Privacy Policy
This Privacy Policy explains how Coach Pilot Trading Pty Ltd ("Coach Pilot", "we", "us", or "our") collects, uses, and discloses information about you when you access or use our Website (https://coachpilot.com), our Web Application ("App"), and other online products or services that link to this Privacy Policy (collectively, the "Services"). This Privacy Policy does not apply to any other data gathered or used by Coach Pilot, including data collected through websites that do not link to this Privacy Policy.
By using the Website, App, or Services, you assent to this Privacy Policy. If you do not assent, do not use the Website, App, or Services or otherwise submit personally identifiable information ("PII") or personal information ("PI") to us.
We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices. Your continued use of the Services following the posting of any changes verifies that you accept such changes.
When our customers and their admins use our Services to submit, manage, or otherwise use content relating to their data ("Customer Data"), we have contractually committed ourselves to only process such information on behalf of and under the instruction of the respective customer, who is the "data controller". This Privacy Policy does not apply to such processing.
1. Information Collection
When you use the Website, App, or Services, we may collect the following types of information. Some of this information may be considered PII or PI, meaning it reasonably identifies you or your device. We also collect, use, and disclose aggregated or de-identified data that does not identify you.
Information You Provide to Us
When you open an Account, we may ask for your name, email address, and other information you provide. We may also collect identifiers when you participate in interactive features, fill out forms, make purchases, apply for a job, communicate via social media, or request customer support.
When you pay for our Services, your credit card is passed directly to our payment processor (Stripe). We do not store full card numbers on our servers. We store a record of the payment transaction, including the last 4 digits of the credit card number, for account history, invoicing, and billing support.
Information Collected Automatically
Identifiers: IP address, ISP, device type, unique device identifiers, and identifiers associated with cookies and web beacons.
Internet Activity: Browser type, language, operating system, referring web page, pages visited, and hyperlinks clicked.
Commercial Information: Purchase history, records of products or services considered or purchased.
Geolocation: Approximate location derived from your IP address.
Information Collected from Third Parties
We may obtain information about you from third parties, including identity verification services, mailing list providers, joint marketing partners, and social media platforms. If you connect your social media account to your Account, certain information from your social media profile will be shared with us.
2. Information Usage
We use the information we collect for the following purposes:
Provide, maintain, and improve the Website, App, or Services.
Process, complete, and maintain records on transactions.
Send technical notices, updates, security alerts, and support and administrative messages.
Respond to your comments, questions, and requests, and to provide customer service.
Communicate with you about products, services, offers, promotions, and events.
Monitor and analyse trends, usage, and activities in connection with our Services.
Detect, investigate, and prevent fraudulent transactions and other illegal activities.
Link or combine with information we get from others to help understand your needs.
Carry out any other purpose described to you at the time the information was collected.
3. Information Sharing
With the Coach Pilot Corporate Family. We may share information between and among our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership.
With Service Providers or Customers. We may disclose your information to vendors, consultants, and other service providers under contract who help with our business operations, and to customers purchasing services from Coach Pilot.
With Data Analytics and Aggregation Vendors. We may share aggregated, non-personally-identifiable information with third parties for data analysis and demographic profiling. Any aggregated information shared will not contain your personal information.
With Other Users. If you share information with other users on the Services, they may use it for their own purposes. Information posted publicly may become available on the Internet and we cannot prevent further use.
With Legal and Law Enforcement. We may share information with law enforcement or governmental agencies in response to a verified request relating to a criminal investigation or alleged illegal activity, or as required by law.
In Connection with a Change of Control. We may transfer or disclose your information in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business.
With your Consent. Where applicable, we may share your information with your consent or at your specific direction.
4. Children's Privacy
Our App and Services are not intended for individuals under the age of 16. We do not knowingly collect personal information from users in this age group. If we learn that we have collected personal information from a child under 16, we will take reasonable steps to delete that information. If you believe we might have any information from or about a child under 16, please contact us at contact@coachpilot.com.
5. Social Sharing Features
The Services may offer social sharing features and other integrated tools. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. Please refer to those third-party sites' privacy policies to learn more about their privacy practices, which we do not control.
6. Links to Third-Party Sites
Our Services may contain links to other websites that are not controlled by us. We are not responsible for the privacy practices or content of other websites or mobile applications. Visiting these other websites is at your own risk.
7. Advertising and Analytics Services Provided by Others
We may allow others to provide analytics services and serve advertisements on our behalf. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked, and conversion information.
8. Additional Notice to California Residents (CCPA)
In accordance with the California Consumer Privacy Act ("CCPA"), the following summarises our personal information collection, use, and sharing practices in the preceding twelve (12) months.
Category of Personal Information | Business Purpose(s) | Third Parties Disclosed To |
Personal Identifiers and Contact Information | Account management; Transaction processing; Service delivery; Security; Marketing | IT vendors; Cloud providers; Data analytics providers; Coach Pilot customers |
Internet Activity and Technical Data | Improve website experience; Security monitoring; Debugging; Analytics | IT vendors; Cloud providers; Data analytics providers |
Geolocation Data | Improve website experience; Security monitoring; Analytics | IT vendors; Cloud providers; Data analytics providers |
Financial Data | Payment processing; Billing records; Tax compliance | Payment processor (Stripe); IT vendors |
Transaction Data | Payment management; Service delivery; Business records | IT vendors; Business customers |
Profile Data | Service delivery; Marketing; Analytics; Customer community features | IT vendors; Business customers; Data analytics providers |
Usage Data | Analytics; Product improvement; Marketing effectiveness | IT vendors; Business customers; Data analytics providers |
Marketing and Communications Data | Marketing communications; Service notifications; Preference management | IT vendors; Business customers; Data analytics providers |
Sale of Personal Information: We do not sell your information. We do not knowingly sell or otherwise disclose the PII or PI of minors under 16.
Your CCPA Rights
Right to Know: Request, up to twice in a 12-month period, that we identify the categories of personal information we have collected, disclosed, or sold about you.
Right to Access: Request that we provide access to or disclose the specific pieces of personal information we have collected about you.
Right to Delete: Request that we delete personal information collected from you, subject to certain exceptions.
Right to Opt-Out: Opt out of the sale of your personal information (Note: we do NOT sell your personal information).
Right to Non-Discrimination: You will not receive different or less favourable pricing or service for exercising any of the above rights.
To exercise these rights, email contact@coachpilot.com. We will verify your identity before fulfilling any request.
9. Do Not Track Signals
The Website, App, and Services do not respond to Do Not Track ("DNT") signals received from a web browser. Because Coach Pilot is unaware of a universally accepted technological or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.
10. Your Choices
Account Information. You may update and correct certain Account information at any time by logging into your Account. To delete or deactivate your Account, email contact@coachpilot.com. We may retain certain information as required by law or for legitimate business purposes.
Location Information. You can stop the collection of location information at any time by changing the preferences on your computer or device. If you do so, certain features may no longer function properly.
Cookies. For more information about our use of cookies and your choices, please see our Cookie Policy.
Marketing Communications. To unsubscribe from marketing emails, click the "Unsubscribe" link at the bottom of any marketing email, or modify your preferences in your Account settings. You may still receive transactional communications about your account or purchases.
Mobile Push Notifications. You can deactivate push notifications at any time by changing the notification settings on your mobile device.
11. Additional Notice for EEA and UK Residents (GDPR)
This section applies if you are located in the European Economic Area (EEA) or the United Kingdom (UK). It supplements the Privacy Policy above and should be read together with it. Where this section conflicts with the main Privacy Policy, this section takes precedence for EEA and UK residents.
Data Controller
Coach Pilot Trading Pty Ltd is the data controller for personal data collected directly from you through this website and application. Where our customers use the Coach Pilot platform to process data about their own users or employees, Coach Pilot acts as a data processor on behalf of that customer. In those circumstances, you should direct any privacy requests to the relevant customer.
Lawful Basis for Processing
Under GDPR Article 6, we are required to identify a lawful basis for each category of processing we carry out. The table below sets out the lawful basis we rely on for each purpose.
Processing Purpose | Lawful Basis |
Creating and managing your account | Performance of a contract (Article 6(1)(b)) |
Processing payments and billing records | Performance of a contract (Article 6(1)(b)) |
Providing and maintaining the platform and services | Performance of a contract (Article 6(1)(b)) |
Sending transactional and service communications | Performance of a contract (Article 6(1)(b)) |
Detecting and preventing fraud and security incidents | Legitimate interests (Article 6(1)(f)) |
Analysing usage trends and improving the platform | Legitimate interests (Article 6(1)(f)) |
Sending marketing communications | Consent (Article 6(1)(a)) — may be withdrawn at any time |
Complying with legal obligations (e.g. retaining financial records) | Legal obligation (Article 6(1)(c)) |
Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by law.
Data Category | Retention Period |
Account and profile data | Duration of account, plus 3 years after closure |
Billing and transaction records | 7 years from date of transaction (Australian tax obligations) |
Security and access logs | 6 months from date of creation |
Marketing preferences and consent records | Until consent withdrawn, plus 3 years |
Support and communications records | 3 years from date of last contact |
Data Residency
All Coach Pilot customer data is stored and processed exclusively within Australia. Our platform is hosted on Amazon Web Services (AWS) Sydney region (ap-southeast-2). Customer data — including call transcripts, coaching outputs, CRM data, and account information — does not leave Australia at any stage, including during processing, backup, and AI inference.
AI and Your Data
Coach Pilot uses AI to generate coaching outputs within your environment. Your data is never used to train our AI models, shared with other customers, or retained beyond your agreed retention period. AI inference runs within our own AWS Sydney environment and is not routed to any external AI provider.
International Data Transfers
Although all Coach Pilot data is stored in Australia, if you are located in the EEA or UK, your personal data is transferred from your jurisdiction to Australia when you use our Services. Australia does not currently hold an adequacy decision from the European Commission or the UK Secretary of State.
For these transfers, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission as the legal transfer mechanism for EEA residents, and the UK International Data Transfer Agreement (IDTA) for UK residents. You may request a copy of the relevant transfer safeguards by contacting us at contact@coachpilot.com.
A small number of operational tools used to run our business — including our payment processor (Stripe) and authentication provider (Auth0/Okta) — may process limited account and transaction data through infrastructure outside Australia. These providers maintain their own SCCs and data transfer safeguards. No customer coaching data, call transcripts, or CRM data is processed by these tools.
Your Rights Under GDPR
Right of access (Article 15): You may request a copy of the personal data we hold about you, along with information about how we use it.
Right to rectification (Article 16): You may ask us to correct inaccurate or incomplete personal data.
Right to erasure (Article 17): You may ask us to delete your personal data where there is no compelling reason for us to continue processing it. This right is not absolute and does not apply where we are required to retain data by law.
Right to restriction of processing (Article 18): You may ask us to restrict the processing of your personal data in certain circumstances, for example while we verify the accuracy of data you have disputed.
Right to data portability (Article 20): Where processing is based on your consent or a contract and carried out by automated means, you may ask us to provide your personal data in a structured, machine-readable format, or to transmit it directly to another controller where technically feasible.
Right to object (Article 21): Where we rely on legitimate interests as our lawful basis, you have the right to object to that processing. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, or the processing is for the establishment, exercise, or defence of legal claims.
Rights related to automated decision-making (Article 22): You have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects. Coach Pilot does not currently make such decisions.
Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, please email contact@coachpilot.com. We will respond within 30 days of receiving your request. We may need to verify your identity before processing your request.
Right to Lodge a Complaint
If you are located in the UK, you have the right to lodge a complaint with the Information Commissioner's Office (ICO): ico.org.uk | Telephone: 0303 123 1113 | Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
If you are located in the EEA, you have the right to lodge a complaint with the supervisory authority in your country of residence. A full list of EEA supervisory authorities is available at edpb.europa.eu. We would appreciate the opportunity to address your concerns before you contact a supervisory authority — please contact us first at contact@coachpilot.com.
12. Contact Us
If you have any questions, comments, or concerns about this Privacy Policy, please email us at contact@coachpilot.com. Please do not email any confidential, sensitive, or personal information to this address.
Coach Pilot Trading Pty Ltd
ACN: 689 145 891 | ABN: 13 689 145 891
Registered in Victoria, Australia
Email: contact@coachpilot.com
Website: https://coachpilot.com
