1. Who We Are

Data Controller: Exceptional Minds Coaching & Consulting Proprietor: Ms. Sonal Singh Registered Address: B-94, The Belaire, DLF Phase 5, Golf Course Road, Sector 54, Gurgaon - 122011, Haryana, India Email: [SONAL'S PROFESSIONAL EMAIL ADDRESS] Data Protection Representative (EU, if applicable): [NAME AND CONTACT — if none, state "Not applicable."]

2. What Information We Collect

2.1 Information You Provide Directly

• Name and contact details (email address, phone number)

• Preferred pronouns

• Information shared in booking forms and intake questionnaires

• Session notes and coaching-related communications

• Payment information (processed securely via third-party payment processors — we do not store card details)

• Newsletter subscription details

2.2 Information Collected Automatically

• IP address and browser type

• Pages visited and time spent on our website

• Referral source (how you found us)

• Device and operating system information

This information is collected via cookies and analytics tools.

2.3 Sensitive Personal Information As an ADHD coaching service, we may collect information that relates to your mental health, neurodevelopmental profile, or personal wellbeing. This is considered sensitive personal data under GDPR and protected health information (PHI) under HIPAA. We collect this information only when you voluntarily provide it, and we handle it with the highest level of care and confidentiality.

3. How We Use Your Information

We use your personal data for the following purposes:

• To provide ADHD coaching and related services

• To communicate with you about sessions, scheduling, and programme updates

• To send newsletters and resources you have opted into

• To process payments and maintain financial records

• To improve our website and services

• To comply with legal obligations

Legal Basis for Processing (GDPR):

• Contract: Processing necessary to deliver the coaching services you have engaged us for

• Consent: For marketing communications and newsletter subscriptions

• Legitimate interests: For website analytics and service improvement

• Legal obligation: Where required by law

4. Confidentiality of Coaching Sessions

Everything you share in coaching sessions is strictly confidential. We do not disclose your personal information to any third party without your explicit consent, except in the following limited circumstances:

• Where required by law or court order

• Where there is a serious risk of harm to you or others

• Where you have given explicit written consent for a specific disclosure

Session notes are stored securely and are accessible only to Sonal. They are not shared with employers, family members, or other parties without your consent.

5. HIPAA Compliance (US Clients)

For clients based in the United States, we are committed to complying with the Health Insurance Portability and Accountability Act (HIPAA) where applicable. Your protected health information (PHI) will not be disclosed without your written authorisation except as permitted by law.

6. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting, or reporting requirements. Session notes are retained for [INSERT RETENTION PERIOD] following the end of our coaching relationship.

7. Your Rights

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

• Right to access your personal data

• Right to correct inaccurate data

• Right to request deletion of your data

• Right to restrict or object to processing

• Right to data portability

• Right to withdraw consent at any time

To exercise any of these rights, please contact us at [SONAL'S PROFESSIONAL EMAIL ADDRESS].

8. Third Party Services

We use the following third-party services which may process your data:

• Payment processing: []

• Website hosting: Framer

• Email/newsletter: [INSERT PLATFORM]

• Scheduling/booking: [INSERT PLATFORM]

• Analytics: [INSERT PLATFORM]

Each of these providers has their own privacy policy governing how they handle your data.

9. Cookies

Our website uses cookies to improve your experience. You may disable cookies in your browser settings, though this may affect certain functionality. A full cookie policy is available at [INSERT COOKIE POLICY URL].

10. International Data Transfers

If you are accessing our services from outside India, your data may be transferred to and processed in India. Where we transfer data internationally, we ensure appropriate safeguards are in place in accordance with applicable law.

11. Children's Privacy

Our services are intended for adults aged 18 and above. We do not knowingly collect personal information from children under 18.

12. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. However, no method of transmission over the internet is completely secure.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website with a revised effective date. Your continued use of our services after such changes constitutes your acceptance of the updated policy.

14. Contact Us

Exceptional Minds Coaching & Consulting Ms. Sonal Singh,
Registered Office: B-94, The Belaire, DLF Phase 5, Golf Course Road, Sector 54, Gurgaon - 122011, Haryana, India

For EU/UK clients, if you are unsatisfied with our response, you have the right to lodge a complaint with your local data protection authority. UK: Information Commissioner's Office (ICO) — ico.org.uk EU: Your national data protection authority