The Transition Coach – Jan Duvenhage

Privacy Policy

Effective date: 26 August 2026 · Last reviewed: 8 November 2026

1. Introduction

The Transition Coach (“we”, “us”, “our”), a coaching practice operated by Jan George Duvenhage, respects your right to privacy and is committed to protecting the personal information of everyone we deal with — website visitors, prospective clients, active coaching clients, and newsletter subscribers (“you”, “data subject”).

This Privacy Policy is drafted to comply with the Protection of Personal Information Act 4 of 2013 (“POPIA”), which regulates how personal information may lawfully be processed in South Africa. It explains what personal information we collect, why we collect it, how we protect it — including the sensitive notes generated during coaching — how long we keep it, and the rights you have over it.

For the purposes of POPIA, The Transition Coach is the “responsible party”: the party that determines the purpose of, and means for, processing your personal information.

2. Who This Policy Applies To

This Policy applies to:

  • Visitors to our website, booking pages, and online checkout;

  • People who submit an enquiry, booking, intake form, or discovery-call request;

  • Clients receiving executive, leadership, or life-transition coaching services, whether based in South Africa, Namibia, Botswana, or Zimbabwe;

  • Subscribers to our newsletters, The Offramp and The Restart; and

  • Any other individual whose personal information we process in the course of running our coaching practice.

3. Definitions

Term Meaning
Personal information Information relating to an identifiable, living natural person (or, where applicable, an existing juristic person), including name, contact details, identity number, and opinions about the person.
Special personal information A protected sub-category comprising religious/philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health, sex life, biometric information, or criminal behaviour (POPIA section 26). Sensitive material disclosed in coaching conversations — for example, health, mental wellbeing, or personal belief information — falls into this category.
Processing Any operation performed on personal information, including collection, storage, use, dissemination, or destruction.
Responsible party The person or organisation that decides why and how personal information is processed — here, The Transition Coach.
Operator A third party that processes personal information on our behalf, under our instruction (e.g. our booking, payment, or email platforms).
Data subject The individual to whom the personal information relates — i.e. you.
Information Officer The person accountable for compliance with POPIA within The Transition Coach.

4. Our Commitment to POPIA’s Eight Conditions for Lawful Processing

Section 4 of POPIA sets out eight conditions that must all be satisfied for processing to be lawful. We structure our entire data practice — and this Policy — around them:

  1. Accountability (section 8): We take responsibility for meeting every condition below, at the point we decide why and how to process your information, and throughout that processing, whether we handle the information ourselves or through an operator acting on our instructions.

  2. Processing limitation (sections 9–12): We process personal information lawfully, in a manner that does not infringe your privacy, and only to the extent that is adequate, relevant, and not excessive for the purpose (data minimisation). We process your information only where you have consented, where it is necessary to perform our coaching agreement with you, where the law requires it, or to protect our or your legitimate interests, and we collect it directly from you wherever possible.

  3. Purpose specification (sections 13–14): We collect personal information only for specific, explicitly defined, and lawful purposes connected to running our coaching practice, and we do not keep it for longer than that purpose requires (see clause 10, Retention).

  4. Further processing limitation (section 15): We do not use personal information for a new purpose that is incompatible with the purpose for which we originally collected it, without obtaining your fresh consent or another lawful basis.

  5. Information quality (section 16): We take reasonably practicable steps to keep your personal information complete, accurate, not misleading, and up to date, and we welcome corrections from you at any time.

  6. Openness (sections 17–18): This Policy, and the notice we give you when you first share your details with us, tell you what information we collect, why, and who may see it — that is the purpose of this document.

  7. Security safeguards (sections 19–22): We maintain appropriate technical and organisational measures to protect personal information — in particular sensitive coaching material — against loss, damage, unauthorised access, or unlawful processing (see clause 11, Security).

  8. Data subject participation (sections 23–25): You may ask us at any time whether we hold personal information about you, request a copy of it, and ask us to correct or delete it (see clause 12, Your Rights).

5. Personal Information We Collect — Data Minimisation

Consistent with the processing-limitation condition above, we only ask for personal information that is adequate, relevant, and not excessive for delivering coaching services, running our practice, and communicating with you. We do not collect special categories of information (such as identity numbers, race, or biometric data) unless a specific, lawful reason requires it.

Depending on how you interact with us, we may collect:

  • Contact and identification details: full name, email address, phone number, and — only where relevant to invoicing — a physical or postal address.

  • Enquiry and intake information: whatever you choose to share in a contact form, booking, or intake questionnaire (including the intake forms Carepatron sends you after you book) about your goals, circumstances, and reason for seeking coaching.

  • Coaching session content: notes, themes, and reflections arising from coaching conversations, which may incidentally include special personal information such as details about your health, wellbeing, beliefs, or relationships that you choose to disclose (see clause 7).

  • Scheduling and administrative data: appointment dates and times, session attendance, and correspondence about rescheduling.

  • Payment and order information: when you pay through our website, our online shop (WooCommerce) records your name, email address, phone number, billing address, and order details, and our payment provider confirms whether the payment succeeded. We also keep invoicing details. We do not store your full card or bank account details ourselves.

  • Marketing preferences: your subscription status for The Offramp and The Restart newsletters and any consent you have given for direct marketing.

  • Website usage data: limited technical information such as IP address and browser type where you interact with our booking or website tools, to the extent those platforms generate it.

We do not knowingly collect more than this, and we periodically review our intake materials to remove any field that is not strictly necessary for the stated purpose.

6. Why We Process Your Personal Information

We process your personal information only for the following specified, explicit, and lawful purposes:

  • To respond to enquiries and schedule discovery calls or coaching sessions;

  • To prepare for, deliver, and follow up on coaching engagements, including maintaining session notes for continuity of the coaching relationship;

  • To administer invoicing and process payments for services rendered;

  • To send you service-related communications (e.g. appointment confirmations, reminders, and administrative notices);

  • To send you marketing communications, such as The Offramp or The Restart, only where you have given your consent (see clause 9);

  • To comply with our legal, tax, and accounting obligations; and

  • To maintain the security, integrity, and proper functioning of our booking and communication systems.

We do not sell, rent, or trade your personal information to any third party, and we do not use it for any purpose beyond those listed here without first obtaining your consent or otherwise establishing a lawful basis, in keeping with the further-processing-limitation condition.

7. Special Personal Information and the Secure Storage of Coaching Notes

Coaching conversations often touch on deeply personal territory — career setbacks, health and wellbeing, relationships, beliefs, and identity. Where this material qualifies as special personal information under POPIA (for example, health or religious/philosophical belief information), our processing is grounded in your explicit, informed consent, obtained when you engage our coaching services, in line with the exception to the general prohibition on processing such information (POPIA sections 26–27).

To protect this material specifically, we commit to the following safeguards:

  • Confidentiality by default. Anything you share with us in a coaching session is treated as confidential. We do not disclose it to an employer, sponsor, family member, or any other third party without your explicit permission — except where we are legally required to do so, or where there is a serious and imminent risk of harm to you or another person.

  • Minimal sponsor reporting. If your coaching is sponsored by an employer or organisation, we share only the fact that coaching has taken place and the number of sessions attended — never the content of what was discussed — unless you specifically agree otherwise.

  • Secure digital storage. Session notes and client records are stored electronically in access-controlled, password-protected systems (Microsoft 365 business-grade storage with multi-factor authentication), never in unsecured shared documents, and are not printed or stored in physical form unless necessary and then kept under lock and key.

  • Restricted access. Only Jan Duvenhage, as the coach and Information Officer, has access to your coaching notes. Notes are not shared with other clients, contractors, or advertisers.

  • No unnecessary retention. Sensitive notes are retained only for as long as necessary in line with our retention schedule (clause 10) and are then securely deleted or anonymised.

  • Consent is always revisable. You may withdraw consent to our holding special personal information, or ask that specific notes be deleted, at any time, subject to any overriding legal retention requirement (see clause 12).

8. Sharing Your Information — Third-Party Operators and Cross-Border Transfers

We use a small number of trusted service providers (“operators”) to help run our practice. They process personal information only on our documented instructions and only to the extent needed to provide their service to us:

Operator Purpose
Carepatron Online appointment booking and scheduling, intake forms, and client booking records
PayFast Processing payments made at our website checkout, and recurring billing for payment plans (including the Reconstitution Method six-month plan) and retainer arrangements
MailerLite Sending The Offramp and The Restart newsletters and marketing communications to consenting subscribers
Microsoft 365 Business Online coaching sessions (Microsoft Teams), email correspondence, document storage, and secure storage of coaching notes and client records
HappyScribe Bilingual (English/Afrikaans) transcription of coaching-session recordings
Website platform (WordPress, WooCommerce, Jetpack) Running our website and online checkout, storing online order records, and recording basic visitor statistics
Wordfence Website security and firewall, which processes visitor IP addresses

Some of these operators process or store information outside South Africa. HappyScribe, for example, is based in the European Union (Ireland) and stores data under the EU General Data Protection Regulation — a framework recognised as providing a level of protection substantially similar to POPIA’s conditions. Where any other operator processes information outside South Africa, we take reasonable steps to confirm the recipient is subject to a law, binding agreement, or certification scheme providing an adequate level of protection, consistent with the cross-border transfer requirements of POPIA section 72. We do not otherwise share your personal information with third parties for their own purposes, and we never sell or rent it.

We may also disclose personal information where required by law, to comply with a court order, or to protect the safety of you or others.

9. Marketing Communications and Your Consent

We take the opt-in requirements of POPIA section 69 seriously. Direct marketing by electronic means (email, SMS, WhatsApp) is prohibited unless you have given consent, or you are already our client being offered similar services.

In practice, this means:

  • We will only add you to The Offramp, The Restart, or other promotional content if you have actively and voluntarily opted in — for example, by ticking a consent checkbox on an intake form or subscribing directly — never by default or through pre-ticked boxes.

  • When we ask for your consent, we will tell you clearly what we intend to send, and how (email, SMS, etc.), so your consent is specific and informed.

  • If you are an existing client, we may send you information about similar coaching services we offer, but we will always give you the opportunity to object, free of charge, both when we first collect your details and in every subsequent marketing communication.

  • Every marketing email includes a clear, working “unsubscribe” link, and you may also withdraw consent at any time by emailing our Information Officer directly.

  • We will not approach you more than once to request marketing consent if you have not responded or have declined.

  • Withdrawing marketing consent does not affect our ability to send you essential service communications related to coaching you have booked.

10. How Long We Keep Your Information (Retention)

In line with the purpose-specification condition, we do not retain personal information for longer than necessary to fulfil the purpose for which it was collected, or as required by law (POPIA section 14):

Category of information Retention period
Enquiry/intake data where no coaching engagement follows Up to 12 months from last contact, then deleted
Client contact details and administrative records Duration of the coaching relationship, plus 5 years thereafter, then deleted or anonymised
Coaching session notes and related sensitive material Duration of the coaching relationship, plus 5 years thereafter (to allow for continuity, reference, and defence of potential claims), then securely destroyed or anonymised, unless you request earlier deletion and no legal ground requires retention
Invoicing, payment, and financial records, including online orders 5 years, in line with South African tax record-keeping obligations under the Tax Administration Act 28 of 2011
Marketing/newsletter consent and subscription data Until you withdraw consent or unsubscribe, at which point we retain only a minimal suppression record to honour your opt-out
Website and booking-platform technical/usage data Up to 24 months

Where information has been used to make a decision about you, we retain it for whatever period the law requires, or otherwise for a period that gives you a reasonable opportunity to request access to it, in line with section 14(3) of POPIA.

11. Security Safeguards

In line with the security-safeguards condition (POPIA sections 19–22), we implement appropriate, reasonable technical and organisational measures to protect personal information against loss, damage, unauthorised destruction, and unlawful access or processing, including:

  • Password-protected, access-controlled digital storage with multi-factor authentication for email and document systems;

  • Restricting access to client records and coaching notes to Jan Duvenhage alone;

  • Using reputable operators (Carepatron, PayFast, MailerLite, Microsoft 365, HappyScribe, and our website platform) that maintain their own industry-standard security certifications, and requiring that they process information only on our instructions;

  • Not storing full payment card or banking details ourselves — this is handled exclusively by our payment providers;

  • Regularly reviewing what information, we hold and deleting what is no longer needed; and

  • Taking reasonable steps to identify and respond promptly to any suspected security compromise, including notifying the Information Regulator and affected data subjects as soon as reasonably possible where a breach creates a real risk of harm.

While we take these precautions seriously, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Your Rights as a Data Subject

Consistent with the data-subject-participation condition (POPIA sections 23–25), you have the right, free of charge (save for a reasonable fee for photocopying/administration where lawfully permitted), to:

  • Right of access: Ask us to confirm whether we hold personal information about you, and request a copy of that information and details of who has had access to it;

  • Right to correction: Ask us to correct or update personal information that is inaccurate, incomplete, or out of date;

  • Right to deletion/destruction: Ask us to delete or destroy personal information that we are no longer authorised to retain, or that was collected unlawfully;

  • Right to object: Object to the processing of your personal information, including for direct marketing purposes, on reasonable grounds;

  • Right to withdraw consent: Withdraw any consent you previously gave, at any time, without affecting the lawfulness of processing carried out before your withdrawal; and

  • Right to complain: Lodge a complaint with the Information Regulator of South Africa if you believe we have processed your personal information unlawfully (see clause 15).

How to exercise these rights: Submit your request in writing to our Information Officer using the contact details in clause 17. We will verify your identity before actioning any request. POPIA does not itself set a fixed reply period for section 23 access requests, but section 23 applies the same procedure PAIA sets for private-body access requests, so we treat 30 days from receipt as our standard response time, extendable in line with PAIA where a request is complex.

13. Children’s Personal Information

Our coaching services are directed at adults, and we do not knowingly collect personal information from children under 18 without the consent of a competent person (such as a parent or guardian), as required under POPIA. If we become aware that we hold a child’s personal information without appropriate consent, we will delete it promptly.

14. Cookies and Website Analytics

Our website runs on WordPress with WooCommerce and is connected to Jetpack (by Automattic). These set cookies needed for core functions, including the shopping cart and checkout, and Jetpack records basic usage statistics. The Carepatron booking calendar on our booking pages, PayFast’s payment pages, and MailerLite’s website script, which loads on our pages to support signup forms, may set their own cookies. We do not use Google Analytics, Meta Pixel, or any other third-party analytics or advertising tool.

Where cookies involve personal information, that information is processed in accordance with this Policy. You can manage or disable cookies through your browser settings, though this may affect how our booking tools function.

15. Complaints — Contacting the Information Regulator

If you are unhappy with how we have handled your personal information, we would appreciate the opportunity to resolve it directly first — please contact our Information Officer (clause 17). You also have the right to lodge a complaint with South Africa’s Information Regulator, the statutory body responsible for enforcing POPIA:

The Information Regulator (South Africa)

Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191

Postal address: P.O. Box 31533, Braamfontein, Johannesburg, 2017

Telephone: 010 023 5200 / Toll-free: 0800 017 160

General enquiries: enquiries@inforegulator.org.za

POPIA complaints: POPIAComplaints@inforegulator.org.za

Website: inforegulator.org.za

16. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, our services, or the law. The “Last reviewed” date at the top of this document will always show when it was most recently updated. Material changes affecting how we use your personal information will be communicated to active clients directly.

17. Contact Us — Information Officer

Any questions, requests, or concerns about this Policy or about how we handle your personal information should be directed to our Information Officer:

Information Officer: Jan George Duvenhage

Business: The Transition Coach

Email: coach@straatpredikant.com

Phone: +27 73 273 2727

Postal/physical address: Hakboslaagte, Coligny, 2725, North West, South Africa

Information Regulator registration: Registered as Information Officer under reference number 2026-065233 (registered 26 August 2026).

Appendix: Legal and Regulatory Sources

This Policy has been drafted with reference to the Protection of Personal Information Act 4 of 2013 and official guidance from South Africa’s Information Regulator, cross-checked directly against the sources below rather than assumed:

This Policy was also reviewed against published privacy practices at other South African coaching and coaching-adjacent businesses and comparable sole-practitioner and small-practice POPIA manuals, to check it aligns with sound sector convention on data collection, retention, marketing consent, and Information Officer disclosure.