Privacy Policy

1. Introduction and Scope

Welcome to Counsel. This Privacy Policy describes how Viva Global LLC, dba Viva ("we," "us," or "Counsel") collects, uses, shares, and protects your personal information when you use our platform, including AI-powered features.

1a. Who We Are

Counsel is a platform that connects coaches, consultants, and experts ("Experts") with individuals seeking guidance ("Members"). We serve two primary user types:

• Experts: Coaches, consultants, and advisors who use Counsel to build their practice, create content, and serve clients
• Members: Individuals who subscribe to Experts for coaching content, AI chat, goals, and bookings

1b. Acceptance of Terms

By accessing or using Counsel, you agree to this Privacy Policy. If you do not agree with any part of this policy, please do not use our Service.

2. Information We Collect

2a. Information You Provide Directly

For All Users:

• Account Information: Name, email address, password
• Profile Information: Photo, bio, location (optional)
• Communications: Messages sent through the platform, support inquiries

For Experts:

• Professional Information: Expertise areas, credentials, certifications, business name
• Content: Lessons, frameworks, worksheets, and other educational materials you create
• AI Training Data: Information you provide to train your AI persona (bio, expertise, FAQ responses, conversation examples)
• Pricing Information: Subscription tier details, pricing, feature descriptions
• Payment Information: Stripe Connect account details for receiving payments
• Availability: Calendar availability and booking preferences

For Members:

• Subscription Information: Which Experts you subscribe to and at what tier
• Goals & Action Items: Personal goals, milestones, and tasks you create
• Content Interactions: Which lessons, frameworks, and worksheets you access
• Payment Information: Payment method details processed by Stripe

2b. AI Conversation Data

When you use AI chat features, we collect:

• Chat Messages: All messages sent to and received from AI personas
• Conversation Context: Previous messages used to maintain conversation continuity
• Interaction Metadata: Timestamps, message counts, session duration

2c. Information We Collect Automatically

When you use Counsel, we automatically collect:

• Usage Information: Pages viewed, features used, content accessed, time spent on platform
• Device Information: Device type, operating system, browser type and version
• Log Information: IP address, access times, referring/exit pages
• Location Information: Approximate geographic location based on IP address
• Cookies: See Section 8 for details

3. AI Data Processing

3a. How AI Processes Your Data

Our AI persona features use your data in the following ways:

• Response Generation: AI reads your messages and generates responses based on the Expert's training data
• Context Retention: Previous messages in a conversation are used to maintain context
• Personalization: Your subscription tier and history may influence response availability

3b. AI Model Provider

We use Anthropic's Claude API for AI processing. When processing your content:

• Your messages are sent to Anthropic's API for processing
• Anthropic does not use your data to train their models
• Data is processed according to Anthropic's Privacy Policy
• Your conversations are isolated from other users and Experts

3c. Expert Access to Conversations

Experts may access conversation data with their subscribers for the purpose of:

• Understanding Member needs and questions
• Improving their AI persona's responses
• Preparing for 1:1 sessions
• Tracking engagement and progress

3d. AI Training for Persona Improvement

When Experts review and correct AI responses:

• Corrections are stored to improve that Expert's AI persona only
• Your individual conversations are not used to train AI for other Experts
• Aggregated, anonymized patterns may be used to improve the platform generally

4. How We Use Your Information

4a. Provide and Improve Our Service

• Create and maintain your account
• Power AI persona conversations
• Deliver content based on your subscription tier
• Track goals, action items, and progress
• Process bookings and appointments
• Facilitate payments between Members and Experts
• Provide customer support
• Improve platform features and user experience

4b. For Experts

• Display your public profile to potential Members
• Power your AI persona with your training content
• Provide analytics on subscriber engagement
• Process subscription payments to your account
• Send notifications about new subscribers and bookings

4c. Communications

• Send transactional emails (account verification, payment confirmations, booking reminders)
• Send service announcements and updates
• Send promotional content (you can opt out anytime)
• Facilitate communication between Experts and Members

4d. Security and Compliance

• Verify identity and prevent fraud
• Detect and prevent security incidents
• Monitor for abuse or Terms violations
• Comply with legal obligations

5. How We Share Your Information

5a. With Experts You Subscribe To

When you subscribe to an Expert, they may access:

• Your name, email, and profile information
• Your subscription tier and status
• Conversation history with their AI persona
• Goals and action items you've set with them
• Content you've accessed from their library
• Booking history and session notes

Experts cannot access: Your payment method details, conversations with other Experts, or data from other subscriptions.

5b. Service Providers

We share information with third-party service providers who perform services on our behalf:

• AI Processing: Anthropic (Claude API for AI personas)
• Hosting and Infrastructure: Cloudflare
• Analytics: PostHog
• Email Services: Resend
• Payment Processing: Stripe

These providers are contractually obligated to protect your information and use it only for the purposes we specify.

5c. Public Information

The following information may be publicly visible:

• Expert Profiles: Public profile pages, bio, expertise, and content previews
• Testimonials: If you provide a testimonial with consent

5d. Business Transfers

If Counsel is involved in a merger, acquisition, or sale of assets, your information may be transferred. We will notify you before your information becomes subject to a different privacy policy.

5e. Legal Requirements

We may disclose your information if required by law or in response to:

• Valid legal processes (subpoenas, court orders)
• Government requests
• Protection of rights, property, or safety

We do not sell your personal information to third parties.

6. Data Security

We take the security of your information seriously:

• Encryption: Data is encrypted in transit using TLS/SSL and at rest
• Access Controls: Strict access controls limit who can view your information
• Authentication: Secure password hashing and session management
• Infrastructure Security: Hosted on secure, SOC 2 compliant infrastructure
• AI Data Isolation: Conversations are isolated between different Expert-Member relationships
• Regular Assessments: Ongoing security monitoring

However, no method of transmission over the internet is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

7. Data Retention

• Active Accounts: Information is retained while your account is active
• AI Conversations: Conversation history is retained to maintain context; you can request deletion
• Goals & Action Items: Retained until you delete them or close your account
• Content Access History: Retained for analytics and progress tracking
• Closed Accounts: We delete or anonymize personal information within 30 days of account deletion
• Legal Requirements: Some information may be retained longer if required by law
• Expert Content: Content created by Experts is retained until the Expert removes it

8. Cookies and Tracking

8a. Types of Cookies We Use

• Essential Cookies: Required for authentication and security
• Functional Cookies: Remember your preferences and settings
• Analytics Cookies: Help us understand how you use the Service (PostHog)

8b. Managing Cookies

You can control cookies through your browser settings. Disabling certain cookies may affect your ability to use some features.

9. Your Rights and Choices

9a. Access and Portability

• Access: View your information through your account dashboard
• Data Export: Request a copy of your data by contacting [email protected]

9b. Correction and Updates

• Update your account information through profile settings
• Contact us to correct inaccurate information

9c. Deletion

• Request account deletion through account settings or by contacting [email protected]
• Request deletion of conversation history
• We will delete or anonymize your information within 30 days

9d. AI Data

• Conversation Deletion: Request deletion of your AI conversation history
• Opt Out: You can choose not to use AI chat features

9e. Marketing Communications

• Opt Out: Unsubscribe from promotional emails using the link in any email
• Transactional Emails: You cannot opt out of essential service communications

9f. Subscription Cancellation

• Cancel subscriptions through your account settings
• You retain access until the end of your billing period

10. Children's Privacy

Counsel is not intended for users under 18 years of age. We do not knowingly collect personal information from anyone under 18. If you believe we have collected information from someone under 18, please contact us immediately at [email protected].

11. International Data Transfers

Counsel is based in the United States. If you are accessing our Service from outside the United States, your information may be transferred to, stored, and processed in the United States.

By using our Service, you consent to the transfer of your information to the United States.

12. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

12a. Right to Know

• Request disclosure of the personal information we collect, use, and share
• Request the specific pieces of personal information we have collected

12b. Right to Delete

• Request deletion of your personal information (subject to certain exceptions)

12c. Right to Opt-Out of Sale

• We do not sell personal information.

12d. Right to Non-Discrimination

• We will not discriminate against you for exercising your CCPA rights

12e. Exercising Your Rights

To exercise these rights, contact us at [email protected]. We will verify your identity before processing your request.

13. Other U.S. State Privacy Rights

Residents of Colorado, Connecticut, Utah, Virginia, and other states with privacy laws have similar rights. Contact us at [email protected] to exercise these rights.

14. Changes to This Privacy Policy

When we make material changes, we will:

• Update the "Last updated" date at the top of this policy
• Notify you via email if you have an account
• Display a prominent notice on our Service

15. Information for Experts

15a. Your Responsibilities as an Expert

As an Expert using Counsel, you are responsible for:

• How you use Member data accessible through your dashboard
• Protecting the confidentiality of Member conversations
• Complying with applicable privacy laws in your jurisdiction
• Any privacy policies you maintain for your own practice

15b. Member Data You Can Access

You may access the following data for Members subscribed to you:

• Profile information (name, email, photo)
• Subscription details and tier
• Conversation history with your AI persona
• Goals, action items, and progress
• Content engagement (what they've viewed)
• Booking history

15c. AI Training Data

Content you provide for AI training is used only for your AI persona:

• Bio, expertise, and FAQ content
• Conversation examples and corrections
• Content library materials

This data is not shared with other Experts or used to train AI for other purposes.