
Privacy Policy
Effective date: 10 May 2025
Sacred Flame, operated by Andrew Mitchell (registered with the Dutch Chamber of Commerce under number 65244435), is committed to protecting your privacy and handling your personal data with care, in accordance with the General Data Protection Regulation (GDPR).
1. Who we are
Sacred Flame offers spiritual coaching and group facilitation, with services provided internationally, primarily online. We are based in the Netherlands and operate under the VAT number NL001160558B11.
If you have any questions about this policy, please contact: andrew@sacredflame.earth.
2. What personal data we collect
We collect and process the following data:
Identification and contact data: name, email address, phone number.
Intake form responses: including personal reflections, life context, and coaching intentions.
Session notes: reflections based on one-on-one or group sessions.
Payment information: only what is necessary for invoicing and bookkeeping.
Communication data: emails or messages relevant to the coaching process.
You may also share sensitive data related to your emotional well-being, spiritual beliefs, or health. This information is treated with extra care and stored only as needed for the coaching relationship.
3. Why we collect this data
Your data is collected and used for:
Scheduling and preparing coaching sessions.
Sending invoices and maintaining financial records.
Tailoring guidance to your specific situation.
Communicating with you effectively.
(In future phases) Offering newsletters, updates, or relevant content.
4. How your data is collected and stored
Intake forms are collected via email or Google Forms.
Notes and files are stored securely on a password-protected laptop and in Google Drive.
Financial data is stored in Moneybird, a Dutch invoicing platform.
No tracking cookies or analytics tools are used at this stage. (If added in future, this policy will be updated accordingly.)
5. Legal basis for processing
We process your data based on:
Your consent, when you voluntarily provide information.
The need to perform a contract, i.e. the coaching agreement.
Our legal obligations, such as financial recordkeeping.
You can withdraw your consent at any time by contacting us.
6. How long your data is retained
Personal and session data are stored only as long as you are an active client.
After the coaching relationship ends, your data will be securely deleted within three months, unless legal obligations require us to retain financial information longer (e.g. for tax purposes, up to seven years).
Communication records (emails, messages) are deleted after this three-month period, unless otherwise agreed.
7. Who has access to your data
Your data is treated as strictly confidential. It is not shared with third parties, except:
Moneybird, for invoicing.
Google Workspace, for intake forms and document storage.
These service providers comply with GDPR regulations and take appropriate data security measures.
No data is ever sold, rented, or shared for marketing purposes without your explicit consent.
8. Security measures
We take appropriate security measures, including:
Password-protected devices and software.
Secure cloud storage (Google Drive).
Session notes are accessible only by Andrew Mitchell.
9. Your rights
Under the GDPR, you have the right to:
Access the personal data we hold about you.
Correct or update your data.
Request deletion of your data.
Withdraw consent at any time.
File a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
Please note: internal notes written during or after sessions are considered private reflections and are not automatically shared, unless there is a compelling reason and mutual agreement.
10. Changes to this policy
This Privacy Policy may be updated from time to time.
When we do, we will notify active clients and publish the new version at www.sacredflame.earth.