This Privacy Policy ("Privacy Policy") explains how Pathara, LLC ("Company," "Pathara," "we," or "us") collects, uses, and discloses information when you access or use Company's AI-assisted coaching practice management, client progress tracking, documentation, and related functionality (collectively, the "Services"), or otherwise interact with us in connection with the Services.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date above and, in some cases, by providing additional notice through the Services or as required by law. We encourage you to review this Privacy Policy whenever you use the Services.
1. About the Services; Roles; No HIPAA
Two Types of Individuals. This Privacy Policy concerns two groups: (a) the coaches and wellness practitioners who hold accounts and use the Services ("Practitioners," "you"); and (b) the individuals whom Practitioners coach and about whom Practitioners enter information into the Services ("Clients"). Practitioners decide what Client information to collect and submit and why. With respect to Client information, the Practitioner is the party that determines the purposes and means of processing, and Company processes Client information on the Practitioner's behalf and in accordance with this Privacy Policy and our Terms of Service. If you are a Client and have questions about how your information is used, please contact the Practitioner who coaches you; you may also contact us using Section 12.
No HIPAA; Not a Healthcare Provider. Company is not a healthcare provider and does not act as a HIPAA "business associate" or enter into Business Associate Agreements. The Services are not intended to receive or maintain "protected health information" on behalf of a HIPAA covered entity. References to the Services as "HIPAA-ready" describe Company's security practices only and do not mean the Services are "HIPAA compliant" or that any HIPAA obligation is satisfied. See also our Consumer Health Data disclosures in Section 4.
2. Collection of Information
As used in this Privacy Policy, "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an identified or identifiable individual. Personal Information does not include information that is aggregated, de-identified, or anonymized such that it cannot reasonably be used to identify an individual.
Account Information. Information you provide when creating an account, such as name, email address, phone number, professional title, certification or specialty, referral or promotional codes, and other registration details.
Your Data and Client Data. Content and materials you choose to create, submit, record, store, or share through the Services, including messages, text, notes, assessments, check-ins, progress and "wheel" data, audio, voice recordings, images, and other data (collectively, "Your Data"). Your Data may include information about your Clients that you submit, which may relate to a Client's goals, wellbeing, or physical or mental states. You are responsible for having the rights and consents necessary to submit Client information, as described in our Terms of Service.
Communications and Support. Information you provide when you contact us, including inquiries, feedback, support requests, and survey responses.
Identity Verification. Where needed to verify identity, prevent fraud, or comply with law, we may collect government-issued identification, photographs, or similar information.
Marketing, Event, and Contact Information. Information you provide through our websites, landing pages, event registrations, surveys, or promotional campaigns, such as name, email, phone, business name, professional title, and other professional or contact information.
Automatically Collected Information. When you use the Services, we automatically collect usage information (feature usage, interaction data, voice-command history, usage patterns); payment and transaction information (we generally do not store full card numbers but may receive limited billing data such as subscription status and the last four digits of a card from our payment processor); log and diagnostic information (access times, screens viewed, crashes and error reports, IP address, audit logs, AI-generation metadata, and authentication events); device information; approximate location derived from IP address; cookies and similar technologies; and analytics and measurement data. See Section 10 for choices regarding cookies.
Information from Other Sources; Derived Information. We may obtain information about you from third parties such as identity-verification services and publicly available sources, and we may derive information or draw inferences from information we collect (for example, inferring approximate location from IP address).
3. Use of Information
Provide the Services. To provide, operate, maintain, support, and improve the Services, including core functionality and availability.
Manage Purchases. To manage subscriptions, renewals, billing status, and entitlements.
Communications. To send transactional, administrative, service-related, and support communications, and, to the extent permitted by law and subject to your preferences, marketing communications.
Monitor Usage; Maintain Functionality; Security. To analyze usage and performance; to identify and repair errors; and to detect, prevent, investigate, and respond to security incidents, fraud, abuse, or unlawful activity.
De-Identified and Aggregated Data; Research. We may create de-identified and aggregated data derived from Your Data, and may use and disclose such data for analytics, to improve the Services, and for research, including research regarding the effectiveness of coaching and wellness practices. We use commercially reasonable measures consistent with applicable law to ensure such data cannot reasonably be used, alone or in combination, to identify any individual, and we do not attempt to re-identify it. We do not use identifiable Client information for research, or to train artificial-intelligence or machine-learning models, except to the extent the relevant Client has provided informed, opt-in consent through a feature made available for that purpose, and as directed by the applicable Practitioner.
Marketing and Promotional Purposes. To send newsletters and marketing materials and to measure campaign effectiveness. When you redeem a promotional, referral, partner, or influencer code, we collect the code with your registration information to attribute the signup for campaign measurement.
4. Consumer Health Data
Some information processed through the Services may relate to an individual's physical or mental health, wellbeing, or bodily or physiological states, and may constitute "consumer health data" or comparable "sensitive" information under laws such as the Washington My Health My Data Act, the Nevada consumer health data law, and the sensitive-data provisions of various state privacy laws.
Consent. Where required by law, the collection and any sharing of consumer health data is based on consent. As described in our Terms of Service, Practitioners are responsible for obtaining from their Clients the consents, authorizations, and disclosures that applicable law requires before submitting Client information, including any separate or heightened consent required to collect or share consumer health data. Where Company collects consumer health data directly from an individual, it will obtain consent as required by applicable law.
No Sale; No Targeted Advertising. Company does not sell consumer health data, does not share it for cross-context behavioral or targeted advertising, and does not use it for any purpose incompatible with this Privacy Policy.
Limited Access and Use. Access to consumer health data within Company is limited to personnel and service providers who need it to provide, secure, or support the Services, and to the limited de-identified and aggregated uses described in Section 3.
Your Rights; Authorized Agents. Subject to applicable law, individuals may have the right to access, withdraw consent to the collection of, and request deletion of their consumer health data, and to have an authorized agent act on their behalf. To exercise these rights, contact us using Section 12; Clients may also contact the Practitioner who coaches them. We will respond as required by applicable law and will not discriminate against you for exercising these rights. A separate Consumer Health Data Privacy Policy may be provided where required by law and, if provided, is incorporated into this Privacy Policy.
5. Sharing of Information
Service Providers and Vendors. We may share information with vendors and service providers that help us operate the Services, including providers of cloud hosting and storage, authentication, artificial-intelligence and machine-learning services used to provide the Services, security and monitoring, customer support, billing, attribution, and analytics. These parties process information only as necessary to provide services to us and may not use it for their own advertising, marketing, resale, or other unrelated purposes.
At the Practitioner's Direction. We process and share Client information as directed by the applicable Practitioner and as needed to provide the Services to that Practitioner.
Legal and Compliance; Protection of Rights and Safety. We may share information if we believe in good faith that disclosure is required by law, regulation, legal process, or governmental request, or where reasonably necessary to enforce our Terms, investigate or prevent violations, fraud, or misuse, or protect the rights, property, or safety of Company, our users, Clients, or others.
Business Transfers. We may share information in connection with a merger, sale of assets, financing, reorganization, bankruptcy, or acquisition, subject to customary confidentiality protections.
Affiliates. We may share information among Company and our current and future parents, affiliates, and subsidiaries for purposes consistent with this Privacy Policy. We do not share consumer health data with affiliates except as needed to provide and support the Services or as permitted by applicable consent and law.
With Your Direction or Consent; Aggregated and De-Identified. We may share information when you direct or consent, and we may share information that has been aggregated or de-identified so that it cannot reasonably be used to identify you or any Client.
6. Data Retention
General. We retain information for as long as your account remains active and for a reasonable period thereafter, consistent with the operation of the Services and the features you enable.
Cancellation; Deletion. Expiration or cancellation of a Subscription does not automatically delete your account or information. If you delete your account or request deletion, we generally take steps to delete or de-identify the information within approximately thirty (30) days, subject to the exceptions below and excluding deletion that occurs through routine system operations.
Exceptions. We may retain information longer where reasonably necessary to comply with legal obligations, respond to lawful requests, protect the safety and security of the Services, prevent fraud, resolve disputes, or enforce our agreements; in aggregated or de-identified form for analytics, research, and operational purposes; and in backup systems for a limited period consistent with standard disaster-recovery practices.
7. Data Location
Company is based in the United States, and the Services are operated from the United States. Information collected through the Services is processed and stored in the United States, subject to applicable law and the practices described in this Privacy Policy.
8. Data Security Measures
We take reasonable administrative, technical, and physical measures designed to protect information against loss, misuse, unauthorized access, disclosure, alteration, or destruction. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials, limiting access to your devices, and notifying us promptly of any suspected unauthorized access.
9. Third-Party Services
The Services may include links to or integrations with third-party websites, applications, or services not operated by Company ("Third-Party Services"). This Privacy Policy does not apply to Third-Party Services, which are governed by the applicable third party's policies. Company is not responsible for the privacy practices, content, or security of any Third-Party Services.
10. Children's Information
The Services are not directed to children under the age of eighteen (18), and we do not knowingly collect Personal Information from people under 18. If you believe we may have collected information from a person under 18 in error, please contact us using Section 12, and we will take appropriate steps to address it. Practitioners must not use the Services to record information about minors without all consents required by law from a parent or legal guardian.
11. Your Choices
Account Information. You may update or correct certain account information by logging into your account or emailing us at hello@usepathara.com. If you request deletion or deactivation, we will process the request in accordance with this Privacy Policy and our Terms, and may retain certain information as described in Section 6 or as permitted by law.
Cookies and Similar Technologies. Most browsers accept cookies by default. You may adjust your browser or device settings to remove or reject cookies or limit certain analytics technologies; doing so may affect functionality.
Marketing Communications. You may opt out of marketing emails by following the unsubscribe instructions in those communications. We may continue to send non-promotional administrative messages.
Push Notifications. With your consent, we may send push notifications or alerts to your mobile device. You can disable these through your device settings.
State Privacy Rights. Depending on your state of residence, you may have rights to access, correct, delete, or obtain a portable copy of your Personal Information, to opt out of certain processing, and to appeal a denial of a request. To exercise these rights, contact us using Section 12. We will verify and respond as required by applicable law and will not discriminate against you for exercising your rights.
12. Contact Us
If you have questions about this Privacy Policy or our information practices, please contact us at:
Pathara, LLC
Email: hello@usepathara.com