Privacy Policy

www.diannwingertcoaching.com

Effective Date: November 1, 2026

Diann Wingert Coaching, LLC (the "Company", "we", "us") respects the privacy of everyone who visits this website (www.diannwingertcoaching.com), uses our services, including our AI digital clone "Di AI", and/or interacts with our coaching programs. This Privacy Policy explains how we collect, use, store, and protect your personal information.

Unfortunately, no data transmission over the Internet is guaranteed to be 100% secure. As such, the Company cannot ensure or warrant the security of any information you transmit via the internet. We maintain the safeguards described under Security Measures below, and nothing in this Privacy Policy limits our legal duties to protect personal information or to notify you of a security breach.

This privacy statement is subject to change by the Company at its discretion; provided that we will provide advance notice of any material changes (Changes to this Privacy Policy). It is your responsibility to review this statement periodically. This Privacy Policy describes our practices. It does not ask you to consent to any optional use of your information, and we will ask separately for any consent the law requires.

1. INFORMATION WE COLLECT

1.1 Website Visitors

When you visit our website, we may collect basic information that does not identify individual users, including: the specific pages visited, the page that referred you to our site, and information about your browser and operating system.

1.2 Personal Information You Provide

Personally identifiable information, such as your name, email address, home address, photographs, and other information, will not be collected unless you willingly and voluntarily submit such information to us. We only collect information from persons 18 years of age or older. When you:

    ◦ Purchase our products or services

    ◦ Register for our programs or downloads

    ◦ Subscribe to our email list or newsletter

    ◦ Submit a contact form or inquiry

    ◦ Access our AI digital clone (Di AI)

We will only store the information you provide in the required fields, and we do not request or intentionally collect sensitive personal information (such as government identifiers, health data, or financial account numbers) through our Website or Di AI. Because Di AI is a conversation, you may choose to mention health conditions, such as ADHD, or other sensitive details in your chats. We use what you share only to respond to you and operate Di AI, and we ask you not to share sensitive details you do not need to share.

1.3 Di AI Digital Clone - Data Collection

Di AI was offered free during a beta phase that ends October 31, 2026. Beginning November 1, 2026, Di AI is available through paid Lifetime access, gifted accounts for coaching clients, and any recurring plan identified at checkout. When you access Di AI, our AI digital clone built on the Coach Vox platform (https://coachvox.ai), we collect:

    ◦ Your name and email address (required for access)

    ◦ Password credentials (optional - only if you choose to create an account to save chat history)

    ◦ The content of your conversations with Di AI

    ◦ Metadata related to your interactions (timestamps, session duration)

    ◦ Technical information (IP address, browser type, device information)

    ◦ Basic usage data necessary for service delivery

    ◦ If you buy or activate access, purchase and activation records such as the access type, amount, date, your acceptance of the Di AI User Agreement, and your choice about marketing emails (Stripe processes your card details)

While Diann technically has access to your Di AI chats, chats are only reviewed for service improvement which includes delivery, security and quality assurance. Diann Wingert and Coach Vox administrators can view conversations, but no one monitors them in real time. Once you set a password, your chats are saved and kept as described under Data Retention below.

1.4 Data Controller Relationship with Coach Vox

IMPORTANT: For Di AI services, data control is shared between Diann Wingert Coaching LLC and Coach Vox Ltd. (the platform provider):

    ◦ Account Data (your name, email, and password if you create one): Diann Wingert Coaching LLC is the sole data controller; Coach Vox acts as a processor on our instructions.

    ◦ Conversation Data (your chats with Di AI): Both Diann Wingert Coaching LLC and Coach Vox are joint controllers. We both determine why and how this data is processed for service delivery, quality assurance, security/abuse prevention, and limited technical improvement, as Coach Vox describes this arrangement in its own privacy policy.

    ◦ Safety Logs (IP addresses, timestamps, abuse flags): Coach Vox controls this data independently for platform security and legal compliance, under its own privacy policy.

    ◦ Your conversations with Di AI may be accessed by Diann Wingert Coaching LLC and, when necessary for technical service delivery or platform security, by Coach Vox administrators. We treat your content as confidential.

You can exercise your data rights (access, correction, deletion, portability, objection) with either Diann Wingert Coaching LLC or Coach Vox, and we will cooperate to ensure your request is addressed; we may request reasonable information to verify your identity and may deny manifestly unfounded or excessive requests as permitted by law. See Contact Information and Exercising Your Rights below.

2. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

• To provide and deliver our coaching services, programs, and products

• To operate Di AI and deliver responses to your queries

• To respond to your inquiries and provide customer support

• To send you information about our products and services (only with your express permission, and you may withdraw consent at any time)

• To enhance your online experience and improve our website

• To prevent fraud and diagnose technical problems

• To comply with legal obligations

• To maintain basic usage statistics necessary for service delivery (not for detailed analytics or training), including aggregated and de-identified metrics that do not identify you.

We will never sell personally identifiable information to third parties, and we do not sell or share personal information for cross-context behavioral advertising as those terms are defined under U.S. state privacy laws. We do not control and are not liable for the actions of any third parties.

IMPORTANT: Email addresses collected through Di AI access are maintained separately from our general marketing email list. If you wish to receive our newsletter, podcast updates, or other marketing communications, you must separately opt in. Accessing Di AI does not automatically subscribe you to marketing emails. Buying Di AI or activating a gifted account does not subscribe you either. You join our marketing list only if you check the optional marketing box, and we keep a record of that choice. We send receipts, activation instructions, billing notices, account and security notices, and necessary service updates whether or not you join the marketing list.

You always have the choice to opt out of receiving future electronic mailings by clicking the "unsubscribe" link at the bottom of any email from us or by contacting us directly.

3. DATA SHARING AND DISCLOSURE

3.1 Service Providers

We share your information with trusted third-party service providers who assist us in operating our business, including:

    ◦ Coach Vox Ltd.: AI platform provider for Di AI, which processes account data on our instructions and acts as a joint controller of conversation data (see Data Controller Relationship with Coach Vox above)

    ◦ Stripe: Payment processing (Stripe handles all payment data; we do not have access to or store credit card information)

    ◦ Email service providers: For sending receipts and account notices and, if you opt in, newsletters and other marketing

    ◦ Analytics providers: For website analytics only

    ◦ Cloud hosting providers: For data storage and infrastructure

Except for Coach Vox’s own uses described above, these service providers are authorized to use your information only as necessary to provide services to us or as required by law.

3.2 Legal Requirements

We may disclose your personally identifiable information when we have a good-faith belief that such disclosure is necessary to identify, contact, or bring legal action against someone who may be causing injury to, or interference with, our rights or property, other users of the site, or anyone else that could be harmed by such activities, or to enforce our Terms and policies. We may also disclose information when required by law or to protect the safety of our users or the public.

3.3 International Data Transfers

Your personal data may be transferred to and stored in countries outside the United States and the European Economic Area (EEA), including the United Kingdom, where Coach Vox is based.

4. DATA SECURITY AND RETENTION

4.1 Security Measures

We implement appropriate technical and organizational security measures designed to protect your personal information from unauthorized access, alteration, disclosure, or destruction and to ensure a level of security appropriate to the risk. For Di AI specifically:

    ◦ Access to user data is restricted to authorized personnel only

    ◦ Coach Vox maintains industry-standard security practices for platform infrastructure

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security and are not responsible for breaches caused by events beyond our reasonable control.

4.2 Data Retention

We retain your information for as long as necessary to provide our services and fulfill the purposes outlined in this Privacy Policy. Specifically:

    ◦ Account information: For as long as your account exists, until you ask us to delete it, or until the law requires us to delete it.

    ◦ Di AI conversation data: Once you set a password, we keep your saved chats indefinitely so you can view, resume, and download them. You cannot delete individual chats yourself. To delete your chats and your account, email support@diannwingertcoaching.com. After we verify your request, we delete them and ask Coach Vox to delete its copies, and copies in backup systems may remain until those backups are overwritten under the platform’s backup practices. Coach Vox’s practices determine how long the platform keeps sessions you do not save. If you cancel a monthly plan, you can no longer view or download your saved chats after your paid month ends, so download any you want to keep before then.

    ◦ Marketing communications data: Until you unsubscribe or request deletion. After you unsubscribe, we keep only your email address and opt-out date so we do not email you again

    ◦ Transaction records: For the period tax and accounting laws require

    ◦ Security logs: Coach Vox maintains minimal security logs as needed for platform protection and legal compliance, under its own retention practices

5. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to enhance your experience on our website, and where required by law we will obtain your consent before setting non-essential cookies. Cookies are small files of information that a website transfers to your computer's hard drive (if your computer allows it) to recognize your browser and capture certain information.

Cookies make using our site easier by saving your preferences; certain cookies and similar technologies may involve the processing of personal data, which we handle in accordance with this Privacy Policy and applicable law. Most browsers are initially set up to accept cookies; however, if you prefer not to receive cookies, you may alter your browser configuration to refuse cookies. If you choose to have your browser refuse cookies, some areas of our site may not function as effectively.

Our website and the Coach Vox platform do not currently respond to Do Not Track signals or similar browser mechanisms. Because we do not sell personal information or use it for targeted advertising, a browser opt-out signal does not change how we handle your information.

Coach Vox may also use cookies and similar technologies for the Di AI platform. You can review Coach Vox's cookie practices at https://coachvox.ai/privacy/.

6. THIRD-PARTY LINKS

Our website may include links to other websites not under our control, and we are not responsible for the privacy or security practices of such websites. These third-party sites may request information from you. The collection and use of your personally identifiable information will be governed by the privacy policy in effect on that third-party site. We do not control the privacy statements, information, and links that may appear on other sites. You are responsible for reviewing the privacy statements of third-party sites before providing any information to them.

7. CHILDREN'S PRIVACY

Our website and services, including Di AI, are intended for persons 18 years of age or older, and we do not knowingly collect personal information from individuals under 18; if you believe a minor has provided information to us, please contact us so we can take appropriate action. We do not knowingly collect personal information from individuals under 18 years of age. If you are under 18, you are not permitted to use this website or our services and must not submit any information under any circumstances. If we become aware that we have collected personal information from someone under 18, we will delete that information immediately.

8. YOUR PRIVACY RIGHTS

8.1 California Residents (CalOPPA)

The California Online Privacy Protection Act (CalOPPA) requires this Privacy Policy to describe how we handle personally identifiable information we collect online from California residents. The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), does not currently apply to us because we do not meet its thresholds. Under CalOPPA, this Privacy Policy discloses the following:

    ◦ Information we collect: your name, email address, and any postal address, photographs, or other details you choose to send us, plus Di AI account credentials, the content of your Di AI conversations, purchase and activation records, and technical information such as your IP address, browser type, and device information. Information We Collect above describes each category.

    ◦ Who we share it with: our AI platform provider (Coach Vox), our payment processor (Stripe), email service providers, analytics providers, cloud hosting providers, and authorities or other parties when the law requires disclosure. Data Sharing and Disclosure above describes each category.

    ◦ Reviewing and changing your information: You can view, resume, and download your saved chats inside Di AI. To review or request changes to any other personally identifiable information we hold about you, email support@diannwingertcoaching.com.

    ◦ Tracking across websites: Third parties, including our analytics providers and Coach Vox, may collect personally identifiable information about your online activities over time and across different websites when you use our website or Di AI.

    ◦ Do Not Track: Cookies and Tracking Technologies above explains how our website responds to Do Not Track signals.

    ◦ Changes and effective date: Changes to this Privacy Policy below explains how we notify you of material changes. The effective date appears at the top of this Privacy Policy.

8.2 Other U.S. State Residents

If you live in Oregon, Colorado, Connecticut, Utah, Virginia, or another U.S. state whose consumer privacy law applies to us, you may have the following rights, subject to applicable statutory exceptions and our ability to verify your request, including:

    ◦ Right to access the personal information we hold about you

    ◦ Right to request deletion of your personal information, subject to legal, security, and operational exceptions (e.g., to complete transactions, detect security incidents, comply with law, or for internal uses reasonably aligned with your expectations)

    ◦ Right to request correction of inaccurate information, taking into account the nature of the data and our purposes for processing it

    ◦ Right to opt out of the sale or targeted advertising (Colorado, Connecticut, Utah, Virginia) and the sharing of personal information for cross‑context behavioral advertising (Colorado, Connecticut, Virginia); however, we do not sell personal information or engage in targeted advertising or cross‑context behavioral advertising as defined by applicable law.

    ◦ Right to data portability in a portable and readily usable format

    ◦ Right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects (Colorado, Connecticut, Virginia); we do not engage in such profiling.

To exercise these rights, contact us using the contact information below; we will take reasonable steps to verify your identity (and authority, if acting as an authorized agent) and respond within 45 days, which we may extend once by an additional 45 days where reasonably necessary and permitted by law. If we deny your request, you may appeal by replying to our decision email, and if your appeal is denied, you may contact your state attorney general.

8.3 European Union and UK Residents (GDPR/UK GDPR)

If you are within the European Union or the United Kingdom, you are entitled to certain information and have certain rights under the EU GDPR and the UK GDPR, subject to applicable exemptions and our ability to verify your identity and authority (where an agent acts on your behalf): 

    ◦ Right of Access: Request access to your personal data that we store

    ◦ Right to Rectification: Request correction of inaccurate or incomplete personal data

    ◦ Right to Erasure: Request deletion of your personal data where one of the grounds in Article 17 applies, subject to statutory exceptions (including compliance with legal obligations and the establishment, exercise, or defense of legal claims)

    ◦ Right to Restriction: Seek restrictions on the processing of your data in the circumstances set out in Article 18 (e.g., contesting accuracy or pending an objection)

    ◦ Right to Object: Object at any time to processing for direct marketing (including profiling) and, where processing is based on legitimate interests, object on grounds relating to your particular situation

    ◦ Right to Data Portability: Receive and transmit to another controller your personal data in a structured, commonly used, and machine‑readable format where processing is based on consent or contract and carried out by automated means

    ◦ Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time 

    ◦ Right to Lodge a Complaint: Lodge a complaint with your local supervisory authority (or the UK ICO, as applicable) if you consider that our processing infringes data protection law

    ◦ Right to Information: We will provide the information required by Articles 13 and 14 and will not condition the provision of services on consent where consent is not the appropriate legal basis

For Di AI services specifically, you can exercise your EU/UK data protection rights with either Diann Wingert Coaching LLC or Coach Vox Ltd. by contacting us at support@diannwingertcoaching.com or Coach Vox at hello@coachvox.com. See Data Controller Relationship with Coach Vox above for details on the joint controller arrangement.

9. CONTACT INFORMATION AND EXERCISING YOUR RIGHTS

If you have any questions or concerns about this Privacy Policy, wish to exercise your privacy rights, or want to update your preferences, please contact us:

Diann Wingert Coaching, LLC

Email: support@diannwingertcoaching.com Website: www.diannwingertcoaching.com 

For matters specifically related to Di AI and the Coach Vox platform: Coach Vox Ltd.

Email: hello@coachvox.com Website: https://coachvox.ai/privacy/ 

10. CAN-SPAM ACT COMPLIANCE

In compliance with the CAN-SPAM Act, all emails sent from our organization clearly state who the email is from and provide clear information on how to contact the sender. All email messages contain concise information on how to unsubscribe from our mailing list so that you receive no further email communications from us.

Users who no longer wish to receive our newsletter or promotional materials may opt out by clicking the unsubscribe link in any email. We honor unsubscribe requests within 10 business days. After you unsubscribe, we send only receipts, account notices, and other messages needed for your purchase or account.

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by:

• Posting the updated policy on our website with a new "Effective Date" 

• Sending an email notification to your registered email address (for material changes)

• Displaying a prominent notice on our website or within Di AI

We encourage you to review this Privacy Policy periodically. Changes to this Privacy Policy do not give us consent to any optional use of your information, and we will ask for that consent separately when the law requires it.

Last Updated: November 1, 2026