PRIVACY POLICY

Next Challenge Coaching ("NCC," "we," "us," or "our") is committed to protecting the privacy of every person who visits our website, purchases our services, or engages with us in any way. This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, and your rights in relation to it.

This policy is governed by British Columbia's Personal Information Protection Act (PIPA, SBC 2003, c. 63) and applies to all personal information collected, used, or disclosed by NCC. Clients located in the European Union or United Kingdom also have additional rights under the General Data Protection Regulation (GDPR) and UK GDPR respectively, as described in Section 10 below.

‍1.   Whom to Contact

As owner of NCC, Olga Netchaeva is responsible for how NCC handles your personal information. If you have any questions about this policy, wish to access your personal information, or want to exercise any of your privacy rights, please contact support@nextchallengecoaching.com

2. Personal Information We Collect

We collect the following categories of personal information:

• Identity & contact information: your name, email address, phone number, city, and country.

• Billing & transaction information: your billing address and transaction history. Note that payment card details are processed directly and securely by our payment processor, Stripe. NCC does not collect, store, or have access to your payment card numbers.

• Coaching content: session dates, goals, note summaries and other personal information you share during coaching engagements. This information is treated as Confidential Information under your service agreement.

• Communications: emails, messages, and other correspondence you send us.

• Website usage data: IP address, browser type, pages visited, session duration, and similar technical data collected automatically when you visit our website.

• Coaching log (ICF): your name*, contact information*, coaching relationship start and end dates, total duration of coaching (in hours). This information is retained in a private coaching log, not shared with anyone outside of NCC. *Clients who do not consent to their name and contact being identified in NCC’s coaching log will be recorded without personally identifying information

3. How We Collect Personal Information

We collect personal information in the following ways:

• Directly from you: when you complete a purchase, submit a contact form, book a session, sign up for our newsletter, or communicate with us by email or other means.

• Through service delivery: information you share during coaching sessions, including goals, challenges, and personal circumstances.

• Automatically: when you visit our website, we automatically collect certain technical data (IP address, browser information, page interactions) through cookies and similar technologies. See Section 9 (Cookies) for details.

• Through third-party platforms: where you access our services through a platform (such as Zoom or Stripe), those platforms may collect information subject to their own privacy policies.

4. Why We Collect Personal Information

We collect and use personal information only for the following identified purposes:

• Delivering our services: providing coaching sessions, team development engagements, group programs, and online courses you have purchased.

• Processing payments: facilitating transactions through our payment processor (Stripe).

• Client communication: sending service-related notices, session confirmations, scheduling information, and other communications necessary to deliver your purchased services.

• Marketing communications: sending newsletters, promotional offers, and updates about our services — but only with your express consent and in compliance with Canada's Anti-Spam Legislation (CASL). You may withdraw consent at any time (see Section 8).

• ICF accreditation: maintaining a private record of client coaching hours, and start and end dates, as required for our professional credential and renewals with the International Coaching Federation.

• Business improvement: using aggregated, anonymized data to understand how our services are used and to improve them.

• Legal compliance: meeting our obligations under applicable laws, including tax and financial reporting requirements.

• Dispute resolution: maintaining records as needed to respond to claims or legal proceedings.

We will not use your personal information for any purpose other than those identified above without first obtaining your consent.

5. Third-Party Service Providers

To deliver our services, we use third-party platforms and service providers that may have access to your personal information. We take reasonable steps to ensure these providers protect your information in a manner consistent with this policy. Our current service providers include:

• Stripe: payment processing. Stripe processes payment transactions on our behalf. Please see stripe.com/privacy for Stripe's privacy policy.

• Zoom: video conferencing for coaching sessions.

• Google Workspace: email, document storage, and scheduling.

• Slack: client communications (where applicable).

• Dropbox: document sharing and storage (where applicable).

• Squarespace: website hosting and content management.

We do not sell, rent, or trade your personal information to any third party for their own marketing purposes. We may disclose your information to a third party if required by law or valid court order, after providing you with prior notice where legally permitted.

6. International Data Transfers

NCC is based in Victoria, British Columbia, Canada. Many of our service providers (including Stripe, Zoom, and Google) are headquartered in the United States or operate global infrastructure, which means your personal information may be transferred to, stored in, or processed in countries outside Canada, including the United States.

When your information is transferred internationally, we take reasonable contractual and technical steps to ensure it continues to receive protection consistent with PIPA. Please be aware that the privacy laws in other jurisdictions may differ from those of your home country.

If you are located in the European Union or United Kingdom, please also see Section 10 for information specific to international transfers from the EU/EEA and UK.

7. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following retention schedule applies:

Data Type: Financial & billing records (invoices, payment history, contracts)

Retention Period: 7 years from end of the relevant tax year

Legal Driver: Canada Revenue Agency (mandatory)

Data Type: Client coaching records, session notes, and correspondence

Retention Period: 2 years after service completion

Legal Driver: BC Limitation Act (dispute protection)

Data Type: Marketing & contact data (non-clients, newsletter subscribers)

Retention Period: 1 year after last interaction, or earlier upon withdrawal of consent

Legal Driver: PIPA, necessity principle

Data Type: ICF coaching hours log (name, contact details, start & end dates, hours)

Retention Period: As required by ICF credentialing requirements

Legal Driver: ICF accreditation obligations

After the applicable retention period, personal information is securely deleted or anonymized. You may request earlier deletion of certain information by contacting me directly (see Section 10 for applicable rights).

8. Marketing Communications & CASL

NCC complies with Canada's Anti-Spam Legislation (CASL). We will only send you commercial electronic messages (including promotional emails and newsletters) if you have given your express consent to receive them.

You may withdraw your consent to receive marketing communications at any time by:

• clicking the unsubscribe link in any marketing email you receive from us; or

• contacting support@nextchallengecoaching.com

We will action all unsubscribe requests within ten (10) business days, as required by CASL. Withdrawing consent to marketing communications will not affect your receipt of transactional or service-related messages (such as session confirmations or purchase receipts), which we may send as necessary to deliver your purchased services.

9. Cookies & Tracking Technologies

Our website uses cookies and similar tracking technologies to collect information about how visitors use the site. Cookies are small text files stored on your device.

We use cookies for the following purposes:

• Essential cookies: necessary for the website to function properly (e.g., maintaining your session during checkout).

• Analytics cookies: help us understand how visitors interact with our website so we can improve it (e.g., pages visited, time on site).

You can control or disable cookies through your browser settings. Disabling cookies may affect the functionality of certain parts of our website. Where required by applicable law, we will obtain your consent before setting non-essential cookies.

10. Your Privacy Rights

Rights under PIPA (all clients)

Under BC's Personal Information Protection Act, you have the right to:

• know what personal information we hold about you;

• request access to your personal information;

• request correction of inaccurate or incomplete personal information;

• withdraw consent to the collection, use, or disclosure of your personal information (subject to legal and contractual restrictions); and

• file a complaint with the BC Office of the Information and Privacy Commissioner (OIPC) if you are unsatisfied with our response to a privacy request.

To make a request under PIPA, please contact me directly. We will respond within 30 business days, and may ask you to verify your identity before processing your request.

If you are dissatisfied with our response, you may contact the OIPC at:

BC Office of the Information and Privacy Commissioner | oipc.bc.ca | 1-250-387-5629

Additional rights for EU and UK residents (GDPR / UK GDPR)

If you are located in the European Union or United Kingdom, you have the following additional rights under the GDPR and UK GDPR:

• Legal basis for processing: we process your personal information on the basis of (a) contract performance — to deliver the services you have purchased; (b) consent — for marketing communications; and (c) legitimate interests — for analytics and service improvement.

• Right to erasure: you may request that we delete your personal information, subject to our legal retention obligations.

• Right to data portability: you may request a copy of your personal information in a structured, machine-readable format.

• Right to restrict processing: you may request that we limit the processing of your personal information in certain circumstances.

• Right to object: you may object to processing based on legitimate interests.

• Right to complain: you have the right to lodge a complaint with your local data protection supervisory authority (for example, the ICO in the UK or your national authority in the EU).

International transfers from the EU/EEA or UK: where your data is transferred outside the EU/EEA or UK, we rely on applicable transfer mechanisms (such as Standard Contractual Clauses with our service providers) to ensure adequate protection.

11. Security

We implement reasonable technical and organizational measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures include:

• use of third-party platforms that are PCI-DSS compliant for payment processing;

• password-protected systems and access controls;

• secure email communications; and

• limited access to personal information to those who need it to deliver our services.

No method of transmission over the internet or electronic storage is completely secure. While we take reasonable precautions, we cannot guarantee absolute security.

12. Privacy Breach Notification

In the event of a privacy breach that creates a real risk of significant harm to any individual, NCC will:

• notify affected individuals as soon as reasonably possible;

• notify the BC Office of the Information and Privacy Commissioner (OIPC) as required under PIPA; and

• maintain a record of all privacy breaches, regardless of whether notification is required.

If you believe your personal information has been improperly accessed or disclosed, please contact support@nextchallengecoaching.com immediately.

13. Sensitive Information

Coaching engagements frequently involve the disclosure of sensitive personal information, including information about career challenges, financial circumstances, personal relationships, mental health, and other confidential matters. We treat all information shared during coaching sessions with the highest degree of care and discretion, consistent with the confidentiality obligations under your service agreement.

We will never use session content for any purpose other than delivering your coaching services, and will not disclose it to any third party except in the following limited circumstances:

With your consent: where you have given prior written permission to share specific information.

Where required by law: where disclosure is required pursuant to a valid court order, subpoena, or lawful direction from a government or regulatory body. In that situation, I will notify you in advance wherever I am legally permitted to do so, and will disclose only the minimum information necessary to satisfy the legal obligation.

Where there is a serious risk of harm: where I have reasonable grounds to believe that disclosure is necessary to prevent an imminent risk of serious harm to you or to another person.

14. Minors

Our services are intended for individuals aged 18 and over. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a minor, please contact support@nextchallengecoaching.com and we will promptly delete it.

15. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or services. The "Last Updated" date at the top of this policy indicates when it was most recently revised.

For material changes, those that significantly affect how we collect, use, or share your personal information, we will notify current clients by email prior to the change taking effect. Continued use of our services after notification constitutes acceptance of the updated policy.

16. Contact & Complaints

For any questions about this Privacy Policy, to make a privacy request, or to lodge a complaint, please contact:

Olga Netchaeva, Next Challenge Coaching

Email: support@nextchallengecoaching.com

We will acknowledge your inquiry within five (5) business days and respond fully within 30 business days. If you are not satisfied with our response, you have the right to escalate your complaint to the BC OIPC:

Office of the Information and Privacy Commissioner for BC

PO Box 9038 Stn Prov Govt, Victoria, BC V8W 9A4

Tel: 250-387-5629 | Toll-free: 1-800-663-7867 | Website: oipc.bc.ca

Next Challenge Coaching

Victoria, BC | support@nextchallengecoaching.com | www.nextchallengecoaching.com

Last Updated: May 31, 2026