Privacy Policy for David Sammel

Effective Date: September 13, 2025 Last Updated: november 23, 2025

1. Introduction

Welcome to David Sammel. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (the "Site"), purchase our courses, or join our community platform hosted on Circle.so (the "Services"). By using our Site and Services, you also agree to our Terms of Service, which can be found at Terms & Conditions. Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site or our services.

For the purpose of the EU General Data protection Regulation (GDPR) and the UK General Data Protection Regulation (UK GDPR), we are the "data controller" of your personal information.

Data Controller:
David Sammel
support@davidsammel.com

2. Information We Collect

We may collect information about you in a variety of ways. The information we may collect includes:

a) Personal Data You Provide to Us:

Contact Information: Your first name, last name, and email address when you sign up for a lead magnet (e.g., the "4-Step Reset"), subscribe to a newsletter, or purchase a product.
Payment Information: When you make a purchase, our payment processor, Stripe, will collect your payment information. We do not store your full credit card number on our servers.
Communications: Any information you provide when you contact us for support or communicate within our Circle community.

b) Data Collected Automatically:

Usage Data: Information about your interactions with our Site and Services.
Device and Browser Data: IP address, browser type, operating system, and other technical information.
Tracking Technologies: We and our third-party service providers use cookies, web beacons, and pixels to collect information. This includes tracking IDs from advertising platforms, such as the Google Click ID (gclid) and Facebook Click ID (fbclid). For detailed information about the specific cookies used on our site, please review our Cookie Policy.

3. How We Use Your Information

a) Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you to:

Create and manage your account.
Process your payments and deliver the digital products and services you have purchased.
Grant you access to our private community on Circle.so.
Email you regarding your account, purchases, or our services.
Send you marketing communications, such as newsletters, special offers, and information about new products, from which you can opt-out at any time.
Measure advertising performance: We use tracking technologies to understand the effectiveness of our advertising campaigns. We securely send conversion data to advertising platforms like Google and Meta. This data includes a hashed (anonymized) version of your personal information (like your email address) and any available advertising click identifiers (gclid or fbclid). This allows the ad platforms to attribute a purchase to an ad you clicked without us exposing your plain text personal information.
Monitor and analyze usage and trends to improve your experience with the Site and our Services.

b) CHILDREN'S PRIVACY: Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children under 18. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us immediately. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

4. Legal Basis for Processing (for UK & European Economic Area Users)

If you are from the UK or the EEA, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. We will normally collect personal information from you only:

Where we need the personal information to perform a contract with you (e.g., to process your payment and provide course access).
Where the processing is in our legitimate interests and not overridden by your rights (e.g., for analytics and marketing).
Where we have your consent to do so (e.g., for you to receive our marketing newsletters).

5. Disclosure of Your Information & Third-Party Services

We may share information we have collected about you with third-party service providers ("Third-Party Tools") that perform services for us or on our behalf, including:

Payment Processing: Stripe, Inc.
Website Hosting: WIX.com
Community Platform: Circle Co., Inc.
Customer Relationship Management (CRM): Zoho Corporation
Email Marketing: Zoho Corporation (Zoho Campaigns)
Advertising Platforms: Google LLC and Meta Platforms, Inc.

Our services rely on these Third-Party Tools to function. While we choose our partners carefully, we are not responsible for the data security practices or privacy policies of these third parties. By using our Services, you acknowledge and agree that your data will be subject to the respective privacy policies, terms, and cookie policies of these services, and you agree to hold us harmless for any data breaches or incidents that occur on their platforms.

AI Sub-Processors: For details on our AI providers (OpenAI and ElevenLabs), please see Section 9 below.

Advanced Matching & Hashed Data: We utilize "Advanced Matching" technologies provided by partners like Meta and Google. If and only if you grant consent via our Cookie Banner, we may share hashed (cryptographically securitized) portions of your data (such as your email address or phone number) to match your visit to your profile on these platforms. This improves ad attribution without sharing your raw plain-text data. If you decline "Marketing Cookies," this hashed data transfer will not occur.

6. International Data Transfers

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. As we are based in the United States, your information will be processed in the US. For transfers of data from the UK/EEA, we rely on appropriate safeguards such as Standard Contractual Clauses to ensure your data is protected.

7. Data Security & retention

DATA SECURITY: We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that no security measures are perfect or impenetrable.

DATA RETENTION: We retain your Personal Data and Chat Logs for as long as your account is active to provide you with continuous access to your coaching history and personalized service. We do not automatically delete your data after a set period of time, as this history is integral to the "24/7 Pocket Coach" experience.

Account & Chat History: We retain your profile information and complete chat history for the lifetime of your account. This allows the AI to maintain context and allows you to review past coaching sessions at any time.
Deletion Upon Request: You have the right to request the permanent deletion of your data at any time. If you wish to delete your account and all associated data (including chat logs and voice inputs), please contact us at support@davidsammel.com. Upon receiving a verified request, we will permanently delete your data from our active databases within 30 days, unless we are required to retain specific information to comply with legal obligations (such as tax/accounting laws).
Inactive Accounts: If your subscription expires, we may retain your data for a reasonable period to allow you to easily reactivate your service. However, we reserve the right to delete accounts that have been inactive for an extended period (e.g., 24 months) after notifying you.

8. Your Data Protection Rights (UK & EEA)

If you are a resident of the UK or European Economic Area, you have the following data protection rights:

The right to access, update, or delete the information we have on you.
The right of rectification.
The right to object to our processing.
The right of restriction.
The right to data portability.
The right to withdraw consent at any time.

To exercise any of these rights, please contact us at support@davidsammel.com.

9. USE OF ARTIFICIAL INTELLIGENCE & DATA PROCESSING

a) AI Sub-Processors: To provide the "24/7 Pocket Coach" service, we utilize specialized third-party Artificial Intelligence (AI) platforms to process your inputs. By using the Service, you acknowledge and agree to the transfer and processing of your data by the following sub-processors:

OpenAI (Large Language Model): We use OpenAI to process your text inputs and generate coaching responses. Your data is sent to OpenAI via their secure API. OpenAI retains API data for a limited period (typically 30 days) solely for abuse monitoring and does not use your data to train their public AI models.
ElevenLabs (Voice Synthesis): We use ElevenLabs to generate the voice of David Sammel. Important: If you use voice features, you acknowledge that your audio inputs are recorded and shared with ElevenLabs for the purpose of transcription and response generation.

b) Human Review ("Feedback Loop"): To ensure the safety and accuracy of the coaching advice, we utilize a "Human-in-the-Loop" review process for quality assurance.

Automated Flagging: If the AI identifies a query it cannot answer (e.g., it generates a "notify David" flag), that specific conversation snippet is logged for review.
Limited Human Access: Authorized members of the David Sammel Team (including David Sammel) may review these flagged, anonymized logs solely to create new training content or correct AI errors.
Confidentiality: These logs are strictly confidential and are never shared publicly or used for marketing purposes.

c) Voice Data Retention: If you use the voice input feature, your audio is immediately transcribed into text. We do not permanently store your raw voice audio files on our servers after transcription is complete; we only retain the text transcript of the conversation for your chat history.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

11. Contact Us

If you have questions or comments about this Privacy Policy, please contact us at: support@davidsammel.com