Privacy Policy

1. Who we are

Ingrained ("we", "us") provides an AI-supported developmental coaching service for individual leaders. This policy explains what personal data we collect, why, and the rights you have over it. It applies to the website, the assessment, and the coaching application.

We act as the data controller for the personal data described here. Contact for privacy matters: privacy@ingrained.coach.

The service is for adults. You must be at least 18 to buy or use it, and we do not knowingly collect data from anyone under 18. If you believe a child has used the service, email us and we will delete the account and its data.

2. What we collect

Account data: email address and authentication credentials (managed by our authentication provider, Supabase).

Assessment data: your answers to the leadership assessment, the derived profile (level, dimension scores, cultural cluster), and intake answers (role level, experience, motivation).

Coaching data: your coaching session conversations (stored encrypted with AES-256), session summaries, reflection prompts and moment captures.

Payment data: handled by Stripe. We never see or store your card details — we store only the Stripe identifiers needed to manage your purchase or subscription.

Technical data: standard server logs (IP address, timestamps) kept for security and reliability.

Analytics data: if you have accepted analytics, anonymous product-usage events, and — separately and only if you accepted screen recording — recordings of the public and assessment pages with all typing masked. Section 7 sets this out in full.

Do you have to give us this? The account, assessment and coaching data is what the service is made of — without it there is nothing to deliver, so providing it is a condition of the contract rather than a legal requirement. Analytics and screen recording are optional and refusing them changes nothing about the product you get.

3. Our lawful bases for using it

Contract (UK/EU GDPR Art. 6(1)(b)) — everything needed to deliver what you bought: running the assessment, generating your profile, running coaching conversations, building the session-to-session memory that makes the coaching coherent, and taking payment.

Legal obligation (Art. 6(1)(c)) — keeping transaction records for tax and accounting.

Legitimate interests (Art. 6(1)(f)) — keeping the service secure, preventing fraud and abuse, and understanding which parts of the product work. Our interest is in running a service that is safe and gets better; we have weighed that against your privacy by keeping analytics cookieless, keeping your profile, coaching and account pages entirely out of it, and letting you object in one click.

Consent (Art. 6(1)(a)) — screen recording on the public and assessment pages, push notifications, and any marketing email. You can withdraw consent at any time, as easily as you gave it, and withdrawing does not affect anything done before you withdrew.

4. Sensitive information in coaching conversations

The assessment does not ask about your health, beliefs, sexuality, ethnicity or any other special category of data, and the profile does not try to infer them.

Coaching is open-ended, though, and people do sometimes mention therapy, a diagnosis, medication, a bereavement or something similar because it is genuinely part of what they are working through. If you do, that is special category data under Art. 9, and our condition for holding it is your explicit consent — which you give by choosing to type it, having read this.

You are never required to share anything of the kind, and the coaching works without it. If you would rather it were not held, you can delete individual sessions or your whole account at any time, and it is erased.

5. Automated processing and your profile

Your developmental profile is produced automatically. Your assessment answers are scored against the framework described on our Frameworks page, and the result places you at one of five stages with scores across four dimensions. No human reviews it before you see it.

It is a description offered back to you for your own reflection, not a decision about you. It does not determine what you can buy, what you are charged, or anything else with a legal or similarly significant effect, and we never send it to anyone else — least of all an employer. On that basis it is not the kind of solely automated decision-making that Art. 22 restricts.

You can still ask us to explain how a result was reached, tell us you disagree with it, ask for it to be corrected, or delete it entirely. Email privacy@ingrained.coach, or use the controls in your account.

Coaching replies are generated by an AI system rather than written by a person. We tell you this in the product itself, and our terms commit us to keeping that disclosure.

6. How we use your data

To deliver the service: generating your profile, running coaching sessions, building the session-to-session memory that makes the coaching coherent.

To process payments and manage subscriptions through Stripe.

To send service emails: profile links, data exports, and payment notices. We do not send marketing email without separate consent.

Your coaching conversations are sent to Anthropic’s Claude API to generate coaching responses. Under the commercial API terms we use, they are not used to train AI models. Anthropic may hold the API request briefly for its own safety and abuse checks before deleting it; it does not become training data at any point.

7. Cookies, analytics and screen recording

We always set one strictly necessary cookie — the authentication token that keeps you signed in. Under UK PECR that one needs no consent, but you should know it is there.

Product analytics (PostHog, hosted in the EU) runs cookieless, with no advertising features and no persistent identifier, and never receives your assessment results, your profile or anything from a coaching session. You can object in one click from the first-visit notice or your account, and no analytics code is loaded at all if you decline.

Screen recording is off unless you switch it on. If you do, it records the public and assessment pages only, with all typed input masked. It never runs on your profile, your coaching sessions or your account pages. You can withdraw that consent at any time.

We use no advertising cookies, no ad personalisation, and no cross-site tracking of any kind.

8. Where your data lives

Your data is stored in Supabase (PostgreSQL) hosted in the EU. Session transcripts are encrypted at the application level with AES-256 before storage.

Sub-processors: Supabase — Database and authentication (EU (Frankfurt)). Anthropic — AI coaching responses — enterprise API, never used to train models (US, under Standard Contractual Clauses). Stripe — Payment processing — card data never reaches our servers (US/EU, under Standard Contractual Clauses). Resend — Transactional email — profile links, receipts, data exports, and the daily prompt if you turn it on (US, under Standard Contractual Clauses). PostHog — Product usage analytics — cookieless, no advertising features. You can opt out at any time. Screen recording is off unless you accept it, and never runs on your profile, coaching or account pages (EU (Frankfurt)). Railway — Backend hosting (US, under Standard Contractual Clauses). Cloudflare — Frontend delivery — no personal data stored (Global edge).

Transfers outside the UK/EEA are made under the European Commission’s Standard Contractual Clauses, together with the UK Addendum issued by the ICO where the transfer is from the UK, as noted against each processor above. We assess each one to satisfy ourselves the protection travels with the data.

9. How long we keep it

Your data is kept while your account exists. If you delete your account, your profile, assessment, sessions, transcripts, memories, prompts, captures and any public share links are permanently erased. Feedback you submitted is stripped of anything identifying you.

Payment records are anonymised rather than deleted and retained for 7 years, because tax and accounting law requires us to keep transaction records. Coaching session data is retained for the duration of your subscription plus 30 days after cancellation. Assessment data is retained for as long as your account exists.

Saved profile links for non-account users expire after 30 days; the underlying assessment is retained so a purchased unlock remains accessible via its permanent link.

Server logs are kept for 90 days and then deleted. Analytics events are kept for 12 months. Screen recordings, if you consented to them, are kept for 30 days.

10. Your rights (UK GDPR / EU GDPR)

You have the right to access your data, to receive it in a portable form, to have it erased, to have it corrected, to restrict how we use it, to object to processing we base on legitimate interests, and not to be subject to solely automated decisions with legal or similarly significant effects.

Most of these you can exercise yourself, without asking us: Profile → Your data. Download all my data emails you a complete JSON export, which is also your portability right. Delete my account permanently erases your data as described above.

Where we rely on your consent — screen recording, push notifications, marketing email — you can withdraw it at any time and as easily as you gave it, from the same controls. Withdrawing does not make anything we did beforehand unlawful.

For anything the in-app controls do not cover, email privacy@ingrained.coach. We will respond within one month.

You can also complain to your data protection supervisory authority. In the UK that is the Information Commissioner’s Office (ico.org.uk, 0303 123 1113); in the EU it is the authority for the country you live in. You do not have to come to us first, though we would rather you did.

11. What we don’t do

We do not sell your data. We do not share it with employers — accounts are individual and self-funded, and there is no employer integration of any kind. We do not use your coaching conversations to train AI models. We do not use advertising trackers.

12. Changes

If this policy changes materially, we will notify you by email before the change takes effect. The latest version always lives at this address.