Privacy Policy

Who We Are

This Privacy Policy applies to Anna Sokol, trading as WAYFINDER™, a Human Potential and Self-Leadership coaching practice based in Dublin, Ireland.

• Business name: Anna Sokol / WAYFINDER™
• Website: www.asokol.com
• Country of establishment: Ireland
• Data Controller: Anna Sokol

As the Data Controller, Anna Sokol determines the purposes and means of processing your personal data and is responsible for its protection under applicable law, including the EU General Data Protection Regulation (GDPR) and the Irish Data Protection Acts 1988–2018.

What Data We Collect

We collect only the data that is necessary to deliver our services and communicate with you effectively. The categories below describe what we may collect and in what context:

We do not collect or process special category data (e.g. health data, religious beliefs, political opinions) without your explicit, informed consent, and only where directly relevant to the services requested.

How We Use Your Data

Every use of your personal data is tied to a clear, defined purpose. The legal bases we rely on under GDPR are listed alongside each purpose:

• To deliver coaching sessions and programmes — Performance of contract / Legitimate interests
• To respond to enquiries and schedule sessions via Calendly — Legitimate interests / Contract
• To generate personalised coaching materials from your intake, reflection, or live session content — Consent / Performance of contract (see Section 4 for details on AI-assisted processing)
• To share your reflections, testimonials, or session insights in our marketing (e.g. website, social media, email) — Explicit consent only, at the level you agree to (see below)
• To record and reuse content from free challenges and group webinars (e.g. the beYOU™ 5k Webinar Challenge) for marketing, education, and social media — Consent given at sign-up for the specific programme (see Section 4)
• To send you our newsletter, programme updates, and resources — Consent (you may withdraw at any time)
• To process payments and issue invoices — Legal obligation / Contract
• To improve the website and user experience — Legitimate interests
• To comply with legal and regulatory obligations — Legal obligation
• To protect our rights in case of dispute — Legitimate interests

We will never use your data for automated decision-making or profiling that produces legal or significant effects without your explicit consent.

Who We Share Your Data With

We do not sell, rent, or trade your personal data. We share data only where necessary with trusted service providers (data processors) who are contractually bound to protect it:

• Calendly — appointment scheduling (Calendly LLC, USA — Standard Contractual Clauses apply)
• MailerLite — email marketing platform (MailerLite Limited, EU-based)
• WhatsApp / Meta — where you initiate contact via WhatsApp (Meta Platforms Ireland Ltd)
• Payment processor — e.g. Stripe or PayPal, where applicable, for secure payment handling
• WordPress / Hosting provider — website hosting and technical infrastructure
• Google Analytics (if active) — anonymised website usage analysis
• Mentimeter — live polls, quizzes, and interactive slides used during webinars and group sessions
• Zoom — video hosting for live webinars, workshops, and coaching calls (including any recordings)
• Google Forms / Google Drive — reflection forms, feedback collection, and secure delivery of personalised materials
• Canva — design and delivery of personalised worksheets, workbooks, or visual materials shared with you

We use these tools both to collect information from you (e.g. your answers in a poll or form) and to share materials with you (e.g. a personalised workbook, a link to your session recording, or a designed resource). In both directions, any personal data passing through these platforms is handled in line with this Privacy Policy.

As a practice, we continually explore new tools to improve how we deliver coaching and programmes. From time to time, we may use additional platforms (such as polling, webinar, form, or design tools) beyond those listed above. Any such tool is chosen with data protection in mind and, where it processes personal data on our behalf, is treated as a data processor under this policy. A current, complete list of all processors in use can be requested at any time by contacting us directly (see Section 13).

AI-Assisted Processing: Where you complete an intake form, reflection exercise, or worksheet, or participate in a live webinar, workshop, or group coaching session as part of our programmes (including WAYFINDER™, beYOU™, and breatheEase™), your responses and shared content may be processed using one or more third-party AI tools in order to generate personalised coaching materials, workbooks, summaries, or feedback on our behalf. We may use different AI tools depending on the nature of the service. These AI providers act as data processors under appropriate data processing agreements and do not use your data to train their underlying models beyond the scope of our engagement. Data may be processed on servers located outside the EEA, safeguarded by Standard Contractual Clauses or equivalent mechanisms, as set out in Section 05.

Marketing Use of Reflections & Testimonials: With your explicit, separate consent, we may share insights, reflections, or testimonials from your sessions or programme in our marketing materials (e.g. website, social media, email). You choose the level of identification you are comfortable with, and we will only ever use the level you agree to:

• First name only (e.g. "Anna")
• First name and first initial of surname (e.g. "Anna S.")
• Full name

We keep an internal record of the consent level each person has agreed to, and this is checked before any reflection or testimonial is used. You may withdraw this consent, or ask us to change the identification level, at any time by contacting us.

Free Challenges & Group Programme Recordings (e.g. the beYOU™ 5k Webinar Challenge): Free group challenges and webinars are recorded, and creating shareable content is one of the stated purposes of these programmes. By registering for and attending a free challenge or group webinar, you consent to being recorded (video, audio, and/or chat contributions) and to that recording — in full or in part — being used for:

• Marketing and promotional materials (e.g. website, email, paid or organic advertising)
• Social media content, both at the time of the event and in the future
• Educational and training materials for current and future programmes
• Other promotional or educational formats we may develop over time

This is a broader and separate consent from the individual testimonial levels described above, given specifically at sign-up for a free challenge or group webinar, because content creation is a core part of how these free programmes are delivered. If you would prefer not to appear on camera, you are welcome to join with your camera off or participate via chat only. If you would like a specific clip or mention removed from future use, you can request this at any time by contacting us, and we will action it going forward (though we cannot recall copies already published or shared by others).

All processors are required to handle your data in accordance with GDPR. We enter into Data Processing Agreements (DPAs) with all processors where required by law.

We may disclose data to legal or regulatory authorities where required by law or where necessary to protect our rights or the rights of others.

International Data Transfers

Some of our service providers, including AI tools referenced in Section 04, are located outside the European Economic Area (EEA). Where data is transferred internationally, we ensure appropriate safeguards are in place:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions where applicable
• Binding corporate rules where relevant

You may request details of the specific safeguards in place for any third-country transfer by contacting us directly.

Cookies & Tracking Technologies

This website uses cookies — small text files stored on your device — to ensure the site works properly and to understand how visitors engage with our content.

You may manage cookie preferences at any time via your browser settings or our cookie consent banner. Note that disabling certain cookies may affect the functionality of this website.

How Long We Keep Your Data

We retain personal data only for as long as is necessary for the purposes stated in this policy, or as required by applicable law. Our general retention periods are:

• Active client data (session notes, coaching records) — for the duration of the coaching relationship, then reviewed and securely deleted once no longer needed, unless a legal or tax obligation requires longer retention
• Raw intake forms, reflections, and live session content — retained only for as long as needed to extract the specific information you have agreed we may keep or use (e.g. for a testimonial, or to prepare your personalised materials); the original raw submission is then securely deleted, typically within 30 days of your session or programme ending
• Extracted testimonials or reflections used in marketing — retained at the identification level you consented to (see Section 04), logged internally, and kept until you withdraw consent or ask for removal
• Financial and invoicing records — 7 years (as required by Irish tax law)
• Marketing and newsletter data — until you unsubscribe or withdraw consent
• Enquiry and general correspondence — up to 2 years from last contact
• Technical/analytics data — as specified by the relevant platform (e.g. 26 months for Google Analytics)

When data is no longer required, it is securely deleted or anonymised.

Your Rights Under GDPR

As a data subject under GDPR, you hold the following rights. These are not formalities — they are real and enforceable:

To exercise any of these rights, please contact us using the details in Section 10. We will respond within 30 days. If the request is complex, we may extend this by a further two months and will inform you accordingly.

We will never charge a fee for exercising your rights unless a request is manifestly unfounded or excessive.

How We Protect Your Data

We take the security of your personal data seriously and implement appropriate technical and organisational measures, including:

• SSL/TLS encryption on all website communications
• Password-protected and access-controlled systems
• Restricted access to personal data on a need-to-know basis
• Use of reputable, GDPR-compliant third-party platforms only
• Regular review of security practices

In the event of a personal data breach that is likely to result in risk to your rights and freedoms, we will notify the Data Protection Commission within 72 hours and inform affected individuals without undue delay where required by law.

Children's Privacy

Our website and services are intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. If you believe a minor has submitted personal data to us, please contact us immediately and we will arrange for its deletion.

Third-Party Links

Our website may contain links to external websites, platforms, or social media profiles (including Instagram, LinkedIn, and others). This Privacy Policy does not apply to those third-party sites. We encourage you to review the privacy policies of any external site you visit. We accept no responsibility or liability for their content or privacy practices.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law. When we do, we will revise the "Last Updated" date at the top of this page.

For significant changes, we will notify active clients and subscribers by email. We encourage you to review this policy periodically. Your continued use of our website after changes are posted constitutes your acceptance of the updated policy.

Update of 12 July 2026: This policy was revised to clarify that data submitted via intake forms, reflection exercises, and content shared during live webinars or group sessions may be processed using third-party AI tools to generate personalised coaching materials. This update applies to data already collected as well as data collected going forward; existing clients and subscribers have been notified by email in accordance with this section.

Contact the Data Controller

For any questions, requests, or concerns relating to this Privacy Policy or the handling of your personal data, please reach out directly:

If you are not satisfied with our response, you have the right to lodge a complaint with the Data Protection Commission of Ireland:

• Website: www.dataprotection.ie
• Phone: +353 57 868 4800
• Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland