NEW LEGACY COACHING

Privacy Policy

Effective Date: August 16, 2026

New Legacy Ventures LLC, d/b/a New Legacy Coaching (“Company,” “Coach,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains what personal information we collect, how we use and share it, and what rights you have — whether you're simply visiting our website or you've engaged us as a coaching client. It applies to:

• Website Visitors: anyone who visits our website, emails us, or books a discovery call.

• Coaching Clients: anyone who has signed our Coaching Agreement and engaged our services. If you are a Client, this policy works alongside the confidentiality terms in your Coaching Agreement — those terms govern our discretion and non-disclosure commitments to you, while this policy explains our broader data collection, use, and sharing practices, including with third-party service providers.

1. Information We Collect

• Direct Emails: When you click an email link on our site and send us a message, we receive your email address, any name associated with your email account, and any information you choose to include in your message.

• Appointment Scheduling: When you book a discovery call or session using our Google Calendar link, we collect your name and email address to confirm and manage the appointment.

• Technical & Infrastructure Data: Our website is hosted on Google Sites through Google Workspace. Google automatically processes standard technical data — such as IP address, browser type, operating system, and device information — needed to securely deliver the website. We do not receive or control this data directly; it is processed by Google as our hosting provider.

• Analytics (Future Use): We do not currently use website analytics or tracking cookies. If we add a tool such as Google Analytics in the future, it will only collect aggregate, anonymized traffic information (such as device type, approximate location, and page views). If we do so, we will update this policy and, for visitors in the UK or European Economic Area, will implement a cookie consent banner before any non-essential cookies are placed, in accordance with applicable law.

• Payment Information (Clients): When you purchase coaching packages or sessions, payment is processed through Stripe payment links. We do not receive or store your full card number; we retain records of transaction amounts and dates for business and accounting purposes.

• Coaching Session Content (Clients): Information you share during coaching sessions, including goals, challenges, and personal or business context relevant to your engagement.

• AI-Assisted Transcripts & Notes (Clients): With your consent under the Coaching Agreement, we use AI-based tools to help produce transcripts and session notes. You may ask us to disable transcription for a specific session by notifying us before that session begins.

2. How We Use Your Information

• To respond to inquiries and messages.

• To schedule, confirm, and manage discovery calls and coaching sessions.

• To operate, maintain, and secure our website.

• To process payments and maintain business and accounting records.

• To prepare session notes and transcripts supporting your coaching engagement.

• To communicate with you about scheduling, billing, and your coaching relationship.

• To comply with legal, tax, or accounting obligations.

• To understand website traffic and improve the site 

We do not use bulk email marketing tools, and we do not sell or rent your personal information to third parties.

3. Sharing With Third-Party Service Providers

We rely on a small number of trusted providers to operate our business. These providers process personal information on our behalf and are bound by their own privacy and security terms:

• Google (Workspace, Sites, Calendar): for website hosting, business email, and appointment scheduling.

• Stripe: for payment processing. Stripe handles your payment data under its own privacy and security terms; we do not store full payment card details.

• AI Processing Tools, e.g. Google Gemini and Anthropic Claude: used to assist with transcription and session notes for active coaching clients, as described above.

These providers may process or store data on servers outside your country of residence, including in the United States. Where required by law (for example, for visitors or clients in the UK or EEA), we rely on each provider's own compliance mechanisms, such as standard contractual clauses, to safeguard international transfers.

We take reasonable steps to use these tools responsibly. If our use of a particular AI tool changes in a way that materially affects how your information is handled, we will update this policy accordingly.

4. Additional Terms for Coaching Clients

Confidentiality

As set out in your Coaching Agreement, we treat the personal and business information you share as confidential and will not publicly disclose your identity, story, or testimonial without your separate written consent. Coaching is not a legally privileged relationship (unlike attorney-client or doctor-patient communications). We may disclose information where required by law, court order, or where we believe in good faith that disclosure is necessary to prevent imminent harm to you or others.

Retention

We retain client records, communications, and session notes for as long as reasonably necessary to deliver our services, support your ongoing coaching relationship, and meet our legal, tax, and accounting obligations. As a general guideline, financial and payment records are typically retained for at least seven years to satisfy standard accounting and tax recordkeeping practices. If you end your coaching engagement, we may continue to retain your records for a reasonable period afterward consistent with these obligations, after which they are securely deleted or archived.

5. Data Retention (Website Visitors)

If you contact us or schedule a call but do not become a client, we generally retain your information only as long as reasonably necessary to respond to your inquiry or manage the appointment, unless we have a legal or business reason to keep it longer.

6. Sensitive Information

We ask that you not send us sensitive personal information — such as Social Security numbers, health or medical details, genetic information, or information about racial/ethnic origin, religious beliefs, or criminal history — through unsecured channels like email or website messages. If you choose to share sensitive information with us in the course of coaching conversations, we treat it with the same confidentiality and care described in Section 4, but we cannot guarantee the security of information sent via email or other unencrypted channels.

7. Data Security & Breach Notification

We maintain reasonable administrative, technical, and physical safeguards designed to protect your personal information, and we rely on the security practices of our third-party providers for the data they process. No system is completely secure. If a data breach affects your personal information, we will notify affected individuals as required by applicable law, including Tennessee's data breach notification statute.

We do not control the independent retention or deletion practices of our third-party service providers (such as Google or Stripe). If you would like a provider to delete its own copy of your data, you may need to contact that provider directly in addition to contacting us.

8. Age Requirement

Our website and coaching services are intended solely for adults aged 18 and older. We do not knowingly collect personal information from, or provide services to, anyone under 18. If we learn that we have inadvertently collected information from a minor, we will delete it promptly.

9. Your Privacy Rights

California Residents

Whether or not California's privacy laws (CCPA/CPRA) formally apply to our business, we are glad to voluntarily extend the following rights to California residents:

• The right to know what personal information we have collected about you.

• The right to request deletion of your personal information, subject to exceptions such as our legal and accounting recordkeeping obligations.

We do not sell or share personal information for cross-context behavioral advertising.

UK / European Economic Area (EEA) Residents

If you are located in the UK or EEA, we process your personal data based on the necessity of processing to respond to your inquiry or perform our Coaching Agreement with you, our legitimate interest in operating our business, or your consent (for example, regarding AI transcription or scheduling). You have the right to access, correct, port, or request erasure of your data, and to object to or restrict certain processing, subject to our legitimate need to retain certain records. You also have the right to lodge a complaint with your local data protection supervisory authority.

Making a Request

To exercise any right described in this section, contact us using the details in Section 11. We will respond to verified requests within 45 days and will let you know if more time is needed. Some information, such as records we are required to retain for legal or accounting purposes, may not be eligible for deletion.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, tools, or legal requirements. We will post the current version on our website with a revised “Effective Date,” and will provide notice of material changes to active clients.

11. Contact Us

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

• Attention: John Irvin

• Email: john@newlegacycoaching.com