Privacy notice: CDL Companion App

This notice explains what the CDL Companion App stores about you, who can see it, and your rights. It applies while you use the app as part of your coaching engagement.

Who is responsible

Jan Krueder, Weiherhofstr. 18, 78467 Konstanz, info@jankrueder.com.

What the app stores

• Your name, and your email address and username if you set them.
• Your programme, current layer and engagement status, your time zone and your settings.
• What you enter: key events and after-action reviews, worksheets and logs, notes on coach prompts.
• What your coach enters for you: reference card, checkpoint confirmations, coach prompts.
• Technical records needed to run the app: sign-in sessions, one-time codes (stored only as a scrambled value), a security log of sign-ins and changes, and the devices you turned reminders on for.

How it is protected

• The app runs on servers of domainfactory in Germany. No other services receive your data, except as described under Reminders.
• Your name, email, username and everything you write in your own words are encrypted before they are stored.
• Backups are encrypted with a key that is kept offline. Server backups are kept for 30 days.
• The app has no advertising, no analytics and no third-party scripts. It sets only one cookie, which keeps you signed in.

Who can see your data

• Your coach sees what you enter, as long as coach sharing is on in Settings. You can switch sharing off at any time, and hide single entries.
• Jan Krueder, who runs and administrates the app, sees an overview of every client: name, programme, layer, status and sign-in status, but not what you enter.
• Your employer or sponsor never has access to the app or its data, in any form, raw or summarised.

Reminders

If you turn reminders on, notifications are delivered through the push service of your phone or browser (Apple, Google, Mozilla or Microsoft). They carry a general text only, never the content of your entries.

Session reminders show the date, time and length of your session, and may greet you by your first name; the wording is the same for all clients.

If you turn email reminders on, you will receive up to three emails before a session in intervals that are being defined by your coach.
The emails may contain your first and last name, your client ID, your coach’s name and the date, time and length of a session. Some are sent on behalf of your coach: if you reply to one of those, your reply goes to your coach’s email address if your coach shows it in the app, otherwise to the practice.

Before each planned session your coach also gets reminders that show your name and the date and time of the session, as a push notification and, if your coach has chosen email notifications, by email.

Why the data is processed, and on what legal basis

In accordance with the General Data Protection Regulation (GDPR), the legal basis for processing your data is:
Contractual necessity (Article 6(1)(b)): The data is an essential part of your coaching assignment.
Express consent (Article 6(1)(a) and Article 9(2)(a)): Since the data can provide insights into personality, emotions, and leadership behavior, we require your express consent to conduct it. You give this consent by using the CDL Companion App.

How long data is kept

Everything you enter in the app is kept for as long as you work with your coach. After your last engagement has ended, it is kept until the end of the third full calendar year after that year, and then deleted automatically. For example, if your last engagement ends in 2026, your data is deleted on 1 January 2030. We keep it for this period so that we can respond to any legal claims arising from the coaching (Art. 6(1)(f) GDPR, in line with the standard limitation period under § 195 German Civil Code). Copies in the app’s backups are overwritten within 14 days after deletion.

Invoices and the coaching agreement are not stored in the app. They are kept separately for the periods required by law: 8 years for invoices and accounting records, 6 years for the agreement and related correspondence.

You can download your data at any time before it is deleted: Settings → “Download my data”.

Your rights

• See and download your data: Settings → "Download my data".
• Have incorrect data corrected, or your data deleted or its use restricted.
• Object to the processing, and withdraw any consent you have given, with effect for the future.
• Your ELI reports are listed there, not included as you have received them from iPEC and in the app.

To use these rights, contact info@jankrueder.com.

Changes

When this notice changes, the app shows the new version the next time you open it.

Version date: 10/10/2026

Version 4 · published 23 Oct 2026