SOTA Neural Edge · UNBOUND
Privacy Policy
Effective date: January 1, 2027 · Last updated: January 1, 2027
1. Who we are
SOTA Neural Edge ("SOTA Neural Edge", "we", "us" or "our") is a coaching practice based in Ontario, Canada. We offer UNBOUND, a science-informed coaching programme for accomplished women, delivered by Daniela Sota in small groups or individually.
This policy explains what personal information we collect, why we collect it, how we use and protect it, who we share it with, and the choices and rights you have. It applies to our website, our booking process, our communications with you and our coaching programmes.
We follow Canada's federal private-sector privacy law, the Personal Information Protection and Electronic Documents Act (PIPEDA), and its ten fair information principles.
2. Our Privacy Officer
Daniela Sota is responsible for how SOTA Neural Edge handles personal information and for our compliance with this policy.
Privacy Officer: Daniela Sota
Email: daniela@sotaneuraledge.com
Please contact the Privacy Officer with any question, request or concern about your personal information.
3. Coaching, not psychotherapy
UNBOUND is coaching for professional development. It is not psychotherapy, counselling or any other health care service, and we do not diagnose or treat any health condition. We do not ask for health information to provide health care.
Coaching conversations can still touch on personal and sensitive matters. If you choose to share something sensitive, such as information about your wellbeing, experiences or relationships, we treat it with a high level of care. We use it only to support your coaching, and we protect it as described in this policy.
Sharing is always voluntary. You can decline any question or exercise without explaining why.
4. What personal information we collect
We collect only the information we need for the purposes described in section 5.
When you visit our website
- No cookies or tracking by us. Our website does not use cookies, advertising pixels or analytics tools to track you.
- Technical information. Like most websites, our hosting provider, Netlify, may automatically record basic technical information, such as your IP address, browser type and the pages you request. This is used to deliver and secure the site.
- Web fonts. Our website loads fonts from Google Fonts. To deliver the fonts, your browser connects to Google's servers, which receive your IP address and basic browser information. Google's own privacy policy applies to that information.
When you book a conversation
We use Cal.com, a third-party scheduling service, to book introductory conversations. When you book, we collect:
- your name and email address, and your phone number if you choose to give it
- your chosen date and time
- your answers to our booking questions: your current role, where you are based (city and province or state), your industry, whether the combined individual and group format suits you, what prompted you to reach out, your timing, whether the investment fits your plans, how you plan to fund the programme (for example, self-funded or employer sponsored), how you heard about us, and your acknowledgement that UNBOUND is coaching and that you have read this policy
- any notes you add, and any changes or cancellations
Please share only what you are comfortable sharing in the booking form. You don't need to include sensitive personal details.
When you contact us
If you email or message us, we collect your name, contact details and whatever you choose to include in your message.
When you join a coaching programme
- Contact and enrolment details: your name, email address, phone number (if provided) and programme choices.
- Professional context: information you choose to share about your role and goals, and about the situations you want to work on.
- Coaching records: brief notes Daniela may keep to support continuity between sessions, your programme agreement and records of your attendance.
- Payment and billing information: your name, billing details and transaction records. Card payments are handled by our payment processor (see section 8). We do not store full card numbers.
- Feedback: any feedback or evaluations you choose to provide.
- Sponsorship details: if your employer pays for all or part of your programme, the organization's name, the billing contact's name and work contact details, purchase order or supplier details, and records of what the organization has been invoiced and paid.
5. Why we collect it
We collect, use and disclose personal information to:
- respond to your enquiries and schedule introductory conversations
- understand whether UNBOUND is a good fit for you
- deliver coaching sessions and programme materials, and keep continuity between sessions
- manage enrolment, agreements, invoicing and payments
- administer employer sponsorship, if your organization pays for all or part of your programme
- send you service messages about your bookings, sessions and programme
- improve our programmes, using feedback you choose to give
- operate and secure our website
- meet our legal, tax, accounting and professional obligations
We tell you the purpose before or at the time we collect your information. If we want to use your information for a new purpose, we will ask for your consent first, unless the law allows or requires otherwise.
6. Consent
By booking a conversation, enrolling in a programme or contacting us, you consent to our collecting, using and disclosing your personal information for the purposes described in this policy.
- Express consent is what we rely on for sensitive information and for anything you would not reasonably expect.
- Withdrawing consent. You can withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. To do this, contact the Privacy Officer. If you withdraw consent, we may not be able to provide some services, such as continuing the coaching programme, and we will explain the impact.
7. Group coaching and confidentiality
In group programmes, participants hear one another's contributions. All participants agree not to repeat anyone's personal story outside the group, and the group sets shared agreements together in the first session.
Daniela treats what you share with care and discretion. In a group, however, confidentiality is a shared commitment among participants and cannot be an absolute guarantee. Its limits are set out in the written programme agreement. Please share only what you are comfortable sharing in a group setting.
Recordings. We do not record coaching sessions unless everyone present has agreed in advance.
8. Who we share it with
We do not sell, rent or trade your personal information.
We share personal information only:
- With service providers who help us run the practice, and only as needed for the services they provide. These include:
- Cal.com, Inc. (United States): appointment scheduling
- Netlify, Inc. (United States): website hosting
- Google (Google Fonts): delivering the fonts on our website
- Google Meet (Google LLC, United States): online coaching sessions
- Wise Business (Wise Payments Canada Inc., Ottawa, part of the Wise group): payments
- Google Workspace (Google LLC, United States): business email and documents
We use contracts and other reasonable means to require these providers to protect your information and use it only for the services they provide to us. - With your sponsoring employer, if you choose employer sponsorship. See "If your employer sponsors your programme" below. - When the law requires or allows it, for example to comply with a court order, subpoena or other legal process, or where there is a serious and imminent risk of harm to someone's life, health or safety. - With your consent, in any other situation.
If your employer sponsors your programme
Employer sponsorship is always your choice. If your organization pays for all or part of your programme, we share with it only what is needed to administer the sponsorship, and only with your consent:
- your name and the programme you are enrolled in
- invoices, payment details and receipts
- confirmation of your enrolment, attendance and completion, if your organization asks for it, and a copy of your certificate of completion if you want us to send it
We never share what you discuss in sessions, your coaching notes, your booking answers or any personal details you have shared with us. Any progress updates come from you directly, at your discretion.
We will confirm with you in writing what your organization will receive before we share anything. You can change what we share at any time by contacting the Privacy Officer, although invoicing and payment records may still need to be shared to complete the sponsorship you agreed to.
Information we receive from your organization, such as its billing contact's details, is used only to administer the sponsorship.
If the practice is ever sold or reorganized, personal information may be transferred to the new owner, who would be required to protect it in line with this policy.
9. Storage outside Canada
Some of our service providers store or process information outside Canada. Cal.com (bookings), Netlify (website hosting) and Google (Google Workspace email, Google Meet video sessions and Google Fonts) are US companies, and Cal.com processes booking data in the United States. Wise, our payment provider, has its main processing centres in the United Kingdom and the European Union. Its subprocessors may process data in other countries.
While your information is in another country, it is subject to that country's laws. It may be accessed by that country's courts, law enforcement and national security authorities. We choose providers with appropriate safeguards and remain accountable for information we transfer to them.
If you would prefer not to use Cal.com, contact us by email and we can arrange a time directly.
10. How long we keep it
We keep personal information only as long as we need it for the purposes in this policy, or as long as the law requires.
| Information | How long we keep it |
|---|---|
| Booking details for people who don't join a programme | Up to 12 months after the conversation, then deleted |
| Enquiries and general correspondence | Up to 24 months after the last contact |
| Coaching notes and programme agreements | Up to 3 years after your programme ends, unless you ask us to delete them sooner and we are not required to keep them |
| Invoices, payment and tax records | 6 years from the end of the tax year they relate to, as Canada Revenue Agency rules require |
| Records of privacy breaches | At least 24 months, as PIPEDA requires |
When information is no longer needed, we securely destroy, delete or anonymize it.
11. How we protect it
We protect personal information with safeguards appropriate to its sensitivity, including:
- Access controls: password-protected accounts with two-factor authentication where available, and access limited to Daniela and to service providers who need it.
- Encryption: encrypted devices and secure, encrypted cloud services.
- Paper records: where any exist, they are kept in a locked location.
- Disposal: secure shredding and deletion when records are no longer needed.
- Choosing providers: we review service providers' privacy and security practices before using them.
No method of transmission or storage is completely secure. We cannot guarantee absolute security, but we work to protect your information and to respond quickly if something goes wrong.
If there is a privacy breach
If a breach of our security safeguards involving your personal information creates a real risk of significant harm to you, we will:
- notify you as soon as feasible
- report the breach to the Office of the Privacy Commissioner of Canada
- notify any other organization that could reduce the risk of harm
We keep a record of every breach, as PIPEDA requires.
12. Emails from us
We email you only about your enquiry, your bookings, your sessions and your programme, as part of providing the service.
We do not send newsletters or marketing emails, and we do not add anyone to a mailing list. If that changes, we will ask for your consent first, as Canada's Anti-Spam Legislation (CASL) requires, and update this policy.
13. Your rights
You have the right to:
- Access. Ask whether we hold personal information about you, how it has been used and to whom it has been disclosed, and get a copy.
- Correction. Ask us to correct information that is inaccurate or incomplete.
- Withdraw consent. Withdraw your consent, as described in section 6.
- Deletion. Ask us to delete information we no longer need. Legal obligations, such as tax record-keeping, may require us to keep some of it.
- Complain. Challenge our compliance with this policy or with the law.
How to make a request
- Send it in writing. Email the Privacy Officer at daniela@sotaneuraledge.com. We may ask you to confirm your identity before releasing any information.
- Response time. We will respond within 30 days. If we need more time, as permitted by PIPEDA, we will tell you within those 30 days, explain why and tell you of your right to complain to the Privacy Commissioner of Canada.
- Cost. We provide access free of charge, or at minimal cost. If there is a cost, we will tell you in advance.
- Limits on access. In limited cases, the law allows or requires us to refuse access, for example where the information would reveal another person's personal information. If we refuse, we will explain why in writing.
If you live outside Ontario, you may also have rights under your province's privacy law.
14. Concerns and complaints
If you have a concern, please contact our Privacy Officer first. We will look into it and respond.
If you are not satisfied with our response, you can file a complaint with the Office of the Privacy Commissioner of Canada:
- Website: www.priv.gc.ca
- Toll-free: 1-800-282-1376
15. Age
Our programmes are for adults. We do not knowingly collect personal information from anyone under 18.
16. Other websites
Our website links to other websites and services, such as Cal.com, which have their own privacy policies. We are not responsible for their privacy practices, so please review their policies when you use them.
17. Changes to this policy
We may update this policy from time to time, for example when the law changes or when we start using a new service. The current version will always be on our website, with the date it was last updated. If we make significant changes, we will let current clients know.