Koomba Privacy Policy

At Koomba Inc. ("Koomba", "we", "our" and "us"), we respect your privacy and appreciate the trust you have placed in us. This Privacy Policy explains how Koomba collects, uses, and discloses information in connection with our provision of services through our website, our platform, and any other online services that link to or refer to this Privacy Policy (collectively, the "Services").

This Privacy Policy is part of our Terms of Service. Terms used here have the same meaning as in our Terms of Service. When you use our Platform, you accept and agree to both the Terms of Service and this Privacy Policy. If you do not agree to this Privacy Policy, you should stop using the Services.

Summary of Key Points

• We collect information you provide directly (including account information, wellbeing check-in responses, and content from your coaching sessions), information provided by a school, club, or other organization that sponsors your access, and technical information collected automatically.
• With notice and consent, coaching sessions conducted through the Platform may be recorded and transcribed to support your coaching. Recordings and transcripts are stored in secure, encrypted infrastructure and are treated as confidential session content.
• If you access Koomba through a partner organization (such as a school, college, or club), we share only aggregate, de-identified insights with that organization. We do not share your individual session content, transcripts, or check-in responses with your organization without your consent, except where required for safety or by law.
• We do not sell your personal information, and we do not use your personal information for third-party advertising.
• The Platform is intended for users 13 years of age and older.

Information We Collect

Information You Provide

We collect information you provide when you use the Services, communicate with our team, or request information from or about our Services, including:

• Contact information and identifiers, such as your name, phone number, email address, username, and password.
• Athletic and demographic information, such as your school or club, sports team, sport played, gender, and age.
• Intake and matching information, such as the challenges you want to work on, the outcomes you are looking for, and your preferences for a provider.
• Wellbeing check-in responses. The Platform may periodically prompt you to complete brief check-ins about topics such as your energy, enjoyment, and engagement in your sport, along with additional questions added by your provider. Responding is always voluntary.
• Session-related content, such as goals, notes, messages, and other information you share in connection with your coaching sessions, including session recordings and transcripts as described below.
• Parent or guardian contact information, for users under 18.
• Payment information, when you transact with us. Payments are processed by Stripe, Inc.; Koomba does not store full payment card numbers.

Information We Receive from Partner Organizations

If you access Koomba through a school, college, club, team, or other organization that has contracted with Koomba (a "Partner Organization"), we may receive information about you from that organization, such as your name, contact information, team, sport, and eligibility for the program.

Information We Collect Automatically

We automatically collect certain technical information from your computer or mobile device when you use the Services, including IP address, device and browser type, operating system, unique device identifiers, and information about how you use the Services. We use cookies and similar technologies for Platform functionality, performance, and analytics. You can set your browser to block certain cookies or notify you when a cookie is set; some features may not function properly if you do.

Session Recording and Transcription

As part of our commitment to quality, safety, and continuity of coaching, coaching sessions conducted through the Platform may be recorded and transcribed. Where sessions are recorded:

• We provide notice and obtain consent before your first recorded session (and, for users under 18, from a parent or guardian where required).
• Transcription is performed using Amazon Transcribe Medical, a HIPAA-eligible automatic speech recognition service from Amazon Web Services designed for health-related speech. The service is stateless: it does not itself store the audio it receives or the transcripts it produces, and Koomba controls where transcripts are stored.
• Session documentation and summaries are generated with the assistance of Claude, an AI model developed by Anthropic, accessed under Anthropic's commercial terms. Under those terms, Anthropic does not use data submitted through its commercial services to train its models.
• Recordings, transcripts, and related coaching records are stored in secure, access-controlled cloud infrastructure provided by Amazon Web Services, with encryption in transit and at rest.
• Recordings and transcripts are used for session documentation, continuity of coaching, safeguarding, quality assurance, and coordination among the members of your Koomba Coaching Team.
• Recordings and transcripts are treated as confidential session content. They are not shared with your Partner Organization, and are disclosed only as described in this Privacy Policy.

How We Use Artificial Intelligence

The Platform uses artificial intelligence, including Claude, an AI model developed by Anthropic, to support certain features, such as matching you with providers, generating session documentation and summaries for your providers, and producing insights from check-in responses. Coaching services are delivered by your providers, not by automated systems. AI-generated content is not medical advice, diagnosis, or treatment, and is subject to the disclaimers in our Terms of Service.

How We Use Your Information

We use the information we collect to:

• Provide the Services, including matching you with providers, scheduling and delivering sessions, and supporting your coaching.
• Coordinate support among the members of your Koomba Coaching Team.
• Communicate with you about your account, sessions, and the Services, including by email and SMS as described below.
• Protect the health and safety of you and others, including through the safeguarding practices described in this Policy and our Terms of Service.
• Improve, develop, and secure our products and services, including understanding usage trends.
• Comply with applicable law and enforce our legal rights.

We do not sell your personal information. We do not use your personal information for third-party targeted advertising.

SMS Communications and Consent

By submitting your phone number through Koomba's intake forms or creating an account, you consent to receiving text messages related to your account, service updates, and personalized support. Message and data rates may apply. You may opt out of SMS communications at any time by replying "STOP" to any message.

How We Share Your Information

Your Koomba Coaching Team

We may share your information with the Koomba providers who support you (for example, a mental performance coach and a sports nutritionist) to coordinate recommendations, avoid conflicting advice, and give you more integrated support.

Partner Organizations

If your access is sponsored by a Partner Organization, we may provide that organization with aggregate, de-identified reporting about program utilization and outcomes. We do not disclose your individual session content, transcripts, or check-in responses to your Partner Organization without your consent, except where disclosure is necessary for safety or required by law.

Parents and Guardians

For users under 18, we may use parent or guardian contact information to obtain required consents, send notifications regarding scheduling, billing, account status, and safety, and request documents through secure links. Parents and guardians do not have access to the content of a user's sessions, messages, or check-in responses, except with the user's consent, where disclosure is necessary to protect the health or safety of the user or others, or as required by law.

Service Providers

We work with third-party service providers who provide hosting and cloud infrastructure (Amazon Web Services), transcription (Amazon Transcribe Medical), AI processing (Anthropic), payment processing (Stripe), communications, development, and similar services on our behalf, under contractual obligations to protect your information.

Safety, Legal, and SafeSport Obligations

We may use and disclose personal information when we reasonably believe it is necessary to comply with law; comply with SafeSport, NCAA, National Governing Body, or institutional policies; fulfill mandatory reporting obligations regarding suspected abuse, neglect, or exploitation of a minor or vulnerable adult; protect health and safety; or respond to lawful requests from courts, law enforcement, or regulatory authorities.

Business Transfers

We reserve the right to transfer information in connection with a corporate transaction, such as a merger, acquisition, financing, or sale of assets.

Health-Related Information

Koomba provides subclinical mental performance and sport nutrition coaching. Koomba is not a healthcare provider and the Services are not medical care, psychotherapy, or clinical mental health treatment. Please do not submit medical records or clinical treatment information through the Platform.

We recognize that information about your wellbeing is sensitive, and we apply heightened protections to session content, transcripts, and check-in responses regardless of whether that information is regulated as health information under applicable law. Where Koomba processes information on behalf of a covered healthcare provider, Koomba executes a Business Associate Agreement and handles that information in accordance with HIPAA. Certain information we collect may constitute "consumer health data" under state privacy laws; residents of applicable states have the rights described below and in those laws.

Your Privacy Choices and Rights

Depending on where you live, you may have the right to:

• Access the personal information we hold about you and obtain a copy of it;
• Correct inaccurate personal information;
• Delete your personal information;
• Opt out of email marketing (via the unsubscribe link in any marketing email) and SMS messages (by replying "STOP").

To exercise any of these rights, contact us at hello@koomba.co. We will verify your request and respond as required by applicable law. We will not discriminate against you for exercising your privacy rights.

Children's Privacy

The Platform is intended for users 13 years of age and older. We do not knowingly collect information from children under 13 or knowingly allow such persons to become users. If we learn that we have collected personal information from a child under 13, we will delete it. Users under 18 may only use the Platform under the supervision of a parent or legal guardian, as described in our Terms of Service.

Data Retention

We retain personal information while your account is active and as needed to provide the Services, comply with our legal and safeguarding obligations, resolve disputes, and enforce our agreements. You may request deletion of your personal information as described above; certain records may be retained where required by law or for safety purposes.

How We Protect Your Information

We use physical, administrative, and technical measures intended to maintain the integrity and security of the information we collect and maintain, including encryption of session recordings, transcripts, and coaching records in transit and at rest, and role-based access controls. Please be aware that no security measures are perfect or impenetrable.

International Users

The Services are intended for users located within the United States. If you choose to use the Services from outside the U.S., you consent to the transfer, storage, and processing of your data in the United States.

Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our information practices or relevant laws. If we make material changes, we will notify you by email or by prominent notice on the Platform before the changes take effect, and, where required by law, obtain your consent.

Contact Information

If you have any questions or comments about this Privacy Policy, please contact us at:

Koomba Inc.
hello@koomba.co

If you or anyone you know are in a crisis or may be in danger, please do not use Koomba. These resources can provide you with immediate help: 988 Suicide & Crisis Lifeline (call or text 988), Crisis Text Line (text HOME to 741741).