Privacy Policy

Personal information you give us

We collect personal information you provide when you register, purchase, participate in activities, or contact us. This may include:

• Name
• Email address
• Phone number
• Password
• Contact preferences
• Billing address
• Debit or credit card information (processed by our payment processors; we do not store full card numbers)

Payment data

Payment information is processed by third-party processors such as Stripe, PayPal, and Kajabi, and by the Apple App Store and Google Play for in-app purchases. We do not store full payment card details.

Health, wellness, and mental-health information (sensitive personal information)

Commune Coach asks you for this information. You do not merely volunteer it.

Commune Coach is designed to ask about your health and wellness goals, physical and emotional challenges, stress, sleep, energy, mood, and related topics, during onboarding, in program check-ins, in goal-setting, and in ongoing conversation, so that it can personalize your programs and guidance. You may also share this kind of information in journal entries, program responses, or community features.

We describe this information as actively and knowingly provided in response to the Coach, rather than as “voluntarily provided,” because the Coach solicits it. We ask for your consent before Commune Coach collects any of it, on a screen that explains what will be collected and why, separately from your general acceptance of our Terms of Service. You choose what to share in conversation, and you can withdraw consent at any time. See Sections 7 and 12.

This information is “sensitive personal information” under the California Consumer Privacy Act and “consumer health data” under Washington’s My Health My Data Act, Nevada’s SB 370, and similar laws. It is governed by this Notice and by our Consumer Health Data Privacy Policy.

Community-generated content

When you participate in community features (forums, group spaces, comments, chats), you may submit text, images, audio, video, or other materials (“Community Content”).

• Visibility. Community Content may be visible to other users based on feature design and your settings. Your Commune Coach conversations are never part of Community Content and are never visible to other members.
• Use. We process Community Content to operate, moderate, secure, and improve the Services and to enforce our Terms.
• Moderation. Content may be reviewed by automated systems, human moderators, or both.
• Retention. Community Content is retained while your account is active, or as otherwise required by law, unless deleted by you or on request.
• External use. If content is shared publicly or reposted by others, we cannot control its use outside our Services.

Information collected automatically

• IP address
• Browser and device characteristics
• Operating system and language preferences
• Referring URLs
• Pages viewed, features used, content watched, program progress, and timestamps

Location data. We may collect imprecise location (such as city or region derived from IP address) and, only with your device-level permission, precise location. You can disable location sharing in your device settings, which may limit certain features. We do not use geofencing around any healthcare facility, and we do not build or use geofences to identify, track, or collect data about anyone seeking health services.

Information from third parties

In limited circumstances we may receive personal information from third parties such as marketing partners, analytics providers, payment processors, or social media platforms where you have connected an account, consistent with this Notice.

We process personal information to:

• Create and manage your account
• Deliver the Services, including courses, programs, community features, and Commune Coach
• Personalize your coaching programs and Coach responses (this is the purpose for which health and wellness information is used)
• Process payments, manage subscriptions, and handle renewals and cancellations
• Send you service, billing, and security communications
• Send marketing communications, subject to your preferences
• Decide which Commune programs, courses, and content to tell you about in our own emails, based on the Commune programs you have enrolled in
• Maintain safety, moderate content, and prevent fraud and abuse
• Surface crisis resources and operate the safety guardrails described on our AI Safety & Crisis Resources page
• Analyze usage trends and improve the performance and quality of the Services
• Measure the effectiveness of our own marketing
• Comply with legal obligations and protect vital interests

We do not disclose your health and wellness information to advertising networks or data brokers, and we do not use it for cross-context behavioral advertising or to train third-party AI models. We do use the Commune programs you enroll in to decide which of our own emails to send you. That happens entirely inside Commune, and the information never reaches an advertising platform. You can stop it at any time through Your Privacy Choices or by unsubscribing.

Depending on your location, we rely on:

• Consent (including for health and wellness information, marketing where required, and non-essential cookies)
• Contractual necessity (delivering the Services you purchased)
• Legitimate interests, balanced against your rights (security, fraud prevention, service improvement)
• Legal obligations
• Vital interests (safety situations)

We share personal information only in the limited circumstances below. We do not sell personal information, and we do not share it for cross-context behavioral advertising.

A member-facing list of the specific categories of third parties who receive health data is maintained in our Consumer Health Data Privacy Policy, as those laws require.

Service provider contracts

Everyone in the table above who processes personal information on our behalf is a service provider or processor under contract, permitted to use the information only to perform services for Commune, prohibited from selling it, and prohibited from using it for their own purposes.

Business transfers

If Commune is involved in a merger, acquisition, financing, or sale of assets, personal information may be transferred as part of that transaction. We will not transfer consumer health data in a way that constitutes a sale under applicable law without obtaining the separate, signed authorization those laws require. We will notify you of any change in control that materially affects how your information is handled.

Third-party services and links

Our Services may contain links to or integrations with third-party services we do not operate. Their privacy practices are governed by their own policies.

We use cookies and similar technologies to support core functionality, analytics, and measurement of our own marketing.

Commune does not run advertising networks or ad-tech inside the Services, and we do not use tracking-based advertising targeting. Our Services feature an internal Marketplace displaying partner brands who pay or provide an affiliate commission to Commune to be included, and those placements are clearly labeled as partnerships or promotions. Advertising-related tracking is used only to measure and improve our own marketing and off-platform outreach. No advertising, tracking, or partner analytics tags run inside Commune Coach or on screens handling health data inputs. We do not use your health data to select which partner brands or offers you see, and partners do not receive information about you from Commune.

No advertising or analytics tags run inside Commune Coach. Coach conversations are not instrumented for advertising or measurement purposes.

You can manage cookies through your browser settings and through our cookie preference center, which appears on first page load. See also Section 13 on Global Privacy Control.

The Services are for adults. We do not knowingly collect personal information from anyone under 18. If we learn that an account belongs to someone under 18, we close the account and delete the associated personal information. Companion-style AI may not be suitable for minors. If you believe a minor has provided us information, contact [email protected].

What Coach is

Commune Coach is an artificial intelligence wellness companion. It is not a person, not a licensed professional, and not healthcare. You acknowledge that it is AI on the consent screen before you first use it. There is no live monitoring of your Coach conversations. See our Terms of Service Section 9 and our AI Safety & Crisis Resources page.

We do not use AI Features to make automated decisions that produce legal or similarly significant effects about you.

Coach Memory

Commune Coach builds a personalized profile from what you tell it, including health and wellness goals, challenges, preferences, and progress (“Coach Memory”), in order to personalize your content, programs, and guidance.

Our AI model providers do not train on your data

To generate its responses, information you share with Commune Coach, including health and wellness information, is processed by one or more third-party AI model providers acting as Commune’s service providers.

Those providers are contractually prohibited from using your information to train, fine-tune, develop, or improve their own general-purpose or foundation models. They may use it only to generate responses back to Commune for the purpose of delivering the Services to you.

Your information is not sold, and is not disclosed to advertisers, ad networks, or data brokers.

Safety logs held by AI providers

Some AI providers retain a short-term copy of inputs and outputs for abuse monitoring and safety purposes, typically about 30 days and in some configurations up to approximately 55 days, on their own schedule. Commune cannot delete these copies on demand. They are not used for training and are not accessible to Commune for any other purpose.

You control Coach Memory

You can request to view, edit, or delete your Coach Memory at any time by emailing [email protected], without deleting your account. Deleting Coach Memory removes the personalization data Coach has built about you. It will change how the Coach works: it will no longer remember your goals, history, or preferences, and your programs will be less personalized until you build it up again.

Crisis guardrails

The Coach is not an emergency service. If a conversation suggests you may be in immediate danger, the system will refuse to answer, and you should take immediate appropriate steps outside of the Services. Crisis resources are listed in Section 9.2 of our Terms of Service.

We keep personal information only as long as necessary for the purposes described in this Notice, except where a longer period is required or permitted by law. The periods below describe our standard practice and may vary where a legal obligation, an investigation, or an operational need requires it:

Backups. Deleted data is removed from live systems promptly, and typically persists in encrypted backups until those backups expire on their normal rotation. Backups are not used for any operational purpose and are restored only for disaster recovery. We say this because immediate erasure from every copy is not technically possible, and we would rather be precise than reassuring.

Legal holds. If information is subject to a legal hold or an open investigation, we retain it until the hold is lifted.

We use reasonable technical and organizational safeguards designed to protect personal information. Depending on the system, these measures include encryption in transit, encryption at rest provided by our hosting infrastructure, and access controls limiting internal access to health-related data to staff with administrative access. We review these safeguards periodically, and no safeguard is perfect.

No system is completely secure and transmission is at your own risk. If a breach affecting your information occurs, we will notify you and the applicable regulators as required by state breach-notification laws and, for health information, the FTC Health Breach Notification Rule.

Commune is based in the United States, and personal information is processed in the United States and in other countries where our service providers operate. Currently, Commune Coach is not available in the European Union or the United Kingdom.

Residents of Australia, New Zealand, South Africa, Canada, and other regions may have additional rights under local law. Contact [email protected].

At or before the point of collection we collect the following categories of personal information, for the purposes described in Section 2, and retain them for the periods in Section 8:

We have not sold personal information in the preceding 12 months, and we do not sell or share the personal information of consumers we know to be under 16.

In the preceding 12 months we disclosed identifiers, customer records, commercial information, internet activity data, and imprecise geolocation data to service providers for the business purposes in Section 2. Once Commune Coach is live, we also disclose sensitive personal information (health and wellness information you share with Commune Coach) to our AI model service providers, solely to generate your personalized Coach responses.

Depending on your jurisdiction, you have the rights below. We honor these rights for all United States members regardless of state, rather than applying them state by state.

Your rights

• Know and access what personal information we hold about you, and obtain a copy
• Correct inaccurate personal information
• Delete your personal information
• Port your information in a portable, machine-readable format
• Withdraw consent, including consent to collect and to share health data
• Limit the use and disclosure of sensitive personal information (see 12.4)
• Opt out of sale or sharing. We do not sell or share, but you may still exercise this right
• Opt out of marketing communications at any time
• Appeal any decision we make about your request (see 12.6)
• Be free from discrimination for exercising any of these rights. Exercising a privacy right will never change your price, your Membership, or your access to the Services

How to submit a request

Two methods, as required:

• Your Privacy Choices: https://resources.onecommune.com/legal/privacy-choices.html
• Email: [email protected]

For Coach Memory, you do not need to submit a request at all: delete it yourself in Account Settings (Section 7.5).

How we handle requests

We confirm receipt within 10 business days and respond substantively within 45 days, extendable once by another 45 days with notice. We must verify your identity, usually by confirming control of the email address on your account. An authorized agent may submit a request on your behalf with written permission and verification. We do not verify your identity for a request to limit the use of sensitive personal information or to opt out of sale or sharing, because the law does not permit us to require it. We may ask for enough information to find your account.

Right to limit the use of sensitive personal information

Commune Coach collects sensitive personal information, and you have the right to limit its use.

We use health and wellness information to provide your personalized Commune Coach experience, to keep it safe and functioning, and to decide which of our own emails to send you based on the Commune programs you have enrolled in. We do not disclose it for cross-context behavioral advertising and we do not use it to build advertising audiences on any advertising platform.

You may nonetheless direct us to limit our use of your sensitive personal information at any time, through our dedicated request page: Your Privacy Choices

What happens if you exercise it. We will stop using your health and wellness information for anything other than the narrow purposes applicable law permits regardless of your direction (such as security, fraud prevention, and legal compliance).

Health data rights

For rights specific to consumer health data, including the right to a list of every third party your health data has been shared with, and the right to withdraw consent to collection and to sharing separately, see the Consumer Health Data Privacy Policy.

Appeals

If we deny your request, you may appeal. Email [email protected] with the subject line “Privacy Request Appeal” within 60 days of our decision, and include your original request and why you believe the denial was wrong. A person who was not involved in the original decision will review it, and we will respond in writing within 45 days explaining the outcome and our reasoning.

If your appeal is denied, you may contact your state Attorney General. Washington residents may contact the Washington State Attorney General at atg.wa.gov/file-complaint, and California residents may contact the California Privacy Protection Agency at cppa.ca.gov.

We do not respond to Do-Not-Track browser signals, because no common standard for them exists.

We honor the Global Privacy Control (GPC) signal. When we detect GPC on your browser, we treat it as a valid request to opt out of any sale or sharing of your personal information and, where technically feasible, apply it to your Commune account as well. We honor GPC for all users, not only where the law requires it.

We may update this Notice. Material changes will be communicated at least 30 days in advance, by email or prominent in-Service notice, and the “Last Updated” date above will change. Where a change materially expands how we collect, use, or share your health data, we will obtain your consent again rather than relying on notice alone.

Commune Media, LLC - 22722 Chamera Lane Topanga, CA 90290 United States

• Privacy questions and requests: [email protected]
• Your Privacy Choices: https://resources.onecommune.com/legal/privacy-choices.html
• Safety concerns about Commune Coach: [email protected]

• Terms of Service: https://resources.onecommune.com/legal/terms-service.html
• Consumer Health Data Privacy Policy: https://resources.onecommune.com/legal/health-data-privacy-policy.html
• AI Safety & Crisis Resources: https://resources.onecommune.com/legal/ai-safety-crisis-resources.html

Commune is not a HIPAA covered entity and does not describe itself as HIPAA compliant. The state consumer health data laws described above are what protect the information you share with Commune Coach.