Privacy Policy

Effective Date: September 5, 2025

Thank you for visiting kapwacc.com (the “Website”). Your privacy matters to us. This Privacy Policy (the “Policy”) explains how Kapwa Coaching & Consulting, LLC (“Kapwa,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards information in connection with our Website, programs, digital content, and related features, materials, and services (collectively, the “Services”).

Quick summary (not a substitute for the full Policy): We collect the information you provide (like contact details and intake form responses), information gathered automatically (like device and usage data), and information from partners (like payment and scheduling providers). We use it to deliver and improve our Services, communicate with you, personalize your experience, process payments, market responsibly, and meet legal obligations. You control certain choices (email/SMS preferences, cookies, and targeted advertising opt‑outs). We do not sell your data in the traditional sense; where the law treats certain advertising/analytics as a “sale” or “share,” you may opt out.

1) Scope & Acceptance

This Policy applies to information collected on or through the Services and to our electronic communications (e.g., email, SMS). By accessing or using the Services, you agree to this Policy. If you do not agree, please discontinue use. We may update this Policy from time to time; material changes will be posted here and, when appropriate, notified via the Services or email.

2) Information We Collect

a) Information You Provide

Contact & Account Data (e.g., name, email, phone, address, password).

Coaching Intake & Questionnaires (e.g., goals, self‑assessments, scheduling preferences, program selections). Do not submit confidential medical information or protected health information (PHI) unless we request it for a specific purpose with appropriate safeguards.

Communications & Support (e.g., emails, messages, call notes).

Transactions (e.g., purchases, billing, shipping, last four digits of card; full payment details are handled by our payment processor).

User Content you post or submit (e.g., community forums, testimonials). Content you choose to make public can be read, collected, and used by others.

b) Information Collected Automatically

Usage & Activity Data (pages viewed, clicks, features used, session duration).

Device & Network Data (IP address, browser type/version, operating system, device identifiers, language settings).

Approximate Location (derived from IP or device settings where enabled).

Cookies/Similar Technologies (see Section 7).

c) Information From Third Parties

Payments via Stripe (limited payment metadata returned to us; we do not store full card numbers).

Email/SMS via Mailgun and Twilio (contact details, deliverability and engagement metrics).

Marketing & CRM via GoHighLevel (GHL) (lead forms, funnels, tags, campaign performance) and advertising platforms (e.g., Google, Meta).

Scheduling/Pathways via tools we use to deliver programs (e.g., calendar/scheduling, learning/coaching platforms such as Quenza). We receive data necessary to operate your program (e.g., activity completions, progress).

3) How We Use Information

We use information to:

Provide, operate, and secure the Services; process payments; fulfill purchases; verify identity; provide customer support.

Deliver coaching programs, activities, and content; personalize experiences; maintain continuity of care between sessions.

Communicate about accounts, transactions, program updates, policy changes, and marketing (you can opt out of marketing at any time).

Analyze and improve the Services; develop new features; run surveys and research; measure campaign performance.

Detect, prevent, and investigate fraud, abuse, security incidents, and other harmful activity.

Comply with legal, regulatory, and contractual requirements; enforce terms; protect our rights and users.

We may aggregate or de‑identify information so it no longer reasonably identifies you; we may use and share such information for any lawful purpose.

4) How We Share Information

We share information as follows:

Service Providers/Processors who perform services for us under written contracts (e.g., hosting, analytics, email/SMS delivery, payments, scheduling, coaching platforms, CRM/marketing, customer support). They must use data only per our instructions.

Advertising/Analytics Partners (e.g., Google Analytics, Google Ads, Meta pixel) to measure usage and deliver relevant content. Some laws may treat certain analytics/ads as a “sale” or “share” of personal information. See Section 8 (Your Choices) to opt out.

Business Transfers in the event of a merger, acquisition, financing, or sale of assets.

Legal/Compliance to comply with law, enforce our terms, or protect rights, safety, and security.

With Your Direction/Consent (e.g., posting a testimonial, connecting an account, referrals).

We do not sell personal information for money. We do not share sensitive categories (e.g., precise geolocation, account log‑in credentials) for cross‑context behavioral advertising.

5) Special Notes on Coaching Data & HIPAA

Kapwa provides coaching and educational services, not clinical care. We are not a covered entity under HIPAA and our Services are not intended to store or process PHI. Do not submit PHI via forms, email, SMS, chat, or uploads. If we collaborate with a covered entity, that relationship will be governed by separate terms (e.g., a BAA) where required.

6) Data Retention

We retain personal information for as long as necessary to provide the Services, comply with legal obligations (e.g., tax, accounting), resolve disputes, and enforce agreements, then delete or de‑identify it according to our retention practices.

7) Cookies & Similar Technologies

We use cookies, pixels, SDKs, and local storage to enable core functionality, remember preferences, analyze usage, and support marketing. You can manage cookies through your browser settings and device controls. Blocking cookies may impact some features. See Section 8 for advertising choices.

8) Your Choices & Rights

Email/SMS Marketing: Unsubscribe via links in messages or reply STOP to SMS.

Cookies/Interest‑Based Ads: Use browser/device settings and industry tools (e.g., Digital Advertising Alliance at AboutAds.info, NAI opt‑out). Platform‑specific tools: Google Ad Settings; Meta Ad Preferences.

Analytics: Use tools such as the Google Analytics opt‑out browser add‑on.

Access/Correction/Deletion: Contact us (Section 12) to request access, correction, or deletion of your personal information, subject to legal exceptions and verification.

“Do Not Sell or Share” (California/CPRA): California residents may opt out of “sale”/“sharing” for cross‑context behavioral advertising. If we recognize a Global Privacy Control (GPC) signal from your browser, we will treat it as a request to opt out for that browser/device.

State‑specific rights (e.g., CA, CO, CT, UT, VA) may include the rights to know/access, correct, delete, obtain a portable copy, and opt out of targeted advertising, sale, or profiling. We will not discriminate for exercising rights.

9) Children’s Privacy

The Services are not directed to children under 18, and we do not knowingly collect personal information from children under 18. If you believe a child has provided personal information to us, contact us and we will take appropriate steps to delete it. Our programming is intended for adults (18+) unless otherwise expressly authorized by a parent/guardian and institution.

10) Security

We implement administrative, technical, and physical safeguards designed to protect personal information (e.g., HTTPS, encryption in transit where applicable, access controls). However, no system is 100% secure. Use caution when transmitting information online and keep your passwords confidential.

11) International Users

If you access the Services from outside the United States, you understand your information may be processed in the U.S. and other countries with different data protection laws. Where required, we rely on appropriate safeguards for cross‑border transfers.

12) Contact Us

Kapwa Coaching & Consulting, LLC
Privacy Inquiries: [email protected]

13) Additional Disclosures by Service/Category

Payments: Processed by Stripe per its privacy policy. We receive limited payment metadata and order details. We do not store full card numbers.

Email/SMS: Delivered via Mailgun/Twilio; we maintain logs necessary for deliverability and compliance (e.g., opt‑in/opt‑out).

Analytics/Ads: Google Analytics, Google Ads, Meta pixel for measurement and advertising. Configure preferences per Section 8.

CRM/Marketing: GoHighLevel supports forms, funnels, event tracking, and automations used to deliver programs and communications.

Program Delivery: We may use Quenza or similar platforms to deliver activities, track progress, and support continuity between sessions.

14) Links & Third‑Party Services

The Services may link to third‑party websites, apps, or features. Their privacy practices are governed by their policies; we are not responsible for their content or practices. Review their policies before using those services.

15) Changes to This Policy

The “Effective Date” above reflects the latest revision. We will post updates on this page and, if changes are material, provide additional notice (e.g., email or in‑Service notice). Your continued use of the Services after changes take effect constitutes acceptance.

16) Indiana & U.S. State Privacy Law Disclosures (Compliance Addendum)

This section summarizes additional disclosures and commitments intended to align this Policy with U.S. privacy laws applicable to Kapwa, including the California Consumer Privacy Act (as amended by the CPRA) and the Indiana Consumer Data Protection Act (INCDPA) (effective January 1, 2026). Where state laws differ, we apply the applicable law to its residents.

16.1 Consumer Rights & Response Timelines

You may have the rights to access, correct, delete, obtain a portable copy of your personal information, and opt out of certain processing (see 16.2). We will respond to verifiable requests within 45 days (with one 45‑day extension where reasonably necessary and we notify you). If we deny a request, we will explain why and provide instructions to appeal. We will respond to appeals within 60 days and, if we deny an appeal, we will provide a method to contact the appropriate state Attorney General.

16.2 Opt‑Outs (Sale, Targeted Advertising, Profiling)

You may opt out of: (a) the sale of personal information (as defined by applicable law), (b) targeted advertising, and (c) profiling in furtherance of decisions that produce legal or similarly significant effects. Kapwa does not sell personal information for money. Where targeted advertising/analytics could be deemed a “sale” or “share,” we provide opt‑outs. Indiana law does not currently require recognition of browser‑based Global Privacy Control (GPC) signals; however, we may voluntarily honor such signals where feasible.

16.3 Sensitive Data & Minors

We will obtain consent before processing sensitive personal data where required. For children under 13, we comply with COPPA and do not knowingly collect data without verifiable parental consent.

16.4 Privacy Notice Content

Our privacy notice includes: categories of data processed; purposes; categories of third parties with whom we share personal data; how to exercise rights (including appeals); and contact details.

16.5 Processor Contracts (DPAs)

We maintain written data processing agreements with service providers/processors that process personal information on our behalf, requiring confidentiality, security, and processing only per our instructions.

16.6 Data Protection Assessments (INCDPA)

Where required (e.g., targeted advertising, “sale,” sensitive data, certain profiling, or other high‑risk processing), Kapwa will conduct data protection assessments for processing activities occurring after December 31, 2025.

16.7 Indiana Data Breach Notifications

In the event of a data security incident involving Indiana residents, we will provide notices without unreasonable delay and no later than 45 days where required by law, and provide any required notices to the Indiana Attorney General and/or consumer reporting agencies (if thresholds are met) consistent with IC 24‑4.9. Law‑enforcement delays may apply.

16.8 How to Submit Requests

Use our Privacy Request form (kapwacc.com/privacy‑request) or email [email protected]. For Indiana residents, appeals can be submitted to the same contact. If your appeal is denied, you may contact the Indiana Attorney General.

17) Your California Privacy Rights (CPRA)

California residents have additional rights, including to limit the use/disclosure of sensitive personal information and to opt out of “sharing” for cross‑context behavioral advertising. We provide a “Do Not Sell or Share My Personal Information” link where required. We recognize GPC signals for California users where required by law.

18) Contact & Controller

Controller: Kapwa Coaching & Consulting, LLC
Email: [email protected]

Last updated: September 5, 2025