PRIVACY POLICY

The Evolved Caveman Inner Leadership AI Coach

Effective Date: 3/30/26 | Last Updated: 4/2/26

1. Introduction

Evolved Caveman AI, LLC (“Company,” “we,” “us,” or “our”) operates The Evolved Caveman Inner Leadership AI Coach (“AI Coach”). This Privacy Policy describes how we collect, use, disclose, retain, and protect your personal information when you use the AI Coach. It also describes your rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”), and the California Privacy Protection Agency’s Automated Decision-Making Technology (“ADMT”) regulations.

By using the AI Coach, you acknowledge that you have read and understood this Privacy Policy. If you do not agree to this Privacy Policy, do not use the AI Coach.

2. Information We Collect

2.1 Information You Provide Directly

• Account information: name, email address, and password when you create an account.
• Payment information: billing address and payment method details processed through our third-party payment processor. We do not store your full credit card number.
• Conversation data: the text of your interactions with the AI Coach, including your inputs (prompts) and the AI Coach’s responses. Conversation data is stored between sessions to enable continuity and personalization of your coaching experience.
• Consent records: your acknowledgment of disclosures and consent to the Terms of Service and this Privacy Policy.
• Support communications: any messages you send to us regarding the Product.

2.2 Information Collected Automatically

• Usage data: session timestamps, session duration, feature usage patterns, and interaction frequency.
• Device and browser information: IP address, browser type, operating system, and device identifiers.
• Safety event logs: if the AI Coach’s crisis safety protocol is triggered during a conversation, we log the occurrence of the trigger event, the timestamp, and the AI Coach’s safety response. This logging is required for compliance with California SB 243.

Beginning July 1, 2027, as required by California SB 243, the Company will publish an annual report documenting how often crisis safety protocols were triggered and how they functioned. These reports will contain aggregated, de-identified data and will not identify individual users.

2.3 Information from Third Parties

We may receive information from our third-party payment processor confirming your subscription status and payment history.

3. How We Use Your Information

Purpose

Categories of Data Used

Provide and operate the AI Coach

Account information, conversation data, usage data

Store conversation history between sessions

Conversation data (linked to your account)

Process payments and manage subscriptions

Account information, payment information

Comply with SB 243 safety requirements

Safety event logs, conversation data (crisis-triggered only)

Improve product quality and safety

Aggregated and de-identified usage data, safety event logs

Respond to support requests

Account information, support communications

Enforce Terms of Service

Account information, usage data, conversation data

Comply with legal obligations

All categories as required by law

4. How We Share Your Information

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.

We share personal information only in the following circumstances:

• Service providers: We use third-party service providers to operate the AI Coach. These include Anthropic (AI model provider—your conversation inputs are sent to Anthropic’s API to generate responses), Supabase (database hosting and authentication), Cloudflare (content delivery, security, and edge computing), and our payment processor. Each provider processes data only as necessary to perform its function and is subject to contractual data protection obligations.
• Regarding Anthropic specifically: your conversation inputs are transmitted to Anthropic’s API servers to generate responses. Anthropic’s data handling practices, including whether and how it retains API inputs, are governed by Anthropic’s API terms of service (available at anthropic.com/policies). The Company has selected API configurations designed to minimize third-party data retention. The Company reviews Anthropic’s terms no less than annually.
• Legal requirements: We may disclose personal information if required by law, subpoena, court order, or governmental request, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.
• Business transfers: If the Company is involved in a merger, acquisition, or sale of assets, your personal information may be transferred as part of that transaction. We will provide notice before your information is subject to a different privacy policy.
• With your consent: We may share information for other purposes with your explicit consent.

5. Automated Decision-Making Technology (ADMT)

The AI Coach uses automated decision-making technology to generate coaching responses based on your inputs. Under California’s ADMT regulations (effective 2026), you have the right to know when automated decision-making technology is being used and how it processes your information.

How the AI Coach’s ADMT works: When you submit a message, it is sent to a third-party large language model (currently Anthropic’s Claude API) along with the Company’s proprietary system instructions and relevant content from the Company’s knowledge base. The model generates a response based on these inputs. No human reviews individual conversations in real time.

Decisions made by ADMT: The AI Coach’s ADMT generates coaching responses, triggers crisis safety protocols when distress signals are detected, and determines which knowledge base content is relevant to your input. It does not make decisions about your creditworthiness, employment, housing, insurance, or access to essential services.

Your rights regarding ADMT: You have the right to opt out of certain automated decision-making processes as provided by California law. Because the AI Coach’s core function is AI-generated coaching, opting out of ADMT would mean discontinuing use of the Product. You may exercise this right by canceling your subscription and requesting account deletion.

6. Data Retention

• Account information: Retained while your account is active and for 24 months after account closure for legal and compliance purposes.
• Conversation data: Retained while your account is active. Deleted within 60 days of account deletion request, except as described below.
• Safety event logs: Retained for a minimum of three (3) years from the date of the event, as required for SB 243 compliance reporting and potential legal defense purposes. Safety event logs may be retained longer if related to a pending or threatened legal claim.
• Payment records: Retained for seven (7) years as required by tax and financial regulations.
• Aggregated and de-identified data: May be retained indefinitely for product improvement, research, and reporting purposes. Aggregated data cannot be used to identify you.
• Legal hold exception: If any of your data is subject to a pending or reasonably anticipated legal claim, investigation, or regulatory proceeding, we may retain that data beyond the standard retention periods described above until the matter is fully resolved, regardless of a deletion request. We will notify you if your deletion request is subject to a legal hold, to the extent permitted by law.

7. Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights under the CCPA/CPRA:

• Right to know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the sources of collection, the business purposes for collection, and the categories of third parties with whom we share it.
• Right to delete: You may request that we delete your personal information, subject to certain exceptions (including legal compliance and safety event retention as described in Section 6).
• Right to correct: You may request that we correct inaccurate personal information.
• Right to opt out of sale/sharing: We do not sell or share your personal information for cross-context behavioral advertising. No opt-out is required.
• Right to limit use of sensitive information: Conversation data may contain sensitive personal information. We use sensitive personal information only for the purposes described in this Privacy Policy. You may request that we limit our use of sensitive personal information to what is necessary to provide the AI Coach service.
• Right to non-discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise any of these rights, contact us at John@GuideToSelf.com. We will verify your identity before processing your request. We will respond to verifiable consumer requests within 45 days, or notify you if we need an extension of up to 45 additional days.

8. Data Security

We implement reasonable technical and organizational measures to protect your personal information, including: encrypted data storage in Supabase; encrypted data transmission via HTTPS; API key management through Cloudflare Worker secrets (not stored in public code repositories); access controls limiting data access to authorized personnel only; and regular security review of third-party service configurations.

No method of electronic transmission or storage is completely secure. While we take reasonable precautions, we cannot guarantee the absolute security of your personal information. If we become aware of a data breach affecting your personal information, we will notify you within thirty (30) calendar days of discovery in compliance with California Civil Code § 1798.82 (as amended by SB 446). If the breach affects more than 500 California residents, we will also notify the California Attorney General.

9. Children’s Privacy

The AI Coach is intended for adults aged 18 and older. We do not knowingly collect personal information from individuals under 18. If we learn that we have collected personal information from a person under 18, we will take steps to delete that information promptly. If you believe a minor has provided personal information to us, please contact us at John@GuideToSelf.com.

10. Third-Party Services and Links

The AI Coach may reference or link to third-party websites, services, or resources (including crisis hotlines and support services). We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party service you access.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide notice through the Product, by email, or by other reasonable means at least thirty (30) days before the changes take effect. Your continued use of the AI Coach after the effective date of an updated Privacy Policy constitutes your acceptance of the changes.

12. Contact Us

Evolved Caveman AI, LLC

Email: John@GuideToSelf.com

Website: https://theevolvedcaveman.com

For CCPA/CPRA requests, include “Privacy Rights Request” in the subject line.