of recordings (for example, from the UK or EU to the United States) are protected using approved legal safeguards, including Standard Contractual Clauses and strong technical security measures.

Additional details about recording purposes, safeguards, and student responsibilities are provided in the iACTcenter Student Recording, Transcription & Data Protection Agreement.

Our goal is to support your learning while honoring privacy, dignity, and applicable data-protection laws at every step.

More Details

7.1 RaeNotes and Other Evaluation Platforms

RaeNotes is a third-party service provider that acts as a data processor under Articles 28–29 of the GDPR. We use RaeNotes under a Data Processing Agreement and appropriate international-transfer safeguards where required. To protect privacy, we upload only pseudonymized or minimized materials (and, where feasible, anonymized materials) and restrict access to authorized roles.

Safeguards include encryption in transit and at rest, role-based access controls, confidentiality requirements, and vetted subprocessors.

7.1.1 RaeNotes Subprocessors (as of the date of this Policy)

RaeNotes’ published documentation confirms the use of the following third-party services within its processing chain: Amazon Web Services (AWS) for hosting and storage infrastructure; Stripe for payment processing; OnceHub for scheduling and booking; and analytics providers used to improve platform performance.

The complete list of RaeNotes subprocessors is available upon request from RaeNotes at support@raenotes.com. The iACTcenter maintains updated vendor records in accordance with its Data Protection Impact Assessment (DPIA), Vendor Review Log, and GDPR compliance obligations.

7.2 Lawful Bases for Recording and Evaluation

We process recordings only when there is a clear and lawful basis to do so. Depending on the context, our lawful bases may include:

7.2.1 Contractual Necessity (Art. 6(1)(b))

Recordings are used when they are necessary to provide the training, mentoring, evaluation, and certification components you enrolled in. This includes competency-based feedback, program completion requirements, and FPE assessment.

7.2.2 Legitimate Interests (Art. 6(1)(f))

We have a legitimate educational and quality-assurance interest in using a standardized, secure evaluation process that supports fair and consistent assessment, faculty calibration, program integrity, and accreditation requirements. These interests are balanced with strong safeguards, including minimization, restricted access, and documented retention schedules.

7.2.3 Accreditation and Audit Requirements

As an ICF-accredited Level 1 and Level 2 training provider, we must evaluate coaching demonstrations using structured, competency-based criteria. Recordings and evaluation documentation help us maintain calibrated assessment practices and provide audit-ready evidence where required.

7.2.4 Consent (Volunteer Clients and Optional Recordings)

When recordings involve volunteer clients, explicit written permission is required before recording. Students are responsible for obtaining this consent and ensuring the recording is appropriately pseudonymized or minimized before submission, in accordance with iACTcenter guidance. Where consent is the lawful basis, it may be withdrawn for future recordings.

7.3 Privacy Safeguards and Responsibilities

7.3.1 Storage, Access, and Retention

Access to recordings is limited through role-based permissions and purpose-specific authorization. Authorized roles may include iACTcenter faculty, mentors, evaluators, administrators with a defined role, accreditation reviewers, and the student whose work is recorded.

Recordings are retained only as long as necessary to meet training, evaluation, accreditation, and legal requirements and are deleted in accordance with documented retention schedules (see Section 10.2: Data Retention).

7.3.2 Student Responsibilities for Submitted Recordings

To protect the privacy of volunteer clients and third parties, students agree to pseudonymize or minimize volunteer-client information before submission (and anonymize where possible), submit only the portion of a recording necessary for assessment, use only clients who have provided written permission for recording for coaching education purposes, and ensure no unnecessary third-party personal information is included.

The iACTcenter does not knowingly process identifiable volunteer-client data. If identifiable data is inadvertently submitted, it will be securely deleted upon discovery, and a resubmission of a pseudonymized or minimized version may be requested.

7.3.3 Resubmission and Administrative Review

If a submission does not meet required data-minimization standards and must be reviewed and resubmitted, an administrative processing fee may be applied, where permitted by law, to cover additional staff time.

7.3.4 Options for Students in GDPR Regions

Students located in GDPR-covered regions (EU, UK, and EEA) may choose to pseudonymize themselves in recorded sessions (for example, using initials or a first name only). They may choose whether to appear on video where appropriate. These options are voluntary and do not affect participation, evaluation outcomes, or program standing.

7.3.5 Data Security

Recordings and related evaluation materials are stored in secure, industry-standard, GDPR-aligned environments, including Zoom, Google Workspace, Vimeo Enterprise, and RaeNotes. Data is encrypted in transit and at rest, and access is limited based on role and purpose.

7.3.6 Chat Protection

Chat data is handled with care. Raw chat is not retained. Where necessary, faculty may temporarily access chat solely to create anonymized records for training purposes. Students may not download, distribute, or publish chat content.

7.3.7 Transcription and Text-Based Processing of Recordings

To protect the privacy, confidentiality, and integrity of all participants, the iACTcenter does not routinely create, store, or distribute transcripts of coaching recordings, including coaching labs, mentor coaching sessions, or Final Performance Evaluations (FPE).

Coaching conversations may include personal, sensitive, and sometimes identifiable information. Converting recordings into text introduces an additional layer of data processing that increases accessibility and searchability, while also increasing the potential for unintended distribution beyond the original context of the session.

In alignment with GDPR and UK GDPR principles—particularly data minimization—we limit the processing of recordings to what is necessary for training, mentoring, evaluation, and accreditation purposes. Text-based formats such as transcripts are not required for these purposes and are therefore not generated as part of our standard practices.

Where transcription functionality may exist within third-party platforms (such as Zoom), it is not enabled, retained, or distributed by the iACTcenter as part of our official data practices. Recordings are instead securely stored and accessed through approved platforms, including Vimeo Enterprise and other GDPR-aligned systems, without generating transcripts.

Students may choose to create personal notes or learning aids from recordings. However, the use of third-party transcription tools may involve additional data processing, storage, or transfer outside of iACTcenter-controlled systems. Any such use is the responsibility of the individual and must be handled in accordance with confidentiality expectations, written consent agreements, and applicable data-protection laws.

The iACTcenter does not assume responsibility for data processing conducted outside its approved systems and encourages all participants to use discretion and care when engaging with external tools.

7.3.8 No Marketing Use Without Separate Permission

Training, mentoring, and evaluation recordings are never used for marketing, public distribution, or promotional purposes without your explicit, separate permission (for example, a media release).

7.4 How Long We Keep Recordings

Recordings are retained only long enough to complete mentor coaching evaluations, FPE scoring, applicable appeal windows, certification, credentialing, and accreditation or audit requirements. After this period, recordings are securely deleted or, where appropriate, irreversibly anonymized. If a longer retention period is required by law or an accrediting body, that requirement is documented and honored (see Section 10: Data Retention).

7.5 International Transfers and Safeguards

When recordings or evaluation data are transferred from the UK or EEA to the United States (or another country without an adequacy decision), we apply appropriate safeguards, including EU Standard Contractual Clauses (SCCs), the UK International Data Transfer Addendum (IDTA), or the UK Addendum to the EU SCCs, where applicable.

Additional technical and organizational safeguards include encryption in transit and at rest, role-based access controls, audit logging, least-privilege access, and confidentiality agreements.

7.6 Who Can Access Recordings

Access is limited to individuals who genuinely need it for training and evaluation purposes, such as iACTcenter faculty and assessors, accreditation reviewers, and authorized contractors operating under written confidentiality and data-processing agreements. No other access is permitted.

7.7 Your Choices and Rights Related to Recordings

You have the right to know when and why a session is being recorded; to request alternatives where feasible (for example, turning off video, private submission, or a separate coaching demonstration); to request access, correction, or deletion of your personal data where applicable; and to restrict or object to processing based on legitimate interests.

Where consent is the lawful basis, you may withdraw consent for future recordings. To exercise these rights, contact assist@iACTcenter.com. If you are located in the EEA or UK, you may also contact your local data-protection authority.

7.8 Security and Protection of Your Recordings

Recordings are protected through encrypted storage and transfer, secure cloud environments, role-based access, strict confidentiality obligations, and documented deletion procedures. When third-party platforms such as RaeNotes or Zoom are used, appropriate contractual, privacy, and security protections are in place.

Your recordings are treated with the highest level of care, professionalism, and respect.

8. How Your Information Is Stored and Protected

8.1 Secure Storage

Your information is stored in secure customer-relationship systems, encrypted databases, and system log files located within the United States and the European Economic Area (EEA). When personal data is transferred outside these regions, we implement appropriate safeguards consistent with UK GDPR requirements, including Standard Contractual Clauses approved by the UK Information Commissioner’s Office.

While we do not sell your personal data, we do share information with trusted service providers—such as payment processors and secure learning platforms—who are contractually required to process your information only as necessary to deliver our services and support the operation of our training programs.

8.2 International Data Transfers

The iACTcenter is based in the United States. This means that if you live in the United Kingdom (UK), the European Union (EU), or another region with data-protection laws, some of your personal information may be transferred outside your home country to provide your training, mentoring, and learning platforms.

We understand how important it is for you to feel confident and informed about how your data is handled across borders. To safeguard your information, we rely on legally approved transfer mechanisms recognized by UK GDPR and EU GDPR, including:

EU Standard Contractual Clauses (SCCs)

These are European Commission–approved contracts that require any organization processing your data outside the EU to meet strict data-protection standards.

UK International Data Transfer Agreement (IDTA)

For learners in the UK, this agreement sets out additional protections to ensure your personal information remains safe when transferred internationally.

UK Addendum to the SCCs

When appropriate, we use the UK Addendum alongside the SCCs to ensure full compliance with UK GDPR requirements.

Encryption, Anonymization, And Internal Privacy And Security Procedures

In addition to these legal tools, we protect your information through encryption, restricted access, secure storage, and strong internal privacy practices. These safeguards help ensure your data remains protected whether it is stored or processed in the U.S. or abroad.

In short:

We use internationally recognized protections, so your personal information stays secure, respected, and handled with care—no matter where it travels to support your learning experience.

9. Use of Third-Party Service Providers (Processors & Subprocessors)

We use trusted third-party services under signed Data Processing Agreements (DPAs), including:

Google Workspace (Business/Education)—secure storage, communication, and student records

Zoom—live virtual classes (restricted recording and privacy settings enabled)

Vimeo Enterprise—encrypted video hosting

RaeNotes is a pseudonymized, minimized coaching evaluation platform (SOC-2 certified, AWS-hosted). RaeNotes acts as a data processor under a Data Processing Agreement and appropriate international-transfer safeguards. Only anonymized or minimized evaluation materials are uploaded, with restricted access.

Ontraport—CRM and email delivery

Stripe / PayPal—secure payment processing

Analytics providers—website performance insights

Each vendor is vetted for privacy compliance, encryption, access controls, and international transfer mechanisms.

10. Data Retention

We keep your personal information only for as long as it is genuinely needed—for learning, mentoring, certification, accreditation, legal, tax, or administrative purposes. Once information is no longer required, we securely delete it or fully anonymize it so it cannot be connected to you.

Retention periods and deletion timelines for training, mentoring, and Final Performance Evaluation (FPE) recordings are described in Section 7 and the iACTcenter Data Retention Schedule below. These are applied consistently across all platforms, including RaeNotes and our secure cloud systems.

We want you to feel confident in knowing exactly how long different types of information are kept and why.

10.1 How We Determine Retention Periods

Our retention periods are based on:

-what the information is used for,

-accreditation and certification requirements (including ICF audits),

-legal and financial recordkeeping obligations, and

-Our commitment is to keep only what is necessary to support your training journey.

10.2 Specific Retention Timelines Table: iACTcenter Data Retention Schedule

Material	Retention	Reason	Disposal
Identity and Contact Information	Retained for up to 7 years after your last interaction with us	To respond to inquiries, verify past training, support certificate validation, manage alumni records, and comply with accreditation, audit, and legal requirements.	Secure deletion or anonymization once retention period expires, unless required longer by law or accreditation.
Financial and Payment Records	7 years, as required by U.S. accounting standards and UK tax law	Mandatory legal, tax, and accounting retention obligations.	Secure deletion following expiration of statutory retention period.
Marketing Preferences & Consent History	Retained for up to 6 years from your last interaction or until you withdraw your consent	To honor your communication choices, demonstrate consent compliance, and maintain accurate marketing and outreach records.	Secure deletion or anonymization upon withdrawal of consent or expiration of retention period.
Email Correspondence	6 years, depending on purpose	To support student services, administrative operations, dispute resolution, and training documentation.	Secure deletion or anonymization based on purpose and retention timeline.
Mentor Coaching Demonstration Recordings	Program completion + 1 year unless required for certification, credentialing, accreditation, audit or legal purposes.	To support mentor feedback, appeals, and internal quality assurance following program completion.	Secure deletion after the retention period.
Evaluator Notes	Evaluator Notes — Program completion + 1 year unless required for certification, credentialing, accreditation, audit, or legal purposes	To support assessment transparency, appeals, evaluator calibration, and accreditation quality assurance.	Secure deletion after the retention period.
Final Performance Evaluation (FPE) Recordings	6 years (ICF audit and accreditation review)	Required to meet International Coaching Federation (ICF) audit, accreditation, and quality-assurance obligations.	Secure deletion or irreversible anonymization after the retention period.
Final Evaluations (Written Assessments)	6 years (ICF audit)	Required to evidence competency-based evaluation, support audit requests, and document certification decisions.	Secure deletion after the retention period.
RaeNotes Copies	Deleted within 30 days of graduation	To minimize data storage while allowing sufficient time for final evaluation confirmation and appeals.	Secure deletion from the RaeNotes platform and associated storage locations.
Enrollment, Participation, and Training Records	6 years after the completion of your program	Required for accreditation audits, quality assurance, verification of coach training hours, and credential pathway documentation.	Secure deletion or anonymization after the retention period, unless further retention is legally required.
Website Analytics, Cookies & Technical Logs	Retained for up to 3 years, depending on the tool	To analyze site performance, maintain security, prevent fraud, and improve learner experience.	Automated deletion or anonymization according to tool-specific retention settings.

All recordings must be pseudonymized or minimized before submission. Recordings are not used for marketing or public distribution without explicit, separate permission (for example, a media release).

10.3 Secure Deletion and Anonymization

Once retention periods have passed, data is:

-securely deleted, or

-anonymized, so it can no longer identify you.

Anonymized data may be used for curriculum development, statistical reporting, or quality improvement—always without identifying any individual student.

10.4 Your Right to Request Deletion

You may request deletion of certain personal information earlier, where applicable under GDPR. We will explain what can be deleted immediately and what must be retained temporarily for legal or accreditation reasons.

When data is no longer needed, we securely delete or fully anonymize it.

11. Security Measures

We take security seriously. Our safeguards include:

-Anonymization (in transit and at rest)

-Encryption (in transit and at rest)

-Multi-factor authentication

-Staff access controls

-Secure deletion protocols

-Encrypted file uploads

-Annual privacy and security training for faculty

-Approved vendor audits and Data Processing Agreements (DPAs)

-Breach response procedures

If a data breach poses a risk to your rights, we notify you within 72 hours as required by law.

12. Your Privacy Rights

If your request relates specifically to training or evaluation recordings, please see Section 7 for details about what can be accessed, corrected, deleted, or restricted under our evaluation workflow.

12.1 If You Live Where GDPR/UK GDPR Applies to You, You Have the Right to:

-Right to request access: This is your right to obtain a copy of the personal information that we hold about you. We must also provide you with additional information in response to these requests to help you understand how your personal information is used.

-Right to data portability: This right allows you to request that we transfer your personal information to another person or organization. In certain circumstances, you have the right to object to processing where such processing involves profiling (including profiling for direct marketing purposes).

-Right to object (including objection to Legitimate Interests): you may object to us processing your personal information for direct marketing. You can also challenge our processing of your personal data based on Legitimate Interests if your specific circumstances warrant it with your Data Protection Authority.

-Right to correction: You may request the correction of any incorrect personal data and the completion of any incomplete personal data.

-Right to erasure: (this is often called the ‘right to be forgotten’). This right only applies in certain circumstances. Where applicable, you may request that we erase all of your personal information.

-Right to restrict processing: this right only applies in certain circumstances. Where applicable, you may request that we restrict the processing of your personal information.

12.2 How to Exercise Your Privacy Rights

To request access, correction, deletion, or to ask questions about this policy, please contact: assist@iACTcenter.com. We may need to verify your identity to protect your privacy. We honor these rights with transparency, care, and respect.

13. Marketing Preferences

You are always in control of what you receive from us. We want our communication with you to feel supportive, relevant, and never overwhelming. You may adjust your preferences at any time, and we will honor your choices with care and respect.

13.1 Unsubscribing From All Marketing Messages

If you no longer wish to receive any promotional or optional communications, click the “Unsubscribe” link found at the bottom of any email. You may also email us at assist@iACTcenter.com, and we will remove you from our marketing lists. This will not affect your enrollment or access to required program communications.

13.2 Opting Out Of Promotional Messages Only

If you prefer to stop receiving promotional updates—such as new programs, events, or ADHD-related resources—while still wanting educational content, update your preferences using the link in our emails or contact us directly. We will ensure you receive only the types of messages you choose.

13.3 Keeping Educational and Program-Required Messages Active

Even if you opt out of marketing messages, you will continue to receive essential educational communications related to your program, including class reminders, mentor coaching information, evaluation updates, and necessary administrative notices. These are sent under our contractual obligation to support your training and cannot be unsubscribed from while you are enrolled.

We honor your preferences.

-Right to correction: You may request the correction of any incorrect personal data and the completion of any incomplete personal data.

-Right to restrict processing: this right only applies in certain circumstances. Where applicable, you may request that we restrict the processing of your personal information.

14. Cookies & Tracking Technologies

We use cookies to improve website functionality and user experience.

Our Cookie Policy explains:

-Types of cookies used

-Why we use them

-EU/UK cookie banner requirements

-How to manage preferences

15. Children’s Privacy

Our programs are designed for adults 18+. We do not knowingly collect data from children. If we learn that we have received children’s information, we securely delete it.

16. When We Share Your Data

We only share your personal information when it is necessary, appropriate, and aligned with our commitment to protect your privacy at every step of your learning journey. We never sell your personal data. Any sharing is limited to the following trusted groups:

Authorized IACTcenter Faculty and Staff 28(3)(b), Art. 32(4)

iACTcenter faculty, staff, and contractors are required to follow this Privacy Policy and to sign confidentiality and data-protection agreements as a condition of their work with us. They may access personal information only when necessary to perform their training or administrative responsibilities. They access your information only when needed to support your training, mentoring, evaluations, or program participation.

Accredited Mentor Coaches and ICF Evaluators

When required for your mentor coaching or Final Performance Evaluation, limited information may be shared with accredited mentor coaches or independent ICF evaluators. They receive only what is essential to complete their role and are bound by strict professional confidentiality requirements.

Approved Third-Party Service Providers (Processors)

We work with carefully vetted providers—such as secure learning platforms, video hosting tools, CRM systems, and payment processors—who process data on our behalf Data Processing Agreements (DPAs). These agreements require them to:

-follow our instructions only,

-maintain strong security measures, and

-Never use your data for their own purposes.

Legal or Regulatory Disclosures

In rare situations, we may be required to share certain information to comply with laws, accreditation standards, tax or audit requirements, or a lawful request from a regulatory authority. When this happens, we share only what is necessary and always with your privacy in mind.

Potential Business Transfers

If the iACTcenter is ever involved in a merger, acquisition, restructuring, or sale of all or part of our business, we may disclose relevant personal information to the prospective purchaser. If this occurs, we will ensure that your information remains protected in accordance with this Privacy Policy.

We share information only as described in this Privacy Policy and only when necessary to deliver your training, meet accreditation or legal requirements, or operate our learning platforms responsibly.

17. Automated Decision-Making

Automated decision-making means that a decision is made automatically without human involvement. The iACTcenter does not use automated decision-making or profiling for student evaluation, admissions, or program progression.

18. Links to Other Websites (Third-Party Websites)

Our website may include links to other sites. If you click on these links, they will direct you to third-party websites. We are not responsible for the privacy practices of these linked sites, nor do we endorse or guarantee the accuracy of the information they contain. These sites may collect your personal data. To understand how they collect, use, or protect your information, please review their privacy policies.

19. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our programs, legal requirements, or technology. Updates take effect upon publication. We encourage you to review this page from time to time so you always feel informed and supported.

20. Copyright, Ownership Notice, and Intellectual Property Notice

All materials on the iACTcenter site (as well as the organization and layout of the site) are owned and copyrighted by iACTcenter, LLC © Copyright 2015–2026, all rights reserved. No reproduction, distribution, or transmission of the copyrighted materials on this site is permitted without the written permission of the iACTcenter. The iACTcenter owns its training materials and website content. While we may update our privacy policies from time to time, we will always continue to protect your personal information with care, clarity, and respect.

21. Contact Us

If you have questions, please reach out to us at: assist@iACTcenter.com

📍 Blaine, Washington, USA

22. Data Protection Contact

We do not have a formally appointed Data Protection Officer (DPO). However, our Director of Training oversees data protection matters within the iACTcenter and ensures that the practices described in this Privacy Notice are followed throughout our organization.

If you have any questions, feel free to contact us directly at assist@iACTcenter.com.

This Privacy Policy applies to students, prospective students, volunteer clients, and visitors who interact with our website, learning platforms, or training services.

We are committed to conducting our business in accordance with this privacy policy to ensure the confidentiality and protection of your personal information.