Privacy policy.
What we collect, why, for how long, with whom — and your rights.
Last updated: 22 August 2026
This English version is provided for convenience. Only the French version is legally binding and prevails in case of discrepancy: Version française →
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.
1. Data controller
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 [at] wegartner.com
General contact: executive [at] 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.
2. Purposes, legal bases, data and retention periods
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 diagnostics — VALÉRIE (“AI Leadership Quotient”), PHILIPPE (“Leader under pressure”), KATE and CARLA (member area) | Consent (Art. 6(1)(a)); legitimate interest for B2B commercial follow-up (Art. 6(1)(f)), with the right to object at any time | Identity (first and last name), business email, role, sector, company size, questionnaire answers, index, level and generated analysis | Up to 24 months after the last contact, unless you object or request erasure |
| Coaching return-on-investment simulator | Consent (Art. 6(1)(a)); legitimate interest for B2B commercial follow-up (Art. 6(1)(f)) | Business email, role, sector, company size, parameters entered and computed result | Up to 24 months after the last contact |
| Diagnostic positioning statistics | Legitimate interest (Art. 6(1)(f)) — pseudonymised data, only anonymous aggregates are displayed | Index, level, scores by theme, sector, size, role, date (no name or email) | 36 months |
| 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.
3. Recipients and processors
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). |
| Google Ireland Limited / Google LLC | Audience measurement (Google Analytics 4, Google Tag Manager), only after your consent | Ireland / United States | Transfer covered by the EU–US Data Privacy Framework |
| 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).
4. Your rights
Under Articles 15 to 22 of the GDPR, you have the following rights over your data at any time:
- Right of access: obtain confirmation that your data is being processed and receive a copy of it.
- Right to rectification: have inaccurate or incomplete data corrected.
- Right to erasure: request the deletion of your data in the cases provided for by law.
- Right to restriction: request the temporary freezing of a processing activity.
- Right to object: object to processing based on legitimate interest, in particular commercial prospecting, at any time and without justification.
- Right to data portability: receive the data you provided to us in a structured, commonly used and machine-readable format.
- Right to withdraw your consent at any time, where processing is based on it, without affecting the lawfulness of prior processing.
To exercise your rights, send your request to the personal data contact: executive [at] 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).
5. Coaching-specific confidentiality
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:
- The content of your sessions, your confidences, your personal objectives and any individual information are never disclosed to your employer or to the engagement's sponsor.
- The only information that may be shared with the employer concerns the framework of the engagement (attendance, overall progress, achievement of the objectives agreed in the three-party meeting), at a level that reveals no confidential individual information.
- The scope of what may be shared is defined with you, in writing, before the engagement begins.
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.
6. Cookies and trackers
This site uses no advertising trackers.
Audience measurement. We use Google Analytics 4, loaded through Google Tag Manager, to know how the site is visited and which pages are viewed. These tools are not loaded until you have given your consent in the banner shown on your first visit: without consent, no request is sent to Google and no measurement cookie is set. If you decline, or do not answer, your browsing is strictly identical and all our services (forms, diagnostics, simulator, appointment booking) remain available.
If you accept, Google Analytics sets the _ga and _ga_* cookies (lifetime: 13 months) and receives pseudonymised browsing data: pages viewed, timestamp, device and browser type, random visitor identifier. Google Analytics 4 does not store your IP address. Measurement data is kept for two months. Google Ireland Limited and Google LLC (United States) process this data as processors; the transfer to the United States is covered by the EU–US Data Privacy Framework.
Your choice is kept for six months, whether you accepted or declined; the banner is then shown to you again. You can change your choice at any time through the “Manage cookies” link in the footer.
Strictly necessary trackers. They are set without consent, in accordance with Article 82 of the French Data Protection Act: wg-consent — storage of your cookie choice, kept for six months in your browser's local storage (not in a cookie); member area session cookies — duration of the session.
Third-party services. Calendly (appointment booking) is only loaded after you click the booking button.
Legal basis: Article 82 of French Act No. 78-17 of 6 January 1978 (Directive 2002/58/EC); CNIL guidelines and recommendation of 17 September 2020 on cookies and other trackers; Articles 6(1)(a), 28 and 44 to 49 GDPR.
7. Automated processing and AI agents
Wegartner makes no decision producing legal effects concerning you, or similarly significantly affecting you, based solely on automated processing. The analyses produced by our AI agents (Valérie, Philippe, Kate, Carla) are generated automatically from your answers, within a framework designed and supervised by a human: an index is computed from your answers, weighted by theme; an analysis is then written by a language model from that index and your answers, and sent to you without individual review. These analyses are an aid to reflection; they do not in themselves entail any decision about you. You may at any time request human intervention, express your point of view or contest an analysis by writing to executive [at] wegartner.com. How these tools work is detailed on the AI & the AI Act page.
Legal basis: Article 22 GDPR (automated individual decision-making); Articles 5(1)(a) and 12 (transparency).
8. Security
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.
9. Changes
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.