PRIVACY POLICY

The Synergist Group, LLC d/b/a Amplifi Executive Coaching

www.amplificoaching.com

1703 Galway Court

Winter Springs, FL 32708

Effective Date: March 1, 2026

1. Introduction and Scope

This Privacy Policy ("Policy") describes how The Synergist Group, LLC ("The Company") d/b/a Amplifi Executive Coaching ("Amplifi," "we," "us," or "our") collects, uses, shares, and protects personal information. This Policy applies to information collected through our website at www.amplificoaching.com (the "Site"), our coaching and consulting services, online courses and digital products, community platforms, and all other services we provide (collectively, the "Services").

Definition of Personal Information. Throughout this Policy, "personal information" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. This includes, but is not limited to, names, email addresses, phone numbers, mailing addresses, payment information, professional details, IP addresses, and online activity data. Where the EU General Data Protection Regulation ("GDPR") applies, "personal information" as used in this Policy has the same meaning as "personal data" as defined under the GDPR.

We are committed to protecting the privacy and confidentiality of everyone who interacts with us, including website visitors, coaching clients, course participants, community members, and organizational sponsors. By using the Site or engaging in our Services, you consent to the data practices described in this Policy. If you do not agree with these practices, please do not use the Site or Services.

This Policy should be read in conjunction with our Terms & Conditions, available at www.amplificoaching.com/terms. Where individual coaching agreements, sponsor agreements, or program enrollment agreements contain additional privacy or confidentiality provisions, those provisions supplement this Policy.

1.1 Important Note Regarding Sensitive Information

Amplifi provides executive coaching and leadership development services. Our Services are not medical, mental health, therapeutic, or counseling services. We are not a healthcare provider and do not operate as a HIPAA-covered entity. Please do not submit sensitive medical information, protected health information, mental health diagnoses, or similar highly sensitive personal data through our Site, forms, community platforms, or online tools. If coaching conversations touch on health-related topics that affect your leadership, those discussions are handled under our coaching confidentiality obligations, but our Site and digital tools are not designed to collect, store, or process medical information.

2. Who We Are (Data Controller)

For the purposes of applicable data protection laws, including the GDPR, Amplifi acts as the data controller for personal information collected through the Site and in connection with the delivery of our Services. This means we determine the purposes and means of processing your personal information.

Our founder, Gary L. Owens, Jr., EdD, BCC, PCC, serves as the primary point of contact for all privacy-related inquiries. Contact information is provided in Section 19 of this Policy.

3. Information We Collect

3.1 Information You Provide Directly

We collect personal information that you voluntarily provide to us, including when you visit our Site, inquire about or purchase our Services, register for an account, enroll in a course, join a community, or communicate with us. This may include:

Contact and Identity Information: name, email address, phone number, mailing address, job title, employer or organization name, and professional credentials.

Payment Information: billing address, credit card or payment details. Payment processing is handled by our third-party payment processor; we do not store complete credit card numbers on our systems.

Professional and Coaching Information: information you share during coaching sessions, strategy calls, assessments, intake forms, and development planning conversations. This includes responses to leadership assessments, 360-degree feedback instruments, self-assessments, and related evaluation tools.

Stakeholder and Sponsor Information: information provided by organizational sponsors in connection with sponsored coaching engagements, including the client's role, development objectives, and organizational context.

Course and Community Information: course enrollment data, learning progress, discussion posts, community profile information, and content you share in community spaces.

Communications: information contained in emails, contact forms, survey responses, and other communications you send to us.

3.2 Information Collected Automatically

When you visit the Site, certain information is collected automatically through cookies and similar technologies, including:

Device and Browser Information: IP address, browser type and version, operating system, device type, and screen resolution.

Usage Information: pages visited, time spent on pages, referring website addresses, links clicked, and general navigation patterns.

Location Information: general geographic location inferred from your IP address (we do not collect precise geolocation data).

This information is used to operate and improve the Site, analyze usage patterns, and provide general statistics regarding Site traffic.

3.3 Information from Third Parties

We may receive personal information from third parties, including organizational sponsors who engage our coaching services on behalf of their employees, third-party coaching platforms through which we deliver services, referral sources who connect us with prospective clients, and social media platforms if you interact with our content or accounts.

4. How We Use Your Information

4.1 Purposes of Processing

We use your personal information for the following purposes:

Service Delivery. To provide coaching, consulting, courses, community access, and other Services you have requested or purchased, including scheduling sessions, delivering content, administering assessments, and facilitating communication between coach, client, and sponsor.

Account Management. To create and manage your account, process payments, send transactional communications (such as confirmations, invoices, and scheduling notices), and provide customer support.

Improvement and Development. To analyze usage patterns, improve our Services, develop new offerings, and enhance the Site experience.

Marketing and Communications. To send you information about our Services, events, blog posts, resources, and other communications that may be of interest. You may opt out of marketing communications at any time (see Section 13).

Legal and Compliance. To comply with applicable laws, regulations, and legal processes; to protect our rights, privacy, safety, or property; and to enforce our Terms & Conditions and other agreements.

4.2 Lawful Bases for Processing (GDPR)

Where the GDPR applies to our processing of your personal information, we rely on the following lawful bases:

Contract Performance. Processing necessary to perform our contract with you, including delivering coaching services, providing course access, and managing your account.

Legitimate Interests. Processing necessary for our legitimate business interests, including improving our Services, maintaining security, and marketing to existing clients, where those interests are not overridden by your rights and freedoms.

Consent. Processing based on your consent, such as subscribing to our email communications, participating in community features, or consenting to the use of certain cookies. You may withdraw consent at any time.

Legal Obligation. Processing necessary to comply with a legal obligation to which we are subject.

5. Coaching-Specific Data Practices

Executive coaching involves the collection and handling of sensitive professional and personal information. We take additional care with coaching-related data.

5.1 Session Records and Notes

Coaching sessions may be documented through written session notes, AI-assisted transcription and note-taking tools, audio or video recordings (with your prior consent), and post-session summaries and action items. Where AI-powered tools are used for session transcription or note-taking, we will inform you in advance and obtain your consent before using such tools. AI-generated notes and transcriptions are treated with the same confidentiality as all other coaching records.

5.2 Assessments and Feedback Instruments

Our coaching engagements may include leadership assessments, 360-degree feedback instruments, self-assessments, and other evaluation tools. Assessment results are confidential and are shared only with you and, where applicable, with your organizational sponsor to the extent agreed upon in the coaching engagement agreement. Raw data from third-party assessment providers is governed by those providers' privacy policies in addition to this Policy.

5.3 Confidentiality in Sponsored Engagements

When coaching is sponsored by an organization, the boundaries of confidentiality are established in the applicable service agreement. Generally, the specific content of coaching sessions remains confidential between coach and client. Organizational sponsors may receive general progress updates, themes, and outcome summaries as agreed, but not specific session content, unless the client provides written consent. These boundaries are discussed and confirmed at the outset of every sponsored engagement.

5.4 Third-Party Coaching Platforms

We may deliver coaching services through third-party coaching platforms. When this occurs, the platform may collect and process personal information in accordance with its own privacy policies. We encourage you to review the privacy practices of any platform through which you receive our Services.

6. Online Courses, Digital Products, and Community

6.1 Course Data

When you enroll in an online course or purchase a digital product, we collect enrollment information, course progress and completion data, assessment responses and quiz results, and any content you submit as part of course activities. This data is used to deliver the course, track your progress, issue certificates of completion where applicable, and improve our educational offerings.

6.2 Community Data

When you participate in an Amplifi community, we collect your community profile information, discussion posts, comments, and messages, engagement metrics (such as participation frequency), and content you upload or share. Community discussions are visible to other members. Please be thoughtful about the personal information you share in community spaces, as it may be viewed by other participants. We moderate community content in accordance with our Terms & Conditions.

7. Cookies and Tracking Technologies

The Site uses cookies and similar tracking technologies to enhance your experience, analyze traffic, and support our marketing efforts. Cookies are small text files placed on your device by your web browser.

7.1 Types of Cookies We Use

Essential Cookies. Necessary for the Site to function properly, including session management, security features, and account access. These cookies support core site functions and are placed without requiring your consent because the Site cannot operate properly without them. You can block essential cookies through your browser settings, but doing so may prevent the Site from functioning correctly.

Analytics Cookies. Help us understand how visitors interact with the Site by collecting information about pages visited, time on site, and navigation patterns. This data is aggregated and anonymized. These cookies are placed only with your consent where required by applicable law.

Functional Cookies. Remember your preferences and settings to provide a more personalized experience, such as language preferences or previously viewed content. These cookies are placed only with your consent where required by applicable law.

Marketing Cookies. Used to deliver relevant advertising and track the effectiveness of our marketing campaigns. These cookies may be set by third-party advertising partners and may collect information about your browsing activity across different websites to deliver targeted advertisements. Under certain state privacy laws, including the California Privacy Rights Act (CPRA), the use of marketing cookies that share information with third parties for targeted advertising may be considered "sharing" of personal information. These cookies are placed only with your consent where required by applicable law.

7.2 When Consent Is Required

Where required by applicable law, including the GDPR and UK data protection laws, we will obtain your consent before placing non-essential cookies (analytics, functional, and marketing cookies) on your device. When you first visit the Site, you will be presented with a cookie consent mechanism that allows you to accept or decline non-essential cookies. Essential cookies do not require consent because they are strictly necessary for the Site to function.

7.3 Managing Your Cookie Preferences

You can manage your cookie preferences in the following ways:

Cookie Consent Tool. Where a cookie consent banner or preference center is displayed on the Site, you can update your preferences at any time by accessing the cookie settings link, typically located in the Site footer.

Browser Settings. Most web browsers allow you to block, delete, or manage cookies through your browser settings. Please note that blocking all cookies, including essential cookies, may prevent the Site from functioning correctly or affect your ability to access certain features.

Opt-Out of Interest-Based Advertising. You can opt out of interest-based advertising through industry tools such as the Digital Advertising Alliance (DAA) at www.aboutads.info/choices or the Network Advertising Initiative (NAI) at www.networkadvertising.org/choices.

Changing or withdrawing cookie consent does not affect the lawfulness of processing that occurred before the change.

8. How We Share Your Information

We do not sell, rent, or lease your personal information to third parties. We may share your information in the following circumstances:

8.1 Service Providers and Processors

We engage third-party service providers who process personal information on our behalf to support our operations. These providers are contractually obligated to protect your information and may only use it to provide services to us. The specific providers we use may change from time to time; the categories below reflect the types of services for which we engage third parties:

Integrated Business Platform. We use an integrated business platform (such as a customer relationship management, scheduling, email, website hosting, online course delivery, payment processing, and community platform) to operate our business. This provider maintains industry-standard security certifications, including ISO 27001 and SOC monitoring through a third-party managed security service provider, and has executed a comprehensive Data Processing Agreement governing its handling of personal information on our behalf. This provider is also certified under the EU-U.S. Data Privacy Framework and maintains Standard Contractual Clauses for international data transfers. Data processed through this platform is encrypted at rest (AES-256) and in transit (TLS v1.2+).

Video Conferencing. We use a third-party video conferencing platform (such as Zoom or similar services) for virtual coaching sessions, meetings, and workshops.

AI-Powered Tools. We may use AI-powered tools (such as AI note-taking and transcription services, and AI-assisted content and administrative tools) in connection with the delivery and administration of our Services. When AI tools are used in connection with coaching sessions, we obtain client consent in advance. We take steps to minimize the use of personally identifiable information when using AI tools for administrative or content purposes, and all use of AI tools is subject to our confidentiality obligations.

Third-Party Coaching Platforms. Where coaching is delivered through a third-party coaching platform, that platform may process personal information in accordance with its own privacy policies and data processing agreements.

Professional Service Providers. We may share information with accountants, attorneys, insurance providers, and other professional advisors as necessary for our business operations.

8.2 Organizational Sponsors

When coaching is sponsored by an organization, we may share limited information with the sponsor as outlined in the applicable service agreement. This typically includes engagement status, scheduling logistics, and general progress themes. Specific session content is not shared without the client's written consent. Confidentiality boundaries for sponsored engagements are established in the service agreement and discussed at the outset of the coaching relationship.

8.3 Legal Requirements

We may disclose your personal information if required to do so by law, regulation, or legal process, or if we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Amplifi, our clients, or the public; comply with a judicial proceeding, court order, or government request; or detect, prevent, or address fraud, security, or technical issues.

8.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your information.

9. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, comply with our legal and contractual obligations, and resolve disputes. Specific retention periods include:

Coaching Records. Session notes, assessment results, development plans, and related coaching records are retained for a minimum of five (5) years following the conclusion of the coaching engagement, in accordance with professional coaching standards and our service agreements.

Financial and Transaction Records. Payment records and invoices are retained for a minimum of seven (7) years to comply with tax and accounting requirements.

Course and Community Data. Course enrollment and completion records are retained for as long as the course remains available and for a reasonable period thereafter. Community posts and contributions remain available for as long as the community is active, unless you request deletion.

Marketing and Communications Data. Email subscriber information is retained until you unsubscribe or request deletion.

Website Analytics and Cookie Data. Aggregated analytics data may be retained indefinitely. Individual-level analytics data is retained in accordance with our analytics provider's data retention settings. Cookie data is retained for the duration specified in the cookie's expiration setting, which varies by cookie type.

When personal information is no longer needed for any legitimate purpose, we will securely delete or anonymize it.

10. Data Security

We take the security of your personal information seriously and implement appropriate administrative, technical, and organizational measures to protect it from unauthorized access, use, alteration, or disclosure. These measures include:

Encryption. Personal information is encrypted at rest and in transit using industry-standard encryption protocols (AES-256 for data at rest; TLS v1.2+ for data in transit).

Access Controls. Access to personal information is restricted to authorized personnel on a need-to-know basis, with role-based access controls.

Platform Security. Our primary business platform maintains ISO 27001 certification, SOC monitoring through a third-party managed security service provider, and regular third-party penetration testing and vulnerability assessments.

Backup and Recovery. Data is backed up regularly with appropriate granularity to enable restoration in the event of a technical incident.

While we strive to protect your personal information, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, and you acknowledge that there are inherent security and privacy limitations of the Internet that are beyond our control. We encourage you to take steps to protect your own information, including using strong passwords, keeping your account credentials confidential, and notifying us promptly if you suspect any unauthorized access to your account.

11. Your Privacy Rights

11.1 General Rights

Depending on your location and applicable law, you may have the following rights regarding your personal information:

Access. The right to request a copy of the personal information we hold about you.

Correction. The right to request that we correct inaccurate or incomplete personal information.

Deletion. The right to request that we delete your personal information, subject to certain exceptions (such as where retention is required for legal compliance, completion of a transaction, or exercise of legal rights).

Opt-Out of Marketing. The right to opt out of marketing communications at any time.

To exercise any of these rights, please contact us using the information provided in Section 19. We will respond to your request within a reasonable timeframe and in accordance with applicable law. We will not discriminate against you for exercising your privacy rights.

11.2 Additional Rights for Individuals in the European Economic Area, United Kingdom, and Switzerland

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, you have additional rights under the GDPR and applicable local data protection laws, including:

Right to Restriction. The right to request that we restrict the processing of your personal information in certain circumstances.

Right to Data Portability. The right to receive your personal information in a structured, commonly used, machine-readable format and to transmit it to another controller.

Right to Object. The right to object to processing based on our legitimate interests, including direct marketing.

Right to Withdraw Consent. Where processing is based on your consent, you have the right to withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Right to Lodge a Complaint. The right to lodge a complaint with a supervisory authority in the EU member state of your habitual residence, place of work, or place of the alleged infringement.

To exercise these rights, please contact us at the information provided in Section 19. We will respond to verified requests within thirty (30) days, or within the timeframe required by applicable law.

11.3 Rights Under California Privacy Laws (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, "CCPA/CPRA") may provide you with additional rights regarding your personal information.

Categories of Personal Information Collected. We may collect the following categories of personal information as defined by the CCPA/CPRA: identifiers (such as name, email address, phone number, and IP address); professional or employment-related information (such as job title, employer, and professional credentials); commercial information (such as records of Services purchased or considered); internet or other electronic network activity information (such as browsing history, search history, and interactions with our Site); and inferences drawn from the above categories to create a profile reflecting your preferences and interests.

Sources of Personal Information. We collect personal information directly from you, from organizational sponsors, from third-party coaching platforms, and automatically through cookies and tracking technologies on our Site.

Purposes for Collection. We collect personal information for the business and commercial purposes described in Section 4 of this Policy, including service delivery, account management, marketing, and legal compliance.

Retention. We retain personal information for the periods described in Section 9 of this Policy.

Sharing and Disclosure. We share personal information with the categories of service providers described in Section 8 of this Policy. We do not sell personal information as defined under the CCPA/CPRA. If we use marketing cookies that share information with third-party advertising partners for cross-context behavioral advertising, this may constitute "sharing" under the CPRA. You have the right to opt out of such sharing. Please see Section 7 for details on managing cookie preferences and opting out of interest-based advertising.

Your California Privacy Rights. As a California resident, you have the right to: know what personal information we collect, use, disclose, and sell or share; request deletion of your personal information; correct inaccurate personal information; opt out of the sale or sharing of your personal information; limit the use and disclosure of sensitive personal information (to the extent we collect it); and not be discriminated against for exercising your privacy rights.

To exercise your California privacy rights, please contact us using the information provided in Section 19. We will verify your identity before processing your request. You may also designate an authorized agent to submit a request on your behalf.

11.4 Rights Under Other U.S. State Privacy Laws

Residents of other states with applicable consumer privacy laws, including Colorado, Connecticut, Virginia, Texas, Oregon, and others, may have similar rights regarding their personal information, such as the right to access, correct, delete, and opt out of certain processing activities. If you are a resident of a state with applicable privacy legislation and wish to exercise your rights, please contact us using the information provided in Section 19. We will process your request in accordance with applicable law.

12. International Data Transfers

Amplifi is based in the United States. If you access the Site or use our Services from outside the United States, please be aware that your personal information may be transferred to, stored in, and processed in the United States, where data protection laws may differ from those in your country of residence.

Where we transfer personal information from the EEA, UK, or Switzerland to the United States, we rely on appropriate transfer mechanisms to ensure that your information receives an adequate level of protection. These mechanisms include:

EU-U.S. Data Privacy Framework. Our primary platform provider is 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.

Standard Contractual Clauses. Where applicable, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission as a lawful mechanism for data transfers.

Data Processing Agreements. We maintain Data Processing Agreements with our service providers that include appropriate data transfer provisions and safeguards.

By using the Site or Services, you consent to the transfer of your information to the United States as described in this Policy. If you have questions about international data transfers, please contact us at the information provided in Section 19.

13. Email and Marketing Communications

We may send you email communications for the purpose of providing service-related announcements, promotional offers, newsletters, blog posts, event invitations, surveys, and other general communications. We may track whether you open our emails or click links within them to help us improve our communications.

You may opt out of marketing communications at any time by clicking the unsubscribe link included in every marketing email or by contacting us directly. Please note that even if you opt out of marketing emails, we may still send you transactional or service-related communications (such as appointment confirmations, invoices, or account notifications).

14. Testimonials and Anonymized Feedback

We may feature testimonials, reviews, success stories, and client feedback on our Site and in marketing materials. These may include:

Direct Client Testimonials. Shared with the individual's express written permission. We will identify the client only to the extent they have authorized.

Anonymized Feedback. Feedback gathered through third-party coaching platforms or program evaluation processes, from which all personally identifiable information has been removed before use in marketing materials.

Composite Reflections. Paraphrased or composite reflections drawn from multiple client experiences, presented in a way that no individual can be identified.

All testimonials reflect individual experiences and are not intended to represent or guarantee that any current or future client will achieve the same or similar results. We do not compensate clients for testimonials unless explicitly disclosed. If you have provided a testimonial and wish to have it removed, please contact us.

15. Children's Privacy

Amplifi does not knowingly collect personal information from children under the age of thirteen (13), either online or offline. Our Services are designed for adult professionals and are not directed toward minors. If you are under the age of 18, you may use the Site only with the permission of a parent or guardian. If we learn that we have collected personal information from a child under 13, we will take steps to delete that information promptly. If you believe we have inadvertently collected information from a child under 13, please contact us immediately.

16. Use of Artificial Intelligence

Amplifi may use AI-powered tools in connection with the delivery and administration of our Services. This may include AI-assisted note-taking and transcription during coaching sessions (with client consent), AI tools for content development, research, and administrative tasks, and AI-assisted communication drafting and business operations.

When AI tools are used in connection with coaching sessions or client-specific work, we take steps to protect your privacy, including obtaining informed consent before using AI tools during sessions, minimizing the use of personally identifiable information when possible, ensuring that AI tool providers are subject to appropriate confidentiality and data protection obligations, and not using client information to train third-party AI models without explicit consent.

We do not use AI to make automated decisions that produce legal effects or similarly significant effects on you without human oversight.

17. Do Not Track Signals

Some web browsers transmit "Do Not Track" (DNT) signals to websites. Because there is no uniform standard for how DNT signals should be interpreted, we do not currently respond to DNT signals. However, you can manage your cookie preferences as described in Section 7 and opt out of interest-based advertising as described in Section 7.3.

18. Changes to This Policy

We reserve the right to update this Policy from time to time to reflect changes in our practices, Services, technology, legal requirements, or other factors. When we make material changes, we will notify you by posting the updated Policy on the Site with a revised effective date and, where appropriate, by sending you a notification via email or through the Site.

Your continued use of the Site or Services after any changes constitutes your acceptance of the revised Policy. If you do not agree with the revised Policy, your remedy is to discontinue use of the Site and Services and to request deletion of your personal information in accordance with Section 11. We encourage you to review this Policy periodically.

19. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, including requests to exercise your privacy rights, please contact us:

The Synergist Group, LLC d/b/a Amplifi Executive Coaching

Gary L. Owens, Jr., EdD, BCC, PCC

Email: hello@amplificoaching.com

Phone: 689-399-4600

For individuals in the EEA, UK, or Switzerland: If you are not satisfied with our response to a privacy concern, you have the right to lodge a complaint with your local data protection authority.