Privacy Policy

Wellcoaches Corp. ("Wellcoaches," "we," or "us") provides the Multi-Perspective AI platform and related online services (the "Platform") to help Coaches, Leaders, Health Professionals (each a "User"), and Individuals, who may be Clients or Patients of Users, address client/patient, professional, and personal topics. We operate our websites (the "Sites") to promote our Platform to current and prospective customers. Throughout this Privacy Policy, we refer to our Sites and our Platform collectively as the "Services."

Healthcare Patient Information Disclaimer

Certain Users may input individually identifiable patient health information into our Platform that is considered "Protected Health Information" or "PHI," which is subject to the Health Insurance Portability and Accountability Act ("HIPAA"). In such cases, we may be a "business associate" of certain Users under HIPAA, and our processing of PHI on behalf of such Users data is governed by our respective business associate agreements with each User.

This Privacy Policy does not apply to any PHI that Users, who are covered entities under HIPAA, input into the Platform or otherwise share with us in connection with their use of the Services. That information is subject to our contracts with and the privacy policies of the applicable User. Your healthcare provider may present you with a separate notice of privacy practices that addresses how they use and share PHI. If you are a patient and have questions concerning how your healthcare provider collects and uses your PHI, including how Wellcoaches processes your PHI on behalf of your healthcare provider, please contact your health care provider directly.

Personal Information We Collect

Personal information you provide

We collect personal information that you voluntarily provide to us when you use our Services. Information you provide may include:

• Contact information, such as your first and last name, phone number, and email address.
• Account information, such as your email and the username and password you use to log into your account.
• Billing information, needed to complete any transactions with us, including your name, payment card information, and billing information. Billing information is processed by a third party billing partner, and subject to the third party's privacy policy.
• Conversation details, including the questions, prompts and information that you enter, as well as any documents you upload, along with outputs generated by the Services.
• Health information, you provide in connection with your use of the Services, such as information about your physical, mental and emotional health or the physical, mental or emotional health of others, along with outputs generated by the Services, should you choose to provide such information. For more information, see Appendix A: Consumer Health Data Notice at the end of this policy document.
• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
• Marketing information, such as your preferences for receiving our communications, and details about how you engage with our communications.
• Surveys, from time to time you may be able to participate in surveys that we, or third parties, may sponsor. When you participate in these initiatives, we may collect personal information such as name, contact information, reviews, and survey responses or submissions.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Personal information we collect automatically or generate

• Aggregated, anonymized or de-identified information. We may aggregate, anonymize or de-identify information about your use of the Services. This includes generating reports and insights based on usage patterns and health information that has been de-identified in accordance with applicable laws.
• Personal information we collect automatically. We, our service providers and our business partners may automatically log information about you, your computer or mobile device, and your interactions over time with our Services and our communications, such as:
  • Device data, such as your computer's or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, the website you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page or screen, access times, and whether you have opened or otherwise engaged with our communications, such as our marketing emails, or clicked links or files within them.

We may use the following tools for automatic data collection:

• Cookies, which are text files that websites store on a visitor's device to uniquely identify the visitor's browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand website user activity and patterns.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

For more information, please see the “Online tracking opt out” section below.

Information collected from other sources

• Social media pages. We may maintain pages on social media platforms, such as Facebook, X, Instagram, YouTube and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider's privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
• Other sources. We may obtain personal information (e.g., demographic information) from other third parties, such as marketing partners, publicly-available sources, and data providers.

How We Use Personal Information

We use personal information for the following purposes or as otherwise described at the time of collection:

• To provide and improve the Services and respond to your inquiries. This includes:
  • Administering, hosting, and operating the Services, including facilitating account creation, processing payments and transactions, authentication, and otherwise managing user accounts;
  • Communicating with you and responding to any inquiries you may have; and
  • Analyzing your use of the Services to allow us to evaluate and improve the Services.
• For research and development. We may use data for research and development purposes, including to analyze and improve our Services and our business. If personal information is included, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.
• For Surveys. We may conduct surveys and collect feedback or other content from your reviews or submissions. Where we intend to publish your survey responses or reviews with information that identifies you we will ask you for your consent to be able to process this information.
• For marketing and advertising. Where permitted by applicable laws, we may use personal information for marketing and advertising purposes, including:
  • Direct marketing. We may send you newsletters and email marketing in accordance with your preferences, and we may tailor our communications with you to accommodate your interests and use of the Services. You may opt out of our marketing emails as described in the "Opt-out of marketing communications" section below.
  • Interest-based advertising. We may engage third-party advertising companies to display ads promoting our services across the web. These companies may use cookies and similar technologies to collect information about interactions over time across the Internet and use that information to serve online ads that they think will be of interest. For more information, please see the "Online tracking opt-out" section below.
• For compliance and protection, including to comply with our legal obligations, we may use personal information to:
  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  • Protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies;
  • Enforce the terms and conditions that govern our Services; and
  • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How We Disclose Personal Information

We may disclose your personal information in the following ways:

• Affiliates. We may share information we collect with our affiliates, to deliver products and services to you, ensure a consistent level of service across our Services, and enhance our Services and your customer experience.
• Service providers. We may disclose your personal information to third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work (such as our generative artificial intelligence, hosting, information technology, support, email delivery, and Site analytics services).
• Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
• Advertising partners. We may share personal information with third-party advertising companies, including social media platforms, search engines, and other advertising vendors, to help us serve ads to you and others on other websites and platforms.
• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate.
• Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, us or our affiliates (including, in connection with a bankruptcy or similar proceedings).
• With your instruction or permission. We may disclose personal information to relevant third parties, where you give us permission to do so in the course of your relationship with us from time to time.

Your Privacy Rights and Choices

Opt-out of marketing communications

You may opt-out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us or by contacting us as provided in the "Contact Us" section below. You may continue to receive Services-related and other non-marketing emails.

Personal information requests

We offer you choices that affect how we handle your personal information. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal information:

• Information, about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
• Access, to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
• Correction, of personal information that is inaccurate or out of date.
• Deletion, of personal information that we no longer need to provide the Services or for other lawful purposes.

To make a request, please email us or write to us as provided in the "Contact Us" section below. We may ask for specific information from you to help us confirm your identity. You are entitled to exercise the rights described above free from discrimination.

Account deactivation and deletion

If you have an account on our Services, you may deactivate and delete your account by contacting us as described in the "Contact Us" section below. Note that deactivating your account may not cause us to fully delete all of your personal information. To request that we do so, please submit a data deletion request as described in the "Personal information requests" section.

Limits on your choices

In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the "Contact Us" section below.

Online tracking opt-out

You can limit online tracking by:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. Use the following links to learn more about how to control cookies and online tracking through your browser: Firefox; Chrome; Microsoft Edge; Safari (Mac); Safari (Mobile/iOS).
• Blocking advertising ID use in your mobile settings. Your mobile device settings can provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers.
• Google Analytics. We use Google Analytics to help us better understand how people engage with our Services by collecting information and creating reports about how users use our Services. For more information on Google Analytics, click here. For more information about Google's privacy practices, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
• Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
  • Digital Advertising Alliance for Websites: optout.aboutads.info
  • Network Advertising Initiative: optout.networkadvertising.org

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track

Some Internet browsers can be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit www.allaboutdnt.com.

Data Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Children

The Services are not intended for use by individuals under the age of 18. If we learn that we have collected personal information through our Services from an individual under the age of 18 without the consent of the child's parent or guardian as required by law, we will delete it.

Other Sites and Services

Our Services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Site.

Contact Us

If you have any questions or comments about the Privacy Policy, email us at mpai@wellcoaches.com.

Appendix A: Consumer Health Data Policy

This Consumer Health Data Privacy Policy explains how Wellcoaches collects, uses, shares, and protects "consumer health data" as defined under applicable U.S. state laws, and the privacy rights and choices you have, in connection with our Services.

This Consumer Health Data Privacy Policy supplements our Privacy Policy and applies only to consumer health data relating to Connecticut, Nevada and Washington state residents. This Consumer Health Data Privacy Policy excludes PHI as noted above in the Healthcare Patient Information Disclaimer.

Categories of Consumer Health Data We Collect

Depending on your responses and how you interact with the Services, we may collect the following categories of consumer health data related to you or others whom you are using the Services in relation to:

• Information about health conditions, treatment, diseases, or diagnosis, treatment, or medication, such as information about physical and mental health history, symptoms and/or treatment, medications you or others may be taking, or other health-related information.
• Social, psychological, behavioral, and medical interventions, such as information about behavioral or medical routines related to health, including any records provided regarding mental state or other behavioral traits.
• Information that identifies your seeking of health care services, such as information about interest in therapy or other health care services that interest you or others whom you are using the Services in relation to.
• Health information that is derived or inferred from non-health data, such as inferences about your mental health and well-being derived from your general inputs to our Services.

Sources of Consumer Health Data

We collect consumer health data directly from you, when you choose to provide such information in connection with the Services or from other users of the services, should they provide such information about you to the Services. This includes, when you or others:

• Interact with our Services, that are designed to understand your personal circumstances to provide tailored responses;
• Contact us for support, questions or feedback on our Services; or
• Choose to respond to our surveys or leave a review about the Services.

Purposes for Which We Collect and Use Consumer Health Data

We collect and use consumer health data as provided below:

• To provide you with the products and services you have requested, including to communicate with you, tailor responses, and to respond to your questions or requests for support.
• For research and development, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from consumer health data we collect.
• For compliance and protection, including to comply with legal obligations, defend against legal claims or disputes, protect the security and integrity of our Services, and identify and investigate fraudulent, harmful, unauthorized, unethical, or illegal activity.
• At your direction or with your consent, if you choose to provide consumer health data to us for any other purpose, as disclosed at the time you provide such information.

Disclosures of Consumer Health Data

We may disclose the categories of consumer health data described above to:

• Processors or service providers, who assist us in providing the Services to you, such as hosting, research, analytics, consumer survey and review services.
• Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
• Authorities and others, such as law enforcement, government authorities, and private parties, where we believe in good faith to be necessary or appropriate to comply with the law or protect our legitimate interests.
• Business transferees, such as acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Wellcoaches (including, in connection with a bankruptcy or similar proceedings).
• Other third parties, where applicable, at your direction or with your consent.

Your Rights

If you are a Connecticut, Nevada or Washington state resident, you may request the following in relation to your consumer health data:

• Confirm whether we are collecting, sharing, or selling consumer health data, and to access a copy of the consumer health data;
• Delete consumer health data; and
• Withdraw consent for our collection or sharing of consumer health data.

Submitting a Request

To submit a request, please contact us at mpai@wellcoaches.com. We will not discriminate against you for exercising your rights described above.

How to Appeal

If your request to exercise any of the rights described above is denied, you may appeal this decision by emailing us within a reasonable time at mpai@wellcoaches.com. If your appeal is denied, you may issue a complaint with appropriate regulatory enforcement authorities.