Privacy Policy

LAST UPDATED

July 21, 2026

Upper Coaching ("we," "us," or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, store, share, and protect your information when you visit our website, engage in our coaching or consulting services, or interact with us online.

1. INFORMATION WE COLLECT

A. Information You Voluntarily Provide

We collect personal information that you explicitly submit to us when you:

• Register for account access, consultation calls, or coaching programs.

• Fill out contact forms, schedule appointments, or subscribe to newsletters/marketing materials.

• Participate in surveys, webinars, or client assessment tools.

This information may include:

• Contact Data: Name, email address, phone number, and mailing address.

• Billing Data: Account credentials, billing addresses, and payment details (processed securely through PCI-compliant third-party payment processors).

B. Information Collected Automatically

When you access or navigate our website, we automatically log certain technical data. This technical data includes:

• Technical Details: IP address, browser characteristics, device attributes, operating system, language preferences, and referring URLs.

• Usage Data: Pages viewed, links clicked, time spent on site, and operational traffic metrics.

• Tracking Technologies: Information collected via cookies, web beacons, and similar tracking mechanisms.

C. Sensitive Data

We do not intentionally request or process sensitive personal data (e.g., social security numbers, detailed health records, or biometric data) through our public web services.

2. HOW WE PROCESS YOUR INFORMATION

We process your data for legitimate commercial and professional coaching purposes, including:

• Service Delivery: Providing, administering, and fulfilling our coaching programs, consulting engagements, and client agreements.

• Communication: Responding to inquiries, sending operational updates, and providing promotional communications (where permitted).

• Security & Quality Assurance: Preventing fraud, monitoring system integrity, and maintaining network stability.

• Legal Compliance: Complying with applicable legal, accounting, and regulatory requirements.

3. LEGAL BASES FOR PROCESSING (INTERNATIONAL VISITORS)

If you access our website or engage our services from the European Economic Area (EEA), United Kingdom (UK), Canada, or jurisdictions with similar data protection regulations, we process your personal data under the following legal bases:

• Consent: When you have given explicit consent for us to process your data for a specific purpose (such as subscribing to marketing).

• Contractual Necessity: When processing your data is necessary to execute or deliver a coaching contract or agreement.

• Legal Obligations: When required by law to comply with tax, statutory, or regulatory requirements.

• Legitimate Interests: When processing is necessary for our legitimate business operations, such as improving our services, securing our network, or conducting internal analytics.

4. SHARING AND THIRD-PARTY DISCLOSURES

Upper Coaching does not sell, rent, or trade your personal information. We may share your data strictly in the following operational scenarios:

• Service Providers: Trusted third-party vendors who assist with website hosting, cloud storage, payment processing, email communication, scheduling applications, and web analytics.

• Business Operations & Affiliates: Parent entities, subsidiaries, or joint-venture partners operating under equivalent privacy practices.

• Business Transfers: In connection with or during negotiations of any corporate merger, acquisition, financing, or sale of business assets.

• Legal Requirements: When required by law, court order, or governmental authorities to protect our legal rights, property, or safety.

5. INTERNATIONAL DATA TRANSFERS

Our primary operations and servers are located in the United States. If you access our services from outside the United States, your information will be transferred to, stored, and processed in our U.S. facilities or those of our third-party service providers. We take all necessary steps to ensure your data is adequately protected in accordance with applicable privacy laws.

6. DATA SECURITY & RETENTION

Security Measures

We implement appropriate technical and organizational safeguards—including standard data encryption, restricted server access, regular security monitoring, and internal access controls—to protect your personal data against unauthorized access or disclosure.

Retention Period

We retain personal data only as long as necessary to fulfill the purposes outlined in this notice, for up to 60 months, unless a longer retention period is required by law (such as for tax or legal record-keeping). Once no longer required, data is safely deleted, anonymized, or securely isolated.

7. DO-NOT-TRACK (DNT) & COOKIES

• Do-Not-Track Signals: Most web browsers offer a "Do-Not-Track" (DNT) browser setting. Because a uniform technical standard for DNT implementation has not been universally finalized, our systems do not currently respond to automated DNT browser signals.

• Cookies: You can adjust cookie preferences and track opt-outs at any time directly through your individual web browser settings.

8. MINORS & PRIVACY

Our services are strictly intended for individuals aged 18 or older. We do not knowingly solicit or collect data from children under 18. If we discover that personal data from a minor has been collected, we will deactivate the account and delete the data promptly.

9. YOUR PRIVACY RIGHTS & CHOICES

Depending on where you reside (including California, the EU, UK, and other jurisdictions), you may hold specific rights regarding your personal data:

• Account Updates & Deletion: You can review, update, or request the deletion of your account data by contacting us.

• Marketing Opt-Out: You may unsubscribe from marketing emails at any time by selecting the "Unsubscribe" or "Opt-Out" link in any promotional message.

• California Residents ("Shine the Light" & CCPA): California residents may request information regarding categories of personal information shared with third parties, as well as request the specific deletion or access to collected data.

10. UPDATES TO THIS NOTICE

We may update this Privacy Policy periodically to stay compliant with relevant legal and operational requirements. The updated date at the top of this document indicates when changes take effect.

11. CONTACT US

If you have questions, privacy requests, or concerns regarding this policy, please contact us at:

• Email: contact@uppercoaching.org

• Contact Form: Directly via our contact page on the website