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Privacy Policy

Last updated: 10/2026

This Privacy Policy explains which personal data we process when you visit our website, use the WebLAB platform (CommuniCore) or take part in our live coaching (CommuniCoach), for what purposes, on which legal basis and what rights you have. It applies to all users worldwide. Sections 13 to 15 contain additional information for the European Union/EEA (GDPR), Japan (APPI) and Singapore (PDPA).

1. Who Is Responsible for Your Data

Communicue is operated by two companies of the same group, which process personal data jointly:

Communicue K.K. & Communicue Pte. Ltd.
  1. (株式会社Communicue), 3F, 8-7, Roppongi 1-chome, Minato-ku, Tokyo, Japan – contracting partner for live coaching (CommuniCoach) and operator of this website.
Communicue Pte. Ltd.,
  1. 152 Beach Road, #23-02 Gateway East, Singapore 189721, Singapore – owner and operator of the WebLAB platform and contracting partner for CommuniCore licences.

Both companies are jointly responsible for the processing described in this Privacy Policy (joint controllers within the meaning of Art. 26 GDPR; joint use within the meaning of Art. 27(5)(iii) APPI). They have agreed among themselves who fulfils which obligations. You can exercise your rights against either company; the contact point for all data protection matters is:

Data Protection Officer: Liv Johansson [liv@communicue.com]

2. Data We Process

2.1 Visiting our website

When you visit our website, our hosting provider automatically processes technical data such as IP address, date and time of access, pages viewed, browser type and operating system (server log files). We use this data to deliver the website securely and to detect misuse. Log files are deleted after 7 days.

2.2 Contact and quote requests

If you contact us via the contact form or by email, or request a quote, we process the information you provide (e.g. name, email address, company, position, message) in order to answer your enquiry and prepare an offer.

2.3 Booking and contract management

To conclude and perform contracts we process contact and company data of our business customers and their contact persons, data of the participants they register (name, business email, language, programme booked) and billing data. For individual bookings, we also process your billing address and payment information. Payments are processed by Wise, we do not store full card details.

2.4 CommuniCore (WebLAB)

To provide the WebLAB we process your account data (name, email, access code, language), usage data (progress, completed modules, certificate) and the content you enter in the guided self-reflection exercises. From these, your personal communication profile is created.

2.5 CommuniCoach (live coaching)

Our coaches work directly from your communication profile so that the first session can start with applied practice. We therefore make your profile available to the coach(es) assigned to you. During coaching, the coaches take notes on your goals and progress in order to build on previous sessions.

2.6 Information about your health

In voice, speech and breathing work, information about your health (e.g. voice problems, breathing, stress) may come up. You are never required to provide such information. If you choose to share it with us, we process it only for your coaching and only with your explicit consent, which you can withdraw at any time.

2.7 Recordings

Audio or video recordings of coaching sessions are made only with your prior, separate consent – for example for feedback and analysis. Recordings are never used for marketing purposes without an additional, separate consent. Recordings for feedback purposes are deleted no later than 30 days after the end of the respective level.

2.8 Newsletter

We send our newsletter only if you have expressly subscribed to it (double opt-in). You can unsubscribe at any time via the link in every newsletter.

3. What Your Employer Can See

If your participation is booked and paid for by your employer, your employer receives only the information required for organisation and invoicing: that you have been registered, whether you have completed CommuniCore and which sessions you attended. Your employer has no access to your communication profile, your reflection entries, coaching notes or the content of the sessions. We only share such information with your employer if you have expressly agreed to it in the individual case.

In in-house programmes, internal company cases are discussed. We treat these strictly confidentially and do not use them for any other purpose.

4. Purposes and Legal Bases

  • Provision of the website and IT security – legitimate interest (Art. 6(1)(f) GDPR).
  • Answering enquiries and preparing offers – pre-contractual measures (Art. 6(1)(b) GDPR) or legitimate interest in communicating with business contacts (Art. 6(1)(f) GDPR).
  • Performance of contracts, including WebLAB access, sharing the profile with your coach and coaching notes – performance of a contract (Art. 6(1)(b) GDPR). Where your employer is our contracting partner: legitimate interest of the employer and of Communicue in delivering the booked programme (Art. 6(1)(f) GDPR).
  • Health information – explicit consent (Art. 9(2)(a) GDPR).
  • Recordings, newsletter, non-essential cookies – consent (Art. 6(1)(a) GDPR).
  • Invoicing and retention obligations – legal obligation (Art. 6(1)(c) GDPR).

We do not use your data for automated decision-making or profiling with legal or similarly significant effects. We do not sell personal data.

5. Cookies and Similar Technologies

We use technically necessary cookies that are required for the website and the WebLAB to function (e.g. login, language setting, storing your cookie choice). All other cookies and tools – for example for analytics or embedded external content – are only used if you have given your consent via our cookie banner. You can change or withdraw your consent at any time under "Cookie Settings" in the footer.

6. Service Providers

We use carefully selected service providers who process data on our behalf and in accordance with our instructions (processors). These include:

  • Website and WebLAB hosting: Strato, Germany
  • Video conferencing for online sessions: Zoom, USA
  • Email and communication: Strato
  • Payment processing: Wise
  • Newsletter: Odoo
  • Accounting and tax advice: our tax accountants in Japan and Singapore

Coaches who are not employed by us are bound by contract to confidentiality and data protection.

7. International Data Transfers

Because our companies are based in Japan and Singapore and our customers are located worldwide, your data is transferred between countries. We safeguard such transfers as follows:

  • Japan: The European Commission has recognised that Japan provides an adequate level of data protection (adequacy decision).
  • Singapore: No adequacy decision exists. Transfers are based on the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR), concluded between the companies of our group.
  • Other countries (e.g. USA): Where service providers are located outside the EU/EEA, transfers are based on an adequacy decision (e.g. EU-U.S. Data Privacy Framework for certified providers) or on Standard Contractual Clauses.

You can request a copy of the safeguards from our Data Protection Officer.

8. Retention Periods

  • Enquiries without a subsequent contract: 12 months after the last contact.
  • WebLAB account and communication profile: for the duration of your access plus 12 months, so that you can still take part in CommuniCoach; then deleted.
  • Coaching notes: until 24 months after the end of your last level; then deleted.
  • Health information: deleted as soon as it is no longer needed for your coaching, no later than at the end of your programme, or immediately if you withdraw consent.
  • Contract and invoicing data: as required by commercial and tax law (in particular 7 years in Japan and 5 years in Singapore).

9. Data Security

We protect your data with appropriate technical and organisational measures, including encrypted transmission (TLS), access restrictions based on roles (coaches only see the profiles of participants assigned to them), regular backups, confidentiality obligations for all staff and coaches, and regular review of our measures.

10. Your Rights

Depending on the applicable law, you have the right to access your data, to have it corrected or deleted, to restrict or object to its processing, to data portability, and to withdraw consent at any time with effect for the future. To exercise your rights, please contact our Data Protection Officer. We respond within one month (GDPR) or within the period required by the applicable law.

You also have the right to lodge a complaint with a data protection supervisory authority (see Sections 13–15).

11. Children

Our services are directed at adults. We do not knowingly collect personal data from persons under the age of 18.

12. Changes to This Privacy Policy

We update this Privacy Policy when our services or the legal requirements change. The current version is always available on our website.

13. Additional Information for the EU/EEA (GDPR)

  • Right to object: Where we process data on the basis of legitimate interest (Art. 6(1)(f) GDPR), you may object at any time on grounds relating to your particular situation. You may object to direct marketing at any time without giving reasons.
  • Supervisory authority: You can contact any data protection supervisory authority in the EU, in particular in your country of residence.

14. Additional Information for Japan (APPI)

  • Purposes of use: as described in Sections 2 and 4.
  • Joint use (共同利用): Communicate K.K. and Communicue Pte. Ltd. jointly use the personal data described in Section 2 for the purposes described in Section 4. The party responsible for managing the jointly used data is Communicue K.K., represented by Iva Henrik Johansson, address as in Section 1.
  • Transfers to third parties in foreign countries: Data is provided to Communicue Pte. Ltd. in Singapore and to service providers in Japan. Singapore has a comprehensive data protection law (PDPA). Both companies have agreed on measures equivalent to the APPI.
  • Sensitive personal information (要配慮個人情報): Information about your health is only obtained with your consent (see Section 2.6).
  • Security control measures: see Section 9; further details on request.
  • Requests for disclosure, correction, cessation of use etc.: please contact our Data Protection Officer. Supervisory authority: Personal Information Protection Commission (個人情報保護委員会).

15. Additional Information for Singapore (PDPA)

  • Data Protection Officer: Liv Johansson, liv@communicue.com.
  • Consent and withdrawal: Where we rely on your consent, you may withdraw it at any time by notifying our Data Protection Officer. We will inform you of the likely consequences of the withdrawal.
  • Access and correction: You may request access to and correction of your personal data. We may charge a reasonable fee for access requests, which we will inform you of in advance.
  • Supervisory authority: Personal Data Protection Commission (PDPC), Singapore.