Privacy Policy

Last Updated: March 27, 2025

NeverGiveUp ("we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, share, and protect your information when you use our accountability coaching services, website, mobile applications, and related services (collectively, the "Service").

By accessing or using our Service, you agree to the collection, use, and sharing of your information as described in this Privacy Policy. If you do not agree with our policies and practices, please do not use our Service.

We understand the importance of privacy and are committed to being transparent about our data practices. This Privacy Policy is designed to help you understand:

• What information we collect about you
• How we use your information
• When and with whom we share your information
• How we protect your information
• Your rights and choices regarding your information

This Privacy Policy applies to all users of our Service, including those who register for an account, subscribe to our coaching services, or simply visit our website. Please read this Privacy Policy carefully to understand our practices regarding your information.

We collect several types of information from and about users of our Service. The information we collect depends on how you interact with our Service and the features you use.

2.1 Personal Information

We collect personal information that you voluntarily provide to us when you:

• Register for an Account: Name, email address, phone number, and messaging platform contact information (iMessage or WhatsApp)
• Complete the Onboarding Process: Information about your goals, preferences, habits, and needs
• Subscribe to the Service: Payment information, billing address, and subscription preferences
• Communicate with Your Coach: Messages, images, and other content you share during coaching interactions
• Contact Customer Support: Information you provide when you contact us for assistance
• Participate in Surveys or Feedback: Responses, opinions, and suggestions you provide

2.2 Questionnaire Information

During the onboarding process, we collect information through questionnaires to help us understand your goals and match you with an appropriate coach. This may include:

• Personal goals and objectives
• Current habits and behaviors
• Preferences regarding coaching style and communication frequency
• Challenges or obstacles you're facing
• Time zone and availability information

2.3 Account and Subscription Information

We collect and maintain information related to your account and subscription, including:

• Account credentials and profile information
• Subscription type, status, and history
• Payment method information and transaction records
• Billing history and payment status
• Account preferences and settings

2.4 Usage and Communication Data

We collect information about how you use our Service and communicate with your coach:

• Service Usage: Features accessed, actions taken, time spent using the Service, and interaction patterns
• Communication Patterns: Frequency, timing, and duration of coaching interactions
• Message Content: Text, images, and other content shared during coaching interactions
• Technical Data: IP address, device information, browser type, operating system, and other technical information when you access our website or Dashboard

Please note that while we have access to the content of messages exchanged through our Service, we respect your privacy and only access this content for specific purposes as outlined in the "How We Use Your Information" section below.

We use the information we collect for various purposes related to providing, maintaining, and improving our Service. The primary ways we use your information include:

3.1 Providing and Managing the Service

• Creating and maintaining your account
• Processing your subscription and payments
• Matching you with an appropriate coach based on your goals and preferences
• Facilitating communication between you and your coach
• Providing customer support and responding to your inquiries
• Sending service-related notifications and updates

3.2 Personalizing and Improving the Service

• Tailoring the coaching experience to your specific needs and goals
• Analyzing usage patterns to improve our Service
• Developing new features and functionality
• Troubleshooting issues and fixing bugs
• Training and evaluating coaches
• Conducting research and analysis to enhance our coaching methodologies

3.3 Communication and Marketing

• Sending essential service communications about your account or subscription
• Providing information about new features or services
• Sending promotional materials or special offers (with your consent where required)
• Requesting feedback about your experience with our Service
• Conducting surveys to improve our Service

3.4 Legal and Security Purposes

• Complying with legal obligations and regulatory requirements
• Enforcing our Terms of Service and other policies
• Protecting against fraudulent, unauthorized, or illegal activity
• Ensuring the security and integrity of our Service
• Verifying your identity when required

We process your information based on one or more legal bases, including: your consent, the necessity to perform our contract with you, compliance with our legal obligations, and our legitimate interests (such as providing and improving our Service, ensuring security, and preventing fraud).

We understand the importance of keeping your information confidential. We do not sell your personal information to third parties. However, we may share your information in the following circumstances:

4.1 With Your Coach

We share relevant information with your assigned coach to facilitate the coaching relationship, including:

• Your name and contact information for messaging purposes
• Information from your onboarding questionnaire about your goals and preferences
• Your subscription status and coaching history
• Any other information necessary for providing effective coaching services

Your coach is bound by confidentiality obligations regarding your information.

4.2 With Service Providers

We may share your information with third-party service providers who perform services on our behalf, such as:

• Payment processors to handle subscription payments
• Cloud storage providers to store your information securely
• Analytics providers to help us understand Service usage
• Customer support services to assist with inquiries
• Email service providers to send communications

These service providers are contractually obligated to use your information only for the purposes of providing services to us and in accordance with this Privacy Policy.

4.3 With Messaging Platforms

When you use our Service, your communications with your coach occur through third-party messaging platforms (iMessage or WhatsApp). These platforms have access to the content of these communications according to their own terms and privacy policies. We recommend reviewing the privacy policies of these platforms to understand how they handle your information.

4.4 For Legal Reasons

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency). We may also disclose your information to:

• Enforce or apply our Terms of Service and other agreements
• Protect the rights, property, or safety of NeverGiveUp, our users, or others
• Prevent or investigate possible wrongdoing in connection with the Service
• Defend against legal claims

4.5 Business Transfers

If NeverGiveUp is involved in a merger, acquisition, or sale of all or a portion of its assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any change in ownership or uses of your information, as well as any choices you may have regarding your information.

In all cases, we take reasonable steps to ensure that your information is treated securely and in accordance with this Privacy Policy. We require third parties to respect the security of your information and to treat it in accordance with applicable laws.

5.1 Security Measures

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Encryption of sensitive information
• Secure storage systems with restricted access
• Regular security assessments and testing
• Staff training on data protection and security practices
• Monitoring for suspicious activities

While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security but are committed to implementing reasonable security practices.

5.2 Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The specific retention periods depend on:

• The nature of the information
• The purpose for which it was collected
• Legal, regulatory, or operational requirements
• Your account status and subscription history

5.3 Account Closure and Data Deletion

When you close your account, we will:

• Deactivate your account and end your access to the Service
• Retain certain information as required for legal, regulatory, or legitimate business purposes
• Eventually delete or anonymize your personal information in accordance with our data retention policies

Even after account closure, we may retain some information in aggregated or anonymized form that can no longer be used to identify you.

To request deletion of your personal information, please contact us at [email protected]. Please note that certain information may be retained even after a deletion request for legal, regulatory, or technical reasons.

Depending on your location, you may have certain rights regarding your personal information. We respect these rights and provide mechanisms for you to exercise them.

6.1 Access and Portability

You have the right to access the personal information we hold about you. You can view much of this information by logging into your Dashboard. For additional information, you can submit a request to [email protected]. We will provide this information in a structured, commonly used, and machine-readable format where technically feasible.

6.2 Correction and Update

You can correct or update much of your personal information directly through your Dashboard. For information that cannot be updated through the Dashboard, please contact us at [email protected].

6.3 Deletion and Restriction

You may request deletion of your personal information by contacting us at [email protected]. Please note that we may need to retain certain information for legal, security, or operational purposes. We will inform you if we cannot comply with your deletion request due to such reasons.

You may also have the right to restrict or object to certain processing of your personal information. Please contact us to exercise these rights.

6.4 Communication Preferences

You can manage your communication preferences in the following ways:

• Service Communications: Essential service communications cannot be opted out of as they are necessary for providing the Service.
• Marketing Communications: You can opt out of marketing communications by using the unsubscribe link in our emails or by contacting us directly.
• Coaching Communications: You can discuss communication frequency and timing preferences with your coach.

6.5 Withdrawing Consent

Where we process your information based on consent, you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal.

6.6 Complaints

If you have concerns about our data practices or how we've handled your personal information, please contact us first at [email protected]. You also have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

We will respond to all legitimate requests within a reasonable timeframe, typically within 30 days. Occasionally, it may take longer if your request is particularly complex or you have made multiple requests.

Our website uses cookies and similar tracking technologies to enhance your experience, analyze usage, and assist in our marketing efforts.

7.1 What Are Cookies

Cookies are small text files that are stored on your device when you visit a website. They are widely used to make websites work more efficiently and provide information to the website owners.

7.2 How We Use Cookies

We use cookies and similar technologies for the following purposes:

• Essential Cookies: Required for the operation of our website, such as enabling login functionality and remembering your session information
• Analytical Cookies: Help us understand how visitors interact with our website by collecting and reporting information anonymously
• Functional Cookies: Allow our website to remember choices you make and provide enhanced, personalized features
• Targeting Cookies: Record your visit to our website, the pages you have visited, and the links you have followed to deliver more relevant content and advertisements

7.3 Your Cookie Choices

Most web browsers allow you to control cookies through their settings preferences. You can typically delete existing cookies, block certain types of cookies, or set your browser to notify you when cookies are being placed on your device.

Please note that if you choose to block or delete cookies, you may not be able to access certain features or areas of our website, and your experience may be impacted.

7.4 Do Not Track

Some browsers have a "Do Not Track" feature that signals to websites that you visit that you do not want to have your online activity tracked. Due to the lack of a common understanding of how to interpret these signals, our website does not currently respond to "Do Not Track" signals.

Our Service integrates with third-party services and messaging platforms to provide coaching communications and other functionality. This section explains how these integrations work and their privacy implications.

8.1 Messaging Platforms Overview

We use third-party messaging platforms (iMessage and WhatsApp) to facilitate communications between you and your coach. When you use these platforms:

• Your communications are subject to the privacy policies and terms of service of these platforms
• These platforms may collect and process information according to their own policies
• Message content may be stored on the servers of these platforms

8.2 iMessage Integration

When using iMessage for coaching communications:

• Communications occur through Apple's iMessage service
• Apple's privacy policy and terms apply to these communications
• End-to-end encryption may be applied according to Apple's protocols
• Your Apple ID and associated information may be used to facilitate these communications

8.3 WhatsApp Integration

When using WhatsApp for coaching communications:

• Communications occur through the WhatsApp service
• WhatsApp's privacy policy and terms apply to these communications
• End-to-end encryption may be applied according to WhatsApp's protocols
• Your phone number and associated information may be used to facilitate these communications

8.4 Other Third-Party Services

Our Service may also integrate with other third-party services, such as:

• Payment processors for handling subscription payments
• Analytics providers for understanding website usage
• Cloud storage providers for storing data securely

These third-party services may collect and process your information according to their own privacy policies. We recommend reviewing the privacy policies of these services to understand how they handle your information.

8.5 Links to Other Websites

Our website and communications may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

9.1 Children's Privacy

Our Service is not directed to individuals under the age of 18, and we do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will promptly delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

9.2 International Users

Our Service is based in the United States, and the information we collect is governed by U.S. law. If you access our Service from outside the United States, please be aware that information collected through the Service may be transferred to, processed, stored, and used in the United States and other jurisdictions. Your use of our Service or provision of any information therefore constitutes your consent to the transfer, processing, usage, sharing, and storage of your information in the United States and other jurisdictions, which may have different data protection rules than those of your country.

For users in the European Economic Area (EEA), United Kingdom, or Switzerland, we ensure adequate protection for personal information transferred to countries outside these regions through appropriate safeguards, such as standard contractual clauses approved by the European Commission.

9.3 Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. The updated policy will be effective when it is posted on this page.

For material changes to this Privacy Policy, we will notify you by email or through a notice on our website prior to the change becoming effective. We encourage you to review this Privacy Policy periodically for the latest information on our privacy practices.

Your continued use of the Service after we post any modifications to the Privacy Policy will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

9.4 Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Email: [email protected]

We will make every effort to respond to your inquiry promptly and address your concerns appropriately.