Your coach is part of the founding cohort for CoMentor, a tool that helps coaches grow. It needs to learn from real coaching conversations.
You are asked to contribute a transcript of a session you have already had, to help other coaches with their development. Identifying details are replaced with placeholders on your coach's laptop before anything is sent, it travels encrypted to our server in the European Union, and a person reads every transcript before it is used, looking for anything the software missed and for details that could still point back to you.
The ICF asks every coach to keep a reflective practice. That normally comes from mentor coaching, which the credential requires only a limited number of hours of, and which many coaches cannot reach much of early on. CoMentor helps them do that work between those hours, and after the training when they stop. What it learns goes into the version other coaches use, so one transcript reaches further than your own coach.
Only a small, fixed group of people at WayWise can see your de-identified transcript, and nobody outside it. It is never sold, never shared, and never sent to an outside AI service. Building CoMentor is the only thing it is ever used for. Every time one of them opens a transcript it is written to a log, and there is no download and no export function. The section below sets that out in full.
At most 24 months from the date of your session, then it is deleted. If nobody has reviewed it within 30 days of arriving, it is deleted automatically, before anyone has read it. Every period is listed below.
Your session has a reference number, and your coach has it. Tell them, and the number reaches us without your name. No reason needed, and no number needed to start. Within 72 hours the transcript is deleted and left out of every future round of training. The one thing we cannot undo is a version of the tool already built using it, and we would rather say that now than have you find it out later.
Answered in five parts. Open the ones you care about, or jump to the part you want.
CoMentor is a reflection tool for coaches, and it runs on your coach's own Mac. It records a session if your coach asks it to, transcribes it on the machine, and then asks them the same kind of reflective questions they would ask you: where the conversation turned, what they missed, what they did with a silence. Instead of a coach going back over an hour from memory, they get a structured look at what actually happened, mapped to the competences their own professional body assesses them against. That part is between you and your coach, none of it reaches us, and it is covered by the separate consent you signed at the start of your work together.
This page is about the second, optional thing: whether a transcript of a session may also be sent to us.
Coaching is a craft, and much of learning it happens alone. A coach is in the room with one person at a time, and when the hour ends there is no recording, no colleague who watched, and nothing to go back to. Supervision helps, and it works from what the coach remembers and chooses to bring, which is not the same as what happened. There is very little honest record of what actually goes on inside a good session.
Coaches are trained to invite reflection in other people, and their own ends up happening in fragments, held together by memory. The ICF expects the same reflective practice of coaches that coaches invite in others. CoMentor is being built to close that gap for the coach who uses it. To do that it has to be grounded in real coaching conversations rather than invented ones. Invented ones do not contain the hesitations, the repairs, or the moments where something actually turns, which are the parts worth learning from. There is no way to get real ones except for people to contribute them, and every transcript in that material is there because someone chose to contribute it.
A tool like that can only be built on real coaching. Every transcript that reaches us makes it better at recognising what happens in a session, and what it learns goes into the version that other coaches use. So the practical effect of a yes is that coaches early in this work get something closer to the mentor coaching they are required to have a little of and can rarely afford more of.
That is the reason the request exists. It is not a reason for you to say yes, and we are not going to dress it up as one. Saying no is a complete answer.
Nothing happens. Your coach asks once and will not raise it again, and nothing about your coaching changes.
They are not paid for asking, and nothing they receive from us depends on your answer, or on whether they ask you at all. If your employer arranged or pays for your coaching, they are not asked, they are not told what you decided, and they never receive anything from your sessions.
You do not have to give a reason, and you do not have to say anything at all. Saying nothing is a no.
The submission carries the de-identified transcript, a random reference number generated on your coach's device, and the date of the session. Alongside those it records a few technical facts our reviewers need in order to judge what they are reading: which version of the app produced it, whether the automatic name detection ran, which version of the consent document you signed, and, for a session recorded by other means, which tool produced it.
It also records which coach sent it, because your coach is the person we have an agreement with.
What it does not carry is anything pointing back to you. No name, no alias, no file name, no folder name, and nothing identifying the machine it came from.
Why we mention the coach rather than leaving it off the list. Your reference number, your session date and your coach's identity are three facts we hold. On their own they say nothing about you. Someone who also had your coach's appointment diary could in principle put them together. We do not have that diary and never ask for it, and everyone with access is forbidden to attempt anything of the kind. It is still the honest reason we treat your transcript as your personal data rather than calling it anonymous.
Transmission is over an encrypted connection to our server in the European Union, Amsterdam region, and it is stored encrypted there. Our infrastructure provider has confirmed that automated backups stay in the same data centre and that cross region backup storage is not offered at all.
A person at WayWise reads every transcript before it is used. If one cannot be brought to a proper standard of de-identification, it is not used and its content is destroyed rather than set aside for another look.
No transcript is sent to any external AI service. Review and training both run on our own systems in the EU.
It is never sold. It is never shared beyond the WayWise review team described under access below, which is never more than four people. It is never used to assess, score or profile you, and no automated decision with legal or similarly significant effect on you is made.
Between arrival and the completion of human review, a transcript sits automatically de-identified but not yet checked by a person. In that state it can be reached only by the people of the WayWise review team, and by nobody else at WayWise. That team is never more than four people at any one time. Each of them is bound, before their first access, by written instructions under Article 29 GDPR covering confidentiality, handling, and an express prohibition on any attempt to identify you.
Your consent is to that team and that limit, rather than to a particular set of names. Nobody outside WayWise is ever given access, and that is not a matter this list can change. Who those people are today is below, and it is kept current here, so the list can change without anything you signed becoming untrue.
Two people, of a maximum of four.
The two roles are kept apart on purpose. The operator runs the service and reads the access logs; reviewers read transcripts and are what those logs record. One person holding both would be checking their own work.
Every time one of them opens a transcript, that is written to a log which never contains any of the transcript itself. Training runs are recorded separately, each with the list of transcripts it used.
The intermediate state lasts at most 30 days. If review has not been completed in that time, the transcript is deleted automatically.
Review happens on the server. There is no download function and no export function, and reviewers are instructed not to copy content elsewhere. We do not claim a local copy is technically impossible, because that would not be true. We claim that no feature exists to make one and that our procedures forbid it.
Automatic removal of identifying details is good but not guaranteed complete, which is exactly why a person reads every transcript before it is used, paying particular attention to places, employers, and combinations of details that could point to you indirectly.
What survives an automatic pass is context. A sentence like "a team of four, and someone left two days ago" names nobody and could still place you for a reader who already knows the situation. That is what the human review is for, and it is judgement rather than search and replace.
The test a reviewer applies: would someone who knows you recognise you in this text? If yes, more is removed or generalised. If it cannot be brought to that standard, the transcript is not used.
When a reviewer removes something, we record that they did, when, and what kind of detail it was, never the detail itself. Keeping a record of the removed text would rebuild inside our own logs exactly the thing we had just taken out.
Coaching conversations can touch on health, on how you are feeling, and on other private matters. Data protection law treats that as a special category of personal data, which may only be used with your express agreement to that specific use. Your transcript is treated as special category personal data for the whole of its life with us, including after the automatic removal of names and after the human review.
After anything is deleted on our live systems, it can still be restored from a backup for a while. Our provider gives us a 7 day recovery window, which we cannot change. Whether copies older than that window are actually erased, or only past the point we could restore them, is a question we have put to our provider and cannot yet answer as a fact. We would rather show you where our own knowledge stops than round it in our favour.
You can withdraw at any time, and you do not have to give a reason. It takes effect without undue delay and at the latest within 72 hours.
What we need is your reference number, because it is the only thing that tells us which transcript is yours. Your coach has it and will give it to you whenever you ask. Not having it does not stop you. If you write to us without it, we ask your coach for it rather than send you away, and your withdrawal counts from the moment you asked, not from the moment the number reaches us.
There are two routes, and they differ in what we end up seeing. Telling your coach keeps your name away from us entirely: they pass on your reference number, and nothing about who you are reaches us. Emailing privacy@waywise.coach is equally valid and just as fast, and it means we see the address you write from.
We would rather say this plainly than let you find it out by writing to us. An email address is personal data, and one that carries your name identifies you to us where nothing else on this page does. So: we use that address only to carry out your request and to confirm it is done, we do not add it to your transcript record or to any list, and we delete it once the request is closed. If you would rather we never held it at all, write from an address that does not carry your name, or go through your coach. Neither route is slower, and neither is treated differently.
Withdrawn transcripts are deleted and excluded from every future training round.
The one honest limit is the one named at the top. A contribution to a version already built cannot be selectively extracted from it. That is a technical property of how such tools are trained, and it is written here so that a decision to agree is an informed one. What the tool learns goes into the version of CoMentor that coaches use, which is the point of building it: the improvement is not for us, it is for the next coach and the person sitting with them.
The reference number is how you exercise any right. Give it to us directly, or ask your coach to give it to us, and we can find the record. You never have to tell us your name to make a request. If you write to us yourself we will see the address you write from, which we use only to answer you and then delete; going through your coach avoids that, and so does writing from an address that does not carry your name.
Because we do not routinely know who you are, there may be cases where the number alone is not enough for us to be sure we are acting on the right record for the right person. Where that genuinely arises we may ask for proportionate additional information, including confirmation through your coach. We will not ask for more than is necessary, and we will not ask for your name as a matter of routine.
None of this narrows your rights. We do not claim that your rights stop applying because we cannot identify you.
Access, rectification, erasure, restriction, portability, withdrawal of consent at any time without affecting the lawfulness of what came before, and complaint to a supervisory authority: the Dutch Autoriteit Persoonsgegevens, or the authority where you live.
Coaches join the pilot and can leave it. If yours does, nothing you decided changes and nothing about you is deleted automatically, because your consent was given to WayWise for what WayWise does, not to your coach's continued participation.
Transcripts already sent stay with us and are still used as this page describes. No new ones are sent. Your coach still keeps your signed form and your reference numbers for the five years, still passes on a withdrawal, and still gives you your reference number if you ask. Those obligations outlive their participation on purpose, because they are what makes your rights reachable.
If you would rather not leave it there, you can withdraw at that point as at any other, and you do not need a reason.
This is the summary that Article 26(2) GDPR requires to be available to you. It is word for word the same as Annex 1 of the arrangement between WayWise and your coach, and the same as the copy inside the consent document itself.
Two organisations are involved when you contribute a transcript, and they are responsible for different things.
Your coach decides whether to invite you at all, gives you this document, takes your signature, and keeps it. Your coach also keeps the only record connecting you to the reference number on your transcript. Your name never reaches WayWise.
WayWise decides what happens to the transcript after it arrives: who reads it, whether it is accepted, where it is stored, how long it is kept, and whether it is used to improve CoMentor. For all of that, WayWise is solely responsible. Your coach has no say in any of it and no access to it.
For the step in between, meaning inviting you, informing you, taking your consent and sending the transcript, your coach and WayWise are jointly responsible. That is why this summary exists.
What that means for you.
You can go to either of them. You do not have to work out which one is responsible. If you contact your coach, they will pass it on. If you contact WayWise, they will act.
To exercise any right, the reference number is enough. You do not need to give WayWise your name. If you do not have the number, your coach has it and will give it to you. WayWise will only ask for more information if it genuinely cannot identify the right record without it.
To withdraw, tell either of them. It takes effect within 72 hours at the latest. You do not have to give a reason. There is one honest limit: if your transcript has already been used in a completed round of training, it cannot be removed from what has already been learned. Everything else about it is deleted, apart from a short record that a submission existed and was deleted, which contains nothing of what was said and is what lets WayWise keep your withdrawal honoured in every future round of training.
Your coach keeps your signed form and the reference number for five years, and then destroys them. That is so WayWise can show, if it is ever asked, that your consent existed. It is not a copy of your transcript.
Saying no changes nothing. Not the coaching, not your relationship with your coach. Your coach is contractually required to ask you only once, and not to raise it again.
If your employer arranged or paid for your coaching, they are not part of this. They are not asked, they are not told what you decided, and they never receive session content or transcripts. Your decision has no effect on your coaching or on anything at work.
Who to contact. WayWise is the contact point for anything to do with the contributed transcript: privacy@waywise.coach. Your coach can also pass on anything you would rather raise with them. You can also complain to the Dutch data protection authority, the Autoriteit Persoonsgegevens.
Who WayWise is. An Eenmanszaak (sole proprietorship) owned by Bruno Giulio Winkler, registered in the Netherlands, KvK 42057820.
What you sign is the consent document, which your coach generates from the app so that it is always the current version. This page explains it. The document is what binds.