Privacy Policy

This Privacy Policy for Sardorbek Rakhimov ("Developer", "we", "us", or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Download and use our mobile application (Coach Journal), or any other application of ours that links to this Privacy Policy
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@coachjournal.app.

Summary of Key Points

This summary provides key points from our Privacy Policy, but you can find out more details about any of these topics by reading the full policy below.

• What personal information do we process? We process personal information you provide to us, including coach and athlete/client data, as well as consumption data (information about how you use purchased features, such as session duration, feature access, and subscription status) related to in-app purchases.
• Do we process sensitive personal information? No. We only collect basic contact information, subscription details, and attendance records.
• Do we collect information from minors? We may process minor athlete data only with appropriate parental/guardian consent obtained by coaches.
• How do we process your information? We process your information to provide, improve, and administer our Services, for security, and to comply with law.
• When do we share personal information? We share information with service providers, and specifically with Apple Inc. for payment processing, authentication (Sign in with Apple), and purchase verification purposes. By accepting this policy, you consent to this data sharing.
• What are your rights? Depending on your location, you may have rights to access, correct, delete, or restrict processing of your personal information.
• How do you exercise your rights? Contact us at support@coachjournal.app to exercise your rights.

Table of Contents

1. What Information Do We Collect?
2. How Do We Process Your Information?
3. What Legal Bases Do We Rely On?
4. When and With Whom Do We Share Your Personal Information?
5. Third-Party Services and Processors
6. Local Storage and Data Persistence
7. How Do We Handle Your Social Logins?
8. App Store Integration and Data Sharing
9. Consumption Data Collection and Use
10. Is Your Information Transferred Internationally?
11. How Long Do We Keep Your Information?
12. How Do We Keep Your Information Safe?
13. Do We Collect Information From Minors?
14. What Are Your Privacy Rights?
15. Privacy Rights Under GDPR (European Users)
16. Privacy Rights Under CCPA (California Residents)
17. Controls for Do-Not-Track Features
18. Other US State Privacy Rights
19. Data Breach Procedures
20. Do We Make Updates to This Policy?
21. How Can You Contact Us About This Policy?
22. How Can You Review, Update, or Delete Your Data?

1. What Information Do We Collect?

Coach Account Information

When you register as a coach via social sign-in (Google Sign-In or Sign in with Apple), we collect:

• Name and email address (provided by your sign-in provider)
• Profile picture (if shared by your sign-in provider)
• Unique identifier from the sign-in provider
• Payment and billing information (processed through App Store/Play Store)

Athlete/Client Data (Managed by Coaches)

Coaches using Coach Journal may input information about their athletes and clients, including:

• Contact and identification information
• Subscription and payment details
• Attendance and session records
• Business notes and records at the coach's discretion

Note: Coaches act as data controllers for the client data they input. Coach Journal processes this data on behalf of coaches to provide the service. Coaches are responsible for ensuring their data practices comply with applicable laws.

Automatically Collected Information

When you use our app, we automatically collect:

• Device information (model, operating system, unique device identifiers)
• App usage data (features used, session duration, crash reports)
• IP address and general location (city/region level)
• App performance data and error logs
• Consumption and usage metrics for purchased features (see Section 9 for details)

Information from Third-Party Services

We may receive information from:

• Social login: If you choose social login (e.g., Google Sign-In)
• Sign in with Apple: Name, email address (or private relay email), and Apple user ID
• Apple App Store: Transaction confirmations, purchase receipts, subscription status, and renewal information via App Store Server Notifications
• Google Play Store: Transaction confirmations for Android users
• RevenueCat: Subscription analytics and consumption data processing
• Analytics services: Aggregated usage patterns and app performance metrics

For more details about data received from Apple and how it's used, see Section 8 (Apple App Store Integration).

2. How Do We Process Your Information?

We process your personal information for various legitimate purposes, including:

Service Delivery

• To create and manage coach accounts
• To enable coaches to manage athlete/client profiles
• To facilitate training plan creation and tracking
• To process payments through App Store/Play Store
• To provide customer support
• To send important service notifications

Service Improvement

• To analyze app usage and improve features
• To fix bugs and technical issues
• To develop new features based on user needs
• To conduct internal research and analytics

Legal and Security

• To comply with legal obligations
• To protect against fraud and abuse
• To enforce our terms of service
• To protect the rights and safety of users

Marketing and Communication

• To send optional marketing communications (with consent)
• To inform about new features and updates
• To request feedback and conduct surveys

3. What Legal Bases Do We Rely On?

We process your personal information only when we have a valid legal reason to do so. Our legal bases include:

Contract Performance

We process your information to fulfill our contractual obligations to you, including providing the Coach Journal services you've subscribed to.

Legitimate Interests

We process information for our legitimate business interests, including:

• Improving and securing our services
• Preventing fraud and abuse
• Internal analytics and research
• Responding to legal requests

Consent

Where required by law, we process information based on your explicit consent, which you may withdraw at any time. This includes:

• Marketing communications
• Data sharing with Apple for purchase verification (see Section 8)

Legal Obligations

We process information when necessary to comply with legal obligations, such as responding to court orders or regulatory requirements.

Vital Interests

In rare cases, we may process information to protect someone's vital interests, such as in medical emergencies.

4. When and With Whom Do We Share Your Personal Information?

We do not sell, rent, or trade your personal information. We may share information only in the following situations:

With Your Consent

We may share your information for any purpose with your explicit consent.

Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

Legal Requirements

We may disclose your information where legally required to do so, including:

• To comply with a subpoena or similar legal process
• When we believe disclosure is necessary to protect our rights
• To protect your safety or the safety of others
• To investigate fraud
• To respond to government requests

Service Providers

We share information with third-party service providers who perform services on our behalf, subject to confidentiality agreements.

Data Sharing with Apple Inc.

We share specific consumption and usage data with Apple Inc. for the following purposes:

• Authentication: If you use Sign in with Apple, authentication data is shared with Apple
• Payment Processing: Purchase and subscription data is processed through the App Store
• Purchase Verification: Consumption data is shared to verify purchase authenticity and support Apple's transaction review process

By accepting this Privacy Policy, you explicitly consent to this data sharing with Apple.For comprehensive details about what data is shared with Apple and how it's used, please see Section 8 (Apple App Store Integration and Data Sharing).

5. Third-Party Services and Processors

We work with the following categories of third-party service providers:

Infrastructure and Hosting

• Supabase: Database hosting and authentication services (US East - Ohio region)
• Netlify: Web application hosting

Payment Processing

• Apple App Store: In-app purchase processing for iOS users
• Google Play Store: In-app purchase processing for Android users

Note: We do not directly handle payment card information. All payment processing is handled securely by Apple and Google through their respective platforms.

Subscription Management and Analytics

• RevenueCat: SOC2-certified subscription analytics, management, and purchase verification service. RevenueCat processes consumption data and facilitates data sharing with Apple for purchase verification purposes. See Section 8 for details about RevenueCat's role in Apple data sharing.

Analytics and Performance

• PostHog: Product analytics — receives pseudonymous user ID and usage data
• Sentry: Crash reporting — receives pseudonymous user ID and error data

All third-party service providers are contractually obligated to protect your information and may only use it for the specific purposes we've authorized.

Data Controller and Processor Roles

When coaches use Coach Journal to manage client or athlete data, they act as the data controller under applicable data protection laws (including GDPR), meaning they determine the purposes and means of processing that data. Coach Journal acts as a data processor, processing client data on behalf of coaches solely to provide the Services.

Coaches are responsible for ensuring they have appropriate legal bases (such as consent) to collect and process their clients' personal information through the App.

6. Local Storage and Data Persistence

As a mobile application, Coach Journal uses local storage technologies on your device to provide offline functionality and improve your experience.

Types of Local Storage We Use

• Local Database: Stores your athlete/client data locally for offline access
• App Preferences: Remembers your settings (language, theme, etc.)
• Authentication Tokens: Securely stored credentials for automatic login
• Cache: Temporary data for faster app performance

How We Use Local Storage

• Offline Access: Access your data without internet connection
• Preferences: Remember your language and display settings
• Performance: Reduce loading times and improve responsiveness
• Security: Securely store authentication information

Managing Local Data

You can clear local app data through your device settings or by uninstalling the app. Note that clearing data will remove offline access to your information until it syncs again.

7. How Do We Handle Your Social Logins?

Our Services offer you the ability to register and log in using your third-party account details (Google Sign-In or Sign in with Apple).

If you choose to register or log in using a social media account, we may access certain information from that social media provider, including:

• Your name and email address
• Your profile picture
• Your user ID for that social media service

We will use the information we receive only for the purposes described in this Privacy Policy or otherwise made clear to you. Please note that we do not control, and are not responsible for, how your third-party social media provider uses your information.

8. App Store Integration and Data Sharing

In Short: We integrate with Apple services including Sign in with Apple and App Store for payments. We share specific consumption data with Apple Inc. for purchase verification purposes, and you consent to this sharing by accepting this Privacy Policy.

Sign in with Apple

Coach Journal supports Sign in with Apple as an authentication option. When you use Sign in with Apple, we receive:

• Your name (if you choose to share it)
• Your email address (or Apple's private relay email)
• A unique Apple user identifier

This information is used solely for account creation and authentication. Apple's privacy practices are governed by their own privacy policy, available at https://www.apple.com/legal/privacy/.

App Store Payment Processing

All in-app purchases and subscriptions are processed through the Apple App Store. When you make a purchase, Apple processes your payment information. We receive only:

• Transaction confirmation (purchase successful/failed)
• Transaction ID and receipt information
• Subscription status and expiration dates
• Product purchased and pricing tier

Important: We never receive or store your payment card details. All payment information is handled securely by Apple.

Data Shared with Apple Inc.

To protect against fraudulent refund requests and ensure fair service for all users, we share certain consumption and usage data with Apple Inc. through our purchase verification service provider, RevenueCat. This data sharing is performed via Apple's App Store Server Notifications V2 API.

What Data We Share with Apple:

• Purchase Information: Total amount spent, transaction history, refund history
• Usage Metrics: Total app usage time, time since installation, session frequency
• Consumption Status: Whether purchased features/subscriptions were actively used
• Account Information: Account age, user status (active/inactive)

Why We Share This Data:

This data is shared exclusively for fraud protection. When users request refunds from Apple, this consumption data helps Apple make informed decisions about refund requests based on actual product usage. This protects honest users and helps maintain fair pricing.

How Data Sharing Works:

1. User requests a refund through Apple App Store
2. Apple sends a notification to our purchase verification service (RevenueCat)
3. RevenueCat analyzes the user's consumption data
4. Consumption data is shared with Apple via Server Notifications V2
5. Apple considers this data when making the refund decision
6. Apple makes the final decision (we do not control refund outcomes)

RevenueCat as Data Processor:

We use RevenueCat, a SOC2-certified service provider, to facilitate consumption data sharing with Apple. RevenueCat acts as a data processor on our behalf and is contractually obligated to:

• Process data only for purchase verification purposes
• Maintain appropriate security measures
• Not use data for any other purpose
• Comply with all applicable data protection laws

Your Consent to Apple Data Sharing

Your Rights Regarding Apple Data Sharing

You have the right to:

• Access: Request information about what consumption data has been shared with Apple
• Withdraw Consent: Discontinue use of in-app purchases to stop future data sharing (note: withdrawal does not affect previously shared data)
• Delete: Request deletion of your account and associated consumption data

To exercise these rights, contact us at support@coachjournal.app.

Apple's Privacy Policy

For information about how Apple handles data shared with them, please review Apple's Privacy Policy at: https://www.apple.com/legal/privacy/

Platform Limitation

Note: Consumption data sharing with Apple only applies to iOS users making purchases through the Apple App Store. Android users (Google Play Store) are not subject to this data sharing.

Google Play Store

For Android users, in-app purchases and subscriptions are processed through the Google Play Store. When you make a purchase on Android, Google processes your payment information. We receive only transaction confirmations, subscription status, and product details. We never receive or store your payment card details. Google's privacy practices are governed by their own privacy policy, available at https://policies.google.com/privacy. RevenueCat also facilitates subscription management and analytics for Google Play purchases, subject to the same data processor obligations described above.

9. Consumption Data Collection and Use

In Short: We collect detailed consumption and usage data related to your in-app purchases and subscriptions to provide services, prevent fraud, and improve our app.

What is Consumption Data?

Consumption data refers to information about how you use the features and services you've purchased or subscribed to in Coach Journal. This includes both purchase-related data and usage patterns.

Types of Consumption Data We Collect

Purchase and Transaction Data:

• Transaction IDs and purchase timestamps
• Products and subscriptions purchased
• Purchase amounts and pricing tiers
• Payment status (successful, failed, pending)
• Subscription start dates, renewal dates, and expiration dates
• Trial period usage and conversion status
• Refund requests and refund history
• Total amount spent in the app
• Total amount previously refunded (if applicable)

Feature Usage Data:

• Which premium features you access and how frequently
• Time spent using specific paid features
• Number of athletes/clients managed (for premium tiers)
• Training plans created and templates used
• Data export and backup usage
• Advanced analytics feature usage

App Usage Metrics:

• Total app usage time (session duration and frequency)
• Time since initial app installation
• Account tenure and activity status
• Login frequency and session patterns
• Feature engagement levels
• Whether the app was actively used after purchase

Subscription Status Data:

• Current subscription tier and status (active, expired, cancelled)
• Auto-renewal settings
• Subscription lifecycle events (upgrades, downgrades, cancellations)
• Grace period and billing retry information

How We Use Consumption Data

Service Delivery:

• Activate and manage your subscriptions
• Provide access to premium features
• Process upgrades and downgrades
• Handle billing and payment processing
• Verify purchase entitlements

Fraud Prevention and Security:

• Detect and prevent fraudulent refund requests
• Identify unusual purchase patterns or suspicious activity
• Share consumption data with Apple for refund decision-making (as detailed in Section 8)
• Protect against subscription sharing abuse

Service Improvement:

• Understand which features provide the most value to users
• Identify underutilized premium features for improvement
• Optimize pricing tiers and subscription offerings
• Analyze conversion rates from free to paid tiers
• Measure feature adoption and engagement

Customer Support:

• Troubleshoot subscription and payment issues
• Verify purchase history when assisting with account problems
• Restore purchases on new devices
• Process legitimate refund requests

Analytics and Business Intelligence:

• Generate aggregated reports on app performance
• Analyze revenue metrics and subscription retention
• Measure customer lifetime value
• Identify churn patterns and reasons for cancellation

Data Sources and Collection Methods

Consumption data is collected from multiple sources:

• Apple App Store: Purchase receipts, transaction data, and subscription status via StoreKit and App Store Server Notifications
• In-App Tracking: Feature usage monitored through our analytics SDK
• RevenueCat SDK: Subscription management and analytics platform
• Device Analytics: Session duration, app opens, and engagement metrics (if you've granted tracking permission)

Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), UK, and Switzerland, we process consumption data based on:

• Contract Performance: Necessary to deliver the subscription services you've purchased
• Legitimate Interests: Fraud prevention, service improvement, and business analytics
• Consent: When required by law, particularly for sharing data with Apple

Your Rights

You have the right to:

• Access your consumption data
• Request correction of inaccurate data
• Delete your consumption data (subject to legal retention requirements)
• Export your purchase history
• Object to processing for analytics purposes

To exercise these rights, contact us at support@coachjournal.app.

10. Is Your Information Transferred Internationally?

In Short: We store and process your information in the United States.

Our servers and databases are hosted on Supabase infrastructure located in the US East (Ohio) region. We do not store data in other locations.

If you are accessing our Services from outside the United States, please be aware that your information will be transferred to, stored, and processed in the United States. The United States may have data protection laws that are different from the laws of your country of residence.

European Union Users

For users in the European Economic Area (EEA), United Kingdom (UK), and Switzerland, such transfers are necessary for the performance of the contract between you and us (providing the Services). We implement appropriate safeguards for international data transfers, including:

• Standard contractual clauses approved by regulatory authorities
• Technical and organizational security measures
• Data processing agreements with our service providers

By using our Services, you acknowledge and consent to the transfer, storage, and processing of your information in the United States.

11. How Long Do We Keep Your Information?

We retain your personal information only as long as necessary to:

• Provide the services you requested
• Comply with legal obligations (such as tax and accounting requirements)
• Resolve disputes and enforce our agreements

When data is no longer needed for these purposes, we delete or anonymize it.

Third-Party Services

Data shared with third parties (such as Apple, Google Play, and RevenueCat) is subject to their respective privacy policies and retention practices, as they act as independent data controllers for such processing.

To Delete Your Data

• In the app: Go to Profile → Delete Account
• By email: Contact support@coachjournal.app

12. How Do We Keep Your Information Safe?

In Short: We implement comprehensive technical and organizational security measures to protect your personal information.

Technical Safeguards

• Encryption: Data encrypted in transit using TLS/SSL protocols
• Database security: Encrypted at rest in Supabase infrastructure
• Access controls: Role-based access with multi-factor authentication
• Secure APIs: Authentication tokens and rate limiting
• Regular updates: Security patches and vulnerability scanning

Organizational Measures

• Limited access to personal data on need-to-know basis
• Confidentiality agreements for personnel
• Regular security training and awareness
• Incident response procedures
• Regular security assessments

Your Security Responsibilities

You also play a vital role in keeping your information safe:

• Use strong, unique passwords
• Keep your login credentials confidential
• Log out when using shared devices
• Keep your device and app updated
• Report suspicious activity immediately

Despite our safeguards, no electronic transmission or storage system is 100% secure. If you have reason to believe your interaction with us is no longer secure, please immediately notify us.

13. Do We Collect Information From Minors?

In Short: We do not directly collect information from minors. Coaches are responsible for obtaining appropriate consent for minor athlete data.

Coach Accounts

Coach Journal is intended for use by adults 18 years and older. We do not knowingly allow minors to create coach accounts.

Minor Athlete Data

Coaches may manage profiles for minor athletes (under 18). When doing so, coaches must:

• Obtain verifiable parental or guardian consent before collecting minor data
• Only collect information necessary for legitimate coaching purposes
• Ensure parents/guardians can access and delete their child's information
• Comply with all applicable laws regarding minors' data (including COPPA in the US)

Coach Responsibilities

By using Coach Journal to manage minor athlete data, coaches represent and warrant that they:

• Have obtained all necessary consents from parents/guardians
• Will only use minor data for legitimate coaching purposes
• Will delete minor data within 30 days of receiving a valid parent/guardian request
• Will notify us immediately of any unauthorized access to minor data

Parent/Guardian Rights

Parents or guardians who believe we have information about their child should contact us immediately. Upon verification, we will:

• Provide information about what data we have
• Delete the child's information upon request
• Prevent further collection of the child's information

14. What Are Your Privacy Rights?

In Short: You have rights to access, correct, delete, and control your personal information.

Your Rights Include

• Access: Request a copy of your personal information
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your personal information
• Portability: Receive your data in a portable format
• Restriction: Request we limit processing of your information
• Object: Object to certain types of processing
• Withdraw consent: Withdraw previously given consent

Account Management

You can review and update your account information at any time by:

• Logging into your account settings
• Contacting us directly for assistance

Marketing Communications

You can opt-out of marketing communications at any time by:

• Clicking the unsubscribe link in any marketing email
• Updating your communication preferences in account settings
• Contacting us directly

Response Time

We will respond to your rights requests within 30 days (or sooner if required by law). We may need to verify your identity before processing your request.

15. Privacy Rights Under GDPR (European Users)

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR):

Additional Rights

• Right to be informed: Clear information about our data processing
• Right to object: Object to processing based on legitimate interests
• Rights related to automated decision-making: Not to be subject to decisions based solely on automated processing
• Right to lodge a complaint: File a complaint with your local data protection authority

Legal Basis for Processing

We will only process your personal data when we have a valid legal basis, including: consent, contract, legal obligations, vital interests, public task, or legitimate interests.

Data Protection Officer

For GDPR-related inquiries, you can contact our data protection representative at:support@coachjournal.app

Supervisory Authority

You have the right to lodge a complaint with your local supervisory authority if you believe we have not complied with applicable data protection laws.

16. Privacy Rights Under CCPA (California Residents)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA):

Your CCPA Rights

• Right to know: What personal information we collect, use, share, or sell
• Right to delete: Request deletion of your personal information
• Right to opt-out: Opt-out of the sale of personal information (Note: We do not sell personal information)
• Right to non-discrimination: Equal service and pricing regardless of exercising privacy rights

Categories of Information We Collect

• Identifiers (name, email, phone number)
• Customer records (account information, payment records)
• Internet activity (app usage, interactions)
• Professional information (coaching credentials)
• Inferences (preferences derived from usage)

How to Exercise Your Rights

California residents can submit requests by:

• Email: support@coachjournal.app
• Include "California Privacy Rights" in the subject line

Verification Process

We will verify your identity before processing requests by asking for information that matches our records. We will not discriminate against you for exercising your rights.

"Do Not Sell" Disclosure

We do not sell, rent, or trade your personal information to third parties for monetary or other valuable consideration.

17. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature that signals your privacy preference not to have data about your online browsing activities monitored and collected.

Currently, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

18. Other US State Privacy Rights

Residents of certain US states have additional privacy rights:

Colorado, Connecticut, Virginia, and Utah

Residents of these states have rights similar to CCPA, including:

• Right to access and portability
• Right to correct inaccuracies
• Right to deletion
• Right to opt-out of certain data processing

Nevada

Nevada residents may opt-out of the sale of certain personal information. We do not sell personal information as defined under Nevada law.

How to Exercise State Privacy Rights

To exercise your state privacy rights, contact us at:support@coachjournal.appand specify your state of residence.

19. Data Breach Procedures

In the event of a data breach that may affect your personal information:

Our Response

• Investigate and contain the breach immediately
• Assess the risk to affected individuals
• Notify affected users within 72 hours (where feasible)
• Notify relevant regulatory authorities as required by law
• Document the breach and our response

User Notification

If a breach affects you, we will notify you via:

• Email to your registered email address
• In-app notification
• Prominent notice on our website

Information Provided

Our breach notification will include:

• Description of what happened
• Types of information involved
• Steps we've taken to address the breach
• Steps you can take to protect yourself
• Contact information for questions

20. Do We Make Updates to This Policy?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws and to reflect changes in our practices.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last Updated" date at the top of this Privacy Policy.

If we make material changes to this Privacy Policy, we will notify you either by:

• Prominently posting a notice of such changes
• Sending you a notification through the app
• Emailing you at your registered email address

We encourage you to review this Privacy Policy frequently to stay informed of how we are protecting your information.

21. How Can You Contact Us About This Policy?

If you have questions or comments about this policy, you may contact our data privacy representative:

Please allow up to 30 days for a response. For urgent matters, please indicate "URGENT" in your subject line.

22. How Can You Review, Update, or Delete Your Data?

You have the right to request access to, correction of, or deletion of your personal information.

Delete Your Account (In-App)

To delete your account and all associated data:

• Log into your account
• Navigate to Profile → Delete Account
• Confirm deletion when prompted

Access or Export Your Data (By Request)

To request a copy of your personal data or information about what we store, contact us at support@coachjournal.app with the subject line "Data Access Request" or "Data Export Request".

In your request, please include:

• Your account email address
• Whether you want to view your data or receive an exportable copy

Correction Requests

To correct inaccurate personal information:

• Update your profile information directly in the app
• Contact us at support@coachjournal.app for data you cannot edit yourself

Verification

For your security, we will verify your identity before processing any data access, export, or deletion request. This may include confirming your account email or answering security questions.

Response Time

We will acknowledge your request within 5 business days and complete processing within:

• Data access/export requests: 30 days
• Deletion requests: 30 days
• Correction requests: 15 business days

For complex requests, we may extend the response time by an additional 30 days with notice to you.