Privacy policy

Privacy policy

Privacy Policy

Effective Date: 1st March 2025

Last updated 5th February 2026

1. Introduction

Amberbuzz Consulting Oy (“we”, “us”, or “our”) respects your privacy and is committed to handling personal data responsibly.

This Privacy Policy explains how we collect, use, and protect personal data when you use:

We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and applicable Finnish law.

Coaching sessions are recorded for the purpose of generating session summaries and action items. You will be informed before recording begins and may request that a session not be recorded.

2. Data Controller

Amberbuzz Consulting Oy
Finland
Email: graham@amberbuzz.fi

3. Personal Data We Collect

We may collect:

  • Identity & contact data (name, email)

  • Career and reflection data you choose to provide

  • AI-supported inputs and outputs

  • Technical data (IP address, browser, usage logs)

  • Cookie data (see Cookie Policy)

  • Private session notes maintained by the coach to support coaching quality and continuity

4. How We Collect Data

Data is collected through:

  • direct user input

  • mentoring tools and exercises

  • correspondence

  • cookies and analytics technologies

5. Legal Bases for Processing

We process data based on:

  • performance of a contract

  • legitimate interests (service improvement, security)

  • consent (where required)

  • legal obligations

6. Purpose of Processing

Personal data is processed to:

  • deliver mentoring services

  • support digital and AI-assisted tools

  • communicate with users

  • improve service quality

  • comply with legal requirements

7. AI-Supported Processing

Some services use AI-supported tools to help analyse or reframe information you provide.

These tools:

  • operate only on data you choose to submit

  • support reflection rather than decision-making

  • do not use your data to train public AI models

AI tools are used to identify patterns in exercise responses and session notes, including linguistic and behavioural signals relevant to coaching. A running Pattern Summary is maintained for each client across their engagement. This is used solely to improve session preparation and coaching quality, not for automated decision-making. Clients may request to view or delete their Pattern Summary at any time.

8. Data Sharing

We do not sell personal data.

We may share data with trusted processors (hosting, analytics, AI providers) under GDPR-compliant agreements, or where legally required.

Coaching sessions may be recorded using Fathom (fathom.video). Recordings, transcripts, and AI-generated summaries are processed by Fathom under a data processing agreement. Session data is retained for 24 months after the engagement ends.

Some processors are based outside the EU/EEA. Transfers are governed by Standard Contractual Clauses or equivalent GDPR-compliant mechanisms.

9. Cookies

We use cookies as described in our Cookie Policy.

10. Data Retention

Data is retained only as long as necessary for service delivery and legal obligations, after which it is deleted or anonymised.

  • Exercise responses and reflections – Duration of engagement + 2 years
  • Session notes and summaries – Duration of engagement + 2 years
  • Fathom recordings – 6 months after session
  • Coaching log and pattern summary – Duration of engagement + 2 years
  • Billing records – 7 years

11. Data Security

Appropriate technical and organisational measures are used to protect personal data. No system can be guaranteed fully secure, but care is taken to minimise risk.

12. Your Rights

You have the right to access, correct, delete, restrict, object to processing, and request portability of your data. This includes the right to access private session notes maintained about you.

Requests: graham@amberbuzz.fi

You may also lodge a complaint with the Finnish Data Protection Ombudsman.

13. Children

Services are intended for adults aged 18+. We do not knowingly collect data from children.

14. Changes

This Privacy Policy may be updated periodically. The latest version will be published on the website.

15. Contact

Amberbuzz Consulting Oy
Email: graham@amberbuzz.fi

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