This Privacy Policy (this "Policy") is issued by Sagatica Global, Inc., a California corporation with its principal place of business at 8740 Blue Lake Drive, Suite A, San Diego, CA 92119 (hereinafter referred to as "SagatiCoach", "we", "us", or "our"). This Policy governs the manner in which we collect, use, maintain, and disclose information collected from users (each, a "User" or "you") of the SagatiCoach platform (the "Platform").
PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CREATING AN ACCOUNT ON THE SAGATICOACH PLATFORM OR BY ACCESSING OR USING ANY PART OF THE PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THE DATA PRACTICES DESCRIBED IN THIS POLICY. IF YOU DO NOT AGREE WITH THIS POLICY, YOU MUST NOT CREATE AN ACCOUNT OR USE THE PLATFORM.
YOUR CONTINUED USE OF THE PLATFORM FOLLOWING THE CREATION OF YOUR ACCOUNT OR FOLLOWING ANY NOTICE OF CHANGES TO THIS POLICY CONSTITUTES YOUR ONGOING ACCEPTANCE OF AND CONSENT TO THE DATA PRACTICES DESCRIBED IN THIS POLICY IN ITS CURRENT FORM.
ARTICLE 1: OUR COMMITMENT TO PRIVACY
Sagatica Global, Inc. is committed to protecting the privacy and security of our Users' personal information. This Policy has been designed to provide clear and transparent information about the types of data we collect, the purposes for which we use that data, the circumstances in which we may share that data, and the rights available to you in relation to your personal data. We are committed to complying with all applicable privacy laws, including the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act of 2020 (CPRA), and we have designed our data practices with these obligations in mind.
We recognise that the SagatiCoach Platform processes sensitive personal information, including information shared in the context of a coaching relationship. We take our responsibility to handle this information with care and discretion extremely seriously, and we have implemented appropriate technical and organisational measures to protect your data.
ARTICLE 2: INFORMATION WE COLLECT
We collect personal information from Users in a variety of ways and from a variety of sources. The categories of personal information we collect are described below.
2.1. Information You Provide Directly.
When you create an account on the Platform, we collect personal identification information including your name, email address, and any other information you choose to provide in connection with your account registration. When you use the Platform, you may also provide us with Client Content or Coach Content, which may include notes, progress entries, experiment logs, session observations, and other information you choose to record on the Platform.
2.2. Session Transcripts.
All coaching sessions conducted on or through the Platform, including sessions conducted via integrated third-party video conferencing tools such as Zoom, are automatically recorded and transcribed. The resulting Session Transcripts are stored by SagatiCoach and constitute personal information for the purposes of this Policy.
2.3. AI-Generated Data.
The Platform uses AI Systems to automatically analyze Platform Data, including Session Transcripts and User-generated content, to generate insights, progress scores, key wins, areas for development, and other analytical content. This AI-Generated Content is stored by SagatiCoach and constitutes personal information for the purposes of this Policy.
2.4. Technical and Usage Information.
When you access and use the Platform, we automatically collect certain technical and usage information, including your IP address, browser type and version, operating system, device information, pages visited, features used, and other information about how you interact with the Platform.
2.5. Communications.
If you contact us directly, we may collect and retain records of your communications with us, including the content of your messages and any attachments.
The categories of personal information we collect can be summarised as follows:
| Category | Examples | Collected |
|---|---|---|
| Identifiers | Name, email address, account username | Yes |
| Personal records | Contact details, account information | Yes |
| Protected characteristics | Age (to verify eligibility) | Yes |
| Commercial information | Account activity, feature usage | Yes |
| Internet or network activity | IP address, browser type, pages visited | Yes |
| Audio, electronic, visual information | Session recordings and transcripts | Yes |
| Professional or employment-related information | Coaching notes, progress records | Yes |
| Inferences drawn from personal information | AI-generated progress scores and insights | Yes |
ARTICLE 3: HOW WE USE COLLECTED INFORMATION
We use the personal information we collect for the following purposes.
3.1. Providing and Operating the Platform.
We use your personal information to provide you with access to the Platform and its features, to process your account registration, to authenticate your identity when you log in, to facilitate coaching sessions between Coaches and Clients, and to operate and maintain the Platform in accordance with this Policy and our User Agreements.
3.2. AI-Powered Analysis and Insights.
We use your personal information, including Session Transcripts and User-generated content, to power the AI Systems that generate insights, progress scores, key wins, areas for development, and other AI-Generated Content. This analysis is a core feature of the Platform and is conducted automatically by the AI Systems. By using the Platform, you consent to this analysis as described in your applicable User Agreement.
3.3. Improving and Developing the Platform.
We may use anonymised and de-identified data derived from your personal information to improve the Platform, to develop new features and functionality, and to train and improve the AI Systems. We will not use your personal information for this purpose without first anonymising and de-identifying it such that it cannot reasonably be used to identify you.
3.4. Customer Support.
We use your personal information to respond to your enquiries and support requests, to investigate and resolve complaints, and to communicate with you about your account and your use of the Platform.
3.5. Legal and Compliance Purposes.
We may use your personal information to comply with applicable laws and regulations, to respond to legal process, to enforce our User Agreements and this Policy, to protect the rights, property, and safety of SagatiCoach, our Users, and the public, and to detect, prevent, and investigate fraud, security breaches, and other potentially unlawful activities.
3.6. Communications.
We may use your email address to send you administrative communications relating to your account, including account verification emails, security alerts, and notifications of changes to this Policy or our User Agreements. We will not send you marketing communications without your prior consent.
ARTICLE 4: HOW WE SHARE YOUR PERSONAL INFORMATION
We do not sell, trade, or rent your personal information to third parties for their own marketing purposes. We may share your personal information in the following limited circumstances.
4.1. Between Coaches and Clients.
The Platform is designed to facilitate a coaching relationship between Coaches and Clients. In this context, certain information is shared between Coaches and their Clients through the Platform. Specifically, AI-Generated Content relating to a Client's progress, including progress scores, insights, key wins, and areas for development, is visible to both the Client and their Coach. A Client's private notes are not directly accessible to their Coach, although the content of those notes may contribute to AI-Generated Content that is visible to the Coach. A Coach's session notes and coaching records are not accessible to their Clients.
4.2. Third-Party Service Providers.
We may share your personal information with third-party service providers who assist us in operating the Platform and delivering our services. These providers are contractually bound to use your personal information only for the purposes for which it was shared and in accordance with this Policy. Our key third-party service providers include:
| Service Provider | Purpose | Data Shared |
|---|---|---|
| OpenAI | Powering the AI Systems | Platform Data (processed on a closed-loop basis; not retained by the provider) |
| Zoom Video Communications, Inc. | Video conferencing for coaching sessions | Session audio and video (subject to Zoom's own privacy policy) |
| Supabase | Database hosting and storage | All Platform Data |
| Postmark | Transactional email delivery | Name and email address |
| DigitalOcean | Cloud infrastructure and hosting | All Platform Data |
4.3. SagatiCoach Administrative Access.
Senior qualified executives of SagatiCoach may have access to Platform Data, including Session Transcripts and User-generated content, for the limited purposes of technical platform maintenance, quality assurance, and legal compliance. Access is restricted to those individuals who require it for these specific purposes and is subject to strict confidentiality obligations.
4.4. Legal Requirements.
We may disclose your personal information if we are required to do so by law, regulation, court order, or other legal process, or if we believe in good faith that such disclosure is necessary to protect the rights, property, or safety of SagatiCoach, our Users, or the public.
4.5. Business Transfers.
In the event of a merger, acquisition, reorganisation, sale of assets, or other business transaction involving SagatiCoach, your personal information may be transferred to the acquiring or successor entity as part of that transaction. We will notify you of any such transfer and of any material changes to our data practices that result from it.
ARTICLE 5: DATA RETENTION
5.1. Retention During Active Accounts.
We retain all Platform Data, including Session Transcripts, User-generated content, and AI-Generated Content, for as long as your account remains active on the Platform.
5.2. Deletion on Account Closure.
When your account is closed, whether at your request or as a result of the termination of your User Agreement, we will delete your personal data and User-generated content in accordance with our data retention schedules, subject to the exceptions described in Section 5.3 below.
5.3. Anonymised Data.
Following the closure of your account, we reserve the right to retain anonymised and de-identified data derived from your personal information for the purposes of improving the Platform and the AI Systems. Such anonymised data will not contain any information that could reasonably be used to identify you.
5.4. Legal Retention Requirements.
Notwithstanding the foregoing, we may retain certain personal information for longer periods where we are required to do so by applicable law, regulation, or legal process, or where we need to retain it for the purposes of establishing, exercising, or defending legal claims.
ARTICLE 6: DATA SECURITY
6.1. Security Measures.
We implement and maintain appropriate technical and organisational security measures designed to protect your personal information against unauthorised access, disclosure, alteration, loss, or destruction. These measures include, but are not limited to, encryption of data in transit and at rest, access controls and authentication requirements, regular security assessments, and staff training on data protection and security practices.
6.2. No Absolute Security.
While we take the security of your personal information seriously and implement reasonable measures to protect it, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee the absolute security of your personal information, and we encourage you to take steps to protect your own account security, including by using a strong, unique password and keeping your account credentials confidential.
6.3. Security Incidents.
In the event of a security incident that affects your personal information, we will notify you and any applicable regulatory authorities as required by applicable law.
ARTICLE 7: YOUR RIGHTS UNDER CALIFORNIA LAW
As a California resident, you have certain rights regarding your personal information under the CCPA and CPRA. These rights are described below.
7.1. Right to Know.
You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you, the categories of sources from which we collected that information, the purposes for which we use that information, the categories of third parties with whom we share that information, and the categories of personal information we have disclosed for a business purpose.
7.2. Right to Access.
You have the right to request a copy of the specific pieces of personal information we have collected about you.
7.3. Right to Deletion.
You have the right to request that we delete personal information we have collected from you, subject to certain exceptions. We may decline to delete personal information where we are required to retain it by law, where we need it to complete a transaction you have requested, where we need it to detect or prevent security incidents or fraud, or where we need it for other internal purposes permitted by applicable law.
7.4. Right to Correction.
You have the right to request that we correct inaccurate personal information we hold about you.
7.5. Right to Opt Out of Sale or Sharing.
We do not sell or share your personal information for cross-context behavioural advertising purposes. If this practice changes, we will update this Policy and provide you with the opportunity to opt out.
7.6. Right to Limit Use of Sensitive Personal Information.
To the extent that we collect sensitive personal information, you have the right to direct us to limit our use of that information to the purposes specified in the CPRA.
7.7. Right to Non-Discrimination.
We will not discriminate against you for exercising any of your rights under the CCPA or CPRA. We will not deny you goods or services, charge you different prices, provide you with a different level of quality of service, or suggest that you will receive a different level of service as a result of exercising your rights.
7.8. Exercising Your Rights.
To exercise any of the rights described in this Article, please submit a verifiable consumer request to us using the contact details set out in Article 13 of this Policy. We will respond to your request within the timeframes required by applicable law. We may need to verify your identity before processing your request.
| Right | How to Exercise |
|---|---|
| Right to Know | Submit a request to help@sagaticoach.com |
| Right to Access | Submit a request to help@sagaticoach.com |
| Right to Deletion | Submit a request to help@sagaticoach.com |
| Right to Correction | Submit a request to help@sagaticoach.com |
| Right to Opt Out of Sale | Not applicable (we do not sell personal information) |
| Right to Non-Discrimination | Automatically protected |
ARTICLE 8: THIRD-PARTY SERVICES AND LINKS
8.1. Zoom.
The Platform integrates with Zoom Video Communications, Inc. for video conferencing. When you conduct a coaching session via Zoom through the Platform, your session audio and video will be processed by Zoom in accordance with Zoom's own privacy policy, which is available at https://zoom.us/privacy. SagatiCoach is not responsible for the data practices of Zoom.
8.2. AI Provider.
The AI Systems are powered in part by a third-party artificial intelligence provider. SagatiCoach operates the AI Systems on a closed-loop basis, meaning that data processed by the third-party AI provider is not stored or retained by that provider beyond the scope of the immediate processing task. SagatiCoach takes reasonable steps to ensure that its third-party AI provider is bound by appropriate confidentiality and data protection obligations.
8.3. Third-Party Links.
The Platform may contain links to third-party websites or services. SagatiCoach is not responsible for the privacy practices of any third-party website or service, and we encourage you to review the privacy policies of any third-party websites or services you visit.
ARTICLE 9: GOOGLE CALENDAR INTEGRATION
SagatiCoach offers coaches an optional integration with Google Calendar to help keep their availability up to date and prevent double-bookings. Connecting Google Calendar is entirely voluntary, is available only to coaches, and the Platform works without it. When a coach chooses to connect their Google Calendar, we access and use their Google user data only as described in this Article and only to provide the scheduling and availability features of the Platform.
9.1. Google User Data We Access.
When you connect Google Calendar, we access only the events on your primary Google Calendar. We do not access your Google name, email, profile, contacts, or any other Google service. To work out your availability, we read only:
- the start and end times of your events; and
- whether each event shows you as busy or free (including if it was cancelled or declined).
We never read the titles, descriptions, guests, or any other content of your calendar events.
9.2. How We Use Google Calendar Data.
We use Google Calendar data for two purposes only:
- Availability. We use the times of events on your connected calendar to automatically block the periods when you are already busy, so that clients can only book you when you are genuinely free.
- Session events. When a coaching session is booked, rescheduled, or cancelled on the Platform, we automatically create, update, or remove a corresponding event on your connected calendar. These events include the session time, a link to join or view the session, and basic session details such as the client's name and any invited guests.
We only add, change, or remove the calendar events that SagatiCoach creates for your sessions; we do not modify events that you or others created. We also do not send calendar invitations or notifications to attendees through Google on your behalf.
9.3. Permission We Request.
To provide these features, we ask for your consent to a single Google permission — the ability to view and manage calendar events (the https://www.googleapis.com/auth/calendar.events.owned scope). We request this permission so that we can read your event times to calculate your availability and add, update, or remove your SagatiCoach session events. Google shows you this permission when you connect, and you can choose not to grant it.
9.4. Google Data We Store.
When you connect Google Calendar, we store:
- the authorization credentials (access and refresh tokens) that let the Platform connect to your calendar on your behalf, which we keep in encrypted form;
- a reference to your primary calendar; and
- for each session, the identifier of the calendar event we created for it, so that we can keep that event up to date.
We do not store the contents of your Google Calendar events, and we do not store your Google account email or profile information.
9.5. Sharing of Google User Data.
We do not sell or share your Google Calendar data or your Google authorization credentials with any third party. This information is exchanged only between the Platform and Google's own services for the purposes described above. SagatiCoach's use of information received from Google APIs adheres to the Google API Services User Data Policy, including its Limited Use requirements.
9.6. Disconnecting Google Calendar.
You can disconnect Google Calendar at any time from the Calendar section of your coach settings. When you disconnect, we delete the stored authorization credentials from our systems and revoke the Platform's access with Google. Calendar events that were already created for your existing sessions remain on your Google Calendar, but future bookings will no longer be synced. You can also review or revoke SagatiCoach's access at any time from the security settings of your Google Account.
ARTICLE 10: CHILDREN'S PRIVACY
The Platform is intended solely for use by adults who are at least eighteen (18) years of age. We do not knowingly collect personal information from individuals under the age of eighteen (18). If we become aware that we have collected personal information from a person under the age of eighteen (18), we will take steps to delete that information as promptly as possible. If you believe that we may have collected personal information from a minor, please contact us immediately using the contact details set out in Article 13 of this Policy.
ARTICLE 11: INTERNATIONAL DATA TRANSFERS
The Platform is operated from the United States, and your personal information will be stored and processed in the United States. If you are accessing the Platform from outside the United States, please be aware that your personal information will be transferred to, stored, and processed in a country that may have different data protection laws than your country of residence. By using the Platform, you consent to the transfer of your personal information to the United States.
ARTICLE 12: CHANGES TO THIS PRIVACY POLICY
SagatiCoach reserves the right to update, modify, or replace this Policy at any time, in its sole discretion. We will provide notice of material changes to this Policy by posting the updated Policy on the Platform or by sending you an email notification. Your continued use of the Platform following the posting of any such changes constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically to ensure that you are aware of its current terms. The date on which this Policy was last updated is indicated at the top of this document.
ARTICLE 13: CONTACT INFORMATION
If you have any questions, concerns, or complaints regarding this Privacy Policy or our data practices, or if you wish to exercise any of your rights under applicable privacy law, please contact us at:
- Legal Entity:
- Sagatica Global, Inc.
- Address:
- 8740 Blue Lake Drive, Suite A, San Diego, CA 92119
- Email:
- help@sagaticoach.com