1. Scope and Applicability

 

This Privacy Policy governs the collection, processing, storage, use, disclosure, and protection of Personal Information by Evolutionary Mindset Coaching LLC (“Company,” “we,” “us,” or “our”) in connection with:

 

• Corporate consulting engagements

• Executive coaching services

• Leadership intensives and training programs

• Enterprise wellness initiatives

• Speaking engagements

• Digital products and memberships

• Website interactions

 

This Policy applies to individual clients, corporate clients, employees of corporate clients, and website users.

 

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2. Definitions

 

“Personal Information” means information that identifies, relates to, describes, or could reasonably be linked to an identifiable individual.

 

“Corporate Client Data” means information provided to the Company by or on behalf of a corporate client in connection with contracted services.

 

“Sensitive Information” includes information relating to mental health disclosures, behavioral assessments, executive function evaluations, trauma-related discussions, or other high-sensitivity personal disclosures voluntarily provided during coaching engagements.

 

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3. Categories of Information Collected

 

A. Identification and Contact Data

 

• Name

• Email address

• Telephone number

• Business title and employer

• Billing and invoicing information

 

B. Enterprise and Organizational Data

 

• Organizational assessments

• Leadership performance metrics

• Survey and diagnostic results

• Cultural performance reports

• Aggregate behavioral analytics

 

C. Coaching and Program Data

 

• Self-reported psychological or behavioral information

• Executive function assessments

• Identity and leadership development materials

• Session notes maintained by the Company

 

D. Technical and Usage Data

 

• IP address

• Browser and device metadata

• Access logs

• Website analytics

 

We do not sell Personal Information.

 

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4. Role of the Company

 

Depending on the engagement structure, the Company may operate as:

 

• An independent Data Controller with respect to direct client engagements

• A Data Processor acting on behalf of a Corporate Client under a services agreement

 

In processor relationships, we process data strictly pursuant to contractual instructions and applicable law.

 

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5. Purpose of Processing

 

We process Personal Information for the following legitimate business purposes:

 

• Delivery of contracted services

• Executive performance analysis and coaching

• Enterprise leadership development

• Organizational diagnostic reporting

• Payment processing and contract administration

• Risk mitigation and security monitoring

• Legal compliance

 

Processing is limited to what is necessary to fulfill contractual obligations.

 

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6. Confidentiality and Enterprise Safeguards

 

Individual Coaching Confidentiality

 

All individual coaching sessions are treated as confidential. Personal disclosures are not shared with employers without explicit written consent, except where required by law.

 

Enterprise Reporting

 

Where coaching is sponsored by an employer:

 

• Attendance confirmation may be reported

• Aggregate progress metrics may be shared

• No personal disclosures, mental health content, or sensitive personal narratives will be shared without explicit consent

 

Legal Exceptions

 

Confidentiality may be breached only if:

 

• Required by subpoena, court order, or applicable law

• There is credible risk of imminent harm to self or others

 

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7. Data Security and Safeguards

 

The Company implements reasonable administrative, physical, and technical safeguards, including:

 

• Encrypted communication where feasible

• Secure cloud-based storage platforms

• Role-based access controls

• Limited internal access to Sensitive Information

• Vendor due diligence for third-party processors

 

No method of transmission or storage is guaranteed to be fully secure. Clients acknowledge inherent cybersecurity risks.

 

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8. Data Retention

 

We retain Personal Information only as long as reasonably necessary to:

 

• Fulfill contractual obligations

• Maintain business records

• Comply with regulatory and legal requirements

• Defend against legal claims

 

Corporate Client Data retention periods may be governed by enterprise agreements.

 

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9. Data Sharing and Subprocessors

 

We may engage trusted third-party service providers for:

 

• Payment processing

• Scheduling systems

• Analytics services

• Secure hosting

• Administrative support

 

All subprocessors are contractually required to maintain confidentiality and implement reasonable data protection measures.

 

We do not sell or rent Personal Information to third parties.

 

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10. Cross-Border Data Transfers

 

If services involve cross-border data transfers, such transfers will be conducted in compliance with applicable data protection laws and contractual safeguards.

 

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11. Data Subject Rights

 

Where applicable under law, individuals may request:

 

• Access to Personal Information

• Correction of inaccuracies

• Deletion, subject to legal retention requirements

• Restriction of processing

• Objection to processing

• Withdrawal of consent

 

Requests may be submitted to:

[Insert Enterprise Contact Email]

 

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12. Limitation of Liability

 

To the maximum extent permitted by law:

 

• The Company shall not be liable for indirect, incidental, or consequential damages arising from unauthorized access beyond reasonable control.

• The Company’s liability shall be limited in accordance with the governing services agreement.

 

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13. Regulatory Compliance

 

We design our data practices to align with:

 

• Applicable U.S. federal and state privacy laws

• California Consumer Privacy Act (CCPA) where applicable

• General Data Protection Regulation (GDPR) principles where applicable

 

Specific contractual addenda may apply for enterprise clients requiring additional compliance frameworks.

 

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14. Policy Modifications

 

We reserve the right to update this Privacy Policy. Updates will be communicated via website posting or enterprise notification where contractually required.

 

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15. Contact Information

 

Evolutionary Mindset Coaching LLC

4 leesburg court, Mount Sinai, NY, 11766

Evolutinarymindsetcoach@gmail.com

631-335-3046