Privacy policy


Smarthabit Cares About Your Privacy

Last Update Effective: October 12, 2023

Transparency and honesty are a huge part of our mission at Smarthabit. We care about your privacy and especially about the psychological safety of the coaching environment. As such, whether you are a coach providing services on our platform, a user of our platform, an entity that contracts on behalf of users of our platform, or a visitor to our website, we want you to know how we collect, use and share your data. We want to communicate this in plain language, as much as possible.

You may be working with us in other contexts not specifically described in this policy and while we don’t address privacy for all stakeholders and situations in this privacy policy, our philosophy applies to those other contexts as well. Depending on the products, features, or experiences you use, we may provide additional privacy notices at the time we collect your data, such as our Experience Privacy Notice and Lighthouse™ Privacy Notice, or describe more details in the Platform.

Privacy Policy Table of Contents

1. Introduction and Definitions

This privacy policy describes our privacy practices relevant to the Site, Services and Platform and the impact these practices have on Applicants, Site Visitors, Coaches, Users and User Organizations. Each term is defined below. Let’s start with a brief overview of what we do, how and where we might be collecting data and then define some relevant terms.

Smarthabit, Inc. (“Smarthabit”) is the first Whole PersonTM platform to transform performance and growth for people, teams, and organizations where it matters most – career and leadership development, proactive mental fitness, and inclusion and belonging through a variety of behavioral techniques and methods (the “Services”) on our mobile application and online platform (the “Platform”). This policy will also cover the activities of Smarthabit Wellness Services, Inc.

We will need to distinguish between the people to whom we provide Services directly via the Platform (who we will refer to as “Users”) and the entities who contract with us to provide Services to their employees or others on the Platform (who we will refer to as “User Organizations”). We collect, use and share data differently for Users and User Organizations, although they might sometimes be one and the same. In the event you receive Smarthabit Services as a result of your employer or other sponsoring organization, please be aware of the data which may be shared back to your User Organization as a result of using the Smarthabit Platform.

We also collect data from business coaches (“Coaches”) who typically contract with us to provide services to Users via the Platform and from visitors (“Visitors”) to our website and its subdomains (the “Site”). Should you apply for a job with Smarthabit you will be known as an “Applicant”.

To the extent data is associated with an identified or identifiable natural person and is protected as personal information (or substantially equivalent terms) under applicable data protection laws, we will refer to this as “Personal Data”. Please understand that certain local laws may refer to personal information rather than Personal Data and in the context of this Policy, Smarthabit intends these terms to be interchangeable.

2. Data We Collect

2.1 Data You Provide to Us

Data From Our Website

If you are a visitor to our public website, and its subdomains, we and trusted third parties acting on our behalf will collect certain information. We use cookies and similar technologies (e.g., web beacons, pixels and ad tags) to collect data (e.g., device IDs) from our public Site to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Site. We also allow third parties to use cookies as the Cookie Policy describes, including to assist in our marketing and advertising campaigns. We may also collect (or rely on others who collect) data about your device where you have not engaged with our Site (e.g., ad ID, IP address, operating system and browser data) so we can provide our Visitors with a better user experience. You can opt out from our use of data from cookies and similar technologies that track your behavior on the sites of others for ad targeting and other ad-related purposes.

Please review the Cookie Policy for all relevant details.

 Data From Applicants

We collect information if you apply for a job (“Applicant”) with Smarthabit. We will need to collect certain personal information from you in order to process your application, such as your name,

email address, phone number, location, and work history. This information is used to evaluate your experience and communicate with you. Smarthabit does work with several third party vendors to assist in the application process and where those systems will have access to your personal information Smarthabit will provide the appropriate disclosures. If any of these systems will require highly sensitive personal information or request session recordings, you will be notified at that time.

If you are an Applicant based in the European Union, U.K., or California, please review the Applicant Privacy Notice which includes information about: what personal information we collect; how we collect, use and disclose that information and the legal grounds for us doing this; and your rights in respect of your personal information.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the SwissU.S. DPF, Smarthabit commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.

Data From Coaches

If you are a Coach, we collect data when you submit an inquiry to provide coaching services for us, when you use the Platform, when you request technical support, and when you otherwise initiate communication with us.

We never require Coaches to provide us any sensitive Personal Data (e.g. financial data), although we may request demographic or other personal data from Coaches when we are testing a new tool or feature, staffing a specific program for customers, or conducting research studies. The type of demographic or personal data we may request may include gender, race, ethnicity, specialized skills such as ASL, or for federal programs, your citizenship. When asking for demographic data, Smarthabit does so because we believe it will improve the services for our Users and Coaches; however, providing such personal information shall remain optional.

We may ask for your consent as a Coach to record your coaching session for training, research, or additional purposes as further described in Section 2.6, in which case we may collect data capturing your image, voice, and/or a transcript of recording in order to conduct analysis for the betterment of the User, also known as our Members, and your future coaching sessions. Smarthabit understands video recordings may capture sensitive personal information; therefore where possible, Smarthabit will minimize the amount of personal data being accessed by analyzing the recordings after de-identification or conducting analysis on the transcript rather than the full video. We discuss this further within Section 2.6 below.

As a Coach, we may ask you to provide us data to improve your experience on the Platform. For example, we may ask Coaches:

In all circumstances, your decision to provide Smarthabit with Personal Data has no impact on your role as a Coach, and you may withdraw consent at any time by emailing.

Data From Users

If you are a User, we collect data when you register for the Platform and when you access the Services via the Platform. We require certain Personal Data in order to register your account, such as:

We require this data for at least the following reasons: 1) to create your account; 2) to ensure you are matched with a coach in an appropriate time zone; 3) ensure we have minimum location data to honor your specific privacy rights; and 4) to ensure you receive applicable surveys or questionnaires commensurate with your management level. If your access to the Smarthabit Services is being provided by your User Organization, this type of data may be shared with Smarthabit from your User Organization.

We collect data to provide and improve your experience on the Platform. For example, we may ask Users to:

To facilitate a robust and meaningful coaching experience, both you and your Coach will have access to your matching survey and assessment responses. Your sponsoring User Organization will never receive access to your individual assessment or personalization responses although they may see aggregate and de-identified reports of all Users connected to your sponsoring Organization so long as our data scientists can confirm a minimum threshold of Users from your organization to maintain anonymity.

We collect usage data from Users accessing the Platform, such as which programs you respond to and attend, your session ratings, when you attend a coaching session, your employment details and any other usage data you share with us (or your User Organization shares with us) in connection with the Platform.

Your sponsoring User Organization will receive information from Smarthabit about your usage on the Platform in the following ways:

 2.2 Data We Collect About Users from Others

If you are a User registering on the Platform through a license purchased by a User Organization (which may or may not be your employer), the User Organization may provide us with certain demographic data about you.

In some cases, a User Organization may choose to integrate its human resources information system (“HRIS”) with the Platform. If applicable, the User Organization may share employment data such as, but not limited to, your hire date, your history promotions or job changes, or anything else your sponsoring Organization may choose to provide to Smarthabit.

In other cases, the Platform may integrate with third party systems on behalf of a User Organization to manage data and gain insights about the value of the platform.

If you as a User have concerns about this data collected from third parties, please speak with your Smarthabit program manager or your contact at your User Organization.

 2.3 Aggregated Data from Use of Platform

 Whether you are a Coach or User, we may aggregate and de-identify the data related to your use of the Platform apart from what has been detailed above. We may analyze your usage data and content when it is uploaded, sent, received, or stored. We may use your data, activity logs, and direct feedback to improve our Platform and Services.

 2.4 Cookies and Similar Technologies

First, while we use similar technologies within our Platform, they are separate and apart from the cookies and similar technology used on our public website,, which are all disclosed within our Cookie Policy.

In order to provide specific functionality within our Platform, there is limited use of tracking technology within our Platform, as also disclosed within our Cookie Policy. Users may manage their Cookie preferences within their User Profile in the Platform.

2.5 Your Device and Location

We do collect data from Platform Visitors such as data about your device and location via IP address, the type of browser you use, amount of time you spend on the Platform, pages viewed, forms submitted, and the digital channel that brought you to the Platform. Smarthabit will not request precise geo-location data from our Users.

If you access the Platform via a mobile device or have downloaded our mobile application, we may collect data such as the first time the mobile application is opened, mobile carrier, and the type of device that is being used.

 2.6 Audio & Video Data

 We may record coaching sessions on the Platform with the express consent of both Coach and User (each a “Recording”). If you have consented to a Recording, it will be used to inform analyses on the quality and effectiveness of your coaching session. The session recording may be used in the following ways:

We have developed software to view and analyze these sessions and derive insights from them in a deidentified manner to improve your experience and our Platform and Services. When Smarthabit uses the term “deidentified” we understand this is useful as a data minimization technique and included within this term is a commitment not to re-identify the data unless necessary to provide Service to You.

Smarthabit is constantly looking for ways to level up our services, to find a way to use the behavioral sciences to improve your coaching journey. Occasionally in our pursuit of the best tools to provide the analysis we need to serve our Users, we may use third party vendors to assist with analyzing this data. When working with third party vendors, Smarthabit’s priority is to provide data in a deidentified manner and will ensure that your data remains confidential to your experience with Smarthabit. Smarthabit requires all third party vendors to certify in contract they will never sell data and will maintain strict privacy and security controls for all data they may have access to as a result of working with Smarthabit. Occasionally, the third party vendors providing analysis of this data may utilize Artificial Intelligence. That means, in addition to the contractual protections noted above, any data received from Smarthabit cannot be used to train their algorithms or data models and must be immediately deleted after providing the requested analysis. Any data shared with our third party vendors remains encrypted in transit.

The Recordings will be securely stored in our data center in the United States and our employees can access them on a need-to-know basis only. Recordings will never be shared with your User Organization. Your sponsoring User Organization will never receive access to your individual recording although they may see aggregate and de-identified analysis of all Users connected to your sponsoring Organization so long as our data scientists can confirm a minimum threshold of Users from your organization to maintain anonymity.

 2.7 Health Information

Smarthabit’s Services do not collect any Protected Health Information as that is defined under the Health Insurance Portability and Accountability Act (“HIPAA”) and the use of our Services does not require HIPAA compliance. Additionally, Smarthabit is not considered a Covered Entity under HIPAA.

Smarthabit acknowledges and understands the definition of health information is more expansive under GDPR and other privacy regulations, to include general well-being and any data relating to a person’s physical or mental health; therefore, Smarthabit handles all health information as sensitive and has implemented additional security and privacy protocols for all health-related information.

3. How We Use Your Data

 3.1 Services

At the core of Smarthabit is our belief that behavioral sciences can create the world’s most effective approach to human and organizational transformation, driving impact for your whole person and delivering real metrics that measure success. To do so, Smarthabit will use your data to drive these insights and analytics to serve you, our Users. The primary manner in which we use all data is to provide the Services and help us improve the Site, the Platform, and the quality of our Services, and this extends to Personal Data. As described in Section 2, we request sensitive Personal Data only under very limited circumstances, providing it is always voluntary, and you may revoke permission at any time.

3.2 Communicate With Users and Coaches

 We require certain Personal Data from both User and Coaches for routine communication with each and to facilitate the relationship between them.

3.3 Market To You

 As further described in the Cookie Policy and in Section 2.4 and 2.5 above, we collect certain data from Site Visitors for marketing and advertising purposes. Site Visitors may also need to provide data to schedule a demo or interact with a bot on the Site to get what information you need from us more efficiently. We may also use this information to communicate with You or potentially your User Organization about product, services, offers, promotions, rewards, and events offered by Smarthabit or others; provide news and information we think will be of interest to You or your User Organization; and deliver and measure advertisements on other media and third party websites. You have control over what information is collected and used, per our Cookie Policy.

 3.4 Provide Customer Support

 You may provide data via the Site or Platform that we use to provide a better customer support experience to you. For instance, if you were to email our team would request specific information for verification purposes and as necessary to address your concerns.

 3.5 Generate Insights That Do Not Identify You

Most data that we use internally is de-identified and aggregated. This includes research through our Smarthabit Labs, the first-of-its-kind behavioral research lab bringing together business, academia, and science, which we use to improve the Platform, the Site and the quality of our Service.

4. How We Share Data with Third Parties


We share certain Personal Data about Users with Coaches (and vice versa) such as contact information and responses to surveys to facilitate the ability for Coaches to provide services to Users.
If you are a User who is accessing the Platform through a paid subscription through a User Organization (e.g. your employer), we share certain usage data with your sponsoring User Organization, such as data about your Platform usage (e.g. the number of sessions you attended, when the session was attended, or date of completion of an assessment). We share this information with your sponsoring Organization to ensure a User Organization has the tools necessary to ensure the Services are being utilized and that they are effective. We do NOT share your assessment or survey responses or your individual coaching sessions with your User Organization. Your sponsoring Organization may see de-identified and aggregated analysis from all participating Users within your organization as aggregated from your interactions with resources within the Smarthabit Platform and general session topics as identified by your Coach, post-session. As discussed in 2.1 above, we do share limited individual level data with the sponsoring Organization.

Section 2.2 also discusses how third parties may access your data.

We may also share opinions, feedback or reviews you voluntarily provide to us as a User with your User Organization and your Coach on a de-identified basis, for quality or educational purposes.

We may share your own feedback or reviews where you specifically consent to do so within the Platform, such as when You are responding to an assessment of a fellow User such as a 360 review, or if you request to share your data with your immediate manager or supervisor within a Manager Feedback request. Within the Platform, you will be reminded of this additional sharing and you always have the choice to not agree to such sharing.

If you are a Visitor to our public site or an individual User of Smarthabit Direct (, we may share data about your interactions with the Site and the Services (such as whether you purchased a subscription) with our marketing and advertising service partners to help us create and administer campaigns, target and deliver relevant advertisements on third-party websites, and measure and optimize their effectiveness. To opt-out of sharing your data for these purposes, please opt out via the provided links or manage within your cookie preferences.

If you are a Visitor, Coach, User or User Organization, we may also share data about you as follows:

5. Your Choices, Rights and Obligations

 5.1 Data Retention
We store Personal Data for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

5.2 Your Choices About Data Generally

You may update, correct, or delete Personal Data at any time by contacting us through our Privacy Request Form. Your User Profile within the Platform also affords you the ability to update certain preferences and personal information. Please note that we may retain certain data as required by law or for legitimate business purposes. We may also retain cached or archived copies of data about you for a certain period.

5.3 Your Choices About Email Subscriptions

You may opt out of receiving email communications from us by following the unsubscribe link within those communications or by emailing us at

5.4 Your Choices About Promotional Communication

If you are outside of the European Union (“EU”), you may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at If you opt out, we may still send you non-promotional communications specifically related to your use of the Platform.

5.5 Your Jurisdiction-specific Rights

A. Your Rights under State level privacy laws

At this time, the United States is seeing a handful of states passing comprehensive privacy legislation. We understand each state is doing their best to protect the individual privacy rights for their own citizens, which is why Smarthabit has taken the approach of honoring all privacy rights such as the generally accepted principles of right of access, deletion, and correction for all our Users, and will honor the rights described within this Privacy Policy as well as all rights afforded you under your local state laws.

B. Your Rights under the General Data Privacy Regulation (“GDPR”)

If you are a resident of the European Union (EU) and European Economic Area (EEA), GDPR affords you certain rights. These include:

To exercise any of the above rights, please send a request to Please note that we may ask you to verify your identity before responding to such requests.

Your Personal Data may be processed outside your jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislature and/or regulator, and that may not provide for the same level of data protection as your jurisdiction, such as the European Economic Area.

We are based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the United States and other countries, where you might not have the same rights and protections as you do under local law. Smarthabit may be obligated to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

You have the right to complain to a Data Protection Authority (as defined by the GDPR) about our collection and use of your Personal Data. For contact details of your local Data Protection Authority, please see here.

C. Your Rights under the California Consumer Privacy Act (“CCPA”)

If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and ask us not to sell it. You may request what personal information we have about you. If you make this request, we will return to you:

(i) The categories of personal information (as defined by the CCPA) we have collected about you.
(ii) The categories of sources from which we collect your personal information.
(iii) The business or commercial purpose for collecting or selling your personal information.
(iv) The categories of third parties with whom we share personal information.
(v) The specific pieces of personal information we have collected about you.
(vi) A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.
(vii) A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.

If you request we delete your data pursuant to the CCPA, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through deidentification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.

We will not discriminate against you under any circumstances for exercising your rights in connection with the CCPA. To exercise your California data protection rights described above, please send a request to or

6. Other Important Information

6.1 Smarthabit, Machine Learning and AI

We are currently using forms of Machine Learning (ML) and Artificial Intelligence (AI) to deliver ideal coach matches for our members, to guide members to expert topical coaches at the ideal time, and to provide industry-leading insights to our partners, and are constantly exploring the possibility of new AI-driven applications and features. These Services rely on User actions and inputs including Your decision to accept or reject the proposed coaches or the analytic insights provided. AI is a tool — like a pencil or a calculator – that can help us do our jobs better and faster and is here to enable our Users to connect better with a Coach. Smarthabit believes that responsibly designed technology will enhance the coaching experience.

Smarthabit recognizes the use of these technologies can raise new privacy and security concerns. This is why, for example, Smarthabit allows Users to manually override Your coach recommendations. It is also why Smarthabit provides additional disclosures, such as describing a feature as “AI-assisted” throughout our product experience where AI-powered insights may be provided so You may have insight into when Your coaching experience has been enhanced with AI-powered technologies.

In addition to the User controls Smarthabit has identified above, we are also committed to providing transparency in our ongoing research and development efforts related to AI. For example, we’ve published a dedicated Lighthouse™ Privacy Notice to address the privacy of data processed through Lighthouse™, our AI-enabled chat experience, available to some of our Users. To learn more about the benefits, challenges and ethical considerations of AI, and to hear about how AI can help improve human performance and help individuals reach their full potential, you can review our Smarthabit Blog with panel discussions on AI powered human potential and how we’re partnering with industry leaders to help shape the future of coaching.

6.2 Smarthabit’s Commitment to Children’s Privacy

At Smarthabit we take children’s privacy very seriously. The Platform and Services are designed for businesses and individuals over the age of 18 and we do not intentionally collect any data from persons under the age of 18 (each a “Child”). If you believe that Smarthabit may have directly collected Personal Data about a Child and wish to have us remove that Personal Data, please contact us at to let us know. We’ll work with you to make sure that data is removed from our Site and Services, as applicable. In the event that Smarthabit discovers we may have collected Personal Data about a Child, we will proactively remove that information.

6.3 Is Smarthabit a Data Controller or a Data Processor?

Certain data protection laws distinguish between data processors and data controllers, depending on how the data is collected and shared. Smarthabit is a Controller and a Business with respect to our direct relationship with Users within our Platform. Smarthabit may also be a Processor with respect to data provided by a User Organization when registering on behalf of Users it is contracting for.

6.4 Does Smarthabit adhere to Data Privacy Framework?

Yes. Smarthabit complies with the EU-U.S. Data Privacy Framework, UK Extension to the EU-US Data Privacy Framework, and Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, United Kingdom, and Switzerland to the United States. Smarthabit has certified to the U.S. Department of Commerce that it adheres to the Data Privacy Framework principles. If there is any conflict between the terms in this privacy policy and the Data Privacy Principles, the Data Privacy Principles shall govern. For more information about the Framework and its current status visit the Department of Commerce Data Privacy Framework Website at

As discussed within Section 5.5 your personal information may be processed outside your jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislature and/or regulator, and that may not provide for the same level of data protection as your jurisdiction, such as the European Economic Area. We ensure that the recipient of your Personal Data offers an adequate level of data protection, for example, by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses for the transfer of data as approved by the European Commission (as described in Article 46 of the General Data Protection Regulation).

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the SwissU.S. DPF, Smarthabit commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit TRUSTe for more information or to file a complaint. The services of TRUSTe are provided at no cost to you.

Under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint, see here. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. If we share EU Data with a thirdparty service provider that processes the data solely on our behalf, then we will be liable for that third party’s processing of EU Data in violation of the Principles, unless we can prove that we are not responsible for the event giving rise to the damage.

6.5 How Do You Communicate Changes to This Privacy Policy?

If we make changes to this Privacy Policy, we will notify you by revising the date at the top of the policy. In some cases, such as a material change in our practices, we may provide you with additional notice, such as adding a statement to our homepage or sending you an email notification. We encourage you to review the Privacy Policy whenever you access the Site, Platform or Services to stay informed about our data practices and the ways you can help protect your privacy.

6.6 How Can I Contact Smarthabit About This Privacy Policy?

Two ways: