Hey Coach — Privacy Policy

1. Who We Are and Who This Policy Covers

Hey Coach Team LLC is a West Virginia limited liability company with its principal office at 1 Riddle Court, Morgantown, WV 26505. We provide the Hey Coach School Portal, a communication and athlete-development platform used by school athletic programs. The Service is available through a web browser and, where available, the Hey Coach mobile app.

This Policy covers information we handle through the School Portal about school administrators and athletic directors ("Athletic Directors"), coaches, student-athletes ("athletes"), and parents and guardians ("guardians"). Each of these people is a "User." This Policy applies no matter what device a User uses to reach the Service, whether school-provided or personal.

A K-12 school, K-12 school district, or athletic program affiliated with a K-12 school or district that has set up an account with Hey Coach is called an "Organization" in this Policy.

2. Information We Collect, and From Whom

We handle the following categories of information through the School Portal.

2.1 From the Organization (Roster and Account Data)

The Organization gives Hey Coach roster and directory-type information about its athletes, coaches, and administrators. This may include:

• name;
• graduation year;
• sport(s) and team(s);
• role (athlete, coach, Athletic Director, or administrator);
• each athlete's age designation (adult, 13 or older, or under 13; see Section 3); and
• contact information, such as phone numbers and email addresses, for athletes, guardians, coaches, and administrators.

Guardian contact details. The Organization may provide a guardian's name, phone number, and email address and link that guardian to an athlete. The Service uses these details to send guardian-directed messages, such as schedule updates, announcements, and reminders. For athletes designated under 13, every automated text about the athlete goes to the guardian's phone number, never to the child's (see Section 3).

Athlete accounts are created from this roster information. An athlete's continued access depends on the Organization keeping that athlete on its roster.

Birthdates are not stored. Hey Coach does not store a birthdate for any athlete. If an Organization's roster import contains birthdates, each birthdate is converted to an age designation and the birthdate is then discarded.

2.2 Generated Through Use of the Service (Platform Data)

Once an account exists, the Service creates additional information as it is used:

• Message content — messages sent and received between coaches, guardians, and athletes through the Service, including team conversations;
• Journal content — the text of an athlete's Journal entries and related prompts and responses (see Section 4 for who can see this content);
• Coach Ryan conversation content — a User's conversations with Coach Ryan, our AI assistant, including content typed while using Journal Answers in Chat where that feature is turned on (see Section 7);
• Wellbeing flags — a record created when Coach Ryan identifies a possible concern about a User's wellbeing (see Section 7.5);
• Media content — photos and videos uploaded to team event albums by coaches, Athletic Directors, or guardians. Location data is removed from photos and videos before upload. Athletes designated under 13, and athletes with no age designation, are excluded from team photo and video albums;
• Delivery records — records of text-message delivery;
• Audit records — records of certain administrative actions (see Section 12); and
• Consent records — for athletes who need it, guardian consent records for Journal Answers in Chat (see Section 7.6). Hey Coach also keeps a record of acceptance of the Terms of Service.

2.3 Sign-In and Technical Data

Users sign in with a one-time code sent by email or text message. Athletes designated under 13 cannot sign in at all (see Section 3).

Hey Coach collects only the technical data needed to operate and secure the Service. Our service providers may keep their own technical logs under their own terms.

2.4 What We Do Not Collect

We do not collect Social Security numbers, financial account information, or biometric identifiers through the Service.

2.5 Accuracy of Organization Information

Hey Coach does not independently verify a User's age, role, or connection to an Organization beyond the information the Organization provides. The Organization is responsible for the accuracy of the roster, role, and age-designation information it enters.

3. Age Designations

3.1 How Age Designations Work

Organizations must set an age designation for every athlete before inviting them. Organizations are responsible for the accuracy of those designations and for correcting them promptly.

Each athlete has one of three age designations, set by the Organization: adult, 13 or older, or under 13. Hey Coach does not store a birthdate (see Section 2.1). The Service relies on the designation the Organization enters and applies different rules depending on that designation.

3.2 Athletes Designated Under 13

An athlete designated under 13 has a roster record, but:

• cannot sign in to the Service on any path, and so cannot use Coach Ryan, the AI assistant, and cannot answer Journal questions;
• every automated text message about the athlete goes to the guardian's phone number, never to the child's;
• texts received from the child's phone number are ignored by the Service;
• no Journal prompts are sent for the athlete; and
• the athlete is excluded from team photo and video albums.

Information about an athlete designated under 13 comes from the Organization and the athlete's guardians, not from the child. See Section 14.1 for the school-consent framework that applies.

3.3 Athletes With No Age Designation

If an Organization has not set an age designation for an athlete, the Service:

• treats the athlete as 13 or older for sign-in and text messaging;
• treats the athlete as a minor for Journal Answers in Chat, so guardian consent is required before the athlete can use that feature (see Section 7.6); and
• excludes the athlete from team photo and video albums.

Because these default rules allow an athlete with no designation to sign in and receive texts, Organizations must set a designation for every athlete before inviting them.

3.4 Correcting a Designation

An Organization can correct an athlete's age designation at any time. If a school or guardian tells Hey Coach that an athlete has been designated incorrectly, or that an athlete's information was collected in error, Hey Coach will promptly review it (see Section 15).

4. The Journal Feature — What It Is and Who Can See It

The Service includes reflection prompts for athletes, called the "Journal" in the product. Weekly Journal prompts are sent by text message to athletes designated 13 or older. Athletes can answer on the website or by replying to the text. No Journal prompts are sent for athletes designated under 13.

This section explains plainly who can read what an athlete writes in the Journal, and what review does and does not happen. Every athlete sees a version of this notice directly above the Journal entry screen before submitting an entry.

4.1 Who Can Read Journal Entries

Journal entries are not private. They are not visible only to the athlete who wrote them. The following people can read an athlete's Journal entries:

• the coaches of the athlete's team, within the athlete's Organization;
• the Organization's Athletic Director(s); and
• Hey Coach platform staff.

No other athlete and no other student can read an athlete's Journal entries. Teammates cannot see them.

This matches the notice shown in the product:

"The coaches of your team and your athletic director can read what you write, not your teammates."

That notice also tells athletes that if something is seriously wrong, they should tell a trusted adult directly rather than write it in a Journal entry and wait for a coach to read it, because Journal entries are not monitored in real time (see Section 4.2).

4.2 No Safety Monitoring of Journal Entries

No one at Hey Coach or at an Organization is designated to review Journal entries for safety concerns. No response-time standard applies to reading entries, and no escalation procedure exists for concerning Journal content. Coaches, Athletic Directors, and Hey Coach staff who can see Journal entries read them at their own discretion and on their own schedule.

The only automated screening of Journal text is a profanity filter that runs only on entries written on the website. Entries submitted by text-message reply are not screened. The filter does not detect, flag, or screen for self-harm, harm to others, abuse, or any other safety concern.

Hey Coach may add review or escalation tools in the future and will update this document if it does.

Hey Coach does not take on the role of the Organization, its coaches, or its staff in monitoring student communications or reporting suspected abuse, neglect, or other safety concerns — that responsibility remains with the Organization and its personnel under applicable law.

5. How We Use Information

We use the information described in Section 2 to:

• provide, operate, and maintain the Service, including delivering messages, showing Journal entries to the people described in Section 4.1, and operating Coach Ryan as described in Section 7;
• send guardian-directed messages and service notices;
• communicate with Users about their accounts and the Service;
• apply the age-designation rules described in Section 3;
• maintain the security and integrity of the Service and its audit records; and
• comply with legal obligations and the terms of any applicable Data Privacy Agreement.

We do not use Journal content, message content, or Coach Ryan conversation content to train AI models on Hey Coach's own behalf. For our AI provider's handling of data sent to it, see Section 7.4.

We do not use information collected through the Service for targeted or behavioral advertising, and we do not build behavioral profiles of athletes for any purpose other than operating the Service for the Organization.

We do not sell information collected through the Service, and we do not use it for advertising or behavioral profiling.

6. How We Share Information; Service Providers

We share information only with the recipients described in this section.

6.1 Within the Organization

Coaches, Athletic Directors, and other authorized personnel of a User's Organization see information relevant to their role, consistent with the Service's purpose as a team-communication and athlete-development platform. Journal visibility is described in Section 4.1.

6.2 Service Providers

Service providers process information on our behalf to run the Service. They fall into these categories:

• hosting and file storage;
• a managed database;
• authentication;
• text messaging and messaging-app delivery;
• email delivery;
• payment processing for organizations that sign up online;
• bot protection on public sign-up and contact pages;
• push notification delivery for the mobile app;
• an AI assistant provider (see Section 7); and
• Scripture content providers, which receive passage references only and no personal information.

A current list of the service providers that process information for the Service, and details of our technical and security practices, are available to Organizations on request at contact@heycoach.team.

No other third party receives information collected through the Service, except as described in Section 6.3.

6.3 Other Disclosures

We may also disclose information:

• to comply with valid legal process (for example, a subpoena or court order) or applicable law;
• to protect the rights, property, or safety of Hey Coach, our Users, or others;
• in connection with a merger, acquisition, or sale of assets, subject to protections comparable to this Policy; and
• as otherwise directed or authorized by the Organization, consistent with Section 13 (FERPA).

We do not sell personal information collected through the Service, and we do not use it for advertising or behavioral profiling. We do not share Journal content, message content, or roster data with third parties for their own marketing.

7. Coach Ryan (the AI Assistant) — Data Flow

7.1 What Coach Ryan Does

The Service includes an AI assistant presented as "Coach Ryan." Coach Ryan helps Users complete tasks they could otherwise do directly in the Service, such as checking a schedule, responding to an event, or (for a coach) sending a team announcement. Coach Ryan also supports the Journal Answers in Chat feature described below.

Athletes designated under 13 cannot sign in, so they cannot use Coach Ryan or Journal Answers in Chat in any way.

7.2 Journal Answers in Chat

Journal Answers in Chat lets an athlete get help from Coach Ryan drafting a new Journal entry.

It is off by default for every Organization.

It becomes available only after the Organization turns it on. The Organization turns it on with an Organization-wide switch; there is no per-team setting.

For every minor athlete, and for any athlete with no age designation, it is available only after a guardian has consented for that athlete (see Section 7.6).

The athlete must also accept the current in-product notice describing the feature.

Coach Ryan is designed not to read an athlete's existing Journal entries, and automated tests check this behavior. An entry drafted with Coach Ryan's help is labeled "written in chat," so coaches and Athletic Directors can tell assisted entries apart from entries an athlete wrote alone. Entries written in chat are visible to the same people described in Section 4.1.

7.3 What Is Sent to Our AI Provider

When a User talks with Coach Ryan, the following is sent to our AI provider, Anthropic, as part of that conversation:

• the User's first name, role, Organization name, and team names;
• the recent messages in that conversation;
• information the User types during the conversation, including Journal answers drafted in chat and any names or contact details the User enters when asking Coach Ryan to perform a task; and
• the results of Service functions Coach Ryan uses to complete the User's request.

On Hey Coach's side, Coach Ryan conversations are deleted automatically 90 days after the last message in the conversation, or sooner if the User deletes their account (see Section 11.1).

7.4 How Our AI Provider Handles Data

Hey Coach uses Anthropic's AI models under Anthropic's published Commercial Terms of Service. Under those published terms, API inputs and outputs are not used to train Anthropic's models by default. Anthropic's retention of the data it receives is governed by those commercial terms.

Details of Hey Coach's arrangements with its AI provider are available to Organizations on request.

7.5 Wellbeing Flags From Coach Ryan Conversations

This section applies only to conversations with Coach Ryan. It does not apply to Journal entries, which are not screened for safety concerns (see Section 4.2).

If Coach Ryan identifies a possible concern about a User's wellbeing during a conversation, it records a flag and sends a notification to the Organization's designated Safety Contact. If the Organization has not designated a Safety Contact, the notification goes to every active Athletic Director in that Organization. The notification is sent by text message and email.

The notification names the User in the conversation by first and last name, says that a conversation may need attention, and asks the recipient to check in with them. It never includes the content of the conversation. Recipients review the matter by signing in to the Service.

Coach Ryan may not identify every concern, and a flag is not a safety-monitoring service. In an urgent situation, athletes, guardians, coaches, and Organizations should contact a trusted adult or emergency services directly. Responsibility for responding to and reporting safety concerns remains with the Organization and its personnel under applicable law.

7.6 Required Conditions for Journal Answers in Chat

Journal Answers in Chat is available to a specific athlete only if all of the following are true. The Service rechecks these conditions at every use, not just once at setup, and again when a drafted entry is confirmed:

• the athlete's Organization has turned the feature on;
• for every minor athlete, and for any athlete with no age designation, a guardian has given consent for that specific athlete; and
• the athlete has accepted the current in-product notice describing Journal Answers in Chat.

For each guardian consent, Hey Coach records:

• the guardian who gave it;
• the athlete it applies to;
• the version of the notice shown when consent was given;
• the channel through which consent was given; and
• any later withdrawal of that consent.

A guardian may withdraw consent at any time. Withdrawal turns off Journal Answers in Chat for that athlete going forward. Otherwise, consent stays in effect until withdrawn.

8. Text Messaging and Email

The Service sends text messages, messaging-app messages, and email through the service providers described in Section 6.2. These providers process message content, delivery metadata, and recipient phone numbers or email addresses on Hey Coach's behalf to deliver messages, and keep their own delivery logs under their own terms.

A User whose phone number is provided to the Organization or the Service may receive texts about team communication, scheduling, announcements, sign-in codes, Journal prompts (for athletes designated 13 or older), and automated check-ins and reminders, as described in the Terms of Service.

For athletes designated under 13, automated texts go to the guardian's phone number only, and texts from the child's number are ignored (see Section 3.2).

If a recipient replies STOP, Hey Coach records the opt-out and stops sending texts to that number. Opt-out records are kept so that a prior STOP continues to be honored, including after an account is deleted.

9. The Marketing Site

Hey Coach operates a marketing website at heycoach.team (the "Marketing Site"), which is separate from the School Portal. The Marketing Site is intended for adults, such as Organization administrators, coaches, and guardians, and is not directed to children.

Information submitted through forms on the Marketing Site, such as contact details and the content of an inquiry, goes into a customer relationship management (CRM) system that records contact-form and lead information. This information is kept separate from School Portal data and is not combined with any Organization's roster or platform data.

The Marketing Site's cookies, pixels, and similar technologies are described in the Hey Coach School Portal Cookie Policy (Track A), including how to opt out. Those technologies run on the Marketing Site only, and never in the School Portal or on sign-in pages.

10. Data Retention

Messages, Journal entries, delivery records, media, consent records, and audit records are kept while the Organization's account remains active and as the Organization instructs Hey Coach to keep them, except where they are removed through the options described in Section 11. No fixed maximum retention period currently applies. Hey Coach is developing a defined retention schedule and will update this Policy when one is adopted.

Exception — Coach Ryan conversations. Conversations with Coach Ryan are deleted automatically 90 days after the last message in the conversation.

Security-incident notification is addressed in Section 12.

11. Account Deletion, Deactivation, and Other Removal Options

This section describes exactly what can and cannot be removed from the Service today. Please read it carefully: some options permanently destroy data, while others only limit visibility or pause access.

11.1 Self-Service Account Deletion

A signed-in User can delete their own account from Settings.

What account deletion permanently destroys:

• all of that person's Journal entries;
• all of that person's Coach Ryan conversations;
• any wellbeing flags about that person; and
• that person's consent acceptances, except that a guardian consent they gave for an athlete is marked withdrawn and kept.

Account deletion also replaces the person's name and contact details with a generic "former member" label.

What account deletion does not remove:

• messages the person sent in team conversations, which remain under the generic "former member" label;
• photos and videos the person uploaded to team albums;
• audit records, which keep the person's name as it was recorded at the time; and
• opt-out records, which are kept so that a prior STOP request continues to be honored.

Deletion is all-or-nothing for each account. A single Journal entry cannot be deleted by itself; deleting Journal entries requires deleting the whole account.

Who cannot delete their account:

• Hey Coach platform staff;
• the last remaining Athletic Director of an Organization; and
• the last remaining guardian receiving texts for an athlete designated under 13.

When deletion takes effect, and where copies may remain. Deletion takes effect in Hey Coach's live database immediately. However, copies may remain in backups kept by Hey Coach's hosting providers, and in delivery logs and records kept by messaging and email providers and by the AI provider (see Section 7.4), under their own retention schedules, which account deletion does not reach. On Hey Coach's side, Coach Ryan conversations are deleted with the account, or otherwise after 90 days.

11.2 Other Options That Exist Today

Deactivating a person. An Organization administrator can deactivate a User. Deactivation stops that person from sending or receiving messages and from using the Service. Deactivation destroys nothing and can be reversed; a reactivated account has the same underlying data, although its team places and guardian texting are turned back on separately.

Hiding a Journal entry. An athlete can hide one of their own Journal entries from their own view. Hiding is not deletion. Coaches, Athletic Directors, and Hey Coach staff described in Section 4.1 can still read a hidden entry, and the entry is not destroyed.

Removing media. Coaches can remove photos and videos posted to team albums.

Team purge (Hey Coach staff only). Hey Coach platform staff can run a two-step purge of a team's messages, events, prompts, and other team records, including its roster, announcements, resources, and photo and video records. The purge removes those database records, but it keeps the team's audit records and athletes' Journal entries, and it does not remove uploaded files from file storage.

11.3 What Is Not Available Today

The following are not features of the Service today:

• deletion of a single Journal entry;
• deletion directed by a school or Organization of a specific student's data;
• self-service deletion by or for an athlete designated under 13 (who cannot sign in); and
• deletion of an entire Organization's data.

11.4 Requests From Guardians and Organizations

An Organization or a guardian may contact Hey Coach (Section 17) about deleting or correcting information. Hey Coach will review each request and explain what it can and cannot do, consistent with this Section 11. We do not promise a deletion timeline.

12. Data Security

Hey Coach uses safeguards designed to protect information, including encryption in transit, role-based access controls, and audit records of certain administrative actions. Access to information within the Service depends on a User's role, consistent with the visibility rules in Section 4.1 and elsewhere in this Policy.

No method of transmission or storage is completely secure. We will provide notification of a security incident as required by applicable law.

13. FERPA — School Official Status

Where an Organization is, or is part of, a K-12 school or school district subject to the Family Educational Rights and Privacy Act ("FERPA"), and gives Hey Coach student roster or related directory-type information to use the Service, Hey Coach acts as a "school official" with a "legitimate educational interest" in that information under FERPA's school-official exception (34 C.F.R. § 99.31(a)(1)).

In that role, Hey Coach:

• uses student information received from the Organization only to provide the Service to that Organization and its Users, and for purposes the Organization has authorized;
• is under the direct control of the Organization with respect to the use and maintenance of that information; and
• does not disclose or redisclose that student information to any third party except the service providers described in Section 6.2, as directed or authorized by the Organization, or as required by law.

Where a Data Privacy Agreement is in effect for an Organization, that agreement's FERPA and student-data-privacy terms control over this Section to the extent of any conflict.

14. COPPA and Parent and Guardian Rights

14.1 School-Consent Framework for Athletes Under 13

For athletes designated under 13, Hey Coach relies on the school-consent framework recognized in the Federal Trade Commission's guidance under the Children's Online Privacy Protection Act ("COPPA," 16 C.F.R. Part 312). Under that guidance, a school may consent on behalf of parents to an operator's collection of student personal information when the information is used only for the school's educational purpose and for no other commercial purpose.

What the framework covers. The school-consent framework covers:

• roster information about athletes under 13: name, graduation year, age designation, sport and team, and guardian name and contact details; and
• guardian-directed messaging about those athletes, by text message and email.

The child is not a source of information. The Organization and the athlete's guardians supply this information. Athletes designated under 13 cannot sign in, cannot use Coach Ryan or Journal Answers in Chat, do not receive Journal prompts, are excluded from team photo and video albums, and texts from their phone numbers are ignored (see Section 3.2).

Purpose limit. Hey Coach uses information about athletes under 13 only to provide the Service to the Organization for the athletic and educational purpose the Organization has authorized. Hey Coach does not use that information for targeted or behavioral advertising, does not build behavioral profiles of the student, does not sell it, and does not use it for any other purpose.

How the school authorizes it. The school's authorization is documented in the Hey Coach School COPPA Consent and Authorization Form (Track A), signed by an official with authority to bind the Organization. In that form, the school also certifies that its age designations will be accurate and kept current.

Organizations that are not schools. The school-consent framework applies only to K-12 schools, K-12 school districts, and athletic programs affiliated with them. An organization outside that group must not enter personal information about athletes under 13 until it has contacted Hey Coach to arrange verifiable parental consent.

14.2 Parent and Guardian Rights

A parent or guardian may, through the Organization or by contacting Hey Coach directly (Section 17):

• ask what information is held about their athlete;
• ask questions about their athlete's use of the Service;
• withdraw consent for Journal Answers in Chat for their athlete (Section 7.6), which turns the feature off for that athlete going forward; and
• make a deletion or correction request, subject to the limits described in Section 11.

A guardian who believes their child's age designation is wrong may ask the Organization to correct it, or may contact Hey Coach.

15. Children's Data — Additional Notes

Information about athletes under 13 enters the Service through the Organization's roster and through guardians, consistent with the FERPA school-official role described in Section 13 and the COPPA school-consent framework described in Section 14.1.

Hey Coach does not knowingly collect personal information directly from a child under 13. If a school or parent tells Hey Coach that an athlete's information was collected in error, for example because the athlete was given the wrong age designation, Hey Coach will promptly review it. Organizations can correct an athlete's age designation at any time, and the rules in Section 3 apply as soon as the designation changes.

A parent or guardian with questions about a specific child's information should contact the Organization or Hey Coach (Section 17).

16. Changes to This Policy

We may update this Policy from time to time. When we do, we will update the version number and effective date at the top of this document and notify Organizations by email to their Organization administrators. Continued use of the Service after a new version takes effect means acceptance of the updated Policy.

17. Contact Information

Questions about this Privacy Policy, requests described in Sections 11.4 and 14.2, and requests for the current list of service providers or details of our technical and security practices may be sent to:

Hey Coach Team LLC 1 Riddle Court Morgantown, WV 26505 contact@heycoach.team