Privacy Policy

Coach Nova Limited (“CoachNova,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our AI-powered coaching practice platform, support services, training, documentation, and all related services (the “Services”).

This Privacy Policy applies to Coaches and their Coachees who create accounts and use our Services. It explains what personal data we collect as a data controller, how we process it, and your rights regarding your personal information.

1. Who We Are

Coach Nova Limited is a company registered in Ireland. We provide an AI-powered coaching practice platform designed to support professional coaches in their practice (the “Platform”).

2. Personal Data We Collect

We collect and process the following categories of personal data about Coaches and their Coachees:

2.1 Personal Data Coaches Provide Directly

• Account Creation and Profile Information: Full name, address, email address, company name, company registration number, VAT number, username, password, professional credentials, coaching specialisation, telephone number;
• Payment Information: Credit card number, verification number, bank account information, billing address, payment method details (processed by our payment processor), transaction history;
• Marketing and Communications Data: Email address, communication preferences, marketing consent;
• Support and communication information: Name, contact information when you contact customer support, participate in surveys, or provide feedback.

2.2 Personal Data Coachees Provide Directly

• Account Creation and Profile Information: Full name, email address, telephone number, username, password;
• Support and communication information: Name, contact information when you contact customer support, participate in surveys, or provide feedback.
• Coach Companion conversations: If your Coach has enabled the Coach Companion, the messages you write to it and the responses generated for you. This content is written by you directly into the Platform and is not reviewed by your Coach before you receive the response.

Which of this we control, and which we only hold for your Coach. For your account details and the security of the Platform we are the data controller and this Privacy Policy governs. For the substance of your coaching, including the content of your Coach Companion conversations, your Coach is the data controller and we process it on their behalf under our Data Processing Agreement. There is one exception, set out at 3.7 below: we determine the purposes of the safety checks we run on Coach Companion conversations, and we are the controller for that.

2.3 Information Automatically Collected

• Technical data: IP address, browser type and version, device type, operating system, time zone setting, location data
• Usage data: How you interact with our Platform, pages visited, features used, time spent, search queries
• Cookies and tracking technologies: See our Cookie Policy for details
• Log and troubleshooting data: Server logs, error reports, performance data

2.4 Information from Third Parties

• Authentication providers: If you sign up using Google, Microsoft, or other third-party authentication
• Analytics providers: Aggregated usage statistics

3. How We Use Your Personal Data

Under the applicable data protection laws we can only use your personal data if we have one of the following legal bases:

• For the performance of our agreement with you or to take steps at your request before entering into an agreement;
• To comply with our legal obligations;
• For our legitimate interests where they do not disproportionately infringe on your privacy;
• Where you have given consent.

3.1 To Provide and Maintain Our Services to Coaches

Legal Basis: Performance of contract with you

• Create and manage your account
• Provide access to our Platform and services
• Process your subscription and manage billing
• Authenticate your identity and maintain account security
• Provide customer support and respond to your inquiries

3.2 To Provide and Maintain Access of Coachee Services to Coachees

Legal Basis: Performance of contract with you

• Create and manage your account
• Provide access to certain Coachee Services on our Platform
• Authenticate your identity and maintain account security
• Provide customer support and respond to your inquiries

3.3 To Improve and Develop Our Services

Legal Basis: Legitimate interests (to improve our Services and develop new features)

• Analyse usage patterns and trends
• Conduct research and development for new features
• Test and optimize Service performance
• Gather feedback through surveys and user research
• Carry out security-related tasks, such as troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

3.4 To Enable Analysis of Trends and Analytics in Coaching Practices

Legal Basis: Legitimate interests (to enable analysis of trends and analytics in coaching practices in general)

CoachNova derives aggregated and anonymised insights from Coach Content using industry-standard anonymisation techniques, including aggregation thresholds and removal of direct and indirect identifiers. Such anonymised data cannot reasonably be used to identify any Coach, Coachee, or other individual. “Coach Content” has the meaning given in the Terms of Service for Coaches.

3.5 For Marketing and Communications

Legal Basis: Consent (where required) or legitimate interests (for existing customers)

• Send you updates about our Services and solutions, new features, initiatives, announcements
• Provide you with marketing communications and promotional offers (where you have consented)
• Invite you to participate in surveys, webinars, marketing campaigns, training, events and other promotional activities
• Send you administrative information, such as changes to our Terms of Service, Data Processing Agreement or this Privacy Policy

Note: You can opt out of marketing communications at any time by clicking the “unsubscribe” link in our emails or by contacting us at privacy@coachnova.ai.

3.6 For Legal and Security Purposes

Legal Basis: Legal obligation or legitimate interests (to protect our business and comply with laws)

• Comply with legal obligations and regulatory requirements
• Detect, prevent, and respond to fraud, security incidents, or misuse of our Services
• Enforce our Terms of Service for Coaches, Access Terms for Coachees and other policies
• Establish, exercise, or defend legal claims

3.7 To Keep People Safe in Coach Companion Conversations

Legal Basis: Legitimate interests (protecting the life, health and safety of users of the Platform), and vital interests where a risk to life is indicated

• Run automated checks on Coach Companion conversations to identify indications of crisis, self harm or other risk of harm
• Show crisis resources to the person concerned
• Raise a flag to their Coach so that a human being can respond
• Apply and enforce the platform-wide safety guardrails that govern how the Coach Companion behaves
• Review flagged material where necessary to improve the accuracy of these checks

We decide how these checks work, so for this processing we are the data controller rather than a processor acting for your Coach. The flag your Coach receives tells them that something needs attention. It does not hand them a transcript of your conversation.

4. Who We Share Your Personal Data With

We may share personal data with trusted service providers and they solely process your personal information based on our instructions. We conclude appropriate data processor agreements or otherwise include appropriate contractual obligations in our agreements in accordance with local law with these service providers.

Additionally, we may disclose your personal data to: (a) competent authorities, if legally required or necessary to protect our rights, or in the context of (future) legal proceedings; (b) our insurers, brokers, banks; (c) potential corporate buyer in the case of transfer of some or all of our business, during re-structuring or change of ownership of the business.

5. International Data Transfers

5.1 Where Your Data Is Held

Personal Data is hosted in the European Union, on infrastructure located in Frankfurt, Germany. EU data residency is the default on every plan. It is not an upgrade, it is not conditional on the plan You or Your Coach is on, and it does not require a separate agreement.

CoachNova is based in the Republic of Ireland, and your personal data is primarily stored and processed within the EU/European Economic Area (EEA).

However, some of our service providers may be located outside the EU/EEA. When we transfer your personal data outside the EU/EEA, we ensure appropriate safeguards are in place to protect your data, including:

• European Commission adequacy decisions: We transfer data to countries deemed to provide adequate protection (such as the UK, Switzerland);
• Standard Contractual Clauses (SCCs): We use EU-approved Standard Contractual Clauses with third-party recipients;
• Data Privacy Framework (DPF): For US-based service providers certified under the EU-US Data Privacy Framework;
• Other approved mechanisms: Such as binding corporate rules or certification schemes

You can request more information about the specific safeguards we have in place for international data transfers by contacting us at privacy@coachnova.ai.

6. How Long We Keep Your Personal Data

We will keep your personal information while we are providing our Services to you. Thereafter, we will keep your personal information for as long as is necessary to respond to any questions, complaints or claims made by you or on your behalf; to show that we treated you fairly; and to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. By law we have to keep basic information about our customers for 7 (seven) years after they cease being customers.

For coaching content specifically: audio recordings of sessions are never stored, and are discarded once a session has been transcribed. Transcripts, notes and Coach Companion conversations are kept while the coaching engagement is active, because they are what the Platform draws on to be useful. When a Coachee is deactivated, their Coach is invited to download an archive of that engagement, after which the Coach may delete it. Once deleted it is permanently removed from CoachNova and recoverable only from the Coach's own downloaded copy. A Coachee may ask us to access, export or erase their Coach Companion conversations at any time by writing to privacy@coachnova.ai, and does not have to go through their Coach to do so.

When it is no longer necessary to retain your personal information we will securely destroy your personal information in accordance with applicable laws and regulations. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

7. Your Rights

As an individual (including individuals in the EU, EEA, Switzerland or UK) you have the right under the applicable data protection laws to ask questions about or request action regarding your personal data. Subject to certain exceptions and exemptions provided by the applicable data protection law and where applicable, you may:

• Request access to and rectification or erasure of your personal information, restriction of processing of your personal information, the right to object to processing of your personal information, and portability of your personal information. Please contact us using our contact details set out below.
• Withdraw your consent at any time for those processing activities that CoachNova relies on your consent as legal justification for processing it. You can do so by contacting us using our contact details set out below. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.
• Lodge a complaint with the Irish Data Protection Commission or your own local data protection agency.

7.1 If You Are in the United States

Depending on the state you live in, you may have rights under state privacy law, including California, Virginia, Colorado, Connecticut, Utah, Texas and others. Where those laws apply to you, you have the right to know what personal information we collect and why, to access it, to correct it, to delete it, to obtain a portable copy, and not to be discriminated against for exercising any of these rights. Where a state gives you the right to appeal a refusal, you may appeal by writing to privacy@coachnova.ai with the subject line “Privacy appeal”.

We do not sell your personal information, and we do not share it for cross-context behavioural advertising. We have not done so in the preceding twelve months, including for anyone under 16.

Sensitive personal information. Coaching conversations, and Coach Companion conversations in particular, may contain information that California law treats as sensitive personal information. We use it only to provide the Services you and your Coach have asked for, and to keep people safe as described at 3.7. We do not use or disclose it to infer characteristics about you.

Making a request. Write to privacy@coachnova.ai. We will verify your identity before acting, and we will respond within the period the applicable state law requires. You may use an authorised agent where your state permits it. Because your Coach is the controller of your coaching content, we will normally direct that part of your request to them, except for your Coach Companion conversations, which we handle directly as described at section 6. You do not have to rely on that route to delete your own data. You can delete your Coach Companion conversations and your Coachee account yourself, from within the CoachNova mobile application or your account settings, at any time, including after your engagement with your Coach has ended or if your Coach no longer holds a subscription.

8. Security of Your Personal Data

We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, loss, misuse, alteration, or destruction. Further details can be found at coachnova.ai/your-data.

8.1 Security Measures

Personal Data is encrypted in transit and at rest. Access by CoachNova personnel is limited to authorised staff, granted only for support You or Your Coach has requested, logged, and time limited. CoachNova maintains an information security programme that meets SOC 2 Type II standards. CoachNova is not, at the date of this policy, SOC 2 certified, and does not claim to be.

8.2 Audio

Audio recordings of sessions are not stored. Sessions are transcribed and the audio is discarded.

8.3 Separation Between Engagements

Each coaching engagement is held in its own context. Personal Data from one Coachee is not combined with, or made available to, another Coachee, and is not pooled across Coaches.

8.4 Personal Data Breach

Where a personal data breach occurs, CoachNova notifies the competent supervisory authority without undue delay and, where feasible, within seventy-two (72) hours of becoming aware of it, in accordance with Article 33 GDPR. Where the breach is likely to result in a high risk to Your rights and freedoms, CoachNova notifies You without undue delay in accordance with Article 34 GDPR, with a description of what happened, what data was affected, and what is being done about it.

9. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children under 18. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at privacy@coachnova.ai, and we will delete such information from our systems.

10. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy by posting a revised version on our website, with the revision date indicated at the top. We recommend regularly checking this page to stay informed about any changes.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us:

Coach Nova Limited
71 Lower Baggot Street, Dublin 2, D02P593, Republic of Ireland
Privacy inquiries: privacy@coachnova.ai
Website: www.coachnova.ai