Privacy policy

Last updated: 8 September 2026

1. Data controller

Ann Backes - Backes Coaching
Rue des buissons 15, 4000 Liège, Belgium
VAT: BE 1012.591.809
Email: [email protected]
Phone: +32 499 46 23 41

2. Data collected

This site uses Google Analytics 4 to measure its audience and improve the browsing experience. This data is collected only if you consent through the cookie banner.

The data collected by Google Analytics includes:

• Pages visited and time spent on the site
• Traffic source (search engine, direct link, social media)
• Device type, browser and operating system
• Approximate geographic location (country/city)
• IP address (anonymised by default in GA4)

No personally identifying data (name, email, phone number) is collected by the analytics cookies.

3. Cookies used

Your consent choice is stored in your browser's local storage (not a cookie) under the key cookie_consent.

4. Legal basis

Depending on the data concerned, processing rests on one of the following bases:

• Your consent (GDPR article 6.1.a): analytics cookies, contact form, sending the preview of your assessment results. Analytics cookies are only set after you explicitly accept them through the cookie banner.
• Your explicit consent (GDPR article 9.2.a): storage and use of your psychometric assessment results, which we treat as special-category data within the meaning of article 9. This consent is collected separately, through a dedicated checkbox, and can be withdrawn at any time.
• Performance of a contract or pre-contractual steps (GDPR article 6.1.b): organising and following up your coaching and your career assessment, and delivering a paid report ordered online.
• A legal obligation (GDPR article 6.1.c): invoicing and retention of accounting records.
• Our legitimate interest (GDPR article 6.1.f): security of the site and of the assessment platform, abuse prevention, and suppression of email addresses that bounce so that we stop writing to them.

You may withdraw your consent at any time; this does not affect the lawfulness of processing already carried out.

5. Recipients and processors

Your data is never sold, and never shared for advertising purposes. It may be processed by the following processors, each solely for the purpose stated:

• Google LLC (Google Analytics, United States): audience measurement on the website, only after your consent.
• Cloudflare, Inc. (United States): hosting and delivery of the website; processes visitors' requests and IP addresses.

As Google and Cloudflare are established in the United States, any transfers take place under the safeguards provided for by the GDPR (standard contractual clauses and/or the EU-US Data Privacy Framework, depending on the provider). Details of the safeguards applicable to each provider are available on request at [email protected].

The contact form involves additional processors (email delivery and hosting within the European Union), detailed under "Contact form" below.

The assessment platform involves additional processors (EU hosting, email delivery, payment), detailed under "Assessment platform" below.

6. Retention periods

We keep your data only as long as the purpose requires, then delete it:

• Audience measurement (Google Analytics): 14 months, per the GA4 setting.
• Cookie choice: stored in your browser until you change it or clear your browser.
• Contact form: 12 months if your enquiry does not lead to coaching; otherwise for the duration of the coaching relationship, then 3 years.
• Free assessment without email confirmation: 48 hours, then automatic deletion.
• Free assessment with confirmed email: 90 days, then automatic deletion, unless coaching starts in the meantime.
• Assessment results within a coaching relationship: for the duration of the coaching, then 3 years (to allow follow-up or a resumption), then deletion.
• Invoices and accounting records: 7 years, as required by Belgian accounting and tax law. These records contain no assessment results.
• Email addresses that failed delivery (bounce, complaint): kept in secure form so that we no longer write to you, until you ask for their deletion.

You may ask for early deletion of your data at any time (see "Your rights" below), subject to the periods imposed by law.

7. Your rights

Under the GDPR, you have the following rights:

• Withdraw your consent at any time by clicking "Manage cookies" in the site footer
• Access the data concerning you
• Rectify inaccurate data
• Erase your data
• Receive a portable copy of your data
• Request the restriction of a processing operation
• Object to processing
• Lodge a complaint with the Data Protection Authority (Belgium)

To exercise these rights, contact us at [email protected].

8. Managing your preferences

You can change your cookie choice at any time by clicking the "Manage cookies" link in the footer of every page. If you withdraw your consent, the analytics cookies are deleted and tracking stops immediately.

You can also block cookies through your browser settings or use a tool such as Google Analytics Opt-out.

9. Contact form

When you use the contact form, the information you provide (first name, email address, subject and message) is processed in order to answer you.

• Purpose: answering your enquiry and, where relevant, arranging a first conversation or a coaching engagement.
• Legal basis: your consent (the checkbox on the form), under GDPR article 6.1.a.
• Recipient and processing: your enquiry is sent by email to Ann Backes through our email provider Brevo (Sendinblue SAS, European Union); it runs on Backes Coaching's secure infrastructure, hosted within the European Union (at Hetzner, Germany: the same environment as the assessment platform, questionnaire.backescoaching.com). A minimal record of your enquiry (first name, email, subject) is kept to follow it up; the content of your message is not stored in our database: it is only carried by email. This data is never used for advertising purposes, nor shared with third parties for such purposes.
• Retention: 12 months if your enquiry does not lead to coaching; if coaching starts, for the duration of the relationship, then 3 years (see point 6).
• Your rights: you may request access to, rectification of, or erasure of this data at any time by writing to [email protected].

10. Assessment platform (questionnaire.backescoaching.com)

The assessments offered on this site (RIASEC, DISC, career assessment) are hosted on a separate, secure platform at questionnaire.backescoaching.com. That platform is independent from the website and carries no advertising cookies and no marketing trackers.

• Anonymous by default: you take the assessments anonymously. No identifying personal data is recorded unless you ask for it.
• Explicit consent (double opt-in): your email address is only collected if you choose to receive a detailed preview of your results, after confirming through a link sent by email.
• Special-category data (GDPR article 9): psychometric results are treated as special-category data. Storing and using them rests on your explicit consent (article 9.2.a), collected through a dedicated checkbox before your answers are processed, and revocable at any time. These results are encrypted at rest, used only to build your profile and prepare your debrief, never used to train a model, and never sold or shared for advertising purposes.
• How results are computed, and no automated decisions: your profile (scores and report) is computed automatically from your answers. No decision about you is taken automatically: the interpretation and debrief are handled by your coach, and the assessments are used neither for recruitment nor to evaluate your skills (see article 16.1 of the terms and conditions). You are therefore not subject to automated decision-making within the meaning of GDPR article 22.
• Hosting: the assessment platform's data is hosted within the European Union (at Hetzner, Germany) and backed up in encrypted form, also within the European Union.
• Sending results: when you ask to receive your results or a detailed report, the corresponding email (with the report attached where applicable) is delivered through our provider Brevo (Sendinblue SAS, European Union).
• Paid report and payment: some detailed reports can be obtained online against payment. Payment is handled by the provider Mollie (Mollie B.V., Netherlands, European Union) on its own secure payment page; card details and payment identity are collected and processed directly by Mollie. Backes Coaching only keeps the payment reference and status, in particular for accounting purposes.
• Retention: assessment data follows the periods set out in point 6 above (48 hours without email confirmation, 90 days for a confirmed free preview, the duration of the coaching then 3 years where coaching takes place).
• Your rights: you may request access to, rectification of, erasure of, or a portable copy of your assessment data at any time by writing to [email protected]. Erasure removes all of your answers, results and associated notes.