Happy Whole Human® Privacy Policy

Effective Date: January 2026
Last Updated: January 2026

Happy Whole Human® (“HWH,” “we,” “us,” or “our”) is committed to protecting your privacy and handling personal data with care, transparency, and integrity.

This Privacy Policy explains how we collect, use, store, share, and protect personal information when you access or use our services, platforms, assessments, applications, and websites.

This Policy applies globally and is issued jointly by:

• Happy Whole Human, Inc. (Delaware corporation; principal U.S. headquarters: Austin, Texas, USA)

• Happy Whole Human Spain SL (Barcelona, Spain)
   

By using HWH services, you acknowledge that you have read and understood this Privacy Policy.

1. Scope of This Privacy Policy
This Privacy Policy applies to personal data collected through:

• Coaching services (individual, couple, team, organizational)

• Coach training, mentoring, and supervision programs

• Digital platforms, mobile applications, and websites

• Assessments and reports

• AI-enabled tools and features

• Membership communities and communications

This Policy does not apply to third-party platforms or services that you may access separately (e.g., external video, scheduling, or AI providers), which are governed by their own privacy policies.

2. Personal Data We Collect
We may collect the following categories of personal data:
a. Information You Provide Directly

• Name, email address, phone number

• Account credentials

• Billing and payment information

• Coaching intake forms and questionnaires

• Assessment responses

• Messages, reflections, uploads, and other user-submitted content

• Communications with HWH (email, chat, support requests)

b. Coaching, Learning & Assessment Data

• Coaching session notes (where applicable)

• Assessment results and reports

• Progress tracking data

• Participation and attendance information

c. Technical & Usage Data

• IP address and device information

• Browser type and operating system

• Log files and platform usage analytics

• Cookies and similar technologies

d. AI-Enabled Interactions (Where Used)

• Text inputs, prompts, reflections, or responses provided to AI-supported features

• Generated outputs used to support reflection, learning, or continuity
   

3. How We Use Personal Data
We process personal data only where lawful and necessary, including to:

• Provide and deliver HWH services

• Support coaching, learning, and assessment experiences

• Operate, maintain, and improve our platforms

• Communicate with you about your account or services

• Process payments and manage subscriptions

• Ensure safety, security, and quality assurance

• Comply with legal, regulatory, and ethical obligations

• Generate anonymized, aggregated insights for research and improvement

We do not sell personal data.

4. Lawful Bases for Processing (GDPR)
For individuals in the European Union and other GDPR jurisdictions, we process personal data based on one or more of the following lawful bases:

• Your consent

• Performance of a contract

• Compliance with a legal obligation

• Legitimate interests, balanced against your rights and freedoms

You may withdraw consent at any time where processing is based on consent.

5. Confidentiality of Coaching & Assessment Data
Coaching and assessment data are treated as confidential and handled in accordance with:

• This Privacy Policy

• HWH Terms & Conditions

• Applicable laws and professional ethical standards

Individual coaching content and assessment results are not shared with employers, sponsors, or third parties unless:

• You explicitly authorize sharing, or

• Disclosure is required by law

For sponsored programs, only non-identifying administrative or aggregate information may be shared, as described in our Terms.

6. AI-Enabled Features & Data Use
AI-enabled tools within HWH are used solely to support reflection, learning, and continuity, not to replace human coaching or judgment.

• Participation in AI-supported features is optional

• You may opt out at any time

• Identifiable personal data is not used to train foundation AI models without explicit consent

• Fully anonymized and aggregated data may be used to improve platform functionality

AI interactions are subject to the same privacy and security protections as other platform data.
 
AI Training Clarification
Happy Whole Human® does not use identifiable personal data—including coaching conversations, assessment responses, session recordings, transcripts, or AI interactions—to train or fine-tune foundation artificial intelligence models or agents without explicit user consent.
Where fully anonymized and aggregated data is used to improve platform functionality, such data does not identify individual users and is processed in accordance with applicable law and ethical standards.


7. Data Sharing & Disclosure
We may share personal data only with:

• Authorized HWH personnel and coaches under confidentiality obligations

• Service providers and processors who support our operations (e.g., hosting, payment processing), under contractual data protection obligations

• Legal or regulatory authorities where required by law

We do not share personal data for advertising purposes.

Service providers include secure cloud infrastructure, database, and monitoring vendors operating as data processors under contractual confidentiality and data protection obligations.

8. Data Storage, Security & Retention
We implement reasonable administrative, technical, and organizational safeguards to protect personal data against unauthorized access, loss, misuse, or disclosure.
Data is retained in an encrypted GDPR-compliant database as long as necessary to:

• Fulfill our services

• Meet legal, accounting, or regulatory requirements

Users are encouraged to download or retain copies of content they wish to keep.

9. Your Rights
Depending on your location, you may have rights to:

• Access your personal data

• Correct inaccurate data

• Request deletion

• Restrict or object to processing

• Request data portability

• Withdraw consent

Requests may be submitted to contact@happywholehuman.com.
We will respond in accordance with applicable law.

10. Cookies & Tracking Technologies
HWH uses cookies and similar technologies to operate and improve our platforms. You may manage cookie preferences through your browser settings or cookie banner where applicable.

11. Children’s Privacy
HWH services are intended for individuals 18 years of age or older.
We do not knowingly collect personal data from minors.

12. International Data Transfers
Personal data may be processed in the United States, Spain, or other jurisdictions where HWH or its service providers operate. Where required, appropriate safeguards are implemented to protect international data transfers.

13. Updates to This Privacy Policy
We may update this Privacy Policy from time to time. Material changes will be communicated via our website or direct notice where required.
Continued use of HWH services after updates constitutes acceptance of the revised Policy.

14. Contact Us
Happy Whole Human®
contact@happywholehuman.com
www.happywholehuman.com