Last Updated: 01 January  2025

WITY Coaching & Training (“WITY”, “we”, “us”, “our”) respects your privacy and is committed to protecting it. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our website, the WITY App (mobile application), online learning environments, coaching and training services, community spaces (including WhatsApp groups), and any other services or content we provide (collectively, the “Platform” or “Services”).

By accessing or using our Services, you acknowledge you have read and understood this Privacy Policy. If you do not agree, please do not use the Services.

We may update this Privacy Policy from time to time. We will post the updated version with a revised “Last Updated” date. Continued use of the Services after changes means you accept the updated Policy.

This Policy forms part of our Terms & Conditions.

1) Who we are / Contact

Controller: WITY Coaching & Training

Registered location: Colorado, USA

Support & privacy contact: wecare@wity.tech

2) Information we collect

We collect two broad categories of information: Personal Information (data that identifies you or could reasonably identify you) and Non-Personal Information (data that does not identify you directly).

a) Information you provide directly

• Contact details (e.g., name, email, phone number, country/region).
• Account details and credentials you create on our Platform or App.
• Billing information and purchase history when you buy Services.
• Coaching intake forms, questionnaires, scheduling information, and communications with us (including email, chat, surveys, or support requests).
• Content you choose to share in community spaces or live sessions (text, images, recordings).
• If you provide Personal Information about another person, you confirm you have authority to do so and to allow us to use it as described here.

b) Information from third parties

• Payment processors, scheduling tools, analytics providers, advertising and marketing partners, social media platforms, event hosts, and other vendors may provide us information about you consistent with law and your settings/consents with them.

c) Information collected automatically

• Usage data, device identifiers, IP address, browser type, operating system, referring/exit pages, timestamps, page views, approximate geolocation, App interactions, crash logs, and similar technical data.
• We use cookies, SDKs, pixels, and similar technologies on our website and in the App. See our Cookies Policy for details and choices.

3) How we use your information (purposes + legal bases)

We use your Personal Information to:

• Provide and improve the Services: deliver coaching and training; operate the App and learning environments; personalize content; maintain security; troubleshoot; perform analytics; develop new features. (Legal bases: contract, legitimate interests; consent where required.)
• Customer support and communications: respond to enquiries; send service notices (e.g., policy updates, security alerts, session reminders); manage your account and bookings. (Contract, legitimate interests.)
• Business operations: billing, accounting, audits, preventing fraud and abuse, enforcing Terms, and protecting our legal rights. (Legal obligation, legitimate interests.)
• Marketing and newsletters: send you news, offers, and event information in accordance with your preferences. You can opt out at any time. (Consent or legitimate interests, as applicable.)
• Research and statistics: aggregate, de-identify and analyse usage to improve user experience and performance. (Legitimate interests.)

AI/ML notice: We do not retain your Personal Information to train general-purpose AI models. Where we use analytics or assistive tooling, data handling follows this Policy and our vendor agreements.

EEA/UK legal bases (if applicable)

Where GDPR/UK GDPR applies, we process data under: contract, legitimate interests, consent, and legal obligation. If we rely on consent, you may withdraw it at any time (this won’t affect prior lawful processing).

Retention

We retain Personal Information only as long as necessary for the purposes described (and to meet legal, accounting, or reporting requirements). We may anonymise data for research/statistics and use it indefinitely in non-identifiable form.

4) How we protect your information

We implement reasonable administrative, technical, and organisational measures to protect Personal Information against unauthorised access, disclosure, alteration, or destruction. No method of transmission or storage is 100% secure. If you believe your account has been compromised, contact us immediately at wecare@wity.tech.

5) Sharing your information

We do not sell Personal Information for money. We may share Personal Information with:

• Service providers / processors (e.g., hosting, cloud storage, email/SMS tools, analytics, scheduling, payment processing, video platforms) under contracts that limit their use to our instructions and require appropriate safeguards.
• Community and third-party platforms you choose to connect (e.g., WhatsApp groups, video hosts). Their terms and privacy policies apply.
• Professional advisors and authorities where required by law, to protect safety, rights, or comply with legal processes.
• Corporate transactions (e.g., merger, acquisition). Your data may transfer as part of the deal, subject to this Policy.
• With your consent or at your direction.

SMS/phone data: We do not share your SMS opt-in consent or phone number with third parties for their own marketing uses without your explicit consent. Text message originator opt-in data and consent will not be shared except with providers necessary to deliver the messaging service.

We may share aggregated/de-identified information for analytics and improvements.

6) Children’s privacy

Our Services are not directed to children under 16. We do not knowingly collect Personal Information from children under 16 (or a lower age permitted by local law, e.g., 13 under COPPA). If you believe we have collected such data, contact us and we will delete it.

7) Links and third-party services

Our Platform may link to third-party websites, apps, or services. Their privacy practices are independent of WITY. Review their policies before providing data. We are not responsible for third-party content or practices.

8) Do Not Track

Some browsers offer “Do Not Track” (DNT) signals. Our Sites and App currently do not respond to DNT signals. You can control cookies via your browser/device settings and our Cookies preference tools.

9) Your choices & rights

You can:

• Update preferences or unsubscribe from marketing via links in emails or by contacting wecare@wity.tech.
• Access, correct, or delete certain Personal Information (subject to legal exceptions).
• Object or restrict certain processing, or withdraw consent where processing is based on consent.
• Data portability (where applicable).

We will respond in accordance with applicable laws. We may need to verify your identity before actioning a request and may retain limited data as required by law or for legitimate purposes (e.g., billing records).

10) International transfers

We operate from the United States (Colorado). If you are outside the US, your data may be transferred to and processed in the US and other countries with different data protection standards. Where required (e.g., EEA/UK/Switzerland), we use appropriate safeguards such as Standard Contractual Clauses (SCCs) and supplementary measures to protect your Personal Information.

11) State/Regional privacy disclosures

California (CCPA/CPRA)

California residents have rights to: know/access, correct, delete, and opt-out of “sharing” for cross-context behavioural advertising; and to non-discrimination. We do not sell Personal Information. To exercise rights, contact wecare@wity.tech. If you use an authorised agent, we may request proof of authorisation and verification of your identity.

Categories collected in the last 12 months (examples): identifiers (name, email, IP), commercial information (purchases), internet activity (usage/analytics), and inferences (preferences). We retain data as outlined in Section 3 (Retention).

Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Virginia (VCDPA)

Residents of these states may have rights to access, correct, delete, data portability, and to opt-out of targeted advertising or certain profiling. To exercise rights or appeal a decision, contact wecare@wity.tech. We will verify requests as required by law.

EEA/UK/Swiss (GDPR/UK GDPR/nFADP)

See Sections 3, 9 and 10 for your rights, legal bases, and transfer safeguards. You may lodge a complaint with your local supervisory authority, but we encourage you to contact us first.

12) WITY App – additional privacy details

When you use the WITY App, we may process: device identifiers, app usage events, crash logs, notifications preferences, and data you input into planner tools or exercises. We use this to deliver features, synchronise content, troubleshoot, secure your account, and improve the App. App store providers (Apple/Google) have their own terms and privacy policies that also apply.

13) Community and live sessions

If you participate in group coaching, constellation workshops, masterminds, or community groups, you may share personal or sensitive information with other participants. We ask all participants to maintain confidentiality; however, we cannot guarantee others’ actions. Please share thoughtfully.

14) Security of payments

Payments are processed by third-party processors (e.g., Stripe, app stores). We do not store full payment card numbers. Payment providers’ privacy and security terms apply.

15) How to contact us

Questions, requests, or complaints about this Privacy Policy or our data practices:

Email: wecare@wity.tech

We aim to respond within a reasonable timeframe and in accordance with applicable law.

Acceptance: By using our Services or App, you consent to the practices described in this Privacy Policy.