Privacy Notice

Last updated: June 8, 2026

This Privacy Notice explains how Work Pail Holdings, LLC ("we", "us") collects, uses, and shares personal data when you use the SwimCoach AI website and service (the "Service"). Work Pail Holdings, LLC is the data controller responsible for your personal data in connection with the Service.

1. Personal data we collect

Payment card details and billing addresses are collected and processed directly by our payment provider, Paddle, and are not stored by us.

2. How we use personal data

3. Who we share personal data with

We do not sell your personal data.

4. International transfers

Personal data may be processed in countries outside your own, including the United States. Where required, we rely on appropriate safeguards such as Standard Contractual Clauses or adequacy decisions.

5. Retention

We keep personal data only as long as needed to provide the Service, comply with legal obligations, resolve disputes, and enforce our agreements. When data is no longer needed it is deleted or anonymized. You may request deletion of your account and associated data at any time through in-app support.

6. Your rights

Depending on where you live, you may have rights to access, correct, delete, restrict, or object to processing of your personal data, to portability, and to withdraw consent. EEA/UK users also have the right to lodge a complaint with a supervisory authority. We will respond to verifiable requests within the timeframes required by law (generally within one month for GDPR requests).

7. Security

We implement appropriate technical and organizational measures — including encryption in transit, access controls, and least-privilege administration — to protect personal data. No system is perfectly secure; you are responsible for keeping your account credentials safe.

8. Cookies

We use essential cookies and local storage to keep you signed in, remember preferences, and secure the Service. We may also use limited analytics cookies to understand aggregate usage. You can control cookies through your browser settings; disabling essential cookies may break parts of the Service.

9. Children

The Service is not directed to children under 13 (or the minimum age in your jurisdiction). If you believe a child has provided us personal data without appropriate consent, please contact us so we can delete it.

10. Changes

We may update this Privacy Notice from time to time. Material changes will be communicated through the Service or by email.

11. Contact

Work Pail Holdings, LLC — privacy questions can be sent through the in-app support channel.