Privacy Policy

1. Who We Are

L.I.F.ECoach121.com Limited (“L.I.F.E”, “we”, “us”, “our”) is registered in England & Wales. We are the data controller for personal data processed through the L.I.F.E platform, VS Code extension, and associated services at lifecoach-121.com.

Data Protection Contact: Life.coachsergi@gmail.com

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2. Data We Collect

Category	Examples	Lawful Basis
Account & identity	Email, display name, Microsoft identity token	Contract performance
Profile & preferences	Sector, role, goals, targets, education level	Contract / Consent
Usage telemetry	Feature events, session duration, optimisation counts	Legitimate interest
Engine metrics	Venturi gate scores, learning velocity, Phi index	Legitimate interest
Device signals (opt-in)	EEG, biofeedback, VR telemetry	Explicit consent

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3. How We Use Your Data

• Personalise your L.I.F.E Theory pathway and dashboard.
• Compute Venturi gate scores and digital twin state.
• Provide AI-assisted coaching via the Journey Agent.
• Improve the platform through aggregated, anonymised analytics.
• Fulfil contractual obligations (subscription, marketplace).

We never sell personal data to third parties.

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4. Data Storage & Security

Data is stored in Microsoft Azure (UK South region) using Azure Cosmos DB, Azure Blob Storage, and Azure Redis Cache. All data is encrypted at rest (AES-256) and in transit (TLS 1.2+).

Access is restricted by Azure RBAC with least-privilege principles. Secrets are managed via Azure Key Vault. Application telemetry is routed through Azure Application Insights with PII redaction.

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5. Data Sharing

We share data only with:

• Microsoft Azure — cloud infrastructure provider (DPA in place).
• Microsoft Entra ID — authentication provider.
• AI model providers — when you use third-party AI models (Azure OpenAI, Anthropic, Google). Prompts are sent transiently and not retained beyond their stated policies.

We do not share data with advertisers, data brokers, or unrelated third parties.

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6. Data Retention

• Account data: retained while active, plus 30 days after deletion request.
• Usage telemetry: aggregated after 90 days; raw logs deleted after 180 days.
• Device signals (EEG, biofeedback): deleted within 24 hours unless you opt in to research retention.

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7. Your Rights (UK GDPR)

Under UK data protection law, you have the right to:

• Access — request a copy of your personal data.
• Rectification — correct inaccurate data.
• Erasure — request deletion (“right to be forgotten”).
• Portability — receive data in a machine-readable format.
• Restriction — limit how we process your data.
• Objection — object to processing based on legitimate interest.
• Withdraw consent — at any time for consent-based processing.

To exercise any right, email Life.coachsergi@gmail.com. We will respond within 30 days.

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8. Cookies & Tracking

The portal uses essential cookies for session management and authentication. We do not use advertising or cross-site tracking cookies. Analytics cookies (Application Insights) are anonymised.

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9. VS Code Extension

The L.I.F.E AI Enhancer VS Code extension sends telemetry events (feature usage, optimisation counts) to our API. Telemetry can be disabled via VS Code settings (life-copilot.telemetryEnabled: false). No source code is transmitted.

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10. Contact & Complaints

Data Protection Contact: Life.coachsergi@gmail.com

You may also lodge a complaint with the Information Commissioner’s Office (ICO).

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11. Changes to This Policy

We may update this policy from time to time. Material changes will be communicated via the platform dashboard or email. The “Last updated” date reflects the most recent revision.