Key points
- Who we are. IntelliCoach Pte Ltd (Singapore, UEN 201814680E) operates
www.intellicoach.com(marketing site, hosted on systeme.io) andlegacy.intellicoach.com(members area, courses, forum). - What we collect. Your name and email when you sign up, contact us, or join a programme. Limited browsing analytics. No tracking pixels for advertising.
- Why. To deliver coaching services, run the website, send the emails you asked for, and meet our legal obligations.
- Who else sees it. A short list of operational sub-processors (hosting, email delivery, analytics) listed below. We do not sell your data.
- Your rights. You can ask to see, correct, or delete the personal data we hold about you. Email dpo@intellicoach.com and we will respond.
Who is responsible for your data
The data controller is IntelliCoach Pte Ltd:
- Registered office: 7 Temasek Boulevard #12-07, Suntec Tower One, Singapore 038987
- UEN: 201814680E
- Contact: contact@intellicoach.com
Data Protection Officer
Under Singapore's Personal Data Protection Act 2012 section 11(3), every organisation must designate a Data Protection Officer. For IntelliCoach Pte Ltd this is Maik Frank Schroer, who is also the company's sole director. Singapore PDPA permits the same person to act as both controller representative and DPO; the EU GDPR Art. 38(6) "no conflict of interest" rule does not apply to the PDPA designation.
You can reach the DPO at dpo@intellicoach.com. Use this address for any access, correction, or erasure request, or if you believe your personal data is being mishandled.
What personal data we collect
When you visit www.intellicoach.com
- Browsing analytics: Google Analytics 4 sets cookies (
_ga,_ga_*,_gcl_au) that record a pseudonymous identifier, the pages you view, your referrer, and basic device information. Your IP address is read by Google for analytics purposes. - Form submissions: if you fill in a sign-up, contact, or opt-in form, we receive the fields you complete (typically first name and email; sometimes country, phone, or a free-text field). The form is delivered by systeme.io.
- Testimonial widgets (Endorsal): the widgets read your IP for view-attribution analytics.
- Podcast subscribe button (Podlove): loading the embedded button widget exposes your IP to Podlove. Clicking it does not collect data; it just opens your podcast app.
When you use legacy.intellicoach.com as a member
- Account data: name, email, password (hashed), membership level, payment metadata if you bought a paid programme.
- Course progress: which lessons you have viewed, quiz responses, certificates issued.
- Forum activity: posts you publish (visible to other members), private messages if you send any, your IP address against view and post events (used for spam control).
- Signed contracts: where you have signed a coaching contract or NDA via the e-signature feature, your name, email, IP, signature image, and the timestamped audit trail are stored.
- Login attempts: timestamp, IP, attempted username (used to detect brute-force attempts).
When we email you
- Outbound transactional email (password resets, course notifications, forum subscriptions, e-signature notifications): the message is sent through SocketLabs as our SMTP provider. The last 14 days of outbound messages are retained in our log for troubleshooting; older logs are purged automatically.
Why we process this data, and the legal basis
| Purpose | EU/UK GDPR lawful basis | PDPA basis |
|---|---|---|
| Run the website, store your member account, deliver courses you bought | Performance of contract (Art. 6(1)(b)) | Consent (signup) + necessary for the service |
| Send transactional emails you trigger (password reset, course updates) | Performance of contract (Art. 6(1)(b)) | Consent + necessary |
| Marketing emails when you opt in | Consent (Art. 6(1)(a)) | Express consent |
| Browsing analytics (GA4) | Consent (Art. 6(1)(a)), per ePrivacy Directive | Consent |
| Spam protection (forum IP logging, login attempt logging) | Legitimate interest (Art. 6(1)(f)), securing the service | Necessary for our legitimate interest in security |
| Comply with tax, accounting, anti-fraud obligations | Legal obligation (Art. 6(1)(c)) | Required or authorised by law |
Sub-processors
These are the third parties that help us run the site and the services. We pick them deliberately and use written data-processing terms with each.
| Sub-processor | What they do | Where they are |
|---|---|---|
| systeme.io (Systeme.io SAS, France) | Hosts www.intellicoach.com and the funnel pages; stores contacts and tags from form submissions |
France (EU) |
| AWS CloudFront (Amazon Web Services, sub-processor of systeme.io) | Delivers systeme.io's pages and assets via a global CDN | Global edge network |
| StackCP / Krystal Hosting Ltd | Hosts the legacy.intellicoach.com WordPress install |
United Kingdom |
| Google LLC (Google Analytics 4, Google Tag Manager) | Browsing analytics on www.intellicoach.com |
EU primary processing for EEA visitors; United States otherwise |
| SocketLabs Inc. | Outbound transactional email for legacy.intellicoach.com |
United States |
| Microsoft 365 / Exchange Online (Microsoft Ireland Operations Ltd) | Inbound and outbound mail for our @intellicoach.com mailboxes |
Ireland (EU) |
| Endorsal Limited | Testimonial widgets embedded on www.intellicoach.com |
United Kingdom |
| Podlove e.V. | Podcast subscribe button widget | Germany (EU) |
| Caseproof LLC (WishList Member) | Membership plugin that runs inside our WordPress install; vendor receives only licence-check pings | United States (vendor); data stored in the United Kingdom on StackCP |
| Fly Plugins LLC (WP Courseware) | LMS plugin that runs inside our WordPress install; same model as above | United States (vendor); data in the UK |
| gVectors Team (wpForo) | Forum plugin that runs inside our WordPress install | Vendor in Armenia; data in the UK |
| ApproveMe Inc. (e-signature) | E-signature plugin that runs inside our WordPress install; signed documents stored in our WordPress database | United States (vendor); data in the UK |
| OVHcloud (OVH SAS) | Authoritative DNS for the intellicoach.com zone (no visitor personal data) |
France (EU) |
We do not currently use Stripe, PayPal, Mailgun, YouTube embeds, or Hotjar on either property. Earlier policy versions mentioned some of these in error.
International transfers
IntelliCoach Pte Ltd is a Singapore-domiciled controller. When personal data leaves Singapore (which it does whenever it reaches our UK hosting, EU sub-processors, or US sub-processors), we rely on:
- Singapore PDPA section 26: contractual safeguards with each recipient ensuring a comparable standard of protection.
- EU GDPR Chapter V (when the data subject is in the EU): the European Commission's 2021 Standard Contractual Clauses, controller-to-processor module, with a transfer impact assessment for non-adequate countries.
- EU-US Data Privacy Framework: where US sub-processors are certified participants.
- UK IDTA or EU SCCs + UK Addendum: for transfers to or from the UK.
The November 2025 EU-Singapore Digital Trade Agreement is not an adequacy decision. We continue to rely on SCCs and PDPA contractual safeguards for SG↔EU transfers.
How long we keep your data
| Data | Retention |
|---|---|
| Member account (active members) | For the lifetime of your membership |
| Member account (closed) | Up to 24 months after closure, then deleted, except records we must keep for tax or legal reasons |
| Marketing email list (opted in) | Until you unsubscribe |
| Course progress + quiz responses | For the lifetime of your enrolment |
| Signed contracts (e-signature) | 7 years (statutory contract retention) |
| Forum posts | Until you ask us to remove them; public posts may be archived for forum continuity |
| Outbound email logs | 14 days (rolling) |
| Browsing analytics (GA4) | Up to 14 months at default GA4 retention |
| Login attempt log | 90 days |
| Backups | 30 days rolling |
Your rights
Under EU GDPR and UK GDPR you have the right to:
- access the personal data we hold about you;
- ask us to correct inaccurate or incomplete data;
- ask us to erase your data, subject to limited exceptions (e.g., records we must keep by law);
- object to or restrict certain processing;
- withdraw any consent you have given (without affecting the lawfulness of past processing);
- lodge a complaint with your local supervisory authority (EU: your member-state DPA; UK: the Information Commissioner's Office at https://ico.org.uk/).
Under the Singapore PDPA you have the right to:
- request access to the personal data we hold about you;
- request that we correct an error or omission in that data;
- withdraw consent for ongoing processing.
The Singapore PDPA's data-portability provision was passed in the 2020 Amendment Act but has not yet been brought into force; if and when it commences, this policy will be updated to reflect it.
To exercise any of these rights, email dpo@intellicoach.com. We will respond without undue delay and at the latest within one month (GDPR/UK GDPR) or 30 days (PDPA).
If you are unhappy with our response, you can complain to the Personal Data Protection Commission of Singapore (https://www.pdpc.gov.sg/), to your EU member-state DPA, or to the UK Information Commissioner's Office.
Children's data
IntelliCoach.com serves professional coaches, leaders, and learners. We do not knowingly collect personal data from anyone under 18. If you believe a child has submitted personal data through our site, email dpo@intellicoach.com and we will remove it.
Security and breach notification
We use TLS for all traffic, store passwords as salted hashes, restrict access to systems on the principle of least privilege, and use two-factor authentication for member accounts via the WP-2FA plugin. No system is perfectly secure; if a personal-data breach affects you, we will notify you without undue delay.
We also notify the Singapore Personal Data Protection Commission and any other competent supervisory authority within the timelines set by applicable law (PDPA: as soon as practicable after assessment; GDPR/UK GDPR: within 72 hours of becoming aware where feasible).
Changes to this policy
When we change this policy materially, we update the Effective date at the top and, where the change matters to you, we will tell you by email or by a notice on the site. Older versions are not currently archived publicly; if you need a prior version for a legal or audit reason, email dpo@intellicoach.com.
Definitions
- Personal data: information that identifies you, alone or in combination with other data we hold.
- Sub-processor: a third party that processes personal data on our behalf (e.g., a hosting provider).
- Controller / data controller: the entity that decides why and how personal data is processed. Here that is IntelliCoach Pte Ltd.
- DPO / Data Protection Officer: the designated contact for data-protection questions and complaints.
- GDPR: the EU General Data Protection Regulation. UK GDPR is the UK's post-Brexit successor regulation.
- PDPA: Singapore's Personal Data Protection Act 2012, as amended.
Version history
| Date | What changed |
|---|---|
| 2026-04-26 | First version of this policy. Written from a fresh audit of the live IntelliCoach.com web properties. Names IntelliCoach Pte Ltd as data controller, designates dpo@intellicoach.com as the DPO contact under PDPA s.11(3), enumerates the actual sub-processors (systeme.io, AWS CloudFront, StackCP, Google LLC, SocketLabs, Microsoft 365, Endorsal, Podlove, the locally-installed WordPress plugins, OVHcloud), states the international-transfer mechanisms (PDPA s.26 + EU SCCs 2021 + EU-US DPF + UK IDTA), and sets retention periods. Replaces an earlier auto-generated version. |