PRIVACY POLICY

Last Updated: 24 April 2026

This Privacy Policy explains how Spark Ventures Sdn Bhd (“HyperCoach”, “we”, “us”, or “our”) collects, uses, stores, and protects your personal information when you access or use our website, mobile application, and any related services (collectively, the “Services”).

Your trust and privacy are extremely important to us. This Policy is designed to provide transparency into how your personal data is handled, your rights in relation to your data, and the measures we take to ensure confidentiality and security.

1. Our General Approach

HyperCoach is an AI Coaching Platform designed to help individuals and organizations grow through intelligent and human-centered AI coaching. We believe that artificial intelligence, when developed responsibly, can transform how people learn, grow, and lead.

Our Privacy Policy reflects our belief that trust and safety are foundational to that transformation.

Key points:

• We collect limited information to operate and improve HyperCoach.
• Your coaching conversations are private and will never be shared or sold.
• We have strict controls over access to user data and enforce confidentiality.
• You must be 18 years of age or older to use HyperCoach.
• HyperCoach may occasionally generate inaccurate information. Always validate advice before acting.

2. Information We Collect

a. Information You Provide

We may collect personal information that you provide directly:

• Contact and account information (name, email, phone number).
• Conversation data from coaching interactions.
• Feedback and communication from surveys or support.
• Other data you choose to share with us.

b. Automatically Collected

We may automatically collect certain information:

• Device type, operating system, browser, and IP address.
• Log information (time of access, features used, session duration).

c. From Other Sources

If you interact with HyperCoach through a third-party platform (such as WhatsApp), we may collect your profile identifier solely to enable communication.

d. Sensitive Information

In coaching conversations, you may share sensitive personal data. By doing so, you consent to our processing of such data solely to provide and improve the coaching experience.

3. How We Use Your Information

We use your personal information for the following purposes:

• To Provide and Operate: Create and manage your account, deliver AI coaching, and perform obligations under our Terms.
• To Communicate: Respond to inquiries, send updates, deliver reminders, and provide support.
• To Improve and Personalize: Understand user needs and refine quality, responsiveness, and relevance of coaching.
• For Research: Enhance AI performance and accuracy using aggregated and anonymized data.
• For Compliance: Meet legal obligations, enforce terms, and protect users from fraud or abuse.

4. Sharing Your Information

We do not sell, rent, or trade your personal data. We only share in limited circumstances:

• Service Providers: Trusted partners for hosting, processing, or analytics, contractually bound to protect your data.
• Business Transfers: In the event of merger, acquisition, or restructuring under confidentiality safeguards.
• Legal Compliance: Where required by law, subpoena, or governmental request.

All disclosures are limited, controlled, and aligned with our ethical and privacy commitments.

5. Security

Protecting your personal information and the confidentiality of your coaching conversations is of the utmost importance to us. We have implemented strict technical, organizational, and administrative measures including:

• Secure data encryption in transit and at rest.
• Limited employee access on a need-to-know basis.
• Multi-factor authentication for administrative accounts.
• Continuous monitoring for vulnerabilities and attacks.

No exact or raw coaching conversation data will ever be shared with employers or any third party. Data made available to organizations is aggregated and anonymized only.

While we employ robust safeguards, no system can be guaranteed completely secure. HyperCoach is committed to upholding the highest standards of privacy and security.

6. Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, in accordance with applicable laws. Once data is no longer required, it will be securely deleted or anonymized.

7. Your Rights and Choices

You may:

• Request access to, correction, or deletion of your personal data.
• Withdraw your consent (where applicable).
• Request information about how your data is processed.

Requests can be made by contacting us at hello@hypercoach.asia. We may need to verify your identity before fulfilling certain requests.

8. Children

Our Services are intended for users aged 18 and above. We do not knowingly collect data from minors. If you believe a minor is using our Services, please contact us immediately at hello@hypercoach.asia.

9. Changes to This Policy

We may update this Policy from time to time. Updated versions will be posted on our website, and continued use of the Services after such updates constitutes acceptance of the revised Policy.

10. Contact Us

Spark Ventures Sdn Bhd Owner and Operator of HyperCoach

Email: hello@hypercoach.asia Website: www.hypercoach.asia

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