Coaches struggle too.
Mostly alone.

CoMentor is a reflection app 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 what you agreed with your coach about recording. The same goes for a moment your coach takes to their own mentor coach or supervisor, without your name: that is agreed between the two of you and never passes through us.

This page is about the second, optional thing: whether transcripts of your sessions may also be sent to us. If you say yes, they are used to train AI models that become part of tools WayWise offers commercially, such as CoMentor, which runs on coaches' own computers.

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.

That is the reason the request exists. If you say no, nothing about your coaching changes.

A yes covers the sessions you and your coach have already had, and future ones. It is one answer, not a question asked again after every session.

If there is a particular session you would rather keep out, give its date when you say yes on this page, or tell your coach at any time. You can name as many as you like, and you do not have to say why.

If you think of one only later, that is a withdrawal of that one transcript, and it works exactly as described under changing your mind.

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, the code your coach gave you, which matches it to your answer on this page and which our reviewers never see, when you gave that answer and to which version of the consent document, the time your coach confirmed that a lawful basis for the session was in place, the time your coach confirmed that the session was with you, and, for a session recorded by other means, which tool produced it. When it arrives, we also note which language it is in, worked out from the text itself.

It also records which coach sent it, because your coach is the person we have an agreement with.

When your coach gives you your code, the app tells us that a code was handed out, by which coach and when, and which version of our message went with it, and not to whom. If you never use it, that is all we ever learn, and we delete even that twelve months later.

What it does not carry is anything pointing back to you. No name, no alias, no file name, no folder name, no path, and nothing identifying the machine it came from.

Automatic removal of identifying details is good but not guaranteed complete, which is exactly why every transcript is checked again before it is used, paying particular attention to places, employers, and combinations of details that could point to you indirectly. In the first months of the pilot a person reads all of it. After that, a person reads every transcript our checking software flags, and a regular sample of the rest, and we make that change only once we have measured, on the transcripts read in full, that the software finds what our reviewers find.

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. Our checking software is held to the same rule: it records where it suspected something and what kind, never the text.

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.

It is stored in a database of its own, which only our review server is allowed to connect to (how that works).

Every transcript is checked again before it is used, as described under what automatic removal can and cannot do. 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 company ever receives a transcript to use it for an AI model or an AI service of its own, and no transcript ever trains a model that belongs to anyone else. Review, the checking software and training run on computers in the EU that WayWise controls: owned by WayWise, or rented for WayWise alone from a provider under a data processing agreement that forbids the provider any use of its own. Which providers those are is listed under access.

It is never sold. It is never shared beyond the WayWise review team described under access below, whose members are listed there by name. It is never used to assess, score or profile you, and no automated decision with legal or similarly significant effect on you is made. Nor is it ever used to build a tool that an employer or anyone else uses to assess or monitor any one person holding these conversations. An organisation may pay for these tools for the people it works with; the feedback is still for the person holding the conversation, and the organisation never receives your transcript.

Between arrival and the completion of review, a transcript sits automatically de-identified but not yet checked. In that state it can be reached only by the people of the WayWise review team, and by nobody else at WayWise, and by our checking software, which includes an AI model running on computers WayWise controls, and which marks where it suspects an identifying detail is left and what kind, without copying the text anywhere. Each of those people 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.

Who can be on that team. Each member is one person: WayWise's owner, a person employed by WayWise, or a person WayWise engages individually and in writing, paid or unpaid, to review transcripts or to operate the review system. Never an organisation, an agency or a shared login. Each works only inside WayWise's own review system, from within the European Union or the European Economic Area. A member may also be a coach taking part in the CoMentor pilot. What anyone is paid for reviewing never depends on how many transcripts are contributed, by whom, or whether a transcript is accepted.

A reviewer who is also a coach never reviews a transcript their own clients contributed, and the system does not show them one. There is one exception, because without it some transcripts could not be reviewed by anyone: for a language that nobody else on the team reads, a coach may review their own clients' transcripts in that language. They do it for WayWise, under the same written instructions as everyone else, and not as your coach. They may remove or generalise more, pass the transcript for use, or reject it; they may not put back anything that was removed. Your coach already knows what was said in your sessions, so nobody new reads it. It does mean that this reviewer knows who you are, so WayWise treats a transcript reviewed this way as information that identifies you, and handles it and your rights on that footing. Each review of this kind is logged as an own-client review, and anything to do with a withdrawal or a request about your rights is handled by someone else on the team.

Your consent is to that team and those rules, rather than to a particular set of names. Nobody who is not on that team is ever given access, no organisation is ever part of it, and that is not a matter this list can change. Who those people are today, which languages they review and whether they are also a coach, is below, and it is kept current here, so the list can change without anything you sign becoming untrue. If it changes, the new list is published here and your coach is told, so you can ask them at any time.

Every time one of them opens a transcript, that is written to a log which never contains any of the transcript itself. If a training run happens, it will be recorded separately, with the list of transcripts it used.

The intermediate state lasts at most 90 days. If review has not been completed in that time, the transcript is deleted automatically.

Coaching conversations can touch on your health and how you are feeling, and sometimes on other private matters such as religious or political beliefs, or your sex life or sexual orientation. Data protection law treats information like 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.

• Arrived but not yet reviewed: at most 90 days, then deleted automatically if review has not happened.
• Not passed by review: content destroyed at that moment.
• After review: at most 36 months from the date of the session, then deleted, and sooner once it is no longer needed. We check once a year whether it still is.
• When a transcript is deleted, one record of it remains: its reference number, the session date, which coach sent it and with which code, when it reached us, when you said yes and to which version of this page, when your coach confirmed they were allowed to record the session and that it was with you, and the fact that it was deleted and when. It contains none of what was said. It is the only thing that lets us keep a withdrawal honoured in every future round of training. That record is itself destroyed five years after the last thing we do with that transcript.
• The record of your answer on this page stays with us for as long as the deletion record above. The link between you and your code stays with your coach for five years after the last thing done with your transcripts, then is destroyed. A code that was never used is deleted twelve months after it was handed out, and then stops working; ask your coach for a new one if you want to say yes after that. If you said yes and nothing was ever sent, the record of your answer is deleted twelve months after your coach's participation in the pilot ends.

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 code, because it is what tells us which transcripts are yours. It is on the note your coach gave you, and your coach has it too and will give it to you whenever you ask. Not having it does not stop you. If you write to us without it, tell us who your coach is: we ask them for it rather than send you away, they must give it to us within a day, and your withdrawal counts from the moment you asked, not from the moment the code reaches us.

There are three routes, and they differ in what we end up seeing. This page, with your code, and telling your coach both keep your name away from us entirely: your coach passes on only your code, 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.

Withdrawn transcripts are deleted and excluded from every future training round.

Your code 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 code 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 the link between you and your code for the five years, still passes on a withdrawal, and still gives you your code if you ask. A yes or a withdrawal on this page still works. 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 gives you this document, as they give it to every client, with a personal code. Your coach keeps the only record connecting you to that code. Your name is never sent to WayWise.

WayWise records your answer, which you give on WayWise's own page with your code, and 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 build and improve WayWise's tools that give people feedback on how they hold coaching and other professional conversations, for their own learning, starting with CoMentor. For all of that, WayWise is solely responsible. Acting as your coach, your coach has no say in any of it and no access to it. Your coach can see whether a yes is on record for your code, when you gave it and to which version of the Contribution Consent, whether you later withdrew it, and which sessions you left out, because without that they could not send anything.

For the step in between, meaning giving you this document and your code, informing you, and sending the transcript once your yes is on record, 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, your code is enough. You do not need to give WayWise your name. If you no longer have the code, 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, use the same page with your code, or 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.

WayWise keeps the record of your answer, so it can show, if it is ever asked, that your consent existed. Your coach keeps the link between you and your code for five years, and then destroys it, so a request about your rights can always reach the right record. Neither is a copy of your transcript.

Saying no changes nothing. Not the coaching, not your relationship with your coach. You do not have to do anything to say no. Your coach is contractually required to give it to 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 agree to is the consent form, version 5, which you can save as a PDF from this page. This page explains it, and it is where you say yes. The form is what binds.