Privacy Policy

1. Who we are

LeadXCultures is a communication and intercultural coaching practice operated by Chaz Pugliese. We provide one-to-one coaching, team coaching, and communication training services to individuals and organisations worldwide.

For the purposes of applicable data protection law, LeadXCultures is the data controller responsible for your personal data. You can contact us at hello@leadxcultures.com or by telephone at +33 6 71 64 66 61.

2. What data we collect

We collect personal data only when you actively provide it to us:

• Contact form: your name, email address, organisation, area of interest, and the content of your message.
• Consultation booking: your name, email address, and any information you provide when scheduling a session via our booking system.
• Email correspondence: any personal information contained in emails you send to us.

We do not collect sensitive personal data (such as health, political opinions, or religious beliefs) unless you volunteer it in the context of a coaching engagement and give explicit consent.

3. How we use your data

We use your personal data for the following purposes:

• To respond to your enquiry or message.
• To schedule and deliver coaching sessions.
• To send you information about our services where you have requested it or given consent.
• To comply with legal obligations that apply to our business.

We do not use your data for automated decision-making or profiling. We do not sell, rent, or share your personal data with third parties for their own marketing purposes.

4. Legal basis for processing

We process your personal data on the following legal bases under the General Data Protection Regulation (GDPR):

• Legitimate interests: responding to enquiries and communicating with potential clients.
• Contract performance: delivering coaching services you have engaged us for.
• Consent: sending marketing or newsletter communications where you have opted in.
• Legal obligation: where we are required to retain or disclose data by law.

5. Data retention

We retain your personal data only for as long as necessary for the purposes for which it was collected:

• Enquiry data (contact form submissions) is retained for up to 12 months unless a coaching relationship commences.
• Coaching client data is retained for 5 years following the end of the engagement, for legal and professional record-keeping purposes.
• Financial records are retained for 7 years in accordance with applicable accounting and tax law.

6. Data security

We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. This includes using encrypted communication channels and limiting access to personal data to those who need it to perform their role.

No method of transmission over the internet is completely secure. While we take data protection seriously, we cannot guarantee absolute security.

7. Third-party services

We may use third-party tools to operate our business, including:

• Hosting and infrastructure: our website is hosted on Vercel, which processes data in accordance with its own privacy policy.
• Appointment scheduling: we may use a third-party calendar or booking platform. Your data submitted through that platform is subject to its own privacy policy.
• Email: we use standard email services to communicate with you.

We only engage service providers who offer adequate data protection guarantees consistent with GDPR requirements.

8. International transfers

Where we transfer personal data outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as standard contractual clauses approved by the European Commission or transfers to countries with an adequacy decision.

9. Your rights

Under applicable data protection law, you have the following rights:

• Access: to request a copy of the personal data we hold about you.
• Rectification: to request correction of inaccurate data.
• Erasure: to request deletion of your data where there is no legitimate reason for us to continue processing it.
• Restriction: to request that we restrict processing of your data in certain circumstances.
• Portability: to receive your data in a structured, machine-readable format.
• Objection: to object to processing based on legitimate interests.
• Withdraw consent: where processing is based on consent, to withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at hello@leadxcultures.com. We will respond within 30 days. You also have the right to lodge a complaint with your local data protection authority.

10. Cookies

This website uses only essential technical cookies necessary for the site to function. We do not use advertising, tracking, or analytics cookies that require consent. No cookie banner is displayed because no consent is needed for strictly necessary cookies.

11. Changes to this policy

We may update this privacy policy from time to time. The most recent version will always be available on this page, with the date of last update shown at the top. We encourage you to review this page periodically.

12. Contact

For any questions or concerns about this privacy policy or how we handle your data, please contact us: