Privacy Policy

Last Updated: October 6, 2025

Welcome to Coach Kairo ("Kairo", "we", "us", or "our"), operated by Hexentrega LLC, a Wyoming limited liability company ("Hexentrega"). This Privacy Policy explains how we collect, use, and protect your personal data when you use our AI-powered fitness and nutrition coaching service (the "Service"), available via SMS, web, and optional WhatsApp messaging.

By using this Service, you confirm that you are 18 years or older and agree to this Privacy Policy. If you do not agree, please do not use the Service.

1. About Coach Kairo

Coach Kairo is an AI-powered wellness assistant providing personalized fitness and nutrition guidance through SMS, web, and optional WhatsApp communications. Kairo is designed to offer general wellness and educational support only — not medical advice. Always consult a qualified healthcare provider for medical conditions or treatment decisions.

2. Personal Data We Collect

We collect personal data directly from you, automatically from your device, and through your interactions with the Service. We group this information into the following categories:

We do not require or intentionally collect sensitive health or medical information, nor do we share personally identifying information with our AI technology providers.

3. How We Use Personal Data

We use your data to:

We do not sell personal data.

4. Disclosure of Personal Data

We may share personal data with limited categories of trusted recipients to provide and support our Service, including:

We may maintain a list of our subprocessors on a separate "Subprocessor List" page, updated periodically.

5. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Policy, comply with legal obligations, and resolve disputes. You may request deletion or anonymization of your data by contacting privacy@coachkairo.com. We will verify such requests before processing.

6. Security and Communication Channels

We use administrative, technical, and organizational safeguards to protect your data. However, SMS messages are not end-to-end encrypted. By using SMS to interact with Kairo, you acknowledge and accept this security limitation.

If you prefer enhanced privacy, you may use our web-based or WhatsApp channels (which may offer stronger encryption).

7. Cookies and Tracking Technologies

We use cookies and similar technologies to:

You can control or delete cookies through your browser settings. Disabling certain cookies may limit functionality. For more details, see our Cookie Policy.

8. Marketing Communications

We may send you marketing messages via SMS or email with your explicit consent. You can opt out at any time by replying STOP (for SMS) or using the unsubscribe link in emails. Reply HELP for assistance. Message and data rates may apply. Your consent to receive marketing is not a condition of purchase.

For detailed information about SMS communications, including opt-in procedures, message frequency, and how to opt out, please review our SMS Terms & Opt-In Policy.

9. International Data Transfers

Your data may be transferred to and processed in the United States or other jurisdictions that may not offer the same level of data protection as your home country. Where required, we use Standard Contractual Clauses or equivalent safeguards to ensure lawful international data transfers.

10. Your Rights

Depending on your location, you may have the following rights:

Under GDPR (EU/UK)

Under U.S. State Privacy Laws (e.g., California, Virginia, Colorado)

Under PIPEDA (Canada)

To exercise any rights, contact privacy@coachkairo.com. We may request verification to protect your data.

11. Children's Privacy

Kairo is not intended for individuals under 18. We do not knowingly collect personal data from minors. If we discover such data, we will delete it promptly.

12. Additional U.S. State Disclosures (California Notice at Collection)

← Scroll horizontally to view all columns →

Category of Personal Data Purpose of Use Retention Period
Identity & Contact Data Account setup, communication As long as account active
Health & Wellness Preference Data Personalization, service delivery Until deletion request or inactivity
Communications Data Quality assurance, personalization Up to 24 months
Technical & Usage Data Analytics, security Up to 24 months
Transaction Data Payment processing, compliance 7 years (legal requirement)
Referral & Attribution Data Marketing analytics 24 months

We do not sell or share personal data as defined by the CCPA/CPRA.

13. Data Protection Contact

For privacy inquiries, data access requests, or complaints, contact:

Note: No DPO or EU/UK Representative has been appointed at this time; we will update this notice as international operations expand.

14. Legal Basis for Processing (GDPR Only)

For users in the European Economic Area or United Kingdom, we process personal data under the following legal bases:

15. Automated Processing and AI

Coach Kairo uses AI technology to generate personalized responses and recommendations. AI outputs are based on the information you provide and general fitness and nutrition data. Kairo's guidance is informational only and should not replace professional medical advice or clinical judgment.

16. Changes to This Privacy Policy

We may update this Privacy Policy periodically. When we do, we will revise the "Last Updated" date above. Significant changes will be communicated through the Service or other appropriate means.

17. Contact Us

For questions or concerns about this Privacy Policy or your personal data, please contact:
Hexentrega LLC
📧 privacy@coachkairo.com
Jurisdiction: Wyoming, U.S.

Acknowledgment

By using Coach Kairo, you acknowledge that you have read, understood, and agreed to this Privacy Policy.

Coach Kairo™ is a wellness service powered by AI and operated in compliance with applicable privacy laws in the United States, Canada, and the European Union.