Bonfini Coaching Privacy Policy

Last Updated: 9.25.25

1. Who We Are & Our Commitment

This Privacy Policy applies to Bonfini Coaching (referred to as "I," "We," or "Bonfini Coaching"). I am committed to protecting your privacy, ensuring the confidentiality of your personal data, and maintaining transparency in all of our data handling practices.

2. Information We Collect, Use, and Legal Basis

We only collect data necessary to provide our coaching services and operate our website. We will not provide your personal data, including your session notes, to any third parties for marketing purposes without your express consent.

• Contact Data (Name, Email, Phone): We collect this when you fill out forms or sign up for services. The purpose is to communicate with you and fulfill our contractual coaching obligations. Legal Basis: Performance of a Contract (coaching services) or your Consent (newsletter sign-up).

• Sensitive Personal Data (Coaching Notes): We collect personal disclosures during coaching sessions. We use this to provide personalized coaching and track progress. Legal Basis: Explicit Consent is secured via your separate Coaching Contract, as this is special category data.

• Financial Data: We collect transaction details when you purchase a package. Legal Basis: Performance of a Contract (payment processing). This data is processed externally via Venmo, and we do not store financial information on our servers.

• Usage/Technical Data (IP Address, Browser): We automatically collect this data via Google Analytics and Squarespace cookies. Legal Basis: Our Legitimate Interest to administer and improve our website, and to measure marketing effectiveness.

3. Third-Party Data Processing and Safeguards

We share data with third-party service providers (data processors) who assist us in operating our business. These parties are contractually obligated to protect your information.

• Data Processor Safeguards: For all third-party services like Google Analytics, Substack, and Venmo, your data is governed by their respective privacy and security policies. We have chosen these providers based on their commitment to data protection.

• Affiliate Links: We participate in the Amazon Associates affiliate program. If you click on an Amazon link on our site and make a purchase, Amazon may process your data to track the commission.

• International Transfer: As a US-based entity, data collected from clients in the European Union (EU) may be transferred to and stored in the United States. This transfer is governed by Standard Contractual Clauses (SCCs) to ensure your data receives GDPR-level protection.

4. Data Retention

We only retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including for satisfying any legal, accounting, or reporting requirements.

• Coaching Notes and Contract Data: Retained for the duration of the coaching relationship and for a reasonable period thereafter as required by professional and legal obligations.

• Marketing Data (Email List): Retained until you withdraw your consent (unsubscribe).

5. Your Rights (GDPR & CCPA/CPRA)

If you are a resident of the EU or California, you have enhanced rights regarding your personal information. To exercise any of these rights, please contact me directly at the email provided in Section 9.

• Right to Access, Correction, and Deletion: The right to request copies, corrections, or deletion of the personal information we hold about you.

• Right to Opt-Out of Sale/Sharing (California): The right to direct a business that sells or shares your personal information to stop doing so. (Note: Bonfini Coaching does not sell or share your personal data.)

• Right to Limit Use of Sensitive Data (California): The right to limit the use and disclosure of sensitive personal information.

• Right to Restriction of Processing (EU): The right to request that we temporarily stop processing your data under certain conditions.

6. Children's Privacy

Our services and this Website are not intended for, nor directed at, children under the age of 18. We do not knowingly collect personal data from minors. If we learn that we have collected information from a child under 18, we will take steps to delete that information as quickly as possible.

7. Automated Decision-Making and Profiling

Bonfini Coaching does not use automated decision-making or profiling technologies that produce legal or similarly significant effects on our users. All coaching decisions and service offerings are based on human interaction and assessment.

8. Updates to this Policy

We reserve the right to update this Privacy Policy from time to time. When we make material changes to the policy, we will notify users of the changes either through a conspicuous notice on our Website or via email. We encourage you to review this policy periodically.

9. Contact Us & Governing Law

For any questions or concerns regarding this policy, please contact me directly here

This Privacy Policy and any disputes related to it will be governed by the laws of the State of Texas, United States of America.

10. Cookie Policy

Our website uses cookies and similar technologies to help it run effectively and provide you with the best browsing experience. This section explains what cookies are and how you can manage your preferences.

What Are Cookies?

Cookies are small pieces of text sent to your browser when you visit a site. They serve various functions, such as remembering your login status, storing preferences, and tracking site performance.

Types of Cookies We Use:

As is standard practice, our website (which is hosted on Squarespace) places two main kinds of cookies on visitors' browsers:

1. Necessary (Essential) Cookies: These cookies are required for the fundamental functioning of the website. They enable key features like security checks, preventing cross-site request forgery (crumb), and ensuring functionality like shopping cart or client accounts work correctly. We do not require your consent to place these cookies.

2. Non-Essential (Analytics and Performance) Cookies: These cookies collect information about how visitors interact with the site, such as traffic sources, pages viewed, and timestamps. Storing these cookies is how we populate data in Google Analytics and Squarespace analytics. We require your consent to place these cookies.

Managing Your Preferences (GDPR/CPRA Compliance):

• Cookie Banner: When you visit our site, you will see a cookie banner that provides clear information and the option to Accept, Decline All, or Manage your cookie preferences.

• Opting Out: You can change or revoke your consent at any time by revisiting your cookie settings, typically via a link in the website footer.

• Browser Settings: You can also set your browser to not accept cookies, but this may limit your ability to use all features of the Services.