Privacy Policy

This Privacy Policy describes how Platinum Rule Consulting IP Holdings LLC, an Arizona limited liability company (“ClosedCoach,” “we,” “us,” or “our”), collects, uses, stores, and discloses personal information when you access or use the ClosedCoach platform and services (the “Service”) at closedcoach.com or any related subdomain.

By using the Service, you agree to the practices described in this Privacy Policy. If you disagree with any part, please do not use the Service.

2.1 Account and Contact Information. When you register or are invited to the Service, we collect:

• Name and email address
• Organization name and role
• Payment information — processed by our payment provider; we never store full card numbers
• Profile settings and preferences

2.2 Voice and Session Data. When you use voice features, we collect:

• Audio recordings of your voice roleplay sessions
• Voice transcripts generated from those sessions
• Session metadata (duration, scenario, date, outcomes)
• AI-generated coaching scores and feedback

Voice data may include measurements of your vocal characteristics that constitute biometric data under applicable law. See Section 5 for our full biometric data practices. We do not collect or infer emotional expression or emotional state data.

2.3 Usage and Technical Data. We automatically collect:

• Pages visited, features used, and session duration
• Device type, browser type, and operating system
• IP address and approximate location (country/region)
• Cookies and session tokens (see Section 12)

We use your personal information to:

• Create and manage your account and subscription
• Deliver AI-generated scoring, coaching feedback, and performance analytics
• Process payments and prevent fraud
• Send transactional communications (receipts, account notices, updates)
• Respond to support requests
• Improve and develop the Service through aggregated and de-identified analytics (see Section 7)
• Comply with legal obligations and enforce our Terms of Service

We do not use identifiable voice or biometric data to train AI models except with separate, specific consent. We do not sell your personal information.

We share personal information only with third-party service providers necessary to operate the Service. Each provider is bound by contractual data-processing obligations and may only use your data to perform services on our behalf. The categories of providers we engage include:

• AI and voice infrastructure — to power real-time voice sessions and generate coaching analysis
• Database and authentication — to store account data and manage secure login
• Application hosting — to deliver the Service
• Payment processing — to handle subscriptions and billing

Enterprise customers may request our full sub-processor list by contacting legal@closedcoach.com.

We may also disclose your information if required by law, court order, or to protect the rights, safety, or property of ClosedCoach, our users, or the public.

Voice sessions capture your voice and may generate voice-derived data that includes measurements of your vocal characteristics. This data may constitute a “biometric identifier” or “biometric information” under the Illinois Biometric Information Privacy Act (BIPA) and comparable laws in Texas, Washington, and other states.

Collection and Consent. Before your first voice session, ClosedCoach presents a separate Biometric Consent disclosure. You must provide affirmative written consent before any biometric data is collected. If you do not consent, you may not use voice features but may continue to use all other Service features.

Purpose. Biometric data is collected solely to provide and improve the coaching and scoring features of the Service.

Retention and Destruction. ClosedCoach deletes each voice recording within sixty (60) days of the coaching session that produced it from our active systems, and directs its service providers to delete on a comparable schedule. If you save (bookmark) a recording, we retain it until you delete it or your account is terminated, and in no event longer than three (3) years after your last interaction with ClosedCoach, whichever occurs first, after which it is permanently destroyed using commercially reasonable methods. Transcripts and performance scores derived from a session (which do not contain your voice) are retained for up to twelve (12) months. Data may persist temporarily in routine backups, which are purged on their normal cycle. This schedule may be shorter if you request deletion or if your account is terminated (see Section 6).

No Sale or Trade. ClosedCoach does not sell, lease, trade, or profit from biometric data. Biometric data is shared with Sub-Processors only to the extent necessary to provide voice features, and each Sub-Processor is contractually prohibited from using it for other purposes.

We retain personal information for as long as your account is active or as needed to provide the Service. Upon account deletion or termination:

• We retain your data for 30 days to allow you to export it
• After 30 days, we use commercially reasonable efforts to delete your personal data from active systems
• Biometric data is destroyed per the schedule in Section 5
• Data may be retained longer if required by law, a legal hold, or in routine backups (which are purged on their normal cycle)
• De-identified and aggregated data derived from your use may be retained indefinitely

To request deletion, email legal@closedcoach.com. We fulfill deletion requests within 30 days except where retention is required by law.

ClosedCoach may create de-identified or aggregated data from information collected through the Service. De-identified data does not identify any individual. We may use such data without restriction for any lawful purpose, including product improvement, research, benchmarking, and analytics. We will not attempt to re-identify de-identified data.

We implement industry-standard safeguards, including:

• TLS encryption for all data in transit
• Encrypted storage at rest for all data and recordings
• Row-level security policies restricting data access to authorized users
• Role-based access controls separating user, administrator, and service functions
• Regular security reviews of our code, infrastructure, and access policies

No system is 100% secure. If you believe your account has been compromised or you have identified a security vulnerability, contact us immediately at legal@closedcoach.com.

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) gives you additional rights.

Categories of Personal Information We Collect. We collect identifiers (name, email, IP address); commercial information (subscription and payment history); biometric information (voice characteristics as described in Section 5); internet/electronic activity (usage data); audio data (voice recordings); and inferences drawn from session performance data.

Sensitive Personal Information (SPI). We collect voice recordings and biometric data that qualify as SPI under the CPRA. We use SPI only for the purposes of providing and improving the Service, and we do not use or disclose SPI for purposes outside those permitted by law.

Your Rights. As a California resident, you have the right to:

• Know what personal information we collect, use, disclose, and share
• Delete personal information we hold about you, subject to legal exceptions
• Correct inaccurate personal information
• Opt out of the sale or sharing of personal information — we do not sell or share personal information
• Limit use of SPI to the purposes for which it was collected
• Non-discrimination — we will not discriminate against you for exercising your rights

To exercise your California rights, submit a request to legal@closedcoach.com. We will verify your identity and respond within 45 days, with one extension of 45 days if needed.

ClosedCoach is based in Arizona, USA. Your personal information is processed and stored in the United States. If you access the Service from outside the US, your information may be transferred to and processed in the US, where data protection laws may differ from those in your jurisdiction.

Where required by applicable data protection law (including GDPR or UK GDPR), we will ensure that transfers of personal data outside the EEA or UK are made in compliance with those laws, including through Standard Contractual Clauses or other approved transfer mechanisms. Enterprise customers may request a Data Processing Addendum (DPA) at legal@closedcoach.com.

The Service is intended for professionals aged 18 and older. We do not knowingly collect personal information from anyone under 18. If we learn that we have inadvertently collected such information, we will delete it promptly. If you believe a minor has provided us personal information, contact us at legal@closedcoach.com.

We use strictly necessary cookies and similar technologies to maintain your login session and protect against cross-site request forgery. These are required for the Service to function; disabling them will prevent you from logging in.

We may use analytics cookies to understand how the Service is used in aggregate. Non-essential cookies will not be placed without your consent. You can manage cookie settings through your browser or a consent banner when required by law.

We may update this Privacy Policy from time to time. When we make material changes, we will provide notice by email or in-app notification at least 30 days before the changes take effect. We will also update the “Last updated” date at the top of this page.

Your continued use of the Service after the effective date of any update constitutes acceptance of the revised Privacy Policy.

For privacy-related questions, data access requests, deletion requests, or to exercise any rights described in this policy, contact us at:

• Email: legal@closedcoach.com
• Mail: Platinum Rule Consulting IP Holdings LLC, 250 N Litchfield Rd, Ste 261, Goodyear, AZ 85338

We respond within 5 business days and fulfill deletion requests within 30 days.