Privacy Policy

NEXGEN Executive Coaching Academy, LLC  ·  Lyssa deHart · Jake Mannino · Rob Brunhild  ·  Last Updated: January 2026

1. Who We Are

NEXGEN Executive Coaching Academy, LLC ("NEXGEN," "Company," "we," "us," or "our") is a limited liability company based in Michigan, USA. We operate nexgencoaches.com and related websites (collectively, the "Website") and provide executive coaching education programs and related services (the "Services").

Data Controller / Business: NEXGEN Executive Coaching Academy, LLC, Michigan, USA
Contact: support@nexgencoaches.com

For EU/UK residents, we act as the Data Controller of your personal data. For California residents, we act as the Business under the CCPA/CPRA.

2. Information We Collect

We collect personal information in the following categories:

Information You Provide Directly

• Identity data: First name, last name, title, professional background.
• Contact data: Email address, phone number, mailing address.
• Account data: Username, password (hashed), account preferences.
• Transaction data: Purchase history, payment method details (processed by third-party payment processors — we do not store full card numbers).
• Communication data: Messages, inquiries, form submissions, feedback, and correspondence you send us.
• Profile data: Professional experience, coaching goals, program preferences, referral codes.

Information Collected Automatically

• Technical data: IP address, browser type and version, operating system, device identifiers, time zone, browser plug-in types.
• Usage data: Pages visited, links clicked, time spent on pages, referral URLs, search terms used to find our Website.
• Cookie and tracking data: See our Cookie section below for full details.

Information From Third Parties

• Analytics providers (e.g., Google Analytics).
• Advertising partners and social media platforms.
• Payment processors (e.g., Stripe, PayPal).
• Email marketing platforms (e.g., Mailchimp, ActiveCampaign).
• Learning management system (LMS) providers.

Special Categories of Data

We do not intentionally collect sensitive personal data (special category data under GDPR), including health information, racial or ethnic origin, political opinions, religious beliefs, biometric data, or criminal records. Please do not submit such information through our Website or Services.

3. How We Use Your Information

We use your personal data for the following purposes and on the following legal bases:

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another compatible reason and that reason is consistent with the original purpose.

4. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and similar tracking technologies to collect information about your browsing activity on our Website.

Types of Cookies We Use

• Strictly Necessary Cookies: Required for the Website to function. Cannot be disabled.
• Performance / Analytics Cookies: Help us understand how visitors use our Website (e.g., Google Analytics). Collected anonymously.
• Functional Cookies: Remember your preferences and settings.
• Targeting / Advertising Cookies: Used to deliver relevant advertising and track campaign effectiveness (e.g., Facebook Pixel, Google Ads).

Your Cookie Choices

Where required by law (including under GDPR and ePrivacy Directive), we will obtain your consent before placing non-essential cookies. You may withdraw consent or manage cookie preferences at any time by:

• Using our cookie consent banner or preference center.
• Adjusting your browser settings to block or delete cookies.
• Opting out of Google Analytics at tools.google.com/dlpage/gaoptout.

Note: Disabling certain cookies may affect Website functionality.

5. How We Share Your Information

We do not sell your personal data. We may share your information with the following categories of recipients:

Service Providers (Data Processors)

We engage trusted third-party service providers who process data on our behalf and are contractually bound to protect it:

• Payment processors (Stripe, PayPal, or similar)
• Email and marketing platforms (Mailchimp, ActiveCampaign, or similar)
• Website hosting and cloud infrastructure providers
• Learning management system (LMS) providers
• Video conferencing platforms (Zoom or similar)
• Analytics providers (Google Analytics)
• Customer support tools

Business Transfers

If we are involved in a merger, acquisition, financing, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or prominent notice on our Website of any change in ownership or use of your personal data.

Legal Requirements

We may disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g., a court, government agency, or law enforcement) where we believe disclosure is necessary to:

• Comply with a legal obligation.
• Protect and defend the rights or property of NEXGEN.
• Prevent or investigate possible wrongdoing in connection with our Services.
• Protect the personal safety of users of the Services or the public.

With Your Consent

We may share your information for any other purpose with your explicit prior consent.

6. International Data Transfers

NEXGEN is based in the United States. If you are located outside the United States, your personal data will be transferred to and processed in the United States, which may not have the same data protection laws as your country.

For transfers from the European Economic Area (EEA), United Kingdom, or Switzerland to the United States, we rely on one or more of the following safeguards:

• Standard Contractual Clauses (SCCs) approved by the European Commission.
• UK International Data Transfer Agreements (IDTAs) for UK transfers.
• Adequacy decisions where applicable.
• Your explicit consent where required and appropriate.

By using our Website or Services, you acknowledge that your data may be transferred internationally as described in this Policy.

7. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

• Account and enrollment data: Retained for the duration of your relationship with us and for up to 7 years thereafter for legal and tax compliance.
• Transaction records: Retained for up to 7 years to comply with financial and tax laws.
• Marketing data: Retained until you unsubscribe or withdraw consent, then deleted within 30 days.
• Contact form inquiries: Retained for up to 2 years unless you become a customer.
• Technical/log data: Retained for up to 12 months.
• Cookie data: See cookie lifespans in your browser or our cookie consent tool.

When data is no longer required, we will securely delete or anonymize it.

8. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal data:

How to Exercise Your Rights

To exercise any of the above rights, please contact us at support@nexgencoaches.com with the subject line "Privacy Request." We will respond within the timeframe required by applicable law (generally 30 days, or 45 days for CCPA requests).

We may need to verify your identity before processing your request. We will not charge a fee for reasonable requests, but may charge a reasonable fee or decline requests that are manifestly unfounded or excessive.

Right to Lodge a Complaint

If you are located in the EEA or UK and believe we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with your local supervisory authority:

• EU residents: Your national Data Protection Authority (DPA). A full list is available at edpb.europa.eu.
• UK residents: The Information Commissioner's Office (ICO) at ico.org.uk.
• Swiss residents: The Federal Data Protection and Information Commissioner (FDPIC) at edoeb.admin.ch.

9. California Privacy Rights (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) provides you with specific rights in addition to those listed above.

Categories of Personal Information Collected

In the past 12 months, we have collected the following categories of personal information as defined by the CCPA:

• Identifiers (name, email, IP address)
• Personal information categories listed in Cal. Civ. Code § 1798.80(e) (name, address)
• Internet or other electronic network activity information
• Commercial information (purchase records)
• Geolocation data (IP-based, non-precise)
• Inferences drawn from the above to create a profile

We Do Not Sell or Share Your Personal Information

We do not sell your personal information as defined under the CCPA/CPRA, and we do not share your personal information with third parties for cross-context behavioral advertising without your consent.

Sensitive Personal Information

We do not collect or use sensitive personal information as defined by the CPRA beyond what is necessary to provide our Services, and we do not use or disclose it for purposes other than those specified in Cal. Civ. Code § 1798.121.

Shine the Light Law

California Civil Code Section 1798.83 permits California residents to request information about personal information disclosed to third parties for direct marketing purposes. We do not share personal information with third parties for their own direct marketing purposes without your consent.

Do Not Track

Our Website does not currently respond to "Do Not Track" signals from browsers, as no uniform standard exists. We will update this policy if a standard is established.

10. Rights for Canadian Residents (PIPEDA / Law 25)

If you are located in Canada, you have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial laws, including Quebec's Law 25. These include the right to access, correct, and withdraw consent for processing of your personal data. To exercise these rights, contact us at support@nexgencoaches.com.

11. Rights for Australian Residents

If you are located in Australia, we comply with the Australian Privacy Act 1988 and the Australian Privacy Principles (APPs). You have the right to access and correct personal information we hold about you. You may also lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

12. Rights for Brazilian Residents (LGPD)

If you are located in Brazil, you have rights under the Lei Geral de Proteção de Dados (LGPD), including the right to access, correct, delete, and port your personal data, and to revoke consent. To exercise these rights, contact us at support@nexgencoaches.com.

13. Children's Privacy

Our Website and Services are not directed to children under the age of 16 (or such higher age as required by applicable law in your jurisdiction). We do not knowingly collect personal data from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at support@nexgencoaches.com and we will delete such information promptly.

This policy is consistent with the Children's Online Privacy Protection Act (COPPA) in the United States, the GDPR provisions applicable to children's data, and equivalent laws globally.

14. Data Security

We implement appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include:

• SSL/TLS encryption for data in transit.
• Secure, access-controlled servers and infrastructure.
• Password hashing and secure authentication practices.
• Regular security assessments and staff training.
• Access limited to authorized personnel on a need-to-know basis.

However, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee absolute security but are committed to using industry-standard practices to protect your data.

In the event of a personal data breach that is likely to result in high risk to your rights and freedoms, we will notify you and applicable supervisory authorities as required by law.

15. Third-Party Links

Our Website may contain links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. We encourage you to read the privacy policy of every website you visit.

16. Email Marketing and Communications

Where you have provided consent or where otherwise permitted by applicable law, we may send you marketing communications about our programs, events, and resources.

You may opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email.
• Emailing us at support@nexgencoaches.com with the subject line "Unsubscribe."

Opting out of marketing emails will not affect transactional or service-related communications necessary to fulfill your enrollment or respond to your inquiries.

17. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. We will notify you of material changes by:

• Posting the updated policy on this page with a revised "Last Updated" date.
• Sending an email notification to registered users where required by law.
• Displaying a prominent notice on our Website.

We encourage you to review this Policy periodically. Your continued use of the Website or Services after any changes constitutes your acceptance of the updated policy.

18. Contact Us & Data Protection Inquiries

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:

NEXGEN Executive Coaching Academy, LLC
DBA: NEXGEN EXECUTIVE COACHING ACADEMY
Michigan, USA

Privacy & Data Requests: support@nexgencoaches.com
Subject line: "Privacy Request" or "Data Protection Inquiry"

We will acknowledge your request within 5 business days and respond fully within the timeframe required by applicable law.