Accessibility Statement for ABN Consulting

Privacy Policy:

Privacy Policy: CO-Navigator AI

Effective Date: March 17, 2026

Data Controller: ABN Consulting (Adi Ben Nesher)

1. Introduction & Transparency

CO-Navigator is an Artificial Intelligence assistant designed to support participants of Adi Ben-Nesher’s coaching programs. By using this bot, you are interacting with an AI system, not a human. This policy outlines how we protect your data and maintain the "psychological safety" essential for your professional development.

2. What Data We Collect

To provide personalized coaching support, CO-Navigator processes the following:

• Interaction Data: The text, reflections, and questions you input during your sessions.

• Professional Context: Non-sensitive data related to your coaching goals and program progress.

• Technical Logs: IP addresses and timestamps (retained only for security and system stability).

Important: CO-Navigator is designed for professional development. Please avoid sharing "Special Category Data" (e.g., health information, political opinions, or sensitive personal crises) unless it is a direct requirement of your specific coaching module.

3. How Your Data is Used (Purpose Limitation)

Your data is used strictly for:

• Real-time Coaching Support: Generating insights and reflections based on your input.

• Program Continuity: Allowing you to "pick up where you left off" in your coaching journey.

• Non-Training Guarantee: Unlike consumer AI tools, your conversations are NOT used to train or improve the underlying Large Language Models (LLMs) of our third-party providers.

4. Data Sharing & Third Parties

We do not sell your data. We only share information with:

• Infrastructure Providers: AI processing is handled by secure, enterprise-grade partners (e.g., Microsoft Azure or AWS) that comply with GDPR and the EU AI Act.

• Confidentiality: Individual chat transcripts are not shared with your employer or other participants. Only aggregated, anonymized themes (e.g., "The top challenge for this cohort is digital maturity") may be shared with program sponsors.

5. Data Retention & Deletion

• Session Data: Retained for the duration of your active coaching program plus 90 days, allowing you to export your "Captain’s Log" or reflections.

• Right to Erasure: You can request the immediate deletion of your entire chat history at any time by contacting us at [Insert Email].

6. Your Rights

Under the GDPR and AI Act, you have the right to:

1. Access: Request a copy of your stored interactions.

2. Rectification: Correct any inaccurate personal data.

3. Human Intervention: Request that a human coach (Adi Ben-Nesher) review an automated interaction if you feel the AI’s guidance was inappropriate or inaccurate.

4. ​

Data Processing Addendum (DPA): CO-Navigator AI

Effective Date: March 17, 2026

Between: ABN Consulting (the "Processor") and [Client Name] (the "Controller").

1. Scope and Role of the Parties

This DPA applies to the processing of Personal Data by CO-Navigator (the "Service") on behalf of the Client.

• Controller: The Client, who determines the purpose of the coaching program.

• Processor: ABN Consulting, which provides the AI infrastructure and methodology.

2. Types of Data & Purpose

The Processor will process data including participant names, professional titles, and text-based coaching reflections ("Input Data").

• Purpose: To provide AI-driven coaching support, organizational alignment, and digital transformation tracking.

• Duration: The term of the coaching engagement plus a 90-day transition period.

3. Technical and Organizational Measures (TOMs)

ABN Consulting implements the following security standards for CO-Navigator:

• Encryption: All data is encrypted in transit (TLS 1.3) and at rest (AES-256).

• No Model Training: The Processor guarantees that Client’s Input Data and Output Data are not used to train, retrain, or improve any third-party Large Language Models (LLMs).

• Anonymization: For any "Executive Summary" reporting provided to the Client, all individual participant data will be aggregated and anonymized to protect the "safe space" of the coaching relationship.

4. Sub-Processors

The Client provides general authorization for the use of the following Sub-Processors:

• Cloud Infrastructure: [e.g., Microsoft Azure / AWS / Google Cloud] (Region: EU/West).

• AI API Provider: [e.g., OpenAI Enterprise / Anthropic / Mistral] via secure API endpoints.

Note: All Sub-Processors are bound by data protection terms no less restrictive than those in this DPA.

5. Data Subject Rights & Requests

The Processor shall assist the Client in responding to requests from participants exercising their rights under GDPR or the EU AI Act, including:

• The right to access their "Captain’s Log" (chat history).

• The right to request the deletion of specific sessions.

• The right to "Human Intervention" (requesting a review by Adi Ben-Nesher if the AI's output is contested).

6. Data Breach Notification

In the event of a suspected data breach, the Processor will notify the Client’s designated Data Protection Officer (DPO) within 48 hours of discovery.

7. Termination & Deletion

Upon termination of the coaching services, the Processor will, at the Client’s choice, delete or return all Personal Data, unless local law requires continued storage.