Last updated: February 11, 2026
Impactean ("Impactean," "Company," "we," "us," "our") is committed to protecting and respecting your privacy. This Privacy Policy describes our privacy practices in relation to the information we collect from you when you:
Collectively, these are referred to as the "Services." Please read this Privacy Policy carefully. By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. If you do not agree with this policy, please do not access or use our Services.
Impactean is the Data Controller of your personal data collected through the Services. This means we determine the purposes and means of processing your personal data and are responsible for ensuring it is handled in compliance with applicable data protection laws.
If you are using Impactean through an organizational (business) plan provided by your employer, your employer may also act as a Data Controller or Joint Controller for certain categories of data. In such cases, your employer's own privacy policy will also apply.
You can address any privacy-related queries to us by emailing privacy@impactean.com or by using the contact details in Section 18 below.
Personal data includes any information relating to an identified or identifiable natural person. It does not include data that cannot be linked to an individual (such as anonymous or aggregated data). We collect, use, store, and transfer the following categories of personal data:
a. Identity Data — Your first name, last name, and any profile photo you choose to upload.
b. Contact Data — Your email address, and optionally your phone number and mailing address.
c. Account Data — Your username, password (stored in hashed form), account preferences, subscription plan, and billing history.
d. Assessment Data — Your responses to the Wheel of Impact™ assessment, your Impact Capacity Score, pillar scores (Purpose, Passion, Persistence), sub-dimension scores, and your personalized development report content.
e. Coaching Data — Conversations, messages, and interactions with your AI Executive Coach, including goals discussed, commitments made, and coaching session history.
f. Commitment & Progress Data — Weekly commitments you set, progress check-in responses, and reminders.
g. Payment Data — Payment card details (processed securely by our third-party payment processor — we do not store full card numbers), billing address, transaction history, and subscription status.
h. Usage Data — Information about how you use our website, application, and Services, including features accessed, pages viewed, assessment completion rates, and coaching engagement metrics.
i. Technical Data — Your IP address, browser type and version, device information, operating system, time zone setting, cookie data, login timestamps, and other technical information collected when you access our Services.
j. Marketing Communications Data — Your preferences regarding marketing content, communication frequency, and preferred channels.
We use different methods to collect data from and about you, including:
You provide us with personal data directly when you:
As you interact with our Services, we automatically collect Technical Data and Usage Data about your equipment, browsing actions, and engagement patterns. We collect this data using:
We may receive personal data about you from third parties, including:
Note: The provision of your personal data is voluntary. You may choose not to provide certain information; however, this may limit your ability to use the full functionality of the Services.
We process personal data only where we have a lawful basis for doing so. The specific legal basis depends on the context in which the data is collected and processed.
| Purpose | Data Categories | Legal Basis |
|---|---|---|
| To register your account and manage your subscription | Identity, Contact, Account, Payment | Performance of a contract |
| To administer and deliver the Wheel of Impact™ assessment and generate your personalized report | Identity, Assessment | Performance of a contract |
| To provide AI Executive Coaching services personalized to your profile and assessment results | Identity, Assessment, Coaching, Commitment & Progress | Performance of a contract; Consent for sensitive coaching topics |
| To enable commitment tracking, progress monitoring, and accountability features | Identity, Commitment & Progress, Coaching | Performance of a contract |
| To process payments and manage billing | Identity, Contact, Payment | Performance of a contract; Legal obligation |
| To send marketing communications, newsletters, and product updates | Identity, Contact, Marketing Communications | Consent; Legitimate interest (existing customers) |
| To improve our Services, develop new features, and enhance user experience | Usage, Technical, Assessment (aggregated) | Legitimate interest |
| To provide organizational analytics and team insights (Business plans) | Assessment (aggregated), Usage | Performance of a contract; Legitimate interest |
| To respond to your requests, questions, or support inquiries | Identity, Contact, Account | Legitimate interest |
| To comply with legal obligations and respond to lawful requests | As strictly necessary | Legal obligation |
| To detect, prevent, and address fraud, security issues, or technical problems | Technical, Usage, Account | Legitimate interest; Legal obligation |
Given the sensitive nature of coaching conversations and assessment results, we want to be transparent about how this data is handled:
Impactean uses artificial intelligence as a core part of our Services. Here is how AI is used and the safeguards we have in place:
We do not sell, trade, or rent your personal information. We share personal data only with carefully selected partners as necessary to provide our Services and fulfill our obligations. We will obtain your consent where required by law.
| Recipient | Reason for Sharing |
|---|---|
| Cloud Infrastructure Providers | To securely host our platform, databases, and application infrastructure. Data is stored with encryption at rest and in transit. |
| Payment Processors | To securely process your payments. We use PCI-DSS compliant payment processors and do not store full payment card details on our servers. |
| AI Service Providers | To power the AI Executive Coach functionality. Data shared with AI providers is subject to strict data processing agreements and is not used to train their general models. |
| Analytics Providers | To help us understand how our Services are used and improve the user experience. Data shared is anonymized or pseudonymized where possible. |
| Email & Communication Providers | To send transactional emails (e.g., account verification, password resets, coaching reminders) and, where you have opted in, marketing communications. |
| Your Employer (Organizational Plans Only) | If you are on an organizational plan, your employer may receive aggregated, anonymized team analytics and engagement metrics. Individual assessment scores, coaching conversations, and commitment details are never shared without your explicit consent. |
| Government Authorities or Law Enforcement | If we in good faith believe we are compelled by applicable law, regulation, legal process, or government authority, or where necessary to exercise, establish, or defend legal rights. |
| Corporate Transaction Partners | In connection with a merger, acquisition, reorganization, or sale of all or part of our business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections. |
Impactean operates globally, and your personal data may be transferred to and processed in countries outside of your country of residence, including countries that may not have data protection laws equivalent to those in your home country.
When we transfer personal data internationally, we ensure appropriate safeguards are in place, including:
You may request additional information about the safeguards we use for international transfers by contacting us at privacy@impactean.com.
We retain your personal data only as long as necessary to provide you with our Services and for legitimate business purposes. The specific retention periods depend on the type of data and the purpose for which it was collected:
| Data Type | Retention Period |
|---|---|
| Account & Identity Data | For the duration of your active account, plus up to 12 months after account deletion for backup and legal compliance purposes |
| Assessment Data & Reports | For the duration of your active account. You retain access to your report even after canceling a subscription. Deleted upon account deletion request. |
| AI Coaching Conversations | For the duration of your active account. Deleted within 30 days of account deletion request. |
| Payment & Billing Data | As required by applicable tax and financial regulations (typically 7 years) |
| Technical & Usage Data | Up to 24 months, then anonymized or deleted |
| Marketing Consent Records | For as long as the consent is valid, plus records retained for compliance |
In some circumstances, we may anonymize your personal data so that it can no longer be associated with you. We may use such anonymized data indefinitely without further notice for research and product improvement purposes.
We maintain commercially reasonable and industry-standard security safeguards to protect your personal data. Our security measures include:
While we strive to protect your personal data, no method of transmission over the Internet or electronic storage is 100% secure. If you have reason to believe that your interaction with us is not secure or that data has been compromised, please immediately notify us at support@impactean.com.
Under applicable data protection laws (including GDPR, CCPA, and other regional regulations), you may have the following rights. You are not required to pay to exercise these rights.
You have the right to be informed about the collection and use of your personal data. This Privacy Policy serves as the primary means of providing this information.
You have the right to request access to the personal data we hold about you and to receive a copy of it. You can access most of your data directly through your account dashboard.
If you believe any personal data we hold about you is inaccurate or incomplete, you can request that it be corrected or updated. You can update most information directly in your account settings.
You have the right to request deletion of your personal data in certain circumstances. Upon request, we will delete your account, assessment data, coaching conversations, and all associated personal data, subject to any legal retention obligations.
In certain circumstances, you have the right to request that we restrict the processing of your personal data (e.g., while we verify the accuracy of data you have disputed).
You have the right to object to the processing of your personal data where we rely on legitimate interests as our legal basis, including objecting to direct marketing.
You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that we transfer it to another service provider where technically feasible. This includes your assessment results and report data.
Where we rely on your consent to process personal data, you can withdraw consent at any time. This will not affect the lawfulness of processing carried out before the withdrawal.
You have the right to lodge a complaint with your local data protection authority if you believe your personal data has been handled unlawfully.
How to exercise your rights: You can exercise most rights directly through your account settings. For requests that require our assistance, please email privacy@impactean.com. We will respond to your request within 30 days (or sooner as required by applicable law).
We use cookies and similar tracking technologies to enhance your experience, analyze usage patterns, and deliver relevant content. Below is a summary of the types of cookies we use:
| Cookie Type | Purpose | Required? |
|---|---|---|
| Strictly Necessary | Essential for the website and application to function (e.g., authentication, session management, security) | Yes |
| Performance & Analytics | Help us understand how visitors use our website and improve performance (e.g., Google Analytics) | No — opt-out available |
| Functional | Remember your preferences and settings (e.g., language, display preferences) | No — opt-out available |
| Marketing | Used to deliver relevant advertisements and measure campaign effectiveness | No — opt-out available |
You can control and manage cookies through your browser settings. Most browsers allow you to:
Please note that disabling cookies may affect the functionality of our Services. Strictly necessary cookies cannot be disabled as they are essential for the platform to operate.
We will only send you marketing communications if you have opted in to receiving them, or where permitted by law (e.g., if you are an existing customer and we are marketing similar services). Marketing communications may include:
You can opt out of marketing communications at any time by:
Please note that even after opting out of marketing, you will continue to receive transactional and service-related communications (such as assessment completion confirmations, coaching reminders, payment receipts, and security alerts), as these are necessary for the operation of your account.
Our Services are designed for and directed at adults (individuals 18 years of age or older). We do not knowingly collect personal data from children under the age of 16 (or the applicable age of digital consent in your jurisdiction).
If we become aware that we have inadvertently collected personal data from a child, we will take steps to delete that information as soon as possible. If you believe that a child has provided us with personal data, please contact us immediately at privacy@impactean.com.
If you are a resident of California, Virginia, Colorado, Connecticut, Utah, or another US state with a comprehensive privacy law, you may have additional rights, including:
To exercise these rights, please contact us at privacy@impactean.com. We will verify your identity before processing your request and respond within the timeframes required by applicable law.
California Residents: Under the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA), you have specific rights regarding your personal information. We do not sell personal information. For more information, you can submit a verifiable consumer request by emailing us.
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes:
We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.
If you have questions about this Privacy Policy, want to exercise your data protection rights, or have concerns about how we handle your personal data, please get in touch:
We aim to respond to all privacy-related inquiries within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority.