Privacy Policy

Creation Date: 04/01/2025

revision: June 12, 2026

Website: https://DigitalAddictionCoach.com


Website: https://digitaladdictioncoach.com
Entity : DigitalAddictionCoach, LLC

PRIVACY POLICY

DigitalAddictionCoach, LLC

https://digitaladdictioncoach.com

Created Date: 04/01/2025  |  Revised: June 2026

AMENDMENT NOTICE (June 2026): This policy has been amended to comply with the EU General Data Protection Regulation (GDPR) in connection with the onboarding of clients located in the European Economic Area (EEA). Amended and new sections are marked with a green sidebar. All other sections remain unchanged.

1. Who We Are

DigitalAddictionCoach, LLC (“Company,” “we,” “us,” or “our”) provides coaching services for individuals seeking digital addiction recovery. This Privacy Policy explains how we collect, use, and protect your personal data and your rights under applicable laws, including the General Data Protection Regulation (GDPR).

2. Coaching vs. Therapy Disclaimer

Our services are non-clinical coaching and are not a substitute for psychotherapy, psychiatry, or medical treatment. If you are experiencing a mental health emergency, please call 911 or 988, or visit your local emergency room.

3. What Data We Collect

a) Information You Provide Directly

  • Name

  • Email address

  • Phone number

  • Coaching intake responses (optional)

  • Messages and feedback

  • Payment info (via Stripe – see Section 6)


b) Information Automatically Collected

Via Google Analytics:

  • Browser and device info

  • IP address (anonymized)

  • Geographic region (approximate)

  • Pages visited, time spent, and click paths


► NEW/AMENDED: New subsection added for EU/EEA clients.

c) Special Category Data (EU/EEA Clients Only)

For clients located in the European Economic Area (EEA), certain information collected during coaching may constitute “special category data” under GDPR Article 9. This includes data relating to mental health, behavioral health, and addiction status. We collect and process this data only on the basis of your explicit, informed consent, obtained in writing prior to the commencement of any coaching services.

You have the right to withdraw this consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

4. Why We Collect Your Data

We process your personal data to:

  • Deliver coaching services and respond to inquiries

  • Schedule sessions and send confirmations

  • Improve website usability and services

  • Comply with legal and billing requirements

  • Send occasional emails and/or text messages (with your opt-in consent)


Mobile Messaging Privacy: No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

► NEW/AMENDED: Section expanded to explicitly address special category (health/behavioral) data under GDPR Article 9 for EU/EEA clients.

5. Legal Bases (GDPR)

We rely on the following legal bases:

  • Consent (e.g., cookie pop-up, contact form)

  • Contractual necessity (e.g., providing services)

  • Legitimate interest (e.g., analytics)

  • Legal obligation (e.g., financial recordkeeping)


For EU/EEA clients: Where the data we process qualifies as special category data under GDPR Article 9 (including data relating to mental health, behavioral health, or addiction), we rely exclusively on explicit consent (Article 9(2)(a)) as our legal basis. This consent is obtained via a separate written consent form prior to the start of coaching. It is specific, informed, freely given, and unambiguous. You may withdraw it at any time by contacting us at [email protected].

6. Who We Share Your Data With

We only share your data with trusted service providers:

  • Stripe – for payment processing. Stripe collects and stores your payment details securely.

  • GoHighLevel – for hosting our website and CRM.

  • Google Analytics – for site performance analysis.

We do not sell your data.


► NEW/AMENDED: New subsection added for EU/EEA clients regarding third-party data processors.

a) Data Processing Agreements (EU/EEA Clients)

Each third-party service provider listed above that may process EU/EEA personal data on our behalf is required to have a Data Processing Agreement (DPA) in place consistent with GDPR requirements. We have confirmed or are in the process of confirming DPAs with each provider as follows:

  • Stripe: Certified under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (registration confirmed at dataprivacyframework.gov/participant/6436). PCI-DSS compliant for payment processing. DPA available at stripe.com/legal/dpa.

  • GoHighLevel: Certified under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework. SOC 2 Type II accredited. A downloadable Data Processing Agreement (DPA) is available within the account dashboard and has been executed.

  • Google Workspace / Google Analytics / Google Meet: Google LLC and its eligible U.S. subsidiaries are certified under the EU-U.S., Swiss-U.S., and UK Extension Data Privacy Frameworks. Google Meet (used for coaching sessions) is GDPR-compliant and adheres to DPF Principles. DPA in place.

  • CleanBrowsing: DNS-based content filtering tool used as part of the digital safety framework included in coaching programs. GDPR-compliant.

  • Accountable2You: Accountability and monitoring software used as part of the coaching program. GDPR-compliant.

7. Data Security

We take appropriate measures to protect your data:

  • TLS 1.2 or 1.3 encryption for data in transit

  • AES-256 encryption for data at rest

  • Strong password and access protocols

  • Secure storage of coaching records

Stripe is PCI-DSS compliant for secure financial transactions.

8. Data Retention

  • Coaching records: Retained up to 3 years post-service

  • Contact and email data: Up to 3 years


You may request deletion earlier. Upon receiving a written request from the CLIENT, sent via physical mail or email, the COACH will securely destroy any CLIENT-related files in their possession, whether physical or digital, that are still accessible at the time of the request. Destruction will be performed using commercially reasonable methods to prevent recovery (e.g., secure shredding for paper records, secure deletion software for digital files). This obligation does not apply to records the COACH is legally required to retain, such as invoices, payment records, or documentation necessary for resolving disputes, which will be securely destroyed once the retention period ends. The CLIENT acknowledges that some data may exist in automated system backups or archives outside the COACH’s direct control, which will be overwritten or purged in the normal course of business. (Also see Section 10.)

9. Cookies & Tracking

We use cookies (with your consent) for:

  • Website traffic analysis (via Google Analytics)

  • Improving site performance and navigation

You may disable cookies via your browser or refuse tracking via our cookie banner.

► NEW/AMENDED: Cookie consent updated to meet GDPR opt-in standard for EU/EEA visitors.

For visitors accessing our website from the EU/EEA, non-essential cookies (including analytics cookies) will not be placed on your device until you have given active, affirmative consent via our cookie consent banner. You may change or withdraw your cookie preferences at any time.

► NEW/AMENDED: Client rights section expanded with EU/EEA-specific provisions and response timelines per GDPR Article 12.

10. Your Rights Under GDPR

You may request to:

  • Access your data

  • Correct inaccurate data

  • Delete data

  • Restrict or object to processing

  • Withdraw consent

  • Receive a copy in portable format

Email us at: [email protected]

We respond to requests within 48 hours.

For EU/EEA clients: We will respond to all data subject requests within 30 days, as required by GDPR Article 12. In complex cases, this period may be extended by a further two months, and you will be notified. If you believe your rights have not been respected, you have the right to lodge a complaint with your local supervisory authority. For clients in the Netherlands, this is:

Autoriteit Persoonsgegevens (Dutch Data Protection Authority)

Website: autoriteitpersoonsgegevens.nl

Postal address: Hoge Nieuwstraat 8, 2514 EL Den Haag, The Netherlands

► NEW/AMENDED: International transfers section updated with EU-US Data Privacy Framework (DPF) detail and Standard Contractual Clauses.

11. International Data Transfers

Your data may be processed in the U.S. We ensure adequate safeguards are in place for all international transfers of personal data.

For EU/EEA clients: Transfers of your personal data from the EEA to the United States are made under one or more of the following lawful mechanisms:

  • EU-US Data Privacy Framework (DPF): All primary service providers used by DigitalAddictionCoach, LLC (GoHighLevel, Google, Stripe) are certified under the EU-U.S. Data Privacy Framework and its UK and Swiss extensions. This provides an adequate level of protection for personal data transferred from the EEA to the United States.

  • Standard Contractual Clauses (SCCs): For any ancillary processors not covered by DPF certification (including CleanBrowsing and Accountable2You), we rely on GDPR-compliant privacy policies and, where required, SCCs as the lawful transfer mechanism.

We do not transfer your personal data to any country or organization that does not provide adequate safeguards under GDPR Article 46.

12. Children’s Privacy

Our services are only for users 18 years and older. We do not knowingly collect data from minors. If this occurs, we will delete the data promptly.

13. Crisis Disclaimer

We do not provide emergency services. If you are in immediate danger, contact:

  • 911

  • 988 (U.S. Suicide & Crisis Lifeline)

  • Go to the nearest emergency room

► NEW/AMENDED: New section added for EU/EEA clients.

14. EU/EEA Client Consent Form

Prior to beginning coaching services, all EU/EEA clients will receive and must sign a separate EU Client Consent Form. This form:

  • Identifies the specific categories of personal data to be collected, including any special category data under GDPR Article 9

  • States the explicit purpose of each data type collected

  • Confirms the legal basis for processing

  • Explains how data is stored, who has access, and how long it is retained

  • Documents your freely given, specific, informed, and unambiguous consent

  • Explains how to withdraw consent

This form will be provided via email prior to the Discovery Call. Coaching services will not commence until the form is signed and returned.

15. Policy Updates

We may update this Privacy Policy from time to time. Revisions will be posted here with a new “Effective Date.”

16. Contact Us

DigitalAddictionCoach, LLC

2092 Merrymount Drive, Suwanee, GA 30024

Email: [email protected]

Website: https://digitaladdictioncoach.com

Digital Addiction Coach, LLC