What we collect, why, for how long, with whom — and your rights.
Last updated: June 13, 2026
You entrust us with information about yourself — your contact details, your answers to our assessments, sometimes the very substance of your coaching sessions. We handle this data with the rigor you expect from a firm that works with executives, and with one particular standard: what you share within a coaching engagement remains confidential and is never reported back to your employer. This page explains what we collect, why, for how long, with whom, and which rights you can exercise at any time.
The controller of your personal data is:
WE GARTNER — SASU (French simplified joint-stock company) with a share capital of €1,000
40 avenue d'Italie, 75013 Paris, France
SIREN 929 621 969
Personal data contact: executive@wegartner.com
General contact: executive@wegartner.com
WE GARTNER has not appointed a Data Protection Officer (DPO), as this appointment is not mandatory given the nature and volume of its processing activities. The contact above is your single point of contact for any question relating to your data.
We process your data only for specific purposes, each resting on a legal basis within the meaning of Article 6 of the GDPR. The table below summarizes our processing activities.
| Purpose | Legal basis (Art. 6 GDPR) | Categories of data | Retention period |
|---|---|---|---|
| Site browsing and audience measurement | Consent (non-essential cookies); legitimate interest (exempt measurement cookies) | Connection data, IP address, session identifiers, pages visited | Cookies: 13 months maximum; measurement data: 25 months maximum |
| AI assessments — run by our AI agents VALÉRIE (“AI Leadership Quotient”) and KATE (“Life Board”) | Consent (Art. 6.1.a) | Identity (last name, first name, role, company), business email, questionnaire answers, score and generated report | Up to 24 months after the last contact, unless you object or request erasure |
| Appointment scheduling | Pre-contractual measures / performance of a contract (Art. 6.1.b); legitimate interest | Identity, email, booked time slot, purpose of the meeting | 24 months after the appointment |
| B2B commercial prospecting | Legitimate interest (Art. 6.1.f) — developing a professional relationship | Identity, role, company, business email, history of exchanges | 3 years from the last inbound contact |
| Client relationship and contract performance | Performance of the contract (Art. 6.1.b); legal accounting obligation (Art. 6.1.c) | Identity, contact details, billing data, correspondence | Duration of the relationship + 10 years for accounting records (French Commercial Code, Art. L.123-22) |
| Coaching session data | Explicit written consent (Art. 6.1.a; Art. 9 where sensitive data is disclosed) | Session notes, objectives, information shared by the coachee | Duration of the engagement, then archived for 12 months after the engagement ends; deleted on request |
| Newsletter and editorial communications | Consent (Art. 6.1.a) | Email, first name, stated areas of interest | Until consent is withdrawn (unsubscribe link in every email) |
| Compliance with legal obligations and handling of rights requests | Legal obligation (Art. 6.1.c) | Data strictly necessary to process the request | Applicable statutory period |
Legal bases: Articles 6 and 9 of the GDPR (Regulation (EU) 2016/679). Information provided under Articles 13 and 14 of the GDPR.
Your data is processed by WE GARTNER and by authorized personnel only. To deliver its services, WE GARTNER relies on processors within the meaning of Article 28 of the GDPR, bound by data processing agreements (DPAs). The table below details their role, their location and, where applicable, the safeguard governing any transfer outside the European Union.
| Processor | Role | Location | Transfer outside the EU and safeguard |
|---|---|---|---|
| Brevo (formerly Sendinblue) | Email and CRM | France / EU | No transfer outside the EU |
| Airtable | CRM database | United States | Transfer governed by the European Commission's Standard Contractual Clauses (SCCs). |
| Make / Celonis | Workflow automation | European Union | No transfer outside the EU (European data zone). |
| Netlify, Inc. | Website hosting | United States | Transfer governed by the European Commission's Standard Contractual Clauses (SCCs). |
| Anthropic (Claude API) | Generation of the AI analyses for the assessments | United States | Transfer governed by the European Commission's Standard Contractual Clauses (SCCs). |
| PDFMonkey | PDF report generation | France (EU) | No transfer outside the EU (hosted on AWS Paris). |
| Calendly | Appointment scheduling | United States | Transfer governed by the Standard Contractual Clauses (SCCs) and the EU–US Data Privacy Framework. |
WE GARTNER neither sells nor rents your data. Your data is disclosed to third parties only in the cases listed above, or where required by law (competent administrative or judicial authority).
Legal bases: Article 28 of the GDPR (processing on behalf of a controller); Articles 44 to 49 of the GDPR (transfers outside the EU, governed by appropriate safeguards such as the European Commission's Standard Contractual Clauses or participation in the EU–US Data Privacy Framework).
Under Articles 15 to 22 of the GDPR, you have the following rights over your data at any time:
To exercise your rights, send your request to the personal data contact: executive@wegartner.com. We may ask for proof of identity in case of reasonable doubt. We respond within one month, extendable by two months for complex requests.
Complaints: if, after contacting us, you believe your rights are not being respected, you may lodge a complaint with the French data protection authority, the Commission nationale de l'informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France — www.cnil.fr.
Legal bases: Articles 15 to 22 of the GDPR (rights of data subjects); Article 7.3 (withdrawal of consent); Article 77 (right to lodge a complaint with a supervisory authority).
When WE GARTNER operates within a three-party arrangement — that is, a coaching engagement funded by your employer — one non-negotiable principle applies: the complete separation of individual session data.
In practical terms:
This separation is a condition of both the effectiveness and the ethics of coaching, and it prevails over any contrary request from the funding party.
The site uses no advertising trackers. It uses one audience measurement tool, Google Analytics 4, loaded via Google Tag Manager (Google LLC, United States). No audience measurement cookie is set without your consent: by default, measurement is disabled (consent denied by default, Consent Mode v2) and only your explicit acceptance via the consent banner triggers the setting of measurement cookies (_ga, maximum lifetime of 13 months). Cookies strictly necessary for the site to function — including the one storing your consent choice — are set without consent being required.
You can withdraw your consent at any time via the “Cookies” link in the footer, which clears your choice and displays the banner again. Audience measurement involves a transfer of data to the United States, governed by the applicable transfer framework (EU-US Data Privacy Framework). In addition, the appointment scheduling tool (Calendly, a processor established in the United States) is only loaded on the Contact page after you click “Show available times”; you can avoid it by writing to us directly at executive@wegartner.com.
Legal bases: Article 82 of the French Data Protection Act (loi Informatique et Libertés, transposing the e-Privacy Directive) and the CNIL's recommendations on cookies and other trackers.
WE GARTNER makes no decision producing legal effects concerning you, or similarly significantly affecting you, based solely on automated processing, including profiling. The analyses produced by our AI agents (VALÉRIE and KATE) are an aid to reflection; they are systematically supervised and reviewed by a human practitioner and carry no decision concerning you in themselves. How these tools work is detailed on the AI & the AI Act page.
Legal basis: Article 22 of the GDPR (automated individual decision-making).
WE GARTNER implements appropriate technical and organizational measures to protect your data against loss, alteration or unauthorized access, and requires an equivalent level of protection from its processors.
This policy may be updated to reflect changes in our processing activities or in the legal framework. The date of the last update appears at the top of this page. In the event of a substantial change, we will inform you through appropriate means.