Privacy Policy for The Attraction Easy Access Coach Web App

Effective Date: July 17, 2025

This Privacy Policy describes how The Attraction Easy Access Coach ("App," "we," "us," or "our") collects, uses, and discloses your information when you use our web application located at attractioncoachapp.com and related services (collectively, the "Service").

We are committed to protecting your personal data and respecting your privacy. This policy is designed to comply with the General Data Protection Regulation (GDPR) for users within the European Economic Area (EEA) and other applicable data protection laws.

By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this policy, please do not use the Service.

1. Data Controller

The data controller responsible for your personal data under this Privacy Policy is:

The Attraction Easy Access Coach (Owner: [Your Name/Company Name]) Location: Florida, USA Contact Email: admin@attractioncoachapp.com

2. Information We Collect

We collect various types of information to provide and improve our Service to you.

2.1. Information You Provide Directly to Us:

• Account Information: When you register for an account, we collect your email address and mobile number. If you choose to register via social media (Google, Facebook, etc.), we collect basic profile information as allowed by those services (e.g., name, profile picture).

• Communication Content: We collect the text of your typed questions and the audio recordings of your spoken questions, as well as the AI-generated text and audio responses within the chat interface. This data is essential for providing the coaching service.

• Payment Information: When you subscribe to a package, we collect payment details necessary to process your transaction (e.g., credit card information, billing address). This information is processed through third-party payment gateways. We do not store full payment card details on our servers.

• Customer Support Interactions: If you contact us for support, we will collect information related to your query to assist you.

2.2. Information We Collect Automatically (Usage Data):

• Device Information: We may collect information about the device you use to access the Service, including the device model, operating system version, unique device identifiers, and mobile network information.

• Usage Details: We collect data about how you access and use the Service, such as the features you use, the time and date of your use, the pages you visit, and referring/exit pages. This includes interaction with the chat features (e.g., number of queries, duration of sessions).

• Location Information: We derive your approximate location from your IP address. We do not collect precise GPS location data.

• Cookies and Tracking Technologies: We use cookies and similar tracking technologies to track activity on our Service. More details are provided in Section 5.

3. How We Use Your Information and Lawful Basis for Processing

We use the information we collect for various purposes, based on the following lawful bases under GDPR:

• To Provide and Maintain the Service (Contractual Necessity): This includes enabling user registration and login, managing subscriptions and access to features, and delivering the core AI coaching functionality. Processing your chat inputs and responses is fundamental to fulfilling our service contract with you.

• To Process Transactions (Contractual Necessity): To process payments for your subscriptions.

• To Improve and Develop the Service (Legitimate Interests): To understand how users interact with the app, identify areas for improvement, and develop new features. This includes using your chat inputs (questions and responses) to further train and improve the App's AI agents. This processing is necessary for our legitimate interest in continually enhancing the quality and effectiveness of the coaching service.

• To Communicate with You (Contractual Necessity & Legitimate Interests): To send you service-related messages, updates, security alerts, and support responses. This is necessary for our contractual relationship and our legitimate interest in providing effective customer service.

• For Security and Fraud Prevention (Legitimate Interests & Legal Obligation): To protect the integrity and security of our Service and prevent fraudulent activities. This is necessary for our legitimate interest in securing our service and, in some cases, to comply with legal obligations.

• For Analytics and Research (Legitimate Interests & Consent for certain cookies): To perform internal operations, analysis, research, and troubleshooting using Google Analytics. This helps us understand user behavior and improve the app. Where required for non-essential cookies, we rely on your consent.

• To Comply with Legal Obligations (Legal Obligation): To meet our legal and regulatory requirements.

4. How We Share Your Information

We may share your information with third parties only when necessary and for specific purposes, ensuring appropriate safeguards are in place. We confirm that your data will not be shared with third parties for marketing purposes unrelated to our services.

• With Service Providers (Data Processors): We engage third-party companies and individuals to facilitate our Service, provide the Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used. These include:

  • AI Service Providers: For example, OpenAI (or other LLM providers) for processing your queries and generating responses. Your chat inputs (text and transcribed voice) are sent to these providers to generate the coaching responses and for the further training and improvement of the App's AI agents. We ensure that our contracts with these providers reflect our commitment to data protection.

  • Payment Processors: To handle subscription payments.

  • Cloud Hosting Providers: For data storage and infrastructure.

  • Analytics Providers: Google Analytics, to help us understand app usage.

  • Speech-to-Text (STT) and Text-to-Speech (TTS) Providers: For voice interaction functionality. These third parties act as data processors on our behalf and have access to your personal information only to perform these tasks. They are contractually obligated to protect your data and are prohibited from using it for any other purpose.

• For Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

• With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy.

• For Legal Reasons: If required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

• With Your Consent: We may disclose your personal information for any other purpose with your explicit consent.

5. Cookies and Tracking Technologies

We use cookies and similar tracking technologies (e.g., pixels, web beacons) to track activity on our Service and hold certain information. Cookies are small data files placed on your device.

We use the following types of cookies:

• Essential/Functional Cookies: Necessary for the App to function correctly (e.g., managing user sessions, login status).

• Analytics Cookies: Used by Google Analytics to collect information about how you use our App, which pages you visit, and your interactions. This helps us improve the App's performance and user experience.

• Marketing/Advertising Cookies (Retargeting): Used to deliver advertisements more relevant to you and your interests, and to measure the effectiveness of advertising campaigns. These cookies remember that you have visited our website and may share this information with other organizations, such as advertisers.

Where required by law (e.g., GDPR), we will obtain your explicit consent for the use of non-essential cookies (Analytics and Marketing/Advertising cookies) through a clear cookie banner or pop-up. You will have the option to accept or decline these cookies.

6. Data Retention

We retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy, including for the purpose of training and improving our AI agents. We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

7. International Data Transfers

As we operate globally and the App owner is located in Florida, USA, your personal data may be processed and stored in countries outside of your country of residence, including the United States, where data protection laws may differ from those in your jurisdiction (e.g., the EEA).

When we transfer personal data outside the EEA, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

• Transferring data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

• Using specific contracts approved by the European Commission which give personal data the same protection it has in Europe (e.g., Standard Contractual Clauses).

• Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Data Privacy Framework (if applicable and valid) or other approved mechanisms.

8. Data Security

The security of your information is important to us. We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. However, remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

9. Your Data Protection Rights (Under GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

You have the following rights:

• The Right to Access: You have the right to request copies of your personal data.

• The Right to Rectification: You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.

• The Right to Erasure ("Right to be Forgotten"): You have the right to request that we erase your personal data, under certain conditions (e.g., when the data is no longer necessary for the purposes for which it was collected).

• The Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data, under certain conditions (e.g., if you contest the accuracy of the data).

• The Right to Object to Processing: You have the right to object to our processing of your personal data, under certain conditions, particularly where the processing is based on legitimate interests or for direct marketing.

• The Right to Data Portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions, in a structured, commonly used, machine-readable format.

• The Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

• The Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority (data protection authority) in your country of residence if you believe your rights have been violated.

To exercise any of these rights, please contact us at admin@attractioncoachapp.com. We may require you to verify your identity before responding to such requests.

10. Children's Privacy

Our Service is not intended for use by individuals under the age of 18 ("Children"). We do not knowingly collect personally identifiable information from Children. If you are a parent or guardian and you are aware that your Child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from Children without verification of parental consent, we take steps to remove that information from our servers.

11. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

12. Contact Us

If you have any questions about this Privacy Policy or your data protection rights, please contact us:

• By email: admin@attractioncoachapp.com

• By visiting this page on our website: https://attractioncoachapp.com/contact-us