Coaching and counselling for neurodivergent people

Version dated 04.05.2026.

Protecting your personal data is important to me. In this privacy policy I inform you about which data I collect, how I use it and what rights you have.

This privacy policy applies to my website divergente.ch as well as to my work as a coach in my practice in Winterthur.

The basis of this policy is the revised Swiss Data Protection Act (revDSG, in force since 1 September 2023). If you fall within the scope of the EU, the General Data Protection Regulation (GDPR) additionally applies.

1. Responsible person

Responsible for the content of this website within the meaning of the Data Protection Act:

Pablo Hernández Palazón
Coaching & counselling for neurodivergent people
Bosshardengässchen 5
8400 Winterthur
Switzerland

Phone: +41 78 302 18 88
Email: phpalazon@proton.me
Website: divergente.ch

2. What data do I collect?

2.1 When visiting the website

When you access my website, technical data necessary for providing the website is automatically recorded by the hosting provider:

• IP address (anonymised)
• Date and time of access
• Browser and operating system used
• Pages accessed

This data is used exclusively for the technical provision of the website and to defend against attacks. It is not linked to your person.

Note: This website uses NO web analytics tools (no Google Analytics, no Matomo, no tracking cookies). Only technically necessary cookies required for the operation of the website are used.

2.2 When contacting me

If you contact me via the contact form, by email or by phone, the data you provide is stored. This may include:

• First and last name
• Email address
• Phone number (if provided)
• Content of your message

I use this data exclusively to process your enquiry and for the subsequent correspondence.

2.3 In the context of coaching

If you make use of a coaching session, I collect the data necessary for the support:

• General personal data (name, address, date of birth, phone, email)
• Concerns, goals and topics you bring to the coaching
• Session notes (in keyword form)
• Invoicing and payment data

Only data that you provide voluntarily and that is relevant for the support is collected.

3. For what purpose do I process your data?

I process your data exclusively for the following purposes:

• Provision and technical operation of the website
• Answering your enquiries and correspondence
• Preparation, conduct and follow-up of coaching sessions
• Invoicing and accounting
• Fulfilment of legal retention obligations

4. Legal basis for processing

Your data is processed on the basis of:

• Your consent (Art. 6 para. 6 revDSG)
• The performance of the coaching contract between you and me
• Legitimate interests (e.g. secure operation of the website)
• Legal obligations (e.g. tax-related retention)

5. How long is your data stored?

Your data is stored only for as long as is necessary for the stated purposes or required by law:

Enquiries and correspondence
Up to 12 months after the end of the correspondence, provided no coaching relationship arises.

Coaching documents
10 years after the end of the coaching relationship, in accordance with the Swiss Code of Obligations.

Invoices and accounting
10 years, pursuant to Art. 958f of the Code of Obligations.

Data on the website
Server logs are generally deleted after a maximum of 90 days.

6. Disclosure to third parties

As a rule, I do not pass on your personal data to third parties. Exceptions exist only:

• With your explicit written consent
• When I am legally obliged to do so or by court order
• For strictly necessary technical service providers (e.g. hosting providers), who are themselves bound to confidentiality

Disclosure to insurers, health insurance funds or other bodies only takes place with your explicit consent.

7. Data security

I take appropriate technical and organisational measures to protect your data against unauthorised access, loss or misuse:

• Encrypted data transmission (SSL/TLS) on the website
• Password-protected devices and access
• Encrypted storage of sensitive client data
• Regular backups
• Use of the privacy-friendly email provider Proton Mail

8. Written communication

Written communication between me and you generally takes place by email. For sending sensitive content I recommend Proton Mail (end-to-end encrypted) or the messengers Signal or Threema.

Due to data protection concerns, I do not use WhatsApp or Telegram for communication with clients.

Please note that unencrypted emails are generally not considered a secure means of communication. If you would like to share sensitive topics, we can agree together on an encrypted communication channel.

9. Duty of confidentiality

As a coach, I commit to strict confidentiality regarding all content entrusted to me in the course of our collaboration. This duty of confidentiality applies without time limit, even after the end of the coaching relationship.

An exception exists only where there are legal reporting obligations or an acute threat to one’s own or others’ safety.

10. Your rights

You have the following rights regarding your personal data:

Right to information
You can request information at any time about which data I have stored about you.

Right to rectification
You can request the correction of inaccurate or incomplete data.

Right to erasure
You can request the deletion of your data, provided no legal retention obligations prevent this.

Right to data portability
You can request to receive your data in a common electronic format.

Right of withdrawal
You can withdraw consent given at any time.

Right to lodge a complaint
You have the right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC): www.edoeb.admin.ch

To exercise your rights, an informal message to phpalazon@proton.me is sufficient.

11. Cookies

This website uses exclusively technically necessary cookies required for the operation of the website. No cookies are used for tracking, advertising or web analytics.

You can deactivate or delete cookies in your browser at any time. However, this may mean that individual functions of the website are no longer available.

12. Changes to this privacy policy

I reserve the right to adapt this privacy policy in order to bring it into line with current legal requirements or changes to my services. The version in force at the time then applies to your subsequent visit.

13. Contact for data protection questions

If you have questions or concerns about data protection, you can reach me at:

Pablo Hernández Palazón
Email: phpalazon@proton.me
Phone: +41 78 302 18 88

This privacy policy was created on [insert date]. It will be updated as needed. Please regularly check the current version at divergente.ch/datenschutz.