She Starts Over

Privacy Policy

How She Starts Over handles your personal data

Version 1.4  ·  Last updated 16 October 2026

1. Who is responsible for your data

The controller of your personal data is:

ControllerUrte Pocs, sole trader (eenmanszaak)
Trading asShe Starts Over
Business addressPiet Mondriaansingel 91, 1112 WX Diemen, the Netherlands
Chamber of Commerce (KvK)93444028
Email for privacy questionsurte@shestartsover.com
Websitehttps://www.shestartsover.co

We are a small business and we are not required to appoint a Data Protection Officer. Urte Pocs handles privacy questions personally.

This policy explains what we do with personal data when you visit our website, apply to join, become a member, attend an event, or contact us. It applies alongside our Terms & Conditions.

2. What we collect, why, and on what legal basis

What we collectWhy we use itLegal basis
Name, email address, and the answers you give on our application formTo assess your application and get in touch about joiningSteps taken at your request before entering a contract (Art. 6(1)(b) GDPR)
Name, email address, membership type, start date, payment historyTo give you access to the community, take payment, and keep your membership runningPerformance of our contract with you (Art. 6(1)(b) GDPR)
Invoices, payment records and VAT dataTo meet our bookkeeping and tax obligationsLegal obligation (Art. 6(1)(c) GDPR)
Your profile, posts, comments, messages and anything else you share inside the communityTo operate the community and let members interactPerformance of our contract with you (Art. 6(1)(b) GDPR)
Booking details when you book a discovery call with usTo hold the call and follow upSteps taken at your request before entering a contract (Art. 6(1)(b) GDPR)
Name and ticket details when you book an eventTo run the event and admit youPerformance of our contract with you (Art. 6(1)(b) GDPR)
Email address for our newsletter and community updatesTo send you news, invitations and offersYour consent, or our legitimate interest in emailing existing members about similar services (Art. 6(1)(a) or 6(1)(f) GDPR)
Recordings of online sessions, and photos or video at in-person eventsTo create summaries, share sessions with members who could not attend, and, where we say so, to promote the communityYour consent (Art. 6(1)(a) GDPR)
Notes we keep about your membership, such as what you asked for or agreed with usTo administer your membership and give you a better experienceOur legitimate interest in running the membership properly (Art. 6(1)(f) GDPR)
Anonymous, aggregated website statistics: pages viewed, country, referring site, device typeTo understand how the website is used and improve itOur legitimate interest in improving the website (Art. 6(1)(f) GDPR)
Emails and messages you send usTo answer you and keep a recordOur legitimate interest in handling correspondence (Art. 6(1)(f) GDPR)

We do not ask for special categories of data, such as health or beliefs. Members sometimes share sensitive personal circumstances inside the community, but they do so of their own choice and we do not collect or index it.

We use an AI assistant, Claude, made by Anthropic, to help us write and summarise, for example to tidy a note, draft a message or summarise a session. We give it only what the task needs and we never give it special categories of data. A person reads and decides everything. It does not make decisions about you.

Providing your name, email and payment details is necessary to become a member. Without them we cannot give you access. Everything else is optional.

3. Cookies and website tracking

Our website does not use tracking cookies and does not show a cookie banner, because it does not need one.

Heartbeat, the platform hosting the community, does use cookies that are necessary for you to stay logged in. Heartbeat’s own privacy policy applies to your use of the platform.

4. Who we share your data with

We do not sell your personal data, and we do not share it with anyone for their own marketing purposes.

We use a small number of service providers who process personal data on our behalf, under their data processing terms. They may only act on our instructions.

ProviderWhat it is used for
Heartbeat Chat, Inc.Hosting the community, member accounts, discussions
StripeProcessing membership payments
BrevoSending email to members and subscribers
TypeformOur application and interest forms
CalendlyBooking discovery calls
EventbriteTicketing for in-person events
UmamiWebsite analytics
VercelHosting the website
SupabaseOur internal member administration tool
AnthropicAn AI assistant that helps us write and summarise notes, messages and posts, and where our private planning workspace is stored
GoogleStoring our working documents and calendar (Google Drive and Calendar)

Several of these providers are based in, or process data in, the United States.

We may also share personal data with our accountant, and with a lawyer or authority where we are legally required to do so, or where it is necessary to establish or defend a legal claim.

Other members can see what you choose to share inside the community, including your profile and your posts. Our Terms & Conditions require members to treat what is shared inside the community as confidential, but we cannot control what another member does, so please share thoughtfully.

5. Transfers outside the European Economic Area

Some of the providers above are based in the United States or may process data there. When personal data leaves the European Economic Area, we rely on one or both of these safeguards:

You can ask us for a copy of the safeguard that applies to a particular provider by emailing urte@shestartsover.com.

6. How long we keep your data

DataHow long we keep it
Invoices, payment and VAT records7 years, as Dutch tax law requires
Member account and membership recordsFor as long as you are a member, and up to 12 months after your membership ends
Your posts and contributions inside the communityUntil you delete them, or until your account is removed
Applications that do not lead to membership6 months, then deleted
Newsletter subscriptionUntil you unsubscribe, and we keep a record of the unsubscribe so we do not email you again
Recordings of online sessionsUp to 12 months, unless we agree otherwise with the people in them. You can ask for your part to be removed sooner
Correspondence with usUp to 12 months after the matter is closed

When a retention period ends we delete the data or anonymise it so that it can no longer be linked to you.

7. Your rights

Under the GDPR you have the right to:

To exercise any of these rights, email urte@shestartsover.com. We will respond within one month. If your request is complex we may extend that by two further months, and we will tell you if that happens. Exercising your rights is free, and we will only charge or refuse where a request is clearly unfounded or excessive.

We may ask you to confirm your identity before we act, so that we do not give your data to someone else.

8. Complaints

If you are unhappy with how we handle your personal data, please tell us first at urte@shestartsover.com so that we can put it right.

You also have the right to complain to the Dutch Data Protection Authority:

Autoriteit Persoonsgegevens Postbus 93374, 2509 AJ Den Haag, the Netherlands autoriteitpersoonsgegevens.nl

If you live in another EU country, you may complain to the supervisory authority there instead.

9. How we protect your data

We take reasonable technical and organisational measures to protect your personal data, including:

No online service can be completely secure. If a data breach occurs that is likely to create a risk to you, we will report it to the Dutch Data Protection Authority within 72 hours and, where the risk is high, tell you directly.

10. Children

She Starts Over is for adults. Our services are not intended for anyone under 18, and we do not knowingly collect data about children. If you believe a child has given us personal data, email us and we will delete it.

11. Changes to this policy

We may update this Privacy Policy when our services or our legal obligations change. The current version is always available on our website and carries a date, so you can see when it last changed.

If a change materially affects how we use your personal data, we will tell you by email before it takes effect.

She Starts Over is operated by Urte Pocs, sole trader, Diemen, the Netherlands. KvK 93444028. A PDF copy of this document is available on request at urte@shestartsover.com.