Privacy policy Declaration

UPDATED ON 15 OCTOBER 2025

SUMMARY

Here is a quick rundown of our Privacy Policy Declaration to help you understand how we handle your information. When you visit our website, contact us, or use our services, you confirm that you have read and understood our full Privacy Policy below. Consent will only be requested where required by law (e.g., for marketing emails or cookies)

What is this policy about?

This policy explains what personal information we collect from you, how and why we collect it, how we protect it, and who we share it with. It also informs you about your rights regarding your personal information.

What information do we collect?

To provide the services you request, we collect personal details such as your First Name, Last Name, Email Address, Physical Address, and Telephone Number.

When you visit our website, data from your computer is also collected and stored by our website platform provider.

We use third-party applications and platforms that might also collect information about you. Our full Privacy Policy lists these applications and platforms.

How do we process your information?

We always process your personal data according to the purposes outlined in our Privacy Policy.

Why do we process your information?

We process your personal information only with your consent, as part of a contract with you, or when necessary for our legitimate interests, which are detailed in our Privacy Policy.

What are your rights?

You have the right to access the data we have about you. You can also restrict or object to our processing of your personal data. Additionally, you can request that we erase, correct, or transfer your personal data to someone else.

If you are subscribed to our newsletter, you have the right to unsubscribe or opt out of our email marketing. Legally, you can appeal any decisions we make regarding the processing of your personal information.

Do we sell your information?

Absolutely not!

How do we protect your data?

Yes, we have protective measures in place. You can read about them in our full policy.

What if you have complaints about our data handling?

You should contact the Data Protection Authority in your area. Full details are provided below.

How will you know if we change this policy?

We will inform everyone on our email list. If you are not on our list, you can check the date of the last update on our website. By using our services or visiting our website after that date, you are agreeing to the updated policy.

FULL PRIVACY DECLARATION OF CAJOLI BY ANOUK O'LEARY

The following data protection declaration applies to Cajoli, www.cajolicoaching.com and its sub-domains, affiliated sites, and Cajoli’s pages and accounts on Facebook, Instagram, LinkedIn, and Whatsapp. (“Website”/”Site”/“Websites”/”Sites”).

It defines the principles under which we process all personal data that we collect from you or that you provide. We respect your privacy choices and understand your need to keep your personal information confidential. We are committed to safeguarding all information we collect from you when you use or access our content, services, and/or products.

Our commitment to protecting your privacy and ensuring transparent communication aligns with the principles of legal fluency that drive our business practices.

If you are a User, visitor, viewer, subscriber, client, and/or customer of our Sites (referred to collectively as “User,” “You,” or “Your”), please read this Privacy Policy in its entirety before using, viewing, downloading, purchasing from, or accessing our Site, content, services, and/or products.

By using our Sites, you acknowledge this Privacy Policy. We rely on the specific lawful bases set out below (e.g., contract, legitimate interests, consent where required, or legal obligation).

If you do not acknowledge these terms, please do not access our Sites or engage any of our Services.

General Information about the collection of personal data and provider identification

1. Personal data includes all information that relates to an identified or identifiable individual, such as names, addresses, email addresses, User behavior, and similar data.

2. By consenting to our use of cookies in accordance with this policy when you first visit our website, you permit us to use cookies on subsequent visits.

3. These Sites and Cajoli by Anouk O'Leary are represented by Anouk O'Leary (“I”/ “We”/ “Us”/“Our”) and located in Farbstrasse 17 8800Thalwil, Switzerland. You can contact us at anouk.cajoli@gmail.com.

WHAT DO WE COLLECT?

We collect, store, and use the following personal data:

1. Personal Identification Information (First Name, Last Name, Date of Birth, E-mail Address, Physical Address, Telephone/Mobile Number)

2. Billing and Payment Information (Billing and Shipping Address, Payment Details processed by our payment service provider; we do not store full card numbers, only limited identifiers such as last four digits and expiry date)

3. Booking and Scheduling Data (Date and time of booked sessions, time zone, preferences)

4. Communications Data (Emails, chat messages, support requests, and notes exchanged before, during, or after calls)

5. Social Media Data (Social media handles, public interactions such as comments, tags, or direct messages)

6. Technical and Location Data (IP address, device/browser information, approximate location)

7. Other Voluntary Information (Any additional data you choose to provide when engaging with our services)

We also collect, store, and use data regarding your behavior, such as purchase data and information from your computer, including your IP Address, Geographical Location, Browser Type, Time Zone, Operating System, Browser Version, Pages on our Site that you visit, the time and date of your visit, and the duration spent on those pages.

Additionally, we collect information from any communications you send to us via email or through our website, including the content and metadata of such communications.

HOW DO WE COLLECT YOUR PERSONAL DATA?

In most instances, you provide us with the data we collect. We collect and process data when you:

1. Subscribe to our e-mail list or newsletter.

2. Purchase anything from our Sites.

3. Contact us through e-mail or the contact button on our Sites.

4. Leave a review or feedback.

5. Allow us to interview you.

We collect information about your computer, including your IP address, geographical location, browser type and version, and operating system through automated data collection technologies, including Google Analytics, Cookies, and similar methods, as detailed below. This means we are already collecting this data when you browse our Site.

We collect communication content and metadata when you post it to our Sites or mobile application, and when our website generates metadata in connection with your communication.

Before disclosing the personal information of another person to us, you must obtain that person’s consent to disclose and process their personal information in accordance with this policy.

OUR LEGAL BASIS FOR COLLECTING AND PROCESSING YOUR INFORMATION

Personal data that you voluntarily submit to us through our Site or other means will be used for:

1. Enabling your use of the services available on our sites – Performance of a contract.

2. Processing your orders – Performance of a contract.

3. Supplying services you purchased from us – Performance of a contract.

4. Sending newsletters if you subscribe - Consent (you may withdraw at any time).

5. Sending marketing communications related to our business or carefully selected third parties – Consent for electronic marketing (email, SMS) and legitimate interests for postal marketing; you may opt out at any time.

6. Administering our sites and business operations.

7. Personalizing our site for you – Consent (cookies) and legitimate interests (user experience)

8. Providing third parties with aggregated or anonymized statistical information about our Users – Legitimate interests; this data does not identify individuals.

9. Sending non-marketing commercial communications.

10. Sending you email notifications that you have specifically requested.

11. Handling inquiries and complaints made by or about you relating to our site, products, or services – Legitimate interests and, where applicable, performance of a contract.

12. Keeping our sites secure and preventing fraud – Legitimate interests and legal obligations.

13. Verifying compliance with the terms and conditions governing the use of our sites (including monitoring private messages sent to us through our site’s private messaging service).

14. Complying with legal obligations (e.g., accounting, consumer law, data protection) – Legal obligation.

15. Protecting the life or physical safety of the data subject – Vital interests.

If you submit personal information for publication on our site, we will publish and otherwise use that information in accordance with the license you grant us.

Without your express consent, we will not provide your personal information to any third party for their direct marketing, or for any other third party's marketing purposes.

WE WILL DISCLOSE YOUR PERSONAL INFORMATION IN THE FOLLOWING INSTANCES:

We will never sell or trade your personal information.

We may disclose your personal information to any of our employees, insurers, professional advisers, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy.

We will disclose your personal information when required by institutions for purposes of completing further education and/or certification (e.g., International Coaching Federation). The personal information shared will be minimized and, where possible, will not readily identify you.

We will disclose your personal information under the following circumstances:

As required by law.
In connection with any ongoing or prospective legal proceedings.
To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention and credit risk reduction.
To the purchaser (or prospective purchaser) of any business or asset that we are selling or considering selling; and
To any person whom we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would likely order disclosure of that personal information.

Except as provided in this policy, we will not provide your personal information to third parties.

DETAILS ABOUT OUR PLATFORM AND SERVICE PROVIDER

Our website is hosted by Squarespace (“Host”). Our Host provides us with an online platform to host our blog and sell our products and services.

Your data may be stored through our Host's data storage, databases, and general applications.

Our Host and other service providers may use analytical tools to measure traffic and usage trends for our website. For example, when you visit our website, our Host will collect the following information:

The IP address of the computer or device you are using to visit our website,
The date and time of access,
The name and URL of the data accessed,
The website from which access is made to our domain,
Your computer's operating system and the browser you use,
The country from which you access our website, and
The name of your internet service provider.

Your data may be processed by our Host in accordance with its Privacy Policy, which can be found here: https://www.squarespace.com/privacy. We encourage you to review their policy.

INTERNATIONAL DATA TRANSFERS

The information we collect may be stored, processed, and transferred between any countries where we operate in order to utilize the information in accordance with this policy. This means your personal information may be transferred to, stored in, and processed in jurisdictions other than where you reside.

Specifically, the information we collect may be transferred and/or processed in Switzerland, The European Union, The United Kingdom, and The United States.

· Data Privacy Framework (EU/UK/Swiss): Where recipients in the U.S. are certified under the EU–U.S. Data Privacy Framework (DPF), its UK Extension, or the Swiss–U.S. DPF, we rely on those certifications as adequacy mechanisms (GDPR Art. 45; FADP).

· Standard Contractual Clauses (SCCs): If a recipient is not DPF-certified, we use the European Commission’s SCCs (and, where applicable, the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the SCCs, and the Swiss FDPIC-approved SCCs), together with supplementary measures informed by a Transfer Impact Assessment (TIA).

· Other adequate countries: Where transfers are made to countries recognized by the European Commission or the Swiss Federal Council as providing an adequate level of protection, those adequacy decisions serve as the transfer mechanism.

We maintain records of our transfer mechanisms and will update this Policy if the legal frameworks change (e.g., DPF invalidation or adoption of new SCCs).

Personal information that you publish on our sites or submit for publication on our sites will be accessible via the Internet worldwide. We cannot prevent the use or misuse of such information by others.

WHAT ARE YOUR RIGHTS?

1. Right to Access. You have the right to request copies of your personal information from us, subject to the following:

· The supply of appropriate evidence of your identity, such as a photocopy of your passport.

· You have the right to obtain confirmation as to whether we process your personal data and, if so, to access that data. Requests are free of charge. However, if a request is manifestly unfounded, excessive, or repetitive, we may charge an administrative fee of 25.00 Swiss Francs (CHF) Swiss Francs (CHF) or refuse to act on the request, as permitted by law.

· We may withhold the personal information you request to the extent permitted by law.

· You may instruct us at any time not to process your personal information for marketing purposes.

· You also have the right to lodge a complaint with your local supervisory authority if you believe we have violated data protection laws (GDPR Art. 77; FADP Art. 32).

2. Right to Erasure. You may request deletion of your personal data in the circumstances set out in GDPR Art. 17 / FADP.

3. Right to Withdraw Consent: Where we rely on consent (for example, non-essential cookies), you may withdraw it at any time, without affecting the lawfulness of processing before withdrawal.

4. Right to Restrict Processing. You have the right to request that we restrict the processing of your personal information under certain conditions.

5. Right to Object to Processing. You may object at any time to our use of your personal data for direct marketing (we will stop immediately). You may also object to processing based on legitimate interests; in such cases, we will stop unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

6. Right to Data Portability. You have the right to request that we transfer the data we have collected to another organization or directly to you, under certain conditions.

7. Right to Rectification. You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete information you believe is incomplete.

8. Right to Opt-Out. We only share your information with third parties for marketing with your consent (opt-in). You can withdraw your consent (opt-out) at any time by contacting us at anouk.cajoli@gmail.com or using the provided unsubscribe tools. We have thirty (30) days to respond to your request.

We may deny your requests in certain instances; for example, if we cannot verify that you are the owner of the information, or if we are legally required to retain a copy of the personal information. In such cases, we will communicate this fact to you in writing.

Legally, you may appeal our decision by responding to the communication denying your request.

YOU HAVE A RIGHT TO UNSUBSCRIBE

If you wish to unsubscribe from our email list at any time, please send an email to anouk.cajoli@gmail.com or follow the instructions provided at the bottom of every email we send.

Our email service provider allows us to segment and tag our leads. As a result, it is possible that you may be part of several segments or lists, particularly if you interact with us through different methods. For example, you might have sent an inquiry, downloaded a lead magnet, watched a specific presentation, or purchased a particular service or product. Consequently, when you unsubscribe using the link in an email, you may only be unsubscribing from a specific segment or list.

To completely unsubscribe from all of our lists, you may need to send an email to anouk.cajoli@gmail.com.

HOW DO WE RESPOND TO “DO NOT TRACK” REQUESTS?

We do not respond to legacy “Do Not Track” signals, as no industry standard exists. However, where required by law (e.g., California CPRA), we honor browser-based opt-out preference signals such as Global Privacy Control (GPC) for opting out of “sale” or “sharing” of personal information.

HOW LONG DO WE RETAIN YOUR DATA?

We retain data for as long as necessary to fulfill the purposes for which it was collected. We may keep your data even after a particular matter or exchange has concluded, solely for record-keeping purposes and to respond to queries.

Notwithstanding the other provisions herein, we will retain documents, including electronic documents, that contain personal data under the following conditions:

1. To the extent required by law.

2. If we believe the documents may be relevant to any ongoing or prospective legal proceedings.

3. To establish, exercise, or defend our legal rights, including providing information to others for fraud prevention and credit risk reduction.

Accounting and contract records may be retained for up to ten (10) years to comply with legal obligations. Marketing and analytics data will be deleted or anonymized sooner, especially if you withdraw consent. Other data is retained only as long as necessary for the purposes set out in this Privacy Policy.

If you request that we stop sending you marketing communications or unsubscribe from our email list, we will retain certain details, such as your name, to ensure that you are not contacted again.

SECURITY OF YOUR PERSONAL INFORMATION

1. www.cajolicoaching.com uses SSL/TLS encryption for security reasons and to protect the transmission of confidential content. Third parties cannot read the data you transmit to us.

2. We will take appropriate technical and organizational measures to protect your personal information against unauthorized access, loss, misuse, alteration, or disclosure, in line with GDPR Art. 32 and FADP Art. 8.

3. As we use our Host’s platform for our website, we are subject to the processes used by our Host to protect your data, including the use of firewalls and encryption for payments.

4. We primarily operate digitally; if physical documents are created, they are stored securely and destroyed when no longer required.

5. You acknowledge that transmitting information over the Internet is inherently insecure, and we cannot guarantee the security of data sent over the Internet.

6. You are responsible for keeping the password you use to access our Sites. We will not ask you for your password except when you log in to our website.

Data Breach Notification

Where we become aware of a personal data breach, we will assess its risks and notify the competent supervisory authority within the applicable legal timeframe (e.g., GDPR/UK GDPR) and notify affected individuals where required by law (including under FADP and applicable laws where you reside).

COOKIES AND TRACKING TOOLS

Cookies

Our Site uses cookies. These small text files allow us to store specific, User-related information on your device while you are using our Site. Cookies enable us to determine the frequency of use and the number of Users of the pages on our Site, as well as to analyze the behavior of our Site Users. They make our offerings more User-friendly.

Cookies are stored beyond the end of a browser session and can be retrieved when you revisit the Site. If you prefer not to have cookies stored, you should adjust your internet browser settings to refuse cookies.

We have a separate cookies policy that explains what cookies we use and how you can choose to accept or reject them. You can read it here.

You can also delete cookies. If you are in Europe, you can learn more about how to delete cookies at www.youronlinechoices.com.

Note, however, that deleting cookies may negatively impact the usability of many websites.

We Use Google Analytics (GA4)
We use Google Analytics 4 to analyze Site usage. In the EU/UK/Switzerland, we deploy Analytics only after you give consent via our cookie banner. We enable IP anonymization and limit data retention where available. Where Google transfers data to the U.S., we rely on Google’s participation in the EU-U.S. DPF/UK Extension/Swiss-U.S. DPF (where applicable) or SCCs with supplementary measures. You may opt out using the Google Analytics opt-out add-on.

OPT-OUT OF TARGETED ADVERTISING

You can opt-out of targeted advertising by visiting the following websites:

Network Advertising Initiative (NAI): http://www.networkadvertising.org/choices/

Digital Advertising Alliance (DAA): http://www.aboutads.info/choices/

PRIVACY POLICY ON CHILDREN

Our Sites are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If you are under 18, please do not provide any information on our Sites.

If you are a parent or guardian and believe that your child has provided us with personal information, please contact us.

If we become aware that we have collected personal data from anyone under the age of 18 without verifying parental consent, we will take steps to remove the information from our system.

WE WILL NEVER SELL YOUR INFORMATION

We do not sell your personal information. We also do not “share” personal information for cross-context behavioral advertising or similar profiling, unless permitted by law and subject to your right to opt out.

Where required (for example, under the California Consumer Privacy Act as amended by the CPRA), we provide a “Do Not Sell or Share My Personal Information” mechanism and honor browser-based opt-out preference signals such as Global Privacy Control (GPC).

YOUR PERSONAL DATA WHEN YOU PURCHASE ANYTHING FROM OUR SITES

Payments are processed by our payment providers under their privacy notices. Our providers may store tokenized payment credentials on our behalf to enable authorized transactions (e.g., booking charges, no-show fees), and we may access limited payment identifiers (such as the last four digits and expiry month/year).

We utilize the following payment gateways:

Payment through Bank Transfer

If you choose offline payment through Bank Transfer, we will have access to the following information:

1. Your name

2. Your Phone number

3. E-mail address

4. You Bank Account Number

However, we do not have control, nor are we responsible for how Banking institutions handle these details.

If you choose payment via Bank Transfer, you can read about our bank’s Privacy Policy here: https://www.ubs.com/global/en/legal/privacy.html

TWINT

Payments on our Sites may also be processed via TWINT AG (Switzerland) in cooperation with our bank. When you pay with TWINT, we may receive limited identifiers (e.g., your name and mobile number) in order to allocate your payment.

TWINT acts as an independent controller of payment data. Transfers of personal data are handled within Switzerland and the EEA. TWINT processes your personal data in accordance with its own Privacy Policy: https://www.twint.ch/en/data-privacy/.

We do not control how TWINT or our bank process your payment data.

Use of Revolut

Payments on our Sites may also be processed via Revolut Ltd. (UK/EEA). When you pay using Revolut, Revolut may process your payment method and card details, transaction amount and details, account and contact information, and device or app usage data.

Revolut acts as an independent controller of payment data. Transfers of personal data outside Switzerland, the EEA, or the UK rely on the EU Standard Contractual Clauses (SCCs) or equivalent safeguards, as required by law.

We do not collect or store your personal information beyond the limited transaction details necessary to confirm your payment.

You can read Revolut’s Privacy Policy here: https://www.revolut.com/legal/privacy

USE OF SOCIAL MEDIA PLUG-INS

We currently use the following social media plug-ins: Facebook, Instagram, and LinkedIn

You may interact with us through our social media accounts and other third-party applications we utilize. To the extent practicable, this Privacy Policy applies to those interactions.

Please be aware that personal information you provide or transmit via these social media accounts or third-party applications is typically collected and processed by the respective platform providers as independent controllers, not by us. Such information is therefore subject to the privacy policies of those providers, who may also use cookies and similar technologies.

To understand how our social media and third-party application providers collect and use your data, we encourage you to review their respective privacy policies here:

Meta Platforms, Inc (Instagram): https://privacycenter.instagram.com/policy

LinkedIn, Inc.: https://www.linkedin.com/legal/privacy-policy

THIRD-PARTY LINKS

Our sites may contain links to websites not operated by us. If you click on a third-party link, you will be directed to that third-party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We do not control, and are not responsible for, the content, privacy policies, or practices of any third-party sites or services.

OUR SOCIAL MEDIA ACCOUNTS, SOFTWARE, PLATFORMS AND THIRD-PARTY APPLICATIONS WE USE.

You may interact with us through our social media accounts, software, platforms and other third-party applications we utilize. To the extent practicable, this Privacy Policy applies to those interactions.

Please be aware that the personal information you transmit to our social media accounts or through third-party applications is typically collected by the platform providers, not by us. Therefore, such information is subject to the privacy policies of those providers, who also utilize cookies.

To understand how our social media and third-party application providers collect and use your data, we encourage you to review their respective privacy policies here:

Facebook

Owner: Meta Platforms, Inc