Privacy Policy

Last updated: March 2026

Pomera Services sàrl ("we", "us", "our") operates this coaching platform. This policy explains how we collect, use, store, and protect your personal data.

1. Data Controller

Pomera Services sàrl, Geneva, Switzerland.
Contact: contact us

2. Data We Collect

Account data: name, email address, profile information
Usage data: pages visited, features used, AI interactions, session timestamps
Coaching content: documents you upload, AI conversation transcripts, development plans
Payment data: billing details processed by Stripe (we do not store card numbers)
Technical data: IP address, browser type, device information
Communications: feedback and support messages you send us

3. How We Use Your Data

To provide and personalise the coaching platform service
To process payments and manage your subscription
To send transactional emails (session reminders, account notices)
To improve the platform through aggregated usage analytics
To comply with legal obligations

4. AI Processing

Your messages and uploaded documents may be processed by third-party AI providers (Anthropic) to generate coaching responses and development plans. This data is transmitted securely and is not used to train AI models without your explicit consent. Please do not share sensitive personal data (medical records, financial details, passwords) in AI conversations.

5. Legal Basis (GDPR)

Contract: processing necessary to deliver the service you've signed up for
Legitimate interests: platform security, fraud prevention, analytics
Consent: marketing communications (you may opt out at any time)
Legal obligation: compliance with applicable law

6. Data Sharing

We share data only with:

Your coach: your profile, documents, and conversation summaries as part of the coaching relationship
Infrastructure providers: Clerk (authentication), Stripe (payments), Anthropic (AI), Cloudflare R2 (file storage), Railway (hosting)
Legal authorities: where required by law

We do not sell your personal data.

7. Data Retention

We retain your data for as long as your account is active, plus up to 12 months after closure for legal and contractual purposes. Coaching documents and AI plans are retained for the duration of your subscription unless you request deletion.

8. Your Rights (GDPR)

You have the right to:

Access the personal data we hold about you
Rectify inaccurate data
Erasure ("right to be forgotten") — request via your account settings
Portability — receive your data in a structured format
Restriction of processing in certain circumstances
Object to processing based on legitimate interests

To exercise any of these rights, please contact us. We will respond within 30 days.

9. Cookies

We use cookies to maintain your session and for analytics. See our Cookie Policy for details.

10. Security

We use industry-standard security measures including encrypted connections (HTTPS), secure authentication (Clerk), and access controls. No system is 100% secure; please use a strong, unique password for your account.

11. International Transfers

Our service providers may process data outside the EU/EEA. Where this occurs, we ensure appropriate safeguards are in place (Standard Contractual Clauses or equivalent).

12. Changes to This Policy

We may update this policy from time to time. We will notify you of material changes via email.

13. Contact & Complaints

For privacy enquiries: contact us.
You also have the right to lodge a complaint with your local supervisory authority (e.g. CNIL in France, ICO in the UK, FDPIC in Switzerland).