Last updated: July 2026
The AI Executive Career Lounge is a brand of NAKAMA EUROPE LTD. (hereinafter “we” or “us”). We take the protection of your personal data very seriously. This Privacy Policy applies to the website www.ai-careerlounge.com, including the password-protected coaching portal, and informs you in accordance with the General Data Protection Regulation (GDPR) about how we collect, process and protect personal data.
NAKAMA EUROPE LTD.
Ground Floor, 71 Lower Baggot Street
Dublin D02 P593, Ireland
Email: office(at)nakamaeurope.com
Website: www.nakamaeurope.com
For data protection inquiries, please contact: hello(at)ai-careerlounge.com
We process personal data only to the extent necessary. The processing is based on the following legal bases:
For security reasons, our website uses SSL/TLS encryption. You can recognize an encrypted connection by the “https://” prefix and the lock symbol in your browser bar. This ensures that the data you transmit cannot be read by third parties.
Our website and the coaching portal are hosted by IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany. IONOS processes access data on our behalf (server log files, see Section 5) on the basis of Art. 6(1)(f) GDPR and a data processing agreement pursuant to Art. 28 GDPR.
Each time our site is accessed, the following data is automatically recorded: IP address, date/time, name/URL of the file, volume of data transferred, HTTP status, browser type/version and operating system, referrer URL. This data serves exclusively to ensure trouble-free operation; it is not combined with other sources. Legal basis: Art. 6(1)(f) GDPR. Deletion after no more than 30 days, unless retention is required for evidentiary purposes.
Cookies are small text files stored on your device that make our services more user-friendly.
Essential for operation (session information, basic functions). Legal basis: Art. 6(1)(f) GDPR. In the logged-in coaching portal, we set a technically necessary login/session cookie (WordPress) as well as a security token (nonce/CSRF); without these, login is not possible.
Only with your express consent (Art. 6(1)(a) GDPR). Details in Sections 7–9.
You can block/delete cookies via your browser and withdraw any consent you have given at any time with effect for the future.
Google Tag Manager provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The Tag Manager itself does not set cookies and does not collect personal data; it triggers other tags but does not access their data.
We use Google Analytics 4, a web analytics service provided by Google Ireland Limited. Cookies enable an analysis of usage; with IP anonymization activated, your IP address is truncated within the EU. Purpose: optimization of our services. Legal basis: consent (Art. 6(1)(a) GDPR). Retention period: 14 months. Opt-out via the Google browser add-on.
Meta Pixel provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. Purpose: measuring advertising effectiveness, custom audiences. Legal basis: consent (Art. 6(1)(a) GDPR). Data transfers to the USA are based on standard contractual clauses (Art. 46(2)(c) GDPR).
Our website uses Google Fonts, a service provided by Google Ireland Limited. When you visit our website, a connection to Google’s servers is established in order to load fonts. In this process, your IP address is transmitted to Google. Legal basis: your consent pursuant to Art. 6(1)(a) GDPR or our legitimate interest pursuant to Art. 6(1)(f) GDPR in the visually appealing presentation of our website.
Google reCAPTCHA (Google Ireland Limited) to protect against automated access; it analyzes, among other things, IP address, time spent on the page, and mouse movements. Legal basis: legitimate interest (Art. 6(1)(f) GDPR).
LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2 – When you click a LinkedIn button, a direct connection is established; LinkedIn receives your IP address and may be able to associate your visit with your account.
X Corp., 1355 Market Street, San Francisco, USA – When you click an X button, X receives your IP address and the URL.
When you contact us by email, we store your details (name, email, content) for the purpose of processing your inquiry. Legal basis: Art. 6(1)(a) or (b) GDPR. Deletion as soon as the data is no longer required and no retention obligations apply.
For internal organization, we use Google Workspace (Google Ireland Limited). Emails sent in connection with the website are handled via IONOS (Section 4), not via Google. A data processing agreement is in place with Google. Legal basis: Art. 6(1)(f) GDPR and Art. 28 GDPR.
We process: identification data (name, address, date of birth, contact details), professional data (CV, qualifications, career history, LinkedIn profile), salary expectations and career aspirations, nationality/visa/work permit status, contact details of reference persons. Sources: you yourself, professional networks, job boards, reference persons, your website, and, where applicable, clients. Legal basis: Art. 6(1)(b), (a) and (f) GDPR.
We use AI-assisted systems to analyze and structure your documents. No automated individual decision-making takes place (Art. 22 GDPR); every recommendation is reviewed by our experts. EU AI Act: “Low Risk”, AI is used only in a supporting capacity, not for autonomous personnel decisions.
Master data of contact persons, project data, billing data. Legal basis: Art. 6(1)(b) GDPR.
Storage in “Hellotalent” provided by Talentsoft SA, 8 Rue Heyrault, 92100 Boulogne, France (server location: Germany). Online access to your own profile. Legal basis: Art. 6(1)(a) and (f) GDPR.
In the password-protected coaching portal on ai-careerlounge.com, you complete the “AI Executive Career Launch” program. Parts of the coaching are delivered by AI coaching agents with whom you chat directly in the portal. In this context, we process:
AI service provider: The processing of your chat inputs by the AI agents is carried out via Langdock GmbH, Hamburg, Germany (EU hosting, ISO 27001), as a processor (Art. 28 GDPR). Langdock does not use your data to train AI models. The processing takes place in the EU; no transfer to third countries is intended. Only AI models (LLMs) hosted in the EU are approved for use.
Legal bases: Art. 6(1)(b) GDPR (performance of the coaching contract) and Art. 6(1)(a) GDPR (consent to the AI-assisted processing and the storage of sensitive coaching content). You may withdraw your consent at any time with effect for the future. For any special categories of personal data, Section 16 applies.
Transparency (EU AI Act): In the coaching, you knowingly work with artificial intelligence. NAKAMA EUROPE LTD is the “deployer”; the application is classified as minimal/low risk. The AI agents do not make any decisions about you, do not create assessments for third parties or employers, and do not replace human guidance: after each module, a personal conversation with your Executive Career Coach takes place. No exclusively automated decision-making within the meaning of Art. 22 GDPR takes place (see Section 20).
Your control: You can view your logbook and your conversation data in the portal at any time, and, upon request, have them exported and completely deleted (request to hello(at)ai-careerlounge.com; you can also create a PDF export of your logbook yourself in the portal). Uploaded documents are stored in an access-protected area (no public access, no transfer to the AI service provider) and are accessible only to you and your coaching team.
Email communication in the portal: After your account is created, you will receive a welcome email. After completing the career briefing, you and your coaching team will receive an email notification that your briefing summary is available in your personal portal; the content itself remains in the password-protected portal (purpose: preparation of your support; legal basis: Art. 6(1)(b) GDPR).
Appointment booking for coaching sessions (Cal.eu): For booking personal coaching sessions, we use Cal.eu (the EU instance of Cal.com; it processes name, email, appointment data, as well as your answers to two booking questions: your current status in the program and the topics you would like to discuss). Legal basis: Art. 6(1)(b) GDPR.
Appointment booking for initial consultations (TidyCal): For booking free initial consultations by prospective clients, we use TidyCal (processes name, email, appointment data). TidyCal is a provider based in the USA; the safeguards set out in Section 17 apply to the transfer. Legal basis: Art. 6(1)(b) GDPR (pre-contractual measures).
Transcription of coaching sessions: Your personal coaching sessions may be transcribed using the Hedy application (Hedy AI LLC). Speech recognition takes place exclusively locally on your coach’s device; the audio recording and transcript are not transmitted to Hedy’s servers or to any other third parties (cloud synchronization and cloud analysis are deactivated). From the transcript, we create a Coaching Session Summary via our AI service provider Langdock (EU processing, see Section 15.5), which is stored in your coaching logbook; the transcript itself is deleted after the summary has been created. Legal basis: your consent (Art. 6(1)(a) GDPR, and, for sensitive conversation content, Art. 9(2)(a) GDPR), which you give when booking your appointment via a separate question in the booking form. Without consent, the session takes place without transcription. You may withdraw your consent at any time with effect for the future — including at the beginning of the session.
Planned, and in each case only active after a data processing agreement has been concluded: Brevo (email/CRM), Stripe (payment/invoicing). This Privacy Policy will be updated accordingly upon activation.
Data within the meaning of Art. 9(1) GDPR (e.g. health data, religious data, political data) is not required for our services. Please do not send us such data unsolicited. Should such data become relevant in individual cases – for example, if you voluntarily provide information about your health (e.g. stress, exhaustion) or worldview, whether in your inputs in the coaching portal or in your personal coaching sessions (including their transcripts and summaries) – we will process it only on the basis of your express consent pursuant to Art. 9(2)(a) GDPR. For the coaching portal, you give this consent during onboarding; for the session transcription, separately when booking your appointment (see Section 15.6). You may withdraw any consent at any time with effect for the future.
When using services such as Google Analytics, reCAPTCHA, Google Fonts, Meta Pixel, X and TidyCal, data may be transferred to servers in the USA. The USA is covered by an adequacy decision (EU-U.S. Data Privacy Framework); in addition, where necessary, EU standard contractual clauses (Art. 46(2)(c) GDPR) are in place. Processing in the coaching portal (Langdock, IONOS, Cal.eu) takes place in the EU; no transfer to third countries is intended in this respect. The transcription of coaching sessions likewise takes place without any transfer to third countries (local processing, see Section 15.6).
| Data category (service provider) | Retention period |
|---|---|
| Server log files (IONOS) | Max. 30 days |
| Email inquiries | Until resolved + statutory periods |
| Customer data (general) | Until withdrawal of consent, max. 3 years after last contact |
| Contract data (corporate clients) | 10 years (commercial/tax law) |
| Analytics data (Google Analytics) | 14 months |
| Coaching account, profile/AI memory, conversation histories, logbook (WordPress/IONOS) | Until withdrawal/deletion by you, at the latest 24 months after the end of the program |
| Uploaded documents, e.g. CV/personality tests (WordPress/IONOS) | Until withdrawal/deletion by you, at the latest 24 months after the end of the program |
| AI processing of chat inputs (Langdock) | No independent storage beyond the session; no model training. The portal storage period (24 months) is decisive. |
| Coaching appointment booking: name, email, appointment, booking questions (Cal.eu) | For the duration of the appointment handling; thereafter in accordance with the provider’s specifications |
| Initial consultation booking: name, email, appointment (TidyCal) | For the duration of the appointment handling |
| Session transcripts and session summaries | Transcript: deleted after the summary has been created; summary in the logbook: as for coaching data (24 months) |
| Proof of consent (coaching) | For the duration of the processing + periods required for evidentiary purposes |
| (planned) Email/CRM (Brevo), payment (Stripe) | Defined per category upon activation; invoicing data 10 years (tax law) |
Retention of coaching data (24 months): A retention period of 24 months after the end of the program applies to the coaching portal data. This period is stated in this Privacy Policy, documented in our internal deletion concept, and communicated to you transparently. If you exercise your right to erasure, we will delete your data earlier, provided that no statutory retention obligations apply.
You may request deletion at any time (email to hello(at)ai-careerlounge.com). In the coaching portal, upon your request, we will completely delete your profile, conversation histories, logbook and uploaded documents.
Access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), objection (Art. 21), withdrawal of consent (Art. 7(3) GDPR). Contact: hello(at)ai-careerlounge.com.
No exclusively automated decision-making (including profiling) within the meaning of Art. 22 GDPR takes place that produces legal effects concerning you. All AI-assisted analyses – including those of the AI coaching agents – serve exclusively a supporting function and are complemented by human guidance (personal coaching sessions).
You have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). Competent authority: Data Protection Commission (DPC), 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland, Tel. +353 (0)761 104 800, www.dataprotection.ie. Alternatively, you may contact the authority at your place of residence or place of work.
We reserve the right to amend this Privacy Policy. The current version can always be found on this page.
Last updated: July 2026