Privacy Policy
1. Who we are
Ava Houkes (“we”, “us”, “our”) is the controller of your personal data. Ava Houkes is a sole proprietorship (eenmanszaak) registered in the Netherlands.
- Chamber of Commerce (KvK): 42153968
- Address: Van Doornstraat 30, 1851 JK Heiloo, the Netherlands
- Email: ava@avahoukes.com
- Phone: +316 10 3600 14
This policy applies to everything we do under the name Ava Houkes and on www.avahoukes.com. We also work under the trade name Expat Institute, which has its own privacy policy at https://www.expat-institute.com/privacy-policy.
We handle your personal data in line with the General Data Protection Regulation (GDPR) and Dutch privacy law. This applies wherever you live.
2. Scope
This policy covers personal data we collect through:
- A complimentary introductory call
- Individual coaching and mentoring
- Couples coaching
- Group programmes and workshops
- Coaching, facilitation and consulting for organisations
- Our website, forms, downloads and mailing list
- Messages you send us by email, phone or social media
3. What personal data we collect
We collect only what we need for the purposes in section 4.
When you book an introductory call: your name, email address, phone number and your answers in the booking form.
When you become a client: your contact details, your acceptance of the coaching agreement, your intake form, session notes, messages, and what you choose to share in sessions. This can include information about your health, wellbeing or relationship (see section 5). In couples coaching, it includes information about your partner (see section 6).
For organisations: names, roles and business contact details of contact persons and participants, and notes and materials relevant to the engagement.
On our website: your name, email address and message when you fill in a form or request a download.
Technical data: pages visited and general usage statistics, collected through our website platform (see section 12), and whether you open or click our emails.
For invoicing: name, address and payment details.
4. Why we use your data, on what legal basis, and for how long
| Purpose | Data | Legal basis (GDPR) | How long we keep it |
|---|---|---|---|
| Booking and holding a complimentary introductory call | Name, email, phone, booking form answers | Steps at your request before entering into an agreement (art. 6(1)(b)) | 3 months after the call if you do not become a client |
| Delivering coaching, mentoring and programmes | Contact details, coaching agreement, intake, session notes, messages | Performance of the agreement (art. 6(1)(b)) | 2 years after the end of the coaching relationship, or earlier at your request |
| Health, wellbeing or relationship information you share | As above, where it concerns these topics | Your explicit consent (art. 9(2)(a)) | As above |
| Session recordings | Audio and video of a session | Your explicit consent (art. 6(1)(a) and 9(2)(a)) | 30 days after the session, or earlier at your request |
| Coaching log for ICF credentialing | Name, session dates, hours | Your consent (art. 6(1)(a)) | As long as needed for our ICF credential |
| Work for organisations | Contact persons and participants: names, roles, contact details, engagement notes | Performance of the agreement with the organisation (art. 6(1)(b)); for participants, our legitimate interest in delivering it (art. 6(1)(f)) | As agreed in the contract; otherwise 2 years after the end of the engagement |
| Answering your message or contact form | Name, email, message | Our legitimate interest in replying (art. 6(1)(f)) | 1 year after we last replied |
| Mailing list and downloads | Name, email, opens and clicks | Your consent (art. 6(1)(a)) | Until you unsubscribe |
| Website statistics | Pages visited, general usage | Your consent via the cookie banner (art. 6(1)(a)) | As set by our website platform, Systeme.io |
| Invoicing and accounting | Name, address, invoice and payment details | Legal obligation (art. 6(1)(c)) | 7 years (Dutch tax law) |
| Handling your privacy requests | Your request and our reply | Legal obligation (art. 6(1)(c)) | 1 year after we handled it |
Where we rely on consent, you can withdraw it at any time. This does not affect what we did before.
You are not required to give us your personal data. Without your contact details we cannot schedule or deliver coaching. Everything you share in sessions is your choice.
5. Information about your health, wellbeing or relationship
Coaching often touches on wellbeing, stress or relationships. Under the GDPR, information about your health is a special category of personal data. We record it only with your explicit consent, which you give separately when you register, with its own tick box next to accepting the coaching agreement. We record only what is useful for your coaching. You can withdraw your consent at any time; we then delete these notes.
Coaching is not therapy or medical treatment. If we believe you need other help, we will tell you.
6. Couples coaching
In couples coaching, each of you shares information about yourself and about your partner.
- What you share in an individual session stays confidential and is not passed on to your partner without your permission.
- Each partner can exercise their own privacy rights. Where a request concerns information about the other partner, we take both interests into account.
- How notes and accounts are set up for couples is agreed with you before we start.
7. Session recordings
We record a session only if you ask for it or explicitly agree, each time. Recordings are used only to support your coaching. We store them securely and delete them 30 days after the session, or earlier at your request.
8. Coaching log (ICF)
With your consent, we keep a log of your name, session dates and total coaching hours to verify our coaching experience with the International Coaching Federation (ICF). We share identifiable details with the ICF only if they request them in an audit.
9. Mailing list and downloads
When you request a free download on our website, we also add you to our mailing list. We tell you this on the form before you sign up.
- You can unsubscribe at any time through the link in every email.
- We see whether you open or click our emails, to understand what is useful to you.
- We never sell or rent our mailing list.
10. Service providers
We use a small number of providers who process personal data on our behalf, under a data processing agreement. They may use your data only for our purposes.
| Provider | What for | Where data is stored |
|---|---|---|
| CoachAccountable, LLC | Booking, client accounts, coaching agreement, notes, messages | United States |
| Systeme.io | Website, forms, downloads, mailing list, website statistics | European Union (Ireland) |
| Microsoft 365 and Microsoft Teams | Email, files, administration, video calls | European Union |
| Cookiebot (Usercentrics A/S) | Cookie banner and records of your cookie choices | European Union |
We also share data with our bank and the Dutch Tax Administration where the law requires it. We never sell your data.
When we share without your permission. What you share in coaching stays confidential. We share it without your written permission only if the law requires it, or if there is an immediate and serious risk of harm to you or someone else. In that case we share only what is needed to prevent that harm.
When an organisation pays for your coaching. We share with that organisation only what we agreed with you and the organisation in advance, such as attendance or a general progress update. We never share what you said in sessions without your permission.
11. Transfers outside the European Union
CoachAccountable stores data in the United States, partly with its provider Cloudflare. CoachAccountable is certified under the EU–US Data Privacy Framework. The European Commission has decided that this framework offers an adequate level of protection. We check the certification every year.
12. Cookies and website statistics
Our website runs on Systeme.io. It uses cookies that are strictly necessary for the website to work, and Systeme.io’s own statistics to see how the website is used.
We ask your consent through a cookie banner (Cookiebot) before placing any cookies that are not strictly necessary. You can see which cookies we use, and change your choice, through the cookie icon on every page of our website or the link below. We do not use advertising or tracking pixels from third parties.
13. Social media
If you contact us through a platform such as LinkedIn or YouTube, that platform’s privacy policy applies to what you share there publicly. We keep private messages only where they relate to our services, and handle them under this policy.
14. Security
We protect your data with:
- Multi-factor authentication on all accounts
- Encrypted laptops and phones with automatic locking and updates
- Access limited to the people who need it
- A procedure for handling data breaches, including reporting to the Dutch Data Protection Authority where required
15. Your rights
You have the right to:
- access your personal data
- have it corrected
- have it deleted
- restrict or object to its processing, including for direct marketing
- receive it in a usable format (data portability)
- withdraw your consent at any time
Send your request to ava@avahoukes.com. We may ask you to confirm your identity. We respond within one month. If a request is complex, we may extend this by up to two months and will tell you why.
16. Automated decisions
We do not make decisions about you based solely on automated processing, and we do not use profiling.
17. Changes to this policy
We update this policy when our services or tools change. The latest version is always on our website, with its date and version number. If a change affects you significantly, we will let you know.
18. Questions and complaints
Ava Houkes, Expat Transition Coach & Advisor
Van Doornstraat 30, 1851 JK Heiloo, the Netherlands
ava@avahoukes.com · +316 10 3600 14 · www.avahoukes.com
If you are not satisfied with how we handle your data, you can lodge a complaint with the Dutch Data Protection Authority (https://www.autoriteitpersoonsgegevens.nl) or with the authority in the EU country where you live or work.
Privacy Policy — Ava Houkes · Version 5.1 · 25 October 2026