Effective Date: January 21, 2026
Last Updated: January 21, 2026

BESA Coaching (“BESA Coaching,” “B.E.S.A LLC,” “we,” “us,” or “our”) is committed to protecting your privacy and safeguarding your personal information. This Privacy Policy explains how we collect, use, disclose, and protect your information when you visit https://besacoaching.com/, use our coaching services, or interact with any platform or application operated by B.E.S.A LLC (collectively, the “Services”).

This Policy applies to all users, including minors, parents/guardians, clients, coaches, and contractors.
If you do not agree with this Policy, please do not use our Services.

If you have any questions or concerns after reviewing this Privacy Policy, please contact us at support@besacoaching.com.

SUMMARY OF KEY POINTS

 TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS?
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
14. COACHING CODE OF CONDUCT
15. DO WE MAKE UPDATES TO THIS NOTICE?
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. Information We Collect

We collect various types of information in order to provide coaching services, maintain the security of our platform, enhance our offerings, and comply with legal and contractual requirements. The categories of information we collect, and their corresponding purposes, are outlined below.

1. Personal Identifiers and Contact Information

We may collect information that can directly identify you, including:

• Full Name: For identity verification and to personalize your experience.
• Email Address: For registration, communication, notifications, and support.
• Mailing Address: For correspondence, billing, and, where applicable, document delivery.
• Telephone Number: For direct communication, verification, and urgent notifications.
• Date of Birth: To verify age, comply with legal requirements (especially for minors), and ensure appropriate service provision.

1. Account Credentials and Authentication Data

To create and secure your account, we collect:

• Usernames and Passwords: Required for account setup and secure login.
• Authentication Data: May include security questions or multi-factor authentication to protect your account.

1. Payment and Billing Information

To process payments and fulfill our financial obligations, we may collect:

• Payment Card Details: Card number, expiration date, and security code.
• Billing Address: For payment verification and transaction records.
• Transaction History: Records of payments made or received for services.
• Bank Account Information: For coaches and contractors, to process direct deposits.
• Tax Identification Numbers (e.g., W9 forms): For coaches and contractors, to comply with tax regulations.

All payment processing is conducted via secure third-party processors (such as Stripe or Bank of America). We do not store full payment card numbers on our servers.

1. Coaching Session Data

In the course of providing our coaching services, we collect and generate:

• Session Notes: Records of discussions, goals, progress, and recommendations.
• Session Schedules and Attendance: Dates, times, and participation records.
• Session Materials: Documents, assignments, or resources shared during sessions.
• Communications: Messages exchanged between clients and coaches through our platform.

All coaching session data is treated as strictly confidential and is accessible only to authorized individuals, in accordance with our confidentiality obligations.

1. User-Generated Content

We may collect information that you voluntarily submit on our platform, including:

• Feedback, Reviews, and Testimonials: Comments on your coaching experience.
• Survey Responses: Responses to questionnaires or surveys.
• Other Communications: Emails, messages, or inquiries sent to our staff.

1. Technical and Usage Data

When you interact with our website or platform, we automatically collect certain technical information, such as:

• IP Address: For security, fraud prevention, and website analytics.
• Device Information: Type, operating system, unique identifiers, and browser type.
• Usage Logs: Dates/times of access, pages viewed, features used, and actions taken.
• Analytics Data: Aggregated data to understand service usage and improve user experience.
• Cookies and Tracking Technologies: To remember preferences, analyze trends, and enhance performance. (See our Cookie Policy for details.)

1. Information Relating to Minors

We are committed to protecting the privacy of minors and collect only the information necessary for service provision and legal compliance, such as:

• Date of Birth: To confirm eligibility and enforce age-related policies.
• Parent/Guardian Contact Information: To obtain required consents and for communications.
• Parental Consent Documentation: Explicit permission is required for minors to use our services, in compliance with applicable law.

We do not knowingly collect personal information directly from children under 13. If we become aware that such information has been collected, we will promptly delete it.

1. Contractor and Coach Information

For coaches and contractors, we collect additional information to ensure safety, compliance, and quality, including:

• Background Check Results: To verify identity, qualifications, and ensure safety.
• Professional Certifications and Credentials: To confirm eligibility for coaching roles.
• Proof of Professional Liability Insurance: Where applicable, to meet our standards.
• Tax Forms and Identification: Such as W9 forms, for legal compliance.

Accuracy and Updates

You are responsible for ensuring that the information you provide is accurate, complete, and up to date. Please notify us promptly of any changes.

 Sensitive Information

We do not require you to provide sensitive personal information except where necessary for service provision or legal compliance (e.g., background checks, tax purposes, or identity verification). Such information is handled with the highest level of confidentiality and security.

Failure to Provide Data

Where collection of personal information is required by law or contract, failure to provide such information may prevent us from delivering our services to you.

If you have any questions about the information we collect or how it is used, please contact us at support@besacoaching.com.

2. How Do We Process Your Information?

We process your personal information for a variety of purposes to deliver, maintain, and improve our Services, comply with legal and regulatory requirements, and ensure the safety and integrity of our users and platform. The specific purposes and processing activities may vary based on your relationship with us (such as client, coach, contractor, minor, or parent/guardian) and your interactions with our Services.

Our Processing Activities Include:

• Account Creation and Management:
  We use your personal information to register and manage your account, authenticate your identity, and keep your account information current. This includes both initial registration and ongoing profile updates.
• Service Delivery and Administration:
  Your information is processed to provide the coaching services you request, manage session scheduling, match clients with coaches, and personalize content based on your preferences and activity.
• Session Facilitation and Record-Keeping:
  We process session notes, schedules, communications, and materials generated or shared during coaching sessions to ensure quality service, track progress, and maintain accurate records.
• Communication and Support:
  We use your contact information and session history to communicate with you regarding your account, respond to inquiries or support requests, notify you of upcoming sessions, and provide updates about your use of our Services.
• Feedback and Surveys:
  We may process your feedback, testimonials, reviews, and survey responses to monitor and improve our service quality.
• Payment Processing and Financial Management:
  We process payment and billing information to complete transactions, compensate coaches and contractors, manage refunds, and fulfill tax and financial obligations. This includes securely transmitting information to payment processors and maintaining transaction records.
• Coach and Contractor Verification:
  For coaches and contractors, we process background checks, professional credentials, certifications, tax forms, and insurance documentation to verify eligibility and maintain a safe, compliant environment.
• Legal and Regulatory Compliance:
  We process your information to comply with applicable laws and regulations, fulfill contractual obligations, respond to legal requests, and cooperate with law enforcement or regulatory authorities as required.
• Security, Monitoring, and Fraud Prevention:
  Technical and usage data (such as IP addresses and access logs) are processed to secure our platform, monitor for suspicious activity, detect and prevent fraud or misuse, and protect service integrity.
• Marketing and Promotional Communications:
  With your consent and according to your preferences, we may process your contact information to send you marketing materials, newsletters, promotions, or updates about new features. You may opt out of marketing communications at any time.
• Analytics and Service Improvement:
  We process usage and analytics data to identify trends, understand user behavior, evaluate our marketing efforts, and improve our Services and user experience.
• Protection of Vital Interests:
  In rare circumstances, we may process your information to protect your vital interests or those of others, such as in cases of imminent harm or mandatory reporting.
• Other Purposes with Your Consent:
  If we wish to use your information for purposes not described in this Policy, we will obtain your consent where required by law.

3. What Legal Bases Do We Rely on to Process Your Information?

At BESA Coaching, we process your personal information only when we have a valid legal basis for doing so. The legal bases we rely on depend on the context in which we collect and use your information, and may include the following:

• Consent: Where you have given us explicit permission to process your information for specific purposes (for example, to receive marketing communications or for processing information of minors).
• Performance of a Contract: Where processing is necessary to provide you with our Services, fulfill our contractual obligations, or take steps at your request prior to entering into a contract (such as creating your account, facilitating coaching sessions, or processing payments).
• Legal Obligation: Where we are required to process your information to comply with applicable laws or regulations (such as tax or accounting requirements, or to respond to lawful requests from authorities).
• Legitimate Interests: Where processing is necessary for our legitimate business interests (such as improving our Services, ensuring the security of our platform, or communicating with you about your account), unless those interests are overridden by your rights and interests.

The table below provides examples of how we apply these legal bases:

 Where we rely on your consent, you may withdraw it at any time by contacting us at support@besacoaching.com.

4. When and With Whom Do We Share Your Personal Information?

We do not sell or rent your personal information. We only share your information in the specific circumstances described below:

Categories of Recipients:

• Coaches and Contractors:
  Information necessary to facilitate coaching services, scheduling, and communication may be shared with coaches and contractors who are contractually required to maintain confidentiality.
• Parents/Guardians (for Minors):
  For users under 18, we may share personal information with parents or legal guardians to obtain necessary consents, provide oversight, and comply with legal requirements.
• Service Providers and Vendors:
  We engage trusted third-party vendors (such as payment processors, background check agencies, IT providers, analytics companies, and marketing services) to assist with business operations. These vendors are bound by confidentiality agreements and are only permitted to use your information as necessary to provide services on our behalf.
• Law Enforcement and Regulatory Authorities:
  We may disclose your information if required by law, regulation, court order, or legal process, or to protect the rights, property, or safety of BESA Coaching, our users, coaches, or others. This may include mandatory reporting in cases of suspected harm or abuse.
• Corporate Transactions:
  In the event of a merger, acquisition, business transfer, or sale of all or part of our assets, your information may be transferred to the new entity, subject to confidentiality protections.
• With Your Consent:
  We may share your information with third parties or make it public if you have provided explicit consent or directed us to do so, such as by posting testimonials or participating in public forums.

No Unauthorized Disclosure:
All third parties with whom we share your information are required to use it only as directed by us and in accordance with this Privacy Policy and applicable law.

5. Do We Use Cookies and Other Tracking Technologies?

Yes, BESA Coaching uses cookies and similar tracking technologies to enhance your experience, improve our services, and support website functionality.

What Are Cookies?

Cookies are small text files placed on your device when you visit our website. They help us recognize you, remember your preferences, and provide a more personalized experience.

Types of Cookies We Use

• Essential Cookies: Necessary for the operation of our website (e.g., to enable secure log-in and use of core features).
• Performance and Analytics Cookies: Help us understand how visitors interact with our website, so we can improve user experience and troubleshoot issues.
• Functional Cookies: Remember your choices and preferences (such as language or region selection).
• Advertising/Targeting Cookies: If used, these cookies deliver relevant ads to you and track the effectiveness of our marketing campaigns.

 Other Tracking Technologies

We may also use web beacons, pixels, and similar technologies that collect information about your interaction with our website and emails (such as open rates and clicks) to help us assess and improve our communications.

How You Can Control Cookies

You can manage or disable cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling cookies may affect the functionality of our website and your user experience.

For more detailed information about the cookies and tracking technologies we use, and how to manage your preferences, please review our Cookie Policy (or insert link).

Do Not Track

Some browsers offer a “Do Not Track” feature. Currently, our website does not respond to “Do Not Track” signals.

If you have any questions about our use of cookies or other tracking technologies, please contact us at support@besacoaching.com.

6. Is Your Information Transferred Internationally?

BESA Coaching operates globally and may transfer your personal information to countries outside of your country of residence, including the United States, where our servers, offices, or service providers are located.

How and Why International Transfers Happen

Personal data may be transferred internationally for purposes such as cloud storage, payment processing, customer support, or working with contractors and coaches located in other countries. These transfers are necessary to provide you with our Services, fulfill contractual obligations, and support the operation and security of our platform.

Legal Safeguards for International Transfers

We are committed to ensuring that your information is adequately protected, no matter where it is processed. When transferring your personal data internationally, we:

• Comply with applicable data protection laws (such as the GDPR, UK GDPR, or other relevant regulations).
• Use legally recognized safeguards such as Standard Contractual Clauses (SCCs), International Data Transfer Agreements (IDTAs), or other approved mechanisms where required.
• Ensure that our third-party service providers and partners are contractually obligated to protect your information to the same standard we uphold.

 Your Rights Regarding International Transfers

Depending on your location, you may have the right to request further information about how your data is protected during international transfers. If you would like more details or have concerns about how your information is handled internationally, please contact us at support@besacoaching.com.

7. How Long Do We Keep Your Information?

We retain your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with our legal obligations, and protect our legitimate interests. The specific retention periods we apply are as follows:

• Account Information: We retain your account information for as long as your account is active. After your account is closed, we retain related data for up to 7 years to comply with legal, tax, and accounting requirements or to resolve disputes.
• Coaching Session Data: Coaching session notes, schedules, materials, and related communications are retained for up to 7 years after your last session, unless a longer retention period is required by law or you request deletion sooner (subject to applicable legal requirements).
• Payment and Billing Data: Payment records, invoices, and transaction details are retained for 7 years in accordance with tax and financial regulations.
• Contractor and Coach Information: Information related to coaches and contractors (including contracts, tax forms, and background checks) is retained for 7 years after the end of the contractual relationship, or longer if required by law.
• User-Generated Content and Communications: Feedback, reviews, and other user-generated content are retained for as long as necessary to provide our services, improve our platform, or until you request their removal.
• Technical and Usage Data: Technical logs and analytics data are generally retained for up to 2 years for security, analytics, and service improvement.

Data Deletion and Anonymization

When your information is no longer required for the purposes for which it was collected, we will securely delete or anonymize it so that it cannot be used to identify you.

Your Right to Request Deletion

You may request that we delete your personal information at any time, subject to certain exceptions (such as where we are required to retain your data to comply with legal obligations). To request deletion, please contact us at support@besacoaching.com.

If you have questions about our data retention periods or wish to know more about how long a specific type of data is kept, please contact us.

8. HOW DO WE KEEP YOUR INFORMATION SAFE? (DATA SECURITY)

In Short: We are committed to protecting your personal information through a combination of organizational and technical security measures.

We utilize industry-standard technical, administrative, and physical safeguards to protect your information against unauthorized access, loss, misuse, or disclosure. These measures include:

• Encryption of sensitive data during transmission and at rest;
• Access controls, authentication protocols, and audit logs for staff and contractors;
• Regular security assessments and continuous monitoring;
• Contractor and coach agreements that require confidentiality and adherence to security practices.

Despite our efforts, no method of transmission over the Internet or electronic storage is completely secure. We encourage you to use strong passwords and regularly monitor your accounts for unauthorized activity. Transmission of personal information to and from our Services is at your own risk. You should only access the Services through secure environments.

9. DO WE COLLECT INFORMATION FROM MINORS? (POLICY REGARDING MINORS)

In Short: We do not knowingly collect or market to children under 18 years of age.

• Users under 18: Registration and consent must be provided by a parent or legal guardian. Sessions for minors may require adult supervision, as determined by BESA Coaching policy.
• Users under 13: We do not knowingly collect personal information from children under 13 years of age. If we become aware that we have inadvertently collected such information, we will promptly delete it. We comply with the Children’s Online Privacy Protection Act (COPPA) and other applicable child privacy laws.

By using the Services, you represent that you are at least 18 years old or that you are the parent or legal guardian of a minor and consent to their use of the Services.

If we learn that personal information has been collected from a child under the age of 13, we will deactivate the account and take reasonable steps to promptly delete such information from our records. If you become aware of any personal information we may have collected from children under 13, please contact us at support@besacoaching.com.

10. YOUR PRIVACY RIGHTS (YOUR RIGHTS AND CHOICES)

In Short: In certain regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you are granted specific rights regarding your personal information. These rights provide you with greater access to and control over your personal data. You may review, modify, or close your account at any time.

Depending on your location, you may have the right to:

• Access, correct, or update your personal information;
• Request the deletion of your personal information, subject to legal or contractual retention requirements;
• Object to or restrict certain processing of your personal information;
• Request a copy of your data in a portable format;
• Withdraw your consent at any time (this will not affect processing that occurred before your consent was withdrawn).

To exercise any of these rights, please contact us at support@besacoaching.com. We may need to verify your identity before processing your request.

We will review and respond to your request in accordance with applicable data protection laws.

Complaints:
If you are located in the EEA or UK and believe that we are processing your personal information unlawfully, you have the right to lodge a complaint with your local data protection authority.
If you are in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing Your Consent:
If we rely on your consent to process your personal information, you may withdraw your consent at any time by contacting us or updating your preferences. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal, nor does it affect processing based on other lawful grounds where permitted by law.

Opting Out of Marketing and Promotional Communications:
You may unsubscribe from our marketing communications at any time by clicking the ‘unsubscribe’ link in our emails or by contacting us at support@besacoaching.com. Please note that even if you opt out of marketing messages, we may still send you service-related or account-related communications.

Account Information:
To review, update, or delete your account information, you can log in to your account settings and make changes directly. If you request to close your account, we will deactivate or delete your account and remove your personal information from our active databases. However, we may retain certain information as necessary to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal agreements, or comply with legal requirements.

Cookies and Similar Technologies:
Most web browsers accept cookies by default. If you prefer, you can usually modify your browser settings to remove or reject cookies. Please note that disabling cookies may impact the functionality of certain features or services on our website.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile devices and applications include a Do-Not-Track (“DNT”) feature or setting that you can activate to express your preference not to be tracked online. Currently, there is no universally accepted standard for recognizing DNT signals. As a result, we do not respond to DNT signals or similar mechanisms at this time.

If a standard for online tracking is established in the future that we are required to follow, we will update this Privacy Policy accordingly to inform you of our practices.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Residents of California, Colorado, Connecticut, Virginia, and Utah are provided with specific privacy rights regarding their personal information.

Categories of Personal Information We Collect

Within the past twelve (12) months, BESA Coaching has collected the following categories of personal information in connection with our services, as further described in the “Information We Collect” section of this Policy:

We may also collect personal information beyond these categories through your interactions with us, such as:

• Customer support communications
• Survey or contest participation
• Facilitating services and responding to inquiries

How We Use and Share Your Personal Information

We use your personal information as described in the “How We Use Your Information” and “Information Sharing and Disclosure” sections above. This includes providing and improving our services, processing transactions, ensuring safety, responding to inquiries, verifying coach qualifications, and complying with legal obligations.

• We do not sell or rent your personal information.
• We may share your personal information with coaches, contractors, and service providers (such as payment processors, background check agencies, IT and analytics vendors), as required by law, or with your consent.
• For minors, certain information may be shared with parents or guardians to comply with legal and oversight requirements.

 California Residents

Shine The Light Law:
California Civil Code Section 1798.83 allows California residents to request information, once per year and free of charge, regarding our disclosure of personal information to third parties for direct marketing purposes. To make such a request, please email support@besacoaching.com.

California Consumer Privacy Act (CCPA):
If you are a California resident, you have the following rights:

• Right to Know: Request information about the categories and specific pieces of personal information we have collected, used, disclosed, sold, or shared.
• Right to Delete: Request deletion of your personal information, subject to certain exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Non-Discrimination: You will not be discriminated against for exercising any of your privacy rights.
• Right to Limit: Limit the use and disclosure of sensitive personal information. We use sensitive personal information only as permitted by law and do not process it in a manner requiring an opt-out.
• Right to Opt-Out: Request to opt out of the “sale” or “sharing” of your personal information (we do not currently sell or share your personal information).
• Rights of Minors: If you are under 18 and have a registered account, you may request removal of content you have publicly posted on our services.

To exercise any of these rights, please contact us at support@besacoaching.com.

Verification Process:
We will verify your identity before fulfilling any privacy request by matching the information you provide with our records, and may request additional information as needed for security and fraud prevention. Information collected for verification will be deleted after the process is complete.

Authorized Agents:
You may designate an authorized agent to submit requests on your behalf. We may require proof of the agent’s authority.

Colorado, Connecticut, Virginia, and Utah Residents

Depending on your state of residence, you may have the following rights:

• Right to Access: Confirm whether we process your personal data and access that data.
• Right to Correct: Correct inaccuracies in your personal data.
• Right to Delete: Request deletion of your personal data.
• Right to Data Portability: Obtain a copy of your data in a portable format.
• Right to Opt Out: Object to targeted advertising, sale of personal data, or profiling that produces legal or similarly significant effects.

To exercise these rights, please email support@besacoaching.com.

Rights of Minors

For users under 18, a parent or guardian must provide consent and may access or request deletion of the minor’s information as described in Section 8.

 Virginia VCDPA Rights

You may exercise your rights under the Virginia Consumer Data Protection Act by emailing support@besacoaching.com.

If you use an authorized agent to exercise your rights, we may deny the request if the agent does not provide proof of valid authorization.

Verification:
We may request additional information as reasonably necessary to verify your identity and the consumer request. If you submit a request through an authorized agent, we may require verification of your identity before processing the request.

Upon receiving a request, we will respond without undue delay, and in any case within forty-five (45) days. This period may be extended once by an additional forty-five (45) days when reasonably necessary, with notice provided within the initial response period.

Right to Appeal:
If we decline to act on your request, we will inform you of our decision and reasoning. You may appeal this decision by emailing support@besacoaching.com. We will respond to appeals within sixty (60) days with an explanation of our actions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

If you have any questions or wish to exercise your privacy rights, please contact us at support@besacoaching.com

 13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Depending on your country of residence, you may have additional privacy rights.

Australia and New Zealand

We collect and process your personal information in accordance with Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020. This Privacy Policy fulfills the notice requirements under both laws, including details on what personal information we collect, where it comes from, why we collect it, and who else might receive it.

If you choose not to provide personal information necessary for specific purposes, it may impact our ability to provide services, such as:

• Offering you requested products or services;
• Responding to your queries or requests;
• Managing your account;
• Verifying your identity and protecting your account.

You have the right to request access to or correction of your personal information at any time. To do so, please contact us using the information in the section “HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?”

If you believe your personal information is being processed unlawfully, you may submit a complaint:

• For breaches of the Australian Privacy Principles: to the Office of the Australian Information Commissioner.
• For breaches of New Zealand’s Privacy Principles: to the Office of the New Zealand Privacy Commissioner.

Republic of South Africa

You have the right to request access to or correction of your personal information at any time. Please contact us using the information provided in the section “HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?”

If you are dissatisfied with how we handle your complaint about personal information, you may contact the Information Regulator (South Africa):

• General enquiries: enquiries@inforegulator.org.za
• Complaints (using POPIA/PAIA Form 5):
  • PAIAComplaints@inforegulator.org.za
  • POPIAComplaints@inforegulator.org.za

Other International and Regional Rights

Depending on your jurisdiction, you may also have the right to:

• Access, correct, or update your personal information;
• Request deletion of your information, subject to legal or contractual retention requirements;
• Object to or restrict certain processing activities;
• Request a copy of your data in a portable format;
• Withdraw your consent at any time (without affecting processing that occurred before the withdrawal).

To exercise your rights, please contact us at support@besacoaching.com. We may need to verify your identity before fulfilling your request.

 14.BESA LLC Coaching Code of Conduct

At BESA LLC, we are committed to creating a transformative coaching environment rooted in our core values: Believe, Empower, Strive, Achieve. This Code of Conduct outlines the standards, expectations, and responsibilities that apply to all coaches, staff, and affiliates. Our Code is aligned with the International Coaching Federation (ICF) Code of Ethics, recognized as the industry gold standard.

 14.1. Our Core Values in Practice

14.2. Professional Conduct and Integrity

14.2.1. Honesty and Transparency

• Disclose all relevant qualifications, certifications, and experience in accordance with ICF standards.
• Represent services, skills, and expertise truthfully in all communications and marketing.
• Avoid making false or misleading claims regarding coaching outcomes.

14.2.2. Accountability

• Accept responsibility for personal actions, decisions, and their impacts.
• Acknowledge and correct mistakes promptly, using them as learning opportunities.
• Honor all commitments and agreements with clients and colleagues.

14.2.3. Compliance with Laws and Regulations

• Comply with all applicable local, state, and federal laws and regulations.
• Seek legal guidance as needed to ensure all practices are legally and ethically sound.

14.2.4. Promotion of the Profession

• Uphold the reputation of the coaching profession through ethical conduct and mutual respect.
• Refrain from making disparaging remarks about clients, colleagues, other coaches, or the profession.

14.3. Respect for Individuals and Diversity

14.3.1. Non-Discrimination

• Provide coaching services without discrimination based on any protected characteristic.
• Foster an inclusive and welcoming environment for all clients and team members.

14.3.2. Anti-Harassment and Bullying

• Maintain a strict zero-tolerance policy for harassment, bullying, or intimidation.

14.3.3. Accessibility

• Make reasonable accommodations to ensure coaching services are accessible to all clients.

14.3.4. Cultural Sensitivity

• Demonstrate awareness and respect for each client’s cultural background, beliefs, and values.
• Engage in ongoing education and self-reflection to serve a diverse population effectively.

14.3.5. Respect for Autonomy

• Acknowledge that clients are the experts in their own lives and honor their decision-making authority.
• Do not impose personal values, beliefs, or solutions.

14.4. Client Relationship Standards

14.4.1. Informed Consent and Clear Agreements

• Obtain explicit, informed consent from clients regarding coaching processes, confidentiality, data usage, and client rights.
• Clearly outline the scope, nature, and limitations of the coaching relationship before services begin.
• Provide written agreements on confidentiality, fees, scheduling, cancellations, termination, and data protection.

14.4.2. Maintaining Professional Boundaries

• Avoid dual or multiple relationships that could impair objectivity or risk exploitation.
• Do not enter financial, romantic, or other non-professional relationships with clients during or after the coaching engagement.

14.4.3. Confidentiality and Privacy

• Treat all client information as confidential, except where disclosure is required by law (e.g., imminent harm, court orders).
• Secure all records (written, digital, audio) with appropriate safeguards.
• Obtain explicit consent before using any client information for case studies, testimonials, or training purposes.

14.4.4. Client Safety, Wellbeing, and Duty to Report

• Monitor for signs of distress or issues beyond the scope of coaching.
• Refer clients to qualified professionals as needed.
• Do not attempt to diagnose or treat medical or psychological conditions.
• Report suspected abuse, neglect, or imminent harm as required by law.

14.4.5. Ending the Coaching Relationship

• Respect the client’s right to end the coaching relationship at any time, for any reason.
• End the relationship if coaching is no longer beneficial, providing referrals if appropriate.
• Offer closure and resources to support the client’s continued growth after coaching.

14.5. Scope of Practice and Professional Excellence

14.5.1. Scope of Practice

• Clearly communicate the scope and limitations of coaching, and do not provide advice outside areas of competence (e.g., legal, financial, medical).

14.5.2. Competence and Continuous Learning

• Deliver coaching services only within your areas of competence, training, and expertise.
• Engage in ongoing professional development and reflective practice.

14.5.3. Supervision and Support

• Seek regular supervision or mentoring to ensure ethical practice and client safety.
• Participate in peer feedback to maintain coaching effectiveness.

14.5.4. Feedback and Self-Reflection

• Encourage and be receptive to feedback.
• Reflect regularly on your practice to identify and address areas for improvement.

14.5.5. Use of Tools and Techniques

• Use evidence-based, reliable coaching tools and explain their purpose and limitations to clients, obtaining consent when necessary.

14.6. Conflicts of Interest and Transparency

14.6.1. Disclosing Conflicts

• Proactively disclose any real, perceived, or potential conflicts of interest.
• Resolve conflicts in the best interest of the client and the integrity of the coaching relationship.

14.6.2. Avoiding Undue Influence

• Do not use your coaching position for personal, professional, or financial gain outside the agreed-upon relationship.
• Do not solicit or accept gifts, favors, or benefits that could influence professional judgment.

14.7. Use of Client Information and Intellectual Property

14.7.1. Record Keeping and Retention

• Maintain accurate, timely, and secure records.
• Comply with data protection laws and client requests regarding access, correction, or destruction of information.
• Retain records for [3 years] after services end, then securely destroy them in accordance with applicable laws.

14.7.2. Intellectual Property

• Respect intellectual property rights of clients, colleagues, and third parties.
• Use published or proprietary materials only with proper permission or attribution.

14.7.3. Use of Testimonials and Marketing

• Obtain explicit written consent before using client testimonials or success stories in marketing.
• Represent coaching services honestly, without guaranteeing specific results.

14.8. Technology, AI, and Virtual Coaching

14.8.1. Security and Privacy in Digital Coaching

• Use secure, password-protected platforms for virtual coaching.
• Inform clients of risks and limitations of digital communications.
• Encrypt and store digital records in compliance with privacy regulations.

14.8.2. Professionalism Online

• Maintain professionalism in all digital and online interactions.
• Never discuss confidential client matters in online forums or on social media.

14.8.3. Use of AI and Automated Tools

• Clearly inform clients if AI-driven or automated tools are used.
• Ensure all AI assessments are supervised by a qualified coach.
• Manage data from such tools in line with privacy and security best practices.

14.9. Alignment with ICF Ethical Standards

All BESA LLC coaches commit to the following ICF principles:

• Professional Conduct: Model ethical behavior and uphold the integrity of the coaching profession.
• Confidentiality/Privacy: Maintain strict client confidentiality.
• Avoiding Conflicts of Interest: Act transparently and impartially at all times.
• Continuous Development: Commit to lifelong learning and self-improvement.
• Competence: Deliver services only within the scope of your training and expertise.

14.10. Reporting, Accountability, and Enforcement

14.10.1. Reporting Violations

• Any person may report suspected violations of this Code of Conduct to the designated BESA Ethics Officer or via established reporting channels.
• All reports will be treated with confidentiality and respect. BESA LLC strictly prohibits retaliation against anyone who, in good faith, reports a concern or participates in an investigation.

14.10.2. Investigation and Resolution

• All reports of suspected violations will be investigated promptly, impartially, and thoroughly.
• Individuals found to have violated this Code may face disciplinary action, which may include retraining, suspension, termination of employment or engagement, and/or referral to appropriate regulatory or legal authorities, as applicable.

14.10.3. Commitment to Improvement

• Lessons learned from investigations will be used to enhance BESA LLC’s policies, procedures, and training programs.
• BESA LLC is dedicated to promoting a culture of ethical awareness, accountability, and continuous improvement.

14.11. Continuous Review and Acknowledgment

• This Code of Conduct is reviewed at least annually, with input from coaches, clients, and other stakeholders.
• All BESA LLC staff, coaches, and affiliates are required to acknowledge they have read, understood, and agree to abide by this Code as a condition of their employment or affiliation.
• Any updates or significant changes to the Code will be communicated promptly. Re-acknowledgment of the updated Code will be required following substantial revisions.

14.12. Contact and Further Information

For questions, clarification, or to report concerns regarding this Code of Conduct, please contact:

• Email: support@besacoaching.com
• Website: https://besacoaching.com/

 15. Do We Make Updates to This Notice?

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons.

When we make material changes to this Privacy Policy, we will notify you by:

• Posting a prominent notice on our website;
• Updating the “Last Updated” date at the top of this Policy;
• And, where appropriate, notifying you via email or through your account.

We encourage you to review this Privacy Policy regularly to stay informed about how we protect your information.

Your continued use of our Services after any changes to this Privacy Policy means you accept the updated terms.

If you have any questions about updates to this Policy, please contact us at support@besacoaching.com.

16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have any questions, concerns, or would like to exercise your privacy rights, please contact us:

Email: support@besacoaching.com

Address:
B.E.S.A LLC
1601 Willow Lawn Dr, Suite 304
The Shops at Willow Lawn
Richmond, VA 23223
United States

17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Depending on the applicable laws in your country, you may have the right to request access to the personal information we collect about you, as well as to request that we correct or delete that information. To make such a request, please email us at support@besacoaching.com. We may require you to verify your identity before processing your request.

We will handle your request in accordance with applicable data protection laws. We retain your personal information only as long as necessary to:

• Provide our services;
• Fulfill the purposes described in this Policy;
• Comply with legal, regulatory, and contractual obligations;
• Resolve disputes and enforce our agreements.

When your information is no longer required, we will securely delete or de-identify it.

Effective Date: January 21, 2026