Privacy & GDPR Policy
Last Updated: 24th May 2025
1. Introduction
Welcome to AIPractice.Coach from Scruffy Leadership ("we," "us," or "our"). We are committed to protecting your privacy and handling your personal data in an open and transparent manner. This Privacy & GDPR Policy explains how we collect, use, disclose, and safeguard your information when you use our website and services (collectively, the "Service").
Please read this policy carefully. If you do not agree with the terms of this privacy policy, please do not access the Service.
2. Data Controller
The data controller for your personal data is:
Ben Coppin
5a Barton Road, Ely, CB7 4HZ
scruffyleadership@gmail.com
3. Information We Collect
We may collect information about you in a variety of ways. The information we may collect via the Service includes:
- Personal Data: Personally identifiable information, such as your username, email address, and password hash that you voluntarily give to us when you register with the Service.
- Usage Data: Information your browser automatically sends whenever you visit our Service or when you access the Service by or through a mobile device. This may include your IP address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.
- Interaction Data: This includes the content of your interactions with the AI coachees, such as the prompts you provide and the responses generated. We also collect data on the number of interactions you have used.
- Subscription Data: If you subscribe to a paid tier, we will collect information necessary to process your subscription, though payment processing itself may be handled by a third-party payment processor. We do not store your full credit card details. Payment is processed by [Payment Processor Name]
- Cookies and Tracking Technologies: We may use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
4. How We Use Your Information
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Service to:
- Create and manage your account.
- Provide the coaching practice service, including generating AI responses.
- Provide feedback features based on your interactions.
- Process your subscriptions and deliver related services.
- Monitor and analyze usage and trends to improve your experience with the Service.
- Notify you about changes to our Service.
- Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
- Respond to your customer service requests.
- Comply with legal and regulatory requirements.
5. Legal Basis for Processing Your Personal Data (GDPR)
If you are from the European Economic Area (EEA), our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
- Performance of a contract: To provide you with our Service, including account management, processing subscriptions, and delivering the core functionalities of the coaching tool.
- Consent: You have given us permission to do so (e.g., for optional cookies, or specific data uses you opt into).
- Legitimate interests: Processing is necessary for our legitimate interests, such as improving our Service, fraud prevention, and for administrative or legal purposes, and these interests are not overridden by your data protection rights.
- Legal obligation: To comply with the law.
6. Data Retention
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Account data will be retained as long as your account is active, and for a period of 2 years thereafter for legal/archival purposes. Interaction data may be anonymized and retained for model improvement indefinitely.
7. Data Security
We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.
8. 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.
- The right to access, update or delete the information we have on you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.
- The right to lodge a complaint with a Data Protection Authority.
To exercise these rights, please contact us at scruffyleadership@gmail.com
9. Cookies
Cookies are small files stored on your device (computer or mobile device). We use cookies to manage user sessions and to remember user preferences.
10. Third-Party Services
We use [Payment Processor Name] to handle subscription payments. Their privacy policy can be found at [link].
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 "Last Updated" 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, please contact us:
By email: scruffyleadership@gmail.com