CoachAha Privacy Policy

Last updated: 26 April 2025

1. Introduction

CoachAha ("CoachAha", "we,", "our" or "us") operates an online voice-driven coaching platform ("Service") that leverages cutting-edge conversational AI. This Privacy Policy explains how we collect, use, disclose, transfer and store information that directly or indirectly identifies you ("Personal Data") when you interact with the Service, visit our website, communicate with us, or otherwise engage with CoachAha (collectively, the "Sites"). By accessing or using the Service you acknowledge that you have read and understood this Privacy Policy.

2. Personal Data We Collect

You may decline to submit certain information, but this may limit the Service's functionality.

3. How We Use Personal Data

We process Personal Data, to the extent permitted by applicable law, for the following purposes:

1. Service Delivery & Contract Performance
• create, authenticate and maintain your account;
• capture, transcribe and analyze Voice & Conversation Data to generate coaching outputs;
• provide customer support and handle inquiries.
2. Product Improvement & Research
• develop, train, fine-tune and evaluate our AI models;
• conduct analytics to understand usage patterns and enhance accuracy, safety and user experience;
• generate aggregated or de-identified insights for benchmarking and research.
3. Personalization & Marketing
• remember your settings, personalize content and recommend features;
• send you service announcements, surveys, newsletters, promotions and advertisements;
• measure the effectiveness of marketing campaigns.
4. Security & Fraud Prevention
• monitor, detect and protect against malicious, deceptive, fraudulent or illegal activity;
• enforce our Terms of Service and other policies.
5. Legal & Compliance
• comply with legal obligations, requests and orders from public authorities;
• exercise or defend legal claims;
• conduct audits and risk assessments.

Our lawful bases include (i) performance of a contract with you; (ii) our legitimate interests in running and improving the Service; (iii) your consent, where we request it; and (iv) compliance with legal obligations.

4. Sharing & Disclosure

We may disclose Personal Data in the circumstances set out below, always ensuring contractual safeguards and technical measures appropriate to the sensitivity of the data:

• Service Providers & Sub-Processors — hosting, cloud infrastructure, AI inference engines (such as OpenAI, Anthropic, or similar), analytics, payment processors, IT support, marketing platforms and other vendors who act on our instructions.
• Affiliates & Group Companies — entities under common ownership or control that support the Service.
• Business Partners — resellers, distributors or integration partners that you authorize or engage.
• Legal, Regulatory or Safety Purposes — where required to comply with law, protect rights, prevent harm, or enforce agreements.
• Corporate Transactions — in connection with any merger, sale of assets, financing, restructuring, acquisition or in the negotiation thereof (Personal Data may be transferred as part of business assets).
• Aggregated & De-Identified Data — insights that cannot reasonably be linked to an identified or identifiable natural person.
• With Your Direction or Consent — where you explicitly authorize disclosure, for example by connecting a third-party account.

We do not provide Personal Data to unaffiliated third parties for their independent direct marketing unless you choose to opt in. We may, however, share identifiers, device information, and online activity with advertising partners to facilitate interest-based advertising; you can opt out as described in Section 6.

5. International Data Transfers

CoachAha is headquartered in the European Union and relies on global infrastructure. Consequently, Personal Data may be transferred to, processed in, and stored in jurisdictions outside your own, including countries whose data-protection standards differ. We implement appropriate safeguards such as data-processing agreements incorporating industry-standard contractual protections, technical and organizational measures, encryption in transit and at rest, and strict access controls.

6. Your Rights & Choices

Depending on your location and subject to applicable law, you may have the following rights, which you can exercise free of charge:

• Access – obtain confirmation whether we hold Personal Data about you and receive a copy.
• Rectification – request correction of inaccurate or incomplete Personal Data.
• Deletion – request erasure of Personal Data that is no longer necessary for the purposes for which it was collected.
• Restriction – request that we limit processing of Personal Data under certain conditions.
• Portability – receive Personal Data you provided to us in a structured, commonly used, machine-readable format and transmit it to another controller.
• Objection – object to processing based on our legitimate interests, including profiling and direct marketing.
• Withdraw Consent – where processing is based on consent, withdraw at any time without affecting the lawfulness of processing prior to withdrawal.
• Ad Choices – opt out of cookies or targeted advertising via browser settings, cookie banners or the “Do Not Sell or Share My Personal Information” link (if available).
• Lodge a Complaint – raise concerns with your regional privacy regulator or supervisory authority.

To exercise any of these rights, email support@coachaha.com, submit a request via the in-app settings, or write to the address in Section 12. We may verify your identity before fulfilling a request and may deny requests in limited circumstances where permitted by law.

7. Data Retention

We retain Personal Data for as long as (i) your account is active or (ii) necessary to fulfill the purposes described in this policy, plus any additional period required or permitted by law (e.g., tax, accounting, legal obligations, fraud prevention). CoachAha does not record or store the original audio of your coaching sessions by default. Instead, we capture and retain only textual transcripts. These transcripts are kept indefinitely so that you can revisit prior sessions, and so we can continue to enhance the accuracy, reliability and relevance of our AI models. You may request deletion of your transcripts at any time from within the app or by contacting us as set out in Section 12; unless such deletion is restricted by legal or operational requirements, we will honour your request promptly. Aggregated or de-identified information that can no longer be linked to you may be preserved without limitation.

8. Security Measures

CoachAha employs administrative, physical and technical safeguards designed to protect Personal Data, including but not limited to: role-based access controls, multi-factor authentication, encryption in transit and at rest, intrusion detection and secure coding practices. No internet or e-mail transmission, however, is ever fully secure; we cannot guarantee absolute security.

9. Automated Decision-Making & Profiling

Our AI systems generate coaching responses by interpreting your Voice & Conversation Data and other inputs. Our conversational engine relies on statistical and machine-learning techniques that may occasionally produce incomplete, outdated or erroneous outputs. While we strive for accuracy and consistency, the guidance you receive is automatically generated and should be considered informational only. You are solely responsible for verifying any advice or factual statements that could affect your well-being, finances, legal status or other important interests before acting on them. These automated processes are intended to support your personal development and do not create legal, medical, financial or other professional obligations, nor do they generate decisions that produce legal or similarly significant effects on you without further human involvement.

10. Children's Privacy

The Service is not directed to individuals under 18 years of age, and we do not knowingly collect Personal Data from minors. If you believe we have inadvertently processed a minor's information, please contact us so we can delete it promptly.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect operational, legal or regulatory changes. If material changes are made, we will provide reasonable notice through the Sites or by other means, and the revised version will be effective as of the "Last updated" date. Continued use of the Service constitutes acceptance of the revised policy.

12. Contact Us

If you have questions, concerns or requests regarding privacy, please contact:

CoachAha Privacy Office

Playstar d.o.o.

Tolstojeva 45

1000 Ljubljana, Slovenia

European Union

📧 support@coachaha.com

We endeavor to respond to all legitimate inquiries within one month or sooner where required.

By using CoachAha, you acknowledge that you have read and understood this Privacy Policy, and you agree to the collection, use and disclosure of your Personal Data as described herein.