PRIVACY POLICY

Proximity Coaching Platform — All AI Coaches

Effective Date: May 20, 2026  |  Last Updated: May 20, 2026 (data lifecycle update)

1. Introduction and Scope

This Privacy Policy ("Policy") describes how Evolved Caveman AI, LLC, a California limited liability company ("Company," "we," "us," or "our"), collects, uses, stores, shares, and protects personal information when you use the Proximity Coaching platform and its AI coaching products: Proxi He (Men's Inner Leadership Coach), Proxi She (Inner Journey Coach for Women), Proxi We (Elite Couples Coach), and any bundle subscription (collectively, the "AI Coaches" or "Products").

This Policy applies to all users of the AI Coaches and to visitors to our website at proximitycoaching.com.

By using any AI Coach, you consent to the data practices described in this Policy. If you do not agree to this Policy, do not use the AI Coaches.

2. Data Controller and Contact

The data controller responsible for your personal information is:

Evolved Caveman AI, LLC
Email: hello@proximitycoaching.com
Website: proximitycoaching.com

3. Information We Collect

3.1 Information You Provide Directly

3.2 Information We Generate About You

In addition to data you provide directly, we generate and store the following derived information:

3.3 Safety Event Records

When an AI Coach's crisis safety protocol is triggered, we log a safety event record. This record includes the specific message(s) that triggered the safety protocol, along with the AI Coach's response, your email address, your name, the detection method (keyword match or AI classification), and a severity rating. These records are retained for safety, legal compliance, and accountability purposes. See Section 8 for retention rules.

3.4 Information from Third Parties

3.5 Technical Data

4. How We Use Your Information

PurposeLegal Basis
Authenticating your account and delivering access to the AI Coaches you purchasedPerformance of contract
Processing payments and managing subscriptionsPerformance of contract
Sending magic link emails and transactional notificationsPerformance of contract
Generating AI Coach responses to your messages, drawing on retrieved knowledge and prior session contextPerformance of contract
Storing conversation history to provide session continuity and enable the AI Coach to reference prior sessionsPerformance of contract / legitimate interest
Generating and storing session summaries to maintain coaching continuity across visitsPerformance of contract / legitimate interest
Building a longitudinal coaching profile to personalize responses over timePerformance of contract / legitimate interest
Storing emotional state check-in data to track wellbeing trends over timePerformance of contract / legitimate interest
Logging safety events for SB 243 compliance and user safety accountabilityLegal obligation / legitimate interest
Communicating important account updates, renewal notices, and changes to these termsPerformance of contract / legitimate interest
Diagnosing technical problems and improving platform reliabilityLegitimate interest
Protecting against fraud, misuse, and unauthorized accessLegitimate interest

We do not use your conversation content to train third-party AI models. We do not sell your personal information. We do not use your data for targeted advertising.

5. AI Processing and Third-Party AI Providers

When you send a message to an AI Coach, your message is transmitted to Anthropic (the provider of the Claude AI model) for processing. Anthropic receives your message content as part of the API request. Anthropic's handling of data submitted through its API is governed by Anthropic's own privacy policy and terms. As of the date of this Policy, Anthropic does not use API request data to train its models by default. Note: Evolved Caveman AI, LLC does not currently have a Business Associate Agreement (BAA) in place with Anthropic.

When generating AI responses, the Products also use OpenAI's text-embedding API to match your message against a curated knowledge base. OpenAI receives your message content for the purpose of generating an embedding vector. OpenAI's handling of API data is governed by OpenAI's own policies.

You should be aware that messages you send to the AI Coaches are processed by these third-party AI providers and are subject to their applicable policies.

6. Data Sharing and Disclosure

6.1 Service Providers

We share personal information with the following third-party service providers who process data on our behalf:

6.2 Legal Requirements

We may disclose personal information if required to do so by law, court order, subpoena, regulatory authority, or government request, or if we reasonably believe such disclosure is necessary to protect the rights, property, or safety of the Company, our users, or the public.

6.3 Business Transfers

In the event of a merger, acquisition, sale of assets, or similar business transaction, personal information may be transferred to the successor entity. You will be notified of any such transfer and any changes to this Policy.

6.4 Consent

We may share personal information with your consent or at your direction.

We do not sell, rent, or share your personal information with third parties for marketing purposes.

7. Sensitive Personal Information

The AI Coaches are designed to support conversations about emotional wellbeing, relationships, stress, identity, and personal development. In the course of using the AI Coaches, you will likely share information that is sensitive in nature — including information about your mental and emotional health, relationships, family circumstances, workplace stress, personal history, and other private matters.

What We Collect, How Long We Keep It

The following types of emotional and personal data are collected and stored when you use the AI Coaches:

This information is used solely to provide the AI coaching service. It is not shared with third parties except as described in Section 6. It is not used for advertising or model training. See Section 9 for full retention details and Section 12 for your deletion options.

One Important Exception — Safety Event Records

If you share something that triggers an AI Coach's crisis safety protocol, a permanent record is created that cannot be deleted. This record includes the specific message(s) that triggered the protocol, the AI Coach's response, your name, your email address, the detection method, and a severity classification. This record is retained for a minimum of three years and is excluded from all user-initiated deletion requests — including full account deletion. It may be disclosed in response to a legal requirement (see Section 6.2).

We are telling you this now, before you begin a session, so you can make an informed decision about what you share. The crisis safety protocol is designed to respond to expressions of suicidal ideation, intent to harm, or acute safety crises. Ordinary disclosures about stress, relationship conflict, anger, and personal struggles do not trigger it.

Important note on HIPAA: The Products are coaching and self-leadership education tools. They are not medical care, mental health therapy, clinical counseling, or healthcare services. Proximity Coaching does not operate as a HIPAA-covered entity in connection with these Products. However, we apply reasonable data protection practices consistent with the sensitivity of the information you share. If you have questions about this, contact us at hello@proximitycoaching.com.

8. Safety Event Data — Special Retention Rules

As described in Section 3.3, when an AI Coach's crisis safety protocol is triggered, we log a safety event record that includes the message(s) that triggered the protocol, the AI Coach's response, your email address, name, and a severity classification.

Safety event records are retained for a minimum of three (3) years from the date of the event. They may be retained longer if related to a pending or threatened legal claim, regulatory inquiry, or as required by applicable law. Safety event records are excluded from user-initiated deletion requests, as their retention serves safety and legal accountability purposes. Safety event data may be included in anonymized, aggregated compliance reports as required by California SB 243 or similar laws.

9. Data Retention

We believe you should control how long your coaching conversations are stored. The table below describes our defaults and your options. Where auto-deletion applies, it runs automatically each night at 3:00 AM UTC. You can change your retention preference at any time by clicking or tapping the ⚙ icon in the top-right corner of any home screen.

Data TypeDefault RetentionYour Control
Account email and subscription statusDuration of subscription + 3 years, or as required by lawPartial — email retained for legal and financial records
Conversation history (full message text)30 days, then auto-deleted. You may change this to 90 days, 1 year, or indefinite ("Keep forever") via the ⚙ icon in the top-right corner of any home screen.Full — delete today's session, delete by date range, delete all conversations, or delete your account
Session summaries (AI-generated)Deleted alongside conversation history. Same 30-day default; same user-adjustable retention options.Full — deleted by the same controls as conversation history
Longitudinal coaching profile (Coaching Notes)Retained until account deletion. This record is not affected by deleting your conversation history. Deleting conversations removes what you said; the AI Coach's synthesized memory of your patterns is separate and persists until you delete your account.Yes — deleted only via full account deletion
Pulse / emotional state check-insRetained until account deletion. Not affected by conversation deletion.Yes — deleted only via full account deletion
Safety event recordsMinimum 3 years (may not be deleted on request — see Section 8)No
Payment records and subscription historyAs required by law (typically 7 years for financial records)No (legal requirement)
Consent records (disclaimer acceptance)Duration of account + 3 yearsNo (legal record)
Authentication tokens and magic link logsTokens expire after use or within 24 hoursAutomatic
Server and technical logsUp to 90 daysAutomatic

10. Security

We implement reasonable technical and organizational measures to protect your personal information, including:

No security system is impenetrable. We cannot guarantee the absolute security of your information. If you believe your account has been compromised, contact us immediately at hello@proximitycoaching.com.

11. Children's Privacy (COPPA Compliance)

The AI Coaches are not directed at, and are not intended for use by, anyone under the age of 18. We do not knowingly collect personal information from minors. If we learn that we have inadvertently collected personal information from a person under 18, we will take prompt steps to delete it. If you believe a minor has accessed an AI Coach, contact us at hello@proximitycoaching.com.

12. Your Rights and How to Delete Your Data

Right to Know

You may request a summary of the personal information we hold about you, including your conversation history, session summaries, coaching profile, and pulse check-ins. Contact us at hello@proximitycoaching.com.

Right to Delete

You can delete your data at any level of granularity — from a single session to your entire account — without contacting us. All controls are available by clicking or tapping the ⚙ icon in the top-right corner of any home screen.

In-App Deletion Controls (the ⚙ icon in the top-right corner of any home screen)

Session-End Deletion Prompt

When you leave a coaching session, the app will ask whether you want to keep the conversation or delete it before returning to the home screen. You can delete each session individually as you go, without visiting Settings.

Important Notes on Deletion

Deletion by Email

If you prefer, you may request deletion by contacting hello@proximitycoaching.com. We will process your request within 30 days.

Right to Correct

You have the right to request correction of inaccurate personal information. Contact us at hello@proximitycoaching.com.

California Residents (CCPA / CPRA)

If you are a California resident, you have the additional rights described above, plus:

To exercise any of these rights, contact hello@proximitycoaching.com. We will respond within 45 days as required by law and may request verification of your identity before processing your request.

13. Cookies and Tracking Technologies

The AI Coaches use minimal tracking:

14. International Users

The AI Coaches are intended for use within the United States. If you access them from outside the United States, your information may be transferred to, stored, and processed in the United States, where our infrastructure providers are based. By using the AI Coaches, you consent to this transfer, storage, and processing.

15. Links to Third-Party Services

The AI Coaches may include links to third-party websites or services. This Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party services you access.

16. Changes to This Policy

We may update this Policy from time to time. Material changes will be communicated via email or prominent notice within the Products at least thirty (30) days before taking effect. The date of the most recent revision is shown at the top of this page. Your continued use of the AI Coaches after the effective date of any changes constitutes your acceptance of the revised Policy.

17. Contact Us

For privacy questions, deletion requests, or complaints about our data practices:

Evolved Caveman AI, LLC
Email: hello@proximitycoaching.com
Website: proximitycoaching.com

We will respond to verifiable requests within 45 days. If we need additional time, we will notify you.