3DeepCoaching LLC · Draper, Utah
This Privacy Policy explains how 3DEEPCOACHING LLC (“3Deep Coaching,” “we,” “us,” or “our”) collects, uses, discloses, and protects information in connection with Pulse, our coaching companion application featuring the AI reflection companion Lily, and our related session-booking page (together, the “Service”). It applies to information collected from clients who are invited to use the Service by their coach, Jill DePompei-Morales.
This Privacy Policy is incorporated by reference into, and should be read together with, the Pulse Terms and Conditions. If there is a conflict between the two documents regarding data practices, this Privacy Policy controls.
3Deep Coaching is a Utah coaching practice with its principal place of business at Draper, Utah. For purposes of the Utah Consumer Privacy Act and similar laws, 3Deep Coaching is the “controller” of the personal data described in this Policy and the party that decides why and how it is processed.
Pulse is invitation-only: there is no public sign-up, and you receive access because you are, or are becoming, a coaching client of 3Deep Coaching. At onboarding, you are assigned an opaque, anonymous identifier (a “token”). Most of what the Service collects about you is keyed to that token rather than to your name.
Your name, which is held only in a private lookup that Jill alone can read, connecting your token to your identity for purposes of the coaching relationship; your daily check-in data, meaning your Head, Heart, and Body readings, your Gate result, any active parts of self and protective patterns you note, your Flow practice selections, and your LEAP entries; your Inner Compass (Enneagram) type and your coaching track; your habit selections and streaks; your full chat history with Lily; anything you affirmatively choose to share with Jill, including scenarios you submit to the shared learning library; and, if you book live sessions through the Service, your name, email address, and appointment details.
We do not collect your device’s precise location, your contacts, or any data from outside the app. Pulse does not access your device’s camera, microphone, photos, or other apps.
The full detail of your check-ins, habits, chat history, and in-progress drafts is stored on your device and is readable only by you. A private backup of that full state is maintained in a store accessible only to 3Deep Coaching as the service owner, not to Jill. Your role, track, Inner Compass, and display name are stored in a profile record accessible to the app and to Jill. A separate, deliberately limited coach-facing record holds your Gate result, streak, a rolling week-by-week history, your most frequent parts of self, and your last LEAP. This is what Jill sees day to day. Anything you deliberately share with Jill, such as a summary or a thread from a conversation, is stored in a further record visible to her. If you choose to flag a specific exchange with Lily for Jill’s attention, that specific exchange, and only that exchange, becomes visible to her. If 3Deep Coaching runs a post-engagement survey, your responses to it are stored separately and are reviewed only by 3Deep Coaching’s administrative staff.
We use the information described above to: operate and provide the Service, including your daily check-ins, Flow practices, habit tracking, and the LEAP framework; power Lily’s reflective conversations with you, as described in Section 5; give Jill the limited, aggregated view of your progress described in Section 3.3, so she can coach you effectively; operate the shared learning library, if you choose to participate; schedule and manage live coaching sessions you book; maintain the security and integrity of the Service; and comply with our legal obligations.
We do not sell your personal data. We do not use your personal data for third-party advertising or marketing. We do not use your check-in data, chat history, or any other personal data to train artificial intelligence models, ours or anyone else’s.
You are interacting with artificial intelligence. Lily is an AI system, not a human being. No one reviews or responds to your messages to Lily in real time.
When you message Lily, your message and relevant conversation context are transmitted to Anthropic, the maker of the Claude AI models, which generates Lily’s reply on our behalf. Anthropic receives your anonymous token and conversation context, never your name. As of the date this Policy was prepared, Anthropic’s business terms provide that it does not train its models on this content and retains it only as needed to provide the service and for limited trust-and-safety purposes. If we change AI providers, we will update this section.
Lily does not detect, score, or act on risk indicators in what you say. She does not decide to notify Jill or anyone else based on the content of your conversation. Anything Jill learns about a conversation with Lily is because you chose to share it with her, or because you affirmatively flagged a specific exchange for her attention.
We share personal data only in the following circumstances:
With Anthropic, as described in Section 5, solely to generate Lily’s responses.
With service providers who help us host, run, and secure the Service, such as our cloud hosting provider and, if you book paid sessions, our payment processor. These providers are permitted to use your information only to provide services to us, not for their own purposes.
With Jill, limited to the coach-facing data described in Section 3.3, plus anything you affirmatively choose to share with her.
If required by law, such as in response to a valid subpoena, court order, or similar legal process, or where we believe in good faith that disclosure is necessary to protect the rights, property, or safety of 3Deep Coaching, our clients, or the public.
In connection with a merger, acquisition, financing, or sale of business assets, subject to confidentiality protections.
We do not share your personal data with advertisers, data brokers, or other third parties for their own marketing purposes, and we do not sell your personal data.
If you opt in to submit a scenario to the shared learning library, that submission is reviewed by Jill before publication. If approved, it is anonymized before being added to the library your token, name, email address, and other identifying details are removed. Submission is opt-in and scenario-by-scenario; submitting one scenario is not consent to share anything else. See Section 8 of the Pulse Terms and Conditions for the license terms that apply to approved submissions.
We retain your personal data for as long as your account remains active, and for ninety (90) days after your account is closed, unless you request earlier deletion or we are required to retain it longer to comply with law, resolve disputes, or enforce our agreements. You may request export of your data, wipe your local app data, or request full deletion of your account, including the token-to-name lookup at any time by contacting jill@3deepcoaching.com.
We use administrative, technical, and organizational safeguards designed to protect your personal data, including the anonymous-token architecture described in Section 3, which limits how much personal data is exposed in any single record. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. If we experience a breach of security affecting your personal data, we will notify you.
You have the right to: confirm whether we are processing your personal data; access the personal data we hold about you; obtain a portable copy of it; correct inaccuracies in it; delete it; and opt out of the processing of your personal data for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects. We do not sell personal data or use it for targeted advertising, so those particular opt-out rights should not require any action on our part, but we honor requests to confirm this.
To exercise any of these rights, contact us at jill@3deepcoaching.com. We will verify your request, respond within the time required by law, and will not charge a fee for a reasonable number of requests. If we decline a request, you may appeal by contacting us at the same address; if the appeal is denied, we will explain how you may contact the Utah Division of Consumer Protection or the Utah Attorney General’s Office.
The Pulse app itself does not use advertising cookies or third-party tracking pixels. Our session-booking page may use limited cookies or similar local storage necessary to remember your scheduling preferences and to keep the booking process secure.
The Service is intended for adults only and is not directed to, and should not be used by, anyone under 18. We do not knowingly collect personal data from anyone under 18. If we learn that we have inadvertently collected personal data from someone under 18, we will delete it promptly.
The Service is designed for clients located in the United States. If 3Deep Coaching has clients located in the European Union, United Kingdom, or other jurisdictions with their own data protection laws, additional disclosures and legal bases for processing may be required beyond what is described in this Policy.
3Deep Coaching is not a health care provider, and Pulse is not, as of the date of this Policy, offered as part of a HIPAA-covered health plan or health care clearinghouse function. Information you provide through Pulse is therefore not protected by HIPAA in the way information provided to a covered medical or mental health provider would be.
We may update this Privacy Policy from time to time. If we make a material change, we will provide notice through the Service or by email and will update the “Last Updated” date above. Your continued use of the Service after a change takes effect constitutes your acceptance of the updated Policy.
Questions about this Privacy Policy, or requests to exercise your privacy rights, can be directed to jill@3deepcoaching.com.