Privacy Notice for AI Coach

Last Updated: September 2026 (version 2026-09)

1. Introduction

This Privacy Notice explains how personal data is handled when you use AI Coach, an online training platform for healthcare professionals on the responsible use of generative AI (“AI Coach”, “the platform”), operated by Romion Health B.V. (“Romion Health”, “we”, “us”). This notice applies to all individuals who use AI Coach, whether given access by their organisation or on an individual or trial basis. This notice should be read together with the AI Coach Terms of Use.

We comply with the General Data Protection Regulation (GDPR), the Dutch GDPR Implementation Act (UAVG), the Dutch Telecommunications Act (Telecommunicatiewet), and the EU ePrivacy Directive.

2. Who We Are

Romion Health B.V. San Marinostraat 133, 3541DS Utrecht, The Netherlands

Chamber of Commerce Number: 91978955 Email: info@romionhealth.com Phone: +31653454089

Privacy contact: Stephan Romeijn

3. What Personal Data We Process

Which personal data is processed, for which purposes and on which legal basis depends on how you access AI Coach, as set out in Sections 3.1 to 3.4.

Providing your email address is necessary to create and use an AI Coach account; without it, we cannot give you access to the platform. Your name and functional role are used to personalise your training to your role. Other data described below is generated automatically as you use AI Coach and is not something you separately provide.

3.1 AI Coach Users (Organisation-Provisioned Access)

If your organisation gave you access to AI Coach, for example via a domain or named-user whitelist under a licence agreement, we process your email address, name, functional role (e.g. practitioner or organizer, reflecting your training track rather than your job title), login and session data, module progress, and quiz and case-exercise answers, on your organisation’s instructions.

If your organisation added you to AI Coach via a whitelist, your email address may have been provided to us by your organisation before you first logged in, rather than by you directly.

Legal basis:

• Performance of your employment relationship with your organisation (Art. 6(1)(b) GDPR)
• Legitimate interest of your organisation in providing and evidencing compliance and skills training (Art. 6(1)(f) GDPR), which also covers users who are not formally employed by the organisation, such as residents, locums, contractors, or affiliated staff
• Compliance with a legal obligation of your organisation, in particular the AI literacy obligation under Article 4 of the EU AI Act (Art. 6(1)(c) GDPR)

3.2 AI Coach Users (Individual or Trial Access)

If you signed up for AI Coach yourself, or received a trial or test account directly from Romion Health without your organisation having a contract in place with us, we process the same categories of data as in Section 3.1, plus billing details if you become a paying subscriber.

Legal basis:

• Performance of contract, if you are a paying subscriber (Art. 6(1)(b) GDPR)
• Legitimate interest in providing trial or test access (Art. 6(1)(f) GDPR)

3.3 The AI Chat Feature

In line with Article 50 of the EU AI Act, we inform you that the AI Coach chat assistant is an AI system, not a human. You are always interacting with Claude, an AI model provided by Anthropic, when using this feature.

Only your message content and the module’s underlying system prompt are sent to Anthropic; your name and email address are not shared. Anthropic acts as a sub-processor under Anthropic’s Commercial Terms of Service and does not use this data to train its models; Romion Health has not opted in to any data sharing for model improvement.

All case exercises built into AI Coach are fictional or anonymised; the platform’s own content never contains real patient data.

The AI chat assistant is configured to decline to process or answer questions involving identifiable patient information. This safeguard cannot fully prevent a user from typing such information into a message before it reaches that check. Entering identifiable patient data, or any other third party’s personal data, into the chat is not a permitted or intended use of AI Coach. If you do so, you are responsible for that data, including for ensuring you have any necessary legal basis or authorisation to share it. Romion Health does not accept responsibility for personal data entered into the chat in breach of this notice or the AI Coach Terms of Use.

Legal basis: as set out in Section 3.1 or 3.2, depending on how you access AI Coach.

AI Coach does not use your personal data for automated decision-making that produces legal or similarly significant effects on you. The chat assistant supports your training; it does not make decisions about your employment, assessment, or standing with your organisation.

3.4 Anonymised and Aggregated Data

Romion Health stores the conversations you have with the AI Coach chat assistant and analyses them to improve the training modules and the quality of the chat assistant’s responses, for example to identify where exercises are unclear or where the chat assistant responds inaccurately. Before this analysis, your name, email address and other account details are removed, so that the conversations are not linked to your identity. Where needed, additional measures are taken to ensure the data is effectively anonymised. Romion Health also uses anonymised, aggregated usage data from across all AI Coach users to benchmark training outcomes.

Because the chat is not intended for personal data (see Section 3.3), these conversations should not contain information that identifies you or anyone else. If Romion Health nevertheless finds personal data in a conversation during analysis, that information will be deleted or anonymised and will not be used for any other purpose.

Legal basis: the removal of your account details is carried out as part of providing AI Coach, on the legal basis set out in Section 3.1 or 3.2. Once anonymised, the data falls outside the scope of the GDPR.

4. Cookies and Local Storage

AI Coach uses one cookie: a Supabase authentication session cookie, which is strictly necessary to keep you logged in. This is essential for the platform to function, does not require your consent under the ePrivacy Directive, and no consent banner is shown for it. It is disclosed here for transparency.

We do not use cookies or similar technologies for analytics, advertising, or tracking. AI Coach includes no Google Analytics, Google Tag Manager, PostHog, Mixpanel, Meta Pixel, or comparable tools, and the platform is technically configured to block connections to anything other than its own infrastructure and named sub-processors.

The platform also stores a small amount of functional data in your browser’s local storage: which organisation or contract you are logged in under, whether your account is a test account, and whether you are using demo mode. These are used only to run the platform correctly, are not cookies, and are not shared with third parties or used for tracking.

5. Data Recipients & Security Measures

We share personal data with:

• IT and infrastructure sub-processors (see table below)
• Your organisation, where Section 3.1 applies, for progress tracking via the admin dashboard. Your organisation sees your account details and progress data, such as started and completed modules and certificates, but not the content of your conversations with the AI chat assistant. Conversations are not used to assess your performance and are not shared with your manager.
• Payment processors, where Section 3.2 applies and you are a paying subscriber
• Authorities, if legally required

We ensure adequate safeguards through data processing agreements with each sub-processor, in line with Art. 28 GDPR, and implement technical and organisational measures including encryption in transit and at rest, role-based access controls, a hardened passwordless login flow, staff training, and regular security review.

6. International Data Transfers

CaseFlows, Supabase, Vercel, Amazon SES, and Sentry process data within the EU. Anthropic processes and may temporarily store message content in the United States, in accordance with its data retention policy.

This transfer is safeguarded by Anthropic’s Data Processing Addendum, which incorporates the European Commission’s 2021 Standard Contractual Clauses under Art. 46(2)(c) GDPR. This is automatically included in Anthropic’s Commercial Terms of Service, which govern Romion Health’s use of the Anthropic API.

You may request a copy of these safeguards via info@romionhealth.com.

7. Data Retention

Personal data is retained as follows:

• Account, login, progress and chat data: while your access is active, plus 90 days afterwards, unless an earlier deletion is requested
• Certificate data: retained for the same period as your account data; after deletion, a certificate can no longer be verified via AI Coach, but any copy you have downloaded remains yours
• Administrative records: per Dutch legal retention periods
• Anonymised chat data (Section 3.4): no longer personal data; retained for as long as needed to improve AI Coach
• If no other period applies: up to 2 years after collection

8. Your Rights under the GDPR

You have the right to:

• Access, rectify, or delete your personal data
• Restrict processing or object to it
• Data portability
• Withdraw your consent at any time, where processing is based on consent
• File a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens)

Where Section 3.1 applies, your organisation’s own privacy policy or employee privacy regulations also apply and are leading for the exercise of your rights; please direct requests to your organisation’s privacy contact in the first instance; you may also submit requests via info@romionhealth.com and we will forward them. Where Section 3.2 applies, requests can be submitted directly via info@romionhealth.com. We respond within one month of receiving your request; for complex requests this period may be extended by up to two further months, in which case you will be informed.

9. Children’s Privacy

AI Coach is not directed to children under the age of 16, and we do not knowingly collect personal information from individuals under 16. If we learn we have collected or received personal information from an individual under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us immediately.

10. Changes to This Privacy Notice

We may update this notice due to changes in legal requirements or our business operations. The latest version is always available within the platform. Material changes will be communicated to you by email, with a short summary of what has changed and a link to the updated notice.

11. Contact Information

If you have questions or concerns about this Privacy Notice or our privacy practices, please contact us at:

Romion Health B.V.
Email: info@romionhealth.com
Address: San Marinostraat 133, 3541DS Utrecht, The Netherlands
Chamber of Commerce Number: 91978955

12. Governing Law

This Privacy Notice shall be governed by and construed in accordance with the laws of the Netherlands, without regard to its conflict of law provisions. Any disputes relating to this Privacy Notice shall be subject to the exclusive jurisdiction of the courts of the Netherlands.

Romion Health B.V. · San Marinostraat 133, 3541DS Utrecht, The Netherlands · Chamber of Commerce 91978955 · info@romionhealth.com