CoachCorrie.ai -- Privacy Policy
Version 1.5 - 2026-08-05 - Consent version privacy-1.5
1. Who this covers
This policy explains how Paragon Consulting FZE, P.O. Box 393313, Fujairah, United Arab Emirates ("we") handles personal data when you visit coachcorrie.ai, apply for a coach account, or use the platform as a coach. For this data, we are the controller.
Coaching engagement content -- what an Executive Athlete says in sessions, uploaded artefacts, reports -- is different: there, your coach (or you, if you are the coach) is the controller and we process it on the coach's instructions under a Data Processing Agreement. Executive Athletes receive their own privacy notice through their engagement paperwork; this policy is not that notice.
2. What we collect
When you apply for an account
Your name, email address, the certification and profile details you choose to give, and a record of exactly which versions of the Terms of Service, this policy, and the DPA you accepted, with the timestamp. Applications are write-only to the public form: the form that collects your application cannot read applications back.
When you hold an account
Profile data you provide (name, email, LinkedIn and social links, bio, certifications, selected ethics frameworks, avatar); security data (your password stored as a hash, your two-factor secret encrypted at rest, recovery codes stored as hashes, single-use sign-in and reset tokens stored as hashes); credentials for any session-capture tools you connect, encrypted at rest inside your own vault; and the emails we send you (account emails, nudges, reflection questions).
Operational records
Audit and security logs. These are deliberately content-free wherever possible: they record that something happened (a sign-in, a report generation, an email sent), not what was in it.
The compliance ledger. Alongside those logs we keep a per-coach compliance ledger: an append-only record of the agreement versions you accepted and when, of when and how the platform's AI features were used on your account (as events, never content), and of the upload and deletion trail of your files by file name. File names are the one place a name you chose enters a durable record, so choose file names accordingly. The ledger exists so that both you and we can later prove what was agreed, what the AI was asked to do, and what data came and went -- see section 8 for how long it lives.
3. Why, and on what legal basis
We process account data to run your account and provide the service (performance of a contract); to keep the platform secure -- authentication, token handling, abuse prevention, audit (legitimate interests, and in part legal obligation); to notify you of service and legal changes (legal obligation and legitimate interests); and, where we ever rely on it, with your consent, which you can withdraw.
We do not use your data for advertising, we do not sell it, and we do not track you across other sites. The platform sets only the cookies it needs to keep you signed in.
4. AI, and what we never do with your data
The platform uses large language models (via the Anthropic API) to generate coach-facing drafts from each engagement's own knowledgebase. Every AI-generated render carries the EU AI Act Article 50 disclosure and machine-readable marking. No AI output is sent to an Executive Athlete or sponsor by us -- outputs go to the coach, whose documented review stands between AI and any wider audience.
We never use client data to train models -- ours, Anthropic's, or anyone's. Engagement content stays inside its engagement's compartment; coach data stays inside that coach's vault. Session content is handled as if it were special-category data under GDPR Article 9, because coaching conversations reach into health and family whether or not a form asks them to.
5. Website chat
The "Chat with Coach Corrie" box on our public pages is an AI assistant. It answers from this site's published pages only, and it is not a person; every panel carries that disclosure before you type, as the EU AI Act (Article 50) requires.
What we record. When chat recording is switched on -- and the disclosure in the chat panel tells you which it is, because the notice and the behaviour are driven by the same setting -- we keep a transcript of the conversation: the messages you send, the answers the assistant gives, an opaque reference for the conversation, and two coarse labels per exchange (a topic category and what the assistant did with the question). We do not record your IP address, we do not set or read a cookie that identifies you, and the transcript is not linked to any account -- yours or anyone's. There is no field anywhere in the chat records that names a coach, an Executive Athlete, a tenant, or an engagement, so a chat cannot be attached to any coaching record.
Why. Customer service (so we can answer you properly and follow up on what the assistant could not), quality assurance (so we can see where the assistant is wrong, unhelpful, or refusing too much), and improving the product and its published answers (so questions the site keeps failing to answer become published answers).
Lawful basis. Our legitimate interests in running, supporting, and improving the service, and in understanding what visitors to our own site want to know (GDPR Article 6(1)(f)). You can object to this processing, and you can ask us to delete a conversation, as described below. [Subject to counsel review.]
How long. Ninety days from the last message in the conversation, then automatic deletion. Ninety days is the platform's single retention period; nothing about chat is kept longer.
Never used for training. Chat transcripts are never used to train any model -- ours, our AI sub-processor's, or anyone's. This is the same commitment as section 4 and it is not narrower here.
Where it is processed. Transcripts are stored in the European Union like everything else, with the one disclosed exception described in section 6: generating the assistant's reply sends the conversation to our AI sub-processor for inference, and that processing may occur outside the EEA under the safeguards stated in the Data Processing Agreement.
Please do not type anything confidential. The chat box is a public, anonymous surface. It is not the place for client information, health information, or anything you would not want kept for ninety days.
Deleting a chat. Each recorded conversation shows you its reference. Quote that reference in an email to admin@coachcorrie.ai and we will delete that conversation and every message in it. The reference is the only handle we have on a conversation: because we hold no identifier for you, we cannot find your chat without it.
6. Where your data lives
In the European Union, with one disclosed exception. Engagement and account data is stored and processed in the European Union (AWS eu-central-1), and EU data residency is an architectural commitment, not a configuration. The exception is AI inference: when content is sent to the AI sub-processor for inference, that processing may occur outside the EEA, under the safeguards described in the Data Processing Agreement (a contractual no-training warranty, encryption in transit, and the transfer mechanisms stated there). We are evaluating pinning all inference to EU-region endpoints. [Subject to counsel review.] Administrative access from outside the EU is minimized. Our EU representative under GDPR Article 27 and our authorised representative under EU AI Act Article 22 are both appointed and named in section 13.
7. Who else touches it (sub-processors)
Two sub-processors, each bound by contract: Amazon Web Services (EU regions -- hosting and storage, email delivery via Amazon SES, speech-to-text transcription of Executive Athlete voice memos via Amazon Transcribe, and text embeddings via Amazon Bedrock); and Anthropic (AI model inference over our API integration, under commercial terms that exclude training on our data). The current list, with any changes notified in advance, is maintained in the DPA's sub-processor annex.
8. How long we keep it
Account and profile data: for the life of your account; on account closure, personal data is erased or irreversibly anonymised within 90 days, except (a) records we must retain to establish, exercise, or defend legal claims or to comply with legal obligations (GDPR Article 17(3)), which follow the layered schedule described below (up to 7 years), and (b) logs and records the EU AI Act requires us to keep as provider, which are retained for their statutorily required period. [Subject to counsel review.] Security tokens are single-use and short-lived by construction. Audit-trail records are retained for 7 years -- disclosed here at collection -- because coaching ROI reporting and professional-liability defence require a durable integrity record.
Engagement content -- what a coaching engagement's record holds -- follows the Data Processing Agreement rather than this section, and the same post-closure period applies there: a 30-day export window after the Terms of Service end, then deletion within 90 days, with the same Article 17(3) carve-outs. Ninety days is the platform's single post-closure retention period, for account data and engagement content alike; deletion is performed as an audited erasure operation.
Retention is layered against your right to erasure: when erasure is exercised, content-level personal data is erased or anonymized, while pseudonymized integrity log entries may survive under Article 17(3) (establishment, exercise, or defence of legal claims). We tell you which is which when you ask.
The compliance ledger (section 2) follows the audit-trail schedule, not the content schedule: it survives content erasure and account closure and is retained for up to 7 years after account closure, on Article 17(3) and our legitimate interest in defending legal claims and demonstrating regulatory compliance. It keeps your identity, your consent record, event records of AI use, and file names -- never engagement content. You can request a copy of your own ledger at any time. [Subject to counsel review.]
9. Your rights
You have the GDPR rights of access, rectification, erasure, restriction, portability, and objection, and the right not to be subject to solely automated decisions with legal or similarly significant effect -- the platform makes none about you; admission to the platform is decided by a human, and every AI output is addressed to a reviewing professional. Write to admin@coachcorrie.ai to exercise any right; we answer within a month. You can also complain to a supervisory authority -- if you are in the EU, the authority of your member state.
10. How we protect it
Per-tenant isolation is the platform's founding design: every coach's data sits in an isolated vault enforced by database row-level security, and every engagement is a separate compartment inside it -- the isolation model is tested by a permanent suite of deliberate cross-tenant attack queries that must fail on every change and every deployment. On top of that: encryption in transit and at rest (secrets encrypted at the column level), mandatory two-factor authentication, single-use hash-only tokens for every sensitive flow, deny-by-default database grants, and content-free logging.
11. Changes
This policy is versioned. Material changes are notified to your account email and require re-acceptance; the version you accepted is always on record.
12. Contact
Paragon Consulting FZE, P.O. Box 393313, Fujairah, United Arab Emirates - admin@coachcorrie.ai - https://coachcorrie.ai
13. EU representatives
We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:
- European Union (EU)
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website: https://app.prighter.com/portal/15292804891
The representative appointed under GDPR Article 27 is Prighter EU Rep GmbH, Schellinggasse 3/10, 1010 Vienna, Austria. The same entity is appointed as our authorised representative under Article 22 of the EU AI Act, at the same address, and is the point of contact for the AI Office and national competent authorities. Please quote reference ID-15292804891 in any correspondence. Appointments recorded 2026-08-05. [Subject to counsel review.]
