MY DIGITAL SELF, LLC

PRIVACY POLICY

Effective Date: July 25, 2026
Last Updated: July 25, 2026

 

1. Introduction

My Digital Self, LLC, doing business as My Digital Self and My Digital Self Coaching Solutions, is referred to in this Privacy Policy as “MDS,” “we,” “us,” or “our.”

This Privacy Policy explains how MDS collects, uses, discloses, retains, and protects personal information when you interact with our websites, applications, products, programs, and services.

This Privacy Policy applies when you:

  • Visit www.mdself.com or another MDS page linking to this Privacy Policy.
  • Purchase or use an MDS product or service.
  • Use an MDS Kajabi customer portal, course, or resource library.
  • Use the Digital Truth App.
  • Use MyCareerSuperpowerGPT or another MDS artificial-intelligence-enabled service.
  • Complete an intake form, assessment, questionnaire, survey, or report request.
  • Receive an Identity & Success Report or another personalized deliverable.
  • Participate in coaching, consulting, implementation support, group office hours, webinars, workshops, institutional programs, or related sessions.
  • Purchase a physical book, workbook, report, or other product.
  • Communicate with MDS by email, telephone, text message, video conference, contact form, social media, or another method.
  • Apply for employment or contract work with MDS.
  • Otherwise interact with a product or service that links to this Privacy Policy.

MDS currently directs and offers its services to customers and participants in the United States.

This Privacy Policy is a notice of our information practices. It is not a substitute for any consent, authorization, contract, institutional agreement, or other permission that MDS may be required to obtain.

2. Our Roles

Depending on the circumstances, MDS may act as:

  1. The organization responsible for determining why and how personal information is processed.
  2. A service provider or processor acting on behalf of an institution, practitioner, employer, school, nonprofit organization, workforce organization, reentry organization, church, government entity, or other customer.
  3. A recipient of information submitted by a parent, legal guardian, authorized adult facilitator, practitioner, or organizational representative on behalf of a participant.

When MDS processes information under a separately signed institutional, data-processing, student-data, or service agreement, that agreement may impose additional requirements.

If a signed agreement conflicts with this Privacy Policy, the signed agreement will control for the information and services governed by that agreement.

3. Information We Collect

The information MDS collects depends on how you interact with us and which services you use.

A. Contact and account information

We may collect:

  • Name
  • Email address
  • Telephone number
  • Mailing address
  • Shipping address
  • Organization or institution
  • Job title
  • Professional role
  • Username
  • Account login and authentication information
  • Communication preferences
  • Parent, guardian, facilitator, practitioner, employer, or institutional relationship to a participant
  • Information needed to confirm authority to act for another person or organization

Passwords and authentication credentials may be collected and managed by Kajabi, the Digital Truth App, or another platform provider. MDS personnel may not have access to the full password or authentication credential.

B. Purchase and transaction information

We may collect:

  • Product or service purchased
  • Order and purchase history
  • Purchase date
  • Amount paid
  • Payment-plan status
  • Transaction and payment identifiers
  • Billing address
  • Discount or promotional information
  • Shipping address
  • Shipping and delivery status
  • Product-access status
  • Client or participant seat allocations
  • Refund, replacement, return, and fulfillment information
  • Customer-support and billing correspondence

MDS does not intentionally collect or store complete payment-card numbers or card security codes.

Payments are processed through third-party providers, including Kajabi Payments, Stripe, and PayPal. Those providers process payment information under their own terms, privacy notices, and security practices.

C. Career, assessment, and personalized-service information

When you request an Identity & Success Report, Career Identity Diagnostic, Digital Truth App service, MyCareerSuperpowerGPT service, coaching service, career pathway recommendation, workbook support, or another personalized service, we may collect:

  • Age or date of birth
  • Gender
  • Race or ethnicity
  • Education and training
  • Employment history
  • Current employer, role, or occupation
  • Salary or income information
  • Career goals
  • Career interests
  • Work preferences
  • Personality information
  • Strengths
  • Communication preferences
  • Leadership characteristics
  • Learning preferences
  • Personal reflections
  • Family information
  • Relationship information
  • Faith or religious information
  • Disability or accessibility information
  • Criminal-justice or reentry history
  • Professional qualifications
  • Achievements and accomplishments
  • RĂ©sumĂ©-style information
  • Assessment responses
  • Information required to create a requested report, recommendation, profile, strategy, or development plan

Questions involving sensitive personal information are optional unless the information is reasonably necessary to provide a specifically requested service. Participants may skip optional sensitive questions.

D. Information we do not request through standard services

MDS does not request the following through its standard assessment, coaching, or report-generation services:

  • Medical records
  • Medical diagnoses
  • Mental-health treatment records
  • Psychotherapy records
  • Health-insurance information
  • Protected health information
  • Social Security numbers
  • Complete payment-card numbers
  • Bank-account passwords
  • Unnecessary government-issued identifiers

Do not submit these categories unless MDS has expressly authorized their submission through a secured and contractually approved process.

E. Sensitive personal information

Certain information MDS processes may be considered sensitive under applicable law, including:

  • Race or ethnicity
  • Religious beliefs
  • Disability or accessibility information
  • Criminal-justice or reentry information
  • Salary or income information
  • Information relating to a known child
  • Account credentials
  • Other information classified as sensitive by applicable law

MDS processes sensitive personal information only for purposes reasonably related to the requested service, authorized program administration, security, legal compliance, internal operations, or another purpose disclosed when the information is collected.

Where required, MDS will obtain consent before processing sensitive personal information.

MDS does not intentionally use sensitive assessment information for targeted advertising.

F. Institutional participant information

An institution may provide MDS with limited participant contact information, such as an email address, so MDS can:

  • Send program instructions.
  • Provide access.
  • Deliver an authorized product or service.
  • Administer the institution’s contracted program.

MDS does not request broad educational records through its standard institutional onboarding process.

Unless separately agreed, institutions should not send MDS:

  • Grades
  • Disciplinary records
  • Student identification numbers
  • Medical records
  • Detailed accommodation records
  • Attendance histories
  • Academic transcripts
  • Other extensive education records

The participant, parent, guardian, or authorized adult facilitator ordinarily submits the personal information required for an assessment or personalized report.

G. Photographs and visual content

MDS may collect photographs or other visual content when voluntarily submitted for:

  • A personalized report
  • A visual or digital product
  • A customer profile
  • Coaching or development materials
  • Program administration
  • Customer support
  • An expressly authorized publicity purpose

MDS will obtain separate affirmative permission before publicly using an identifiable photograph, video, report excerpt, customer name, institution name, logo, testimonial, or participant story.

H. Calls, meetings, and recordings

MDS may record or transcribe:

  • Coaching sessions
  • Consulting sessions
  • Zoom meetings
  • Institutional implementation calls
  • Group office hours
  • Webinars
  • Workshops
  • Training sessions
  • Customer-support communications

MDS will provide notice at or before the participant enters a recorded session and will obtain any consent required by law.

A recording may include:

  • Name
  • Voice
  • Image
  • Statements
  • Chat messages
  • Screen content
  • Questions
  • Other information voluntarily shared during the session

Participants should not disclose protected health information, confidential client records, confidential student records, passwords, payment data, or other unnecessary sensitive information during a group session.

I. Communications

We may collect and retain information contained in:

  • Emails
  • Contact forms
  • Text messages
  • Telephone calls
  • Support requests
  • Surveys
  • Social-media messages
  • Comments
  • Direct mail
  • Coaching and program communications
  • Privacy requests
  • Privacy appeals
  • Security-incident reports

J. Employment and contractor information

When someone applies to work with MDS, we may collect:

  • Name and contact details
  • RĂ©sumĂ©
  • Employment history
  • Education
  • Professional qualifications
  • References
  • Work-authorization information
  • Interview notes
  • Compensation information
  • Information needed to evaluate or administer the working relationship

K. Information collected automatically

When you visit an MDS website or use an online MDS service, MDS and its providers may automatically collect:

  • Internet Protocol address
  • Browser type
  • Device type
  • Operating system
  • Language settings
  • Referring website
  • Pages viewed
  • Links clicked
  • Date and time of access
  • Course, application, and feature usage
  • Approximate location derived from an Internet Protocol address
  • Cookie identifiers
  • Advertising identifiers
  • Session information
  • Authentication information
  • Error reports
  • Diagnostic information
  • Performance information
  • Interactions with advertisements, forms, emails, and website content

MDS does not intentionally collect precise GPS location through its standard services unless a specific feature requests permission and explains why precise location is needed.

MDS does not intentionally use voice, images, or recordings to create biometric identifiers for identity verification unless that practice is separately disclosed before collection.

4. Sources of Information

MDS may obtain personal information from:

  • You
  • A purchaser
  • A parent or legal guardian
  • An authorized adult facilitator
  • A practitioner or coach
  • An institutional customer
  • A program sponsor
  • A payment processor
  • A website or application provider
  • An advertising or analytics provider
  • A social-media platform through your interaction with MDS
  • Authorized MDS personnel
  • Contractors providing services to MDS
  • Another person or organization you authorize

Institutions generally provide only the limited contact information necessary to administer the contracted program.

MDS does not use identifiable institution-provided information for purposes unrelated to the applicable institutional program.

5. How We Use Information

MDS may use personal information to:

  • Create and administer accounts.
  • Authenticate users.
  • Confirm identity or authority.
  • Process and fulfill purchases.
  • Manage payment plans.
  • Deliver books, workbooks, reports, digital products, and other materials.
  • Generate Identity & Success Reports and other personalized deliverables.
  • Provide assessments, recommendations, coaching, consulting, and implementation support.
  • Personalize career, educational, leadership, or developmental recommendations.
  • Operate the Digital Truth App.
  • Provide MyCareerSuperpowerGPT.
  • Manage report, client, and participant seats.
  • Schedule appointments.
  • Collect pre-session information.
  • Provide program reminders.
  • Record or transcribe sessions after appropriate notice.
  • Provide customer and technical support.
  • Prevent fraud.
  • Maintain security.
  • Investigate unauthorized use.
  • Troubleshoot errors.
  • Monitor and improve service performance.
  • Analyze website, product, and program usage.
  • Conduct internal research.
  • Develop and improve products and services.
  • Produce aggregate or de-identified program summaries.
  • Support program evaluation and grant reporting.
  • Communicate about services, purchases, access, and policies.
  • Send marketing communications where permitted.
  • Display and measure targeted advertising.
  • Measure marketing effectiveness.
  • Enforce agreements and policies.
  • Establish, exercise, or defend legal claims.
  • Comply with legal, regulatory, tax, accounting, audit, and contractual obligations.
  • Support a merger, financing, acquisition, reorganization, or sale of assets.

MDS will not use identifiable school-provided information outside the contracted program unless separately authorized or legally required.

6. Artificial Intelligence and Automated Processing

MDS uses artificial intelligence, automated analysis, and rules-based processing in connection with certain products and internal functions.

These functions may include:

  • Identity & Success Report generation
  • MyCareerSuperpowerGPT
  • Digital Truth App features
  • Career recommendations
  • Career pathway recommendations
  • Automated email summaries
  • Report interpretation
  • Customer-support assistance
  • Marketing-content development

MDS currently uses OpenAI to perform these functions.

Depending on the service, information processed through OpenAI may include:

  • Name
  • Email address
  • Assessment responses
  • Education and employment history
  • Career interests
  • Career goals
  • Personal reflections
  • Demographic information
  • Other information needed to generate the requested output

MDS has disabled the available account setting that permits new conversations to be used to improve OpenAI’s models.

OpenAI separately processes information under its own terms, privacy policies, safety processes, retention practices, and legal obligations.

MDS may replace or supplement OpenAI with another provider. MDS will update this Privacy Policy or provide another appropriate notice when a material change affects the privacy practices described here.

AI-generated information may contain errors, omissions, outdated information, inconsistent conclusions, or inappropriate recommendations.

MDS uses automated processing to provide advisory, educational, developmental, administrative, creative, and support functions.

MDS does not use automated processing to make final decisions concerning:

  • Employment
  • Education admission
  • Program eligibility
  • Discipline
  • Credit
  • Housing
  • Insurance
  • Health care
  • Funding
  • Criminal-justice eligibility
  • Another decision producing a legal or similarly significant effect

Customers, practitioners, institutions, and participants must apply independent judgment and appropriate human review before acting on an AI-generated output.

7. Cookies, Analytics, and Similar Technologies

MDS and its service providers use cookies, pixels, tags, and similar technologies.

These technologies may be used to:

  • Operate essential website functions.
  • Authenticate users.
  • Maintain security.
  • Remember preferences.
  • Analyze website traffic.
  • Measure product usage.
  • Identify referral sources.
  • Measure advertising.
  • Send abandoned-checkout reminders.
  • Personalize content.
  • Display targeted advertising.
  • Retarget website visitors on other platforms.

These providers may include:

  • Kajabi
  • Google Analytics
  • Google Ads
  • Meta or Facebook
  • LinkedIn
  • TikTok
  • Other analytics and advertising platforms

Cookie choices

Where available, the MDS website provides a cookie or privacy-preference tool through which visitors can manage nonessential technologies.

You may also manage cookies through your browser. Blocking cookies may affect the operation of certain website or account features.

Global Privacy Control

Where required by applicable law, MDS recognizes a valid Global Privacy Control signal as a request to opt out of the sale or sharing of personal information for targeted advertising.

A Global Privacy Control signal generally applies to the browser or device from which the signal is transmitted. You may need to activate the signal separately on each browser or device.

Do Not Track

Some browsers provide a Do Not Track setting. Because there is no uniform standard governing all Do Not Track signals, MDS does not treat a general Do Not Track signal as a privacy request unless applicable law requires otherwise.

Global Privacy Control is handled separately as described above.

8. Targeted Advertising and Sale or Sharing

MDS does not sell personal information for money.

MDS may disclose or make limited personal information available to analytics and advertising providers for:

  • Targeted advertising
  • Retargeting
  • Advertising measurement
  • Audience development
  • Campaign attribution
  • Marketing analytics

Depending on applicable law, these activities may be legally defined as “selling,” “sharing,” or processing information for targeted advertising, even when MDS does not receive money in exchange.

Information involved in these activities may include:

  • Internet Protocol address
  • Device identifiers
  • Browser information
  • Cookie identifiers
  • Website activity
  • Pages viewed
  • Links clicked
  • Advertising interactions
  • Approximate location
  • Purchase or product-interest information
  • Hashed or pseudonymous contact identifiers, where used

MDS does not intentionally disclose the following for targeted advertising:

  • Assessment responses
  • Report contents
  • Religious information
  • Race or ethnicity
  • Disability or accessibility information
  • Criminal-justice or reentry information
  • Personal information relating to a child
  • Other sensitive assessment information

You may opt out of targeted-advertising disclosures by:

  • Using the website’s cookie or privacy-preference tool.
  • Activating Global Privacy Control in a supported browser.
  • Contacting MDS at support@mydigitalself.co.

MDS does not knowingly sell or share personal information relating to children under 16 for targeted advertising.

9. How We Disclose Information

MDS may disclose personal information to the following categories of recipients.

A. Website, account, course, and checkout providers

MDS uses Kajabi to provide website pages, checkout pages, accounts, courses, email services, products, and customer portals.

B. Payment processors

MDS uses Kajabi Payments, Stripe, and PayPal to process transactions, administer payments, verify payment methods, and prevent fraud.

C. Forms and automation providers

MDS uses Fillout to collect assessment, intake, and program information.

MDS uses Make.com to execute automated workflows and transmit information among authorized systems.

D. Artificial-intelligence providers

MDS uses OpenAI to assist in generating reports, recommendations, summaries, interpretations, communications, and other requested outputs.

E. Email, storage, and productivity providers

MDS uses Google Workspace, Gmail, Google Drive, and related services for communications, file storage, document administration, and collaboration.

F. Analytics and advertising providers

MDS may disclose website and marketing information to Google Analytics, Google Ads, Meta, LinkedIn, TikTok, and similar providers.

G. Scheduling and communications providers

MDS uses Zoom for meetings, calls, and authorized recordings.

MDS uses Calendly for scheduling and collecting pre-appointment information.

H. Printing and fulfillment providers

MDS uses Lulu and other printing, shipping, and fulfillment providers to produce and deliver physical products.

I. Media, hosting, and technical providers

MDS may use:

  • Synthesia
  • HeyGen
  • Cloudinary
  • Netfirms
  • Acenet
  • cPanel hosting
  • Other technical and media providers

These services may support video production, file storage, media delivery, domain administration, website hosting, or email infrastructure.

J. Digital Truth App providers

MDS uses application hosting, database, development, maintenance, and support services to operate the Digital Truth App and maintain authorized participant information.

K. Personnel and contractors

Authorized MDS personnel may access information when needed to perform their assigned responsibilities.

Certain contractors may access personal information while providing:

  • Automation development
  • Software development
  • Virtual assistance
  • Application support
  • Technical troubleshooting
  • Fulfillment support

Contractor access may include:

  • Fillout submissions
  • Make.com automation history
  • Google Drive report folders
  • Digital Truth App participant information
  • Customer communications
  • Order information

MDS requires applicable contractors to work under confidentiality, nondisclosure, and data-use restrictions.

MDS limits contractor access to information reasonably necessary for the assigned service.

L. Institutional customers

MDS does not provide an individual participant’s report or participant-level information to an institution unless:

  • The participant requests or authorizes the disclosure.
  • A parent or legal guardian authorizes the disclosure.
  • An applicable signed agreement permits the disclosure.
  • Disclosure is required by law.

An institution may receive aggregate or de-identified program information that does not reasonably identify an individual.

M. Legal, compliance, and safety disclosures

MDS may disclose information when reasonably necessary to:

  • Comply with law.
  • Respond to a subpoena, court order, or lawful government request.
  • Protect the rights, property, safety, or security of MDS or another person.
  • Investigate fraud or abuse.
  • Respond to a security incident.
  • Enforce an agreement.
  • Establish, exercise, or defend a legal claim.
  • Respond to an emergency.

N. Business transactions

Information may be disclosed or transferred in connection with:

  • A merger
  • Financing
  • Reorganization
  • Acquisition
  • Sale of assets
  • Bankruptcy
  • Another business transaction

MDS will require the recipient to process personal information according to applicable law and continuing contractual obligations.

10. De-Identified and Aggregate Information

MDS may create aggregated or de-identified information that does not reasonably identify an individual.

MDS may use and disclose that information for:

  • Product improvement
  • Internal research
  • Program evaluation
  • Benchmarking
  • Institutional outcome summaries
  • Grant reporting
  • Public impact reporting
  • Marketing statistics
  • Academic or professional research
  • Business planning

MDS will not attempt to re-identify properly de-identified information except:

  • To test whether de-identification controls are effective.
  • To protect security.
  • As otherwise permitted by law.

Where required, MDS will require a recipient of de-identified information not to attempt to re-identify it.

An institution’s name or logo will not be publicly associated with outcome information without authorization.

11. Publicity and Testimonials

MDS may request permission to use:

  • Customer names
  • Participant names
  • Institution names
  • Logos
  • Testimonials
  • Report excerpts
  • Success stories
  • Photographs
  • Audio recordings
  • Video recordings
  • Case studies
  • Identifiable outcomes

This Privacy Policy does not provide blanket permission for those uses.

MDS will obtain separate affirmative and documented permission before publicly using identifiable information for marketing, publicity, or promotional purposes.

Permission may be obtained through:

  • A release form
  • A clearly labeled consent field
  • An email authorization
  • A signed agreement
  • Another documented method

12. Children and Minors

A. Purchasing age

A person must be at least 18 years old to independently purchase an MDS service or enter into a contract with MDS.

A participant between ages 13 and 17 may participate only through authorization from a parent, legal guardian, institution, or authorized adult program sponsor.

B. Children under 13

MDS does not permit children under 13 to independently:

  • Create an MDS account.
  • Complete an online MDS form or assessment.
  • Use MyCareerSuperpowerGPT.
  • Use the Digital Truth App.
  • Register for an MDS Kajabi product.
  • Communicate directly with MDS.

For a participant between ages 10 and 12:

  • A parent, legal guardian, or authorized adult program facilitator must submit the necessary information.
  • The adult must manage the child’s participation.
  • MDS communications must be directed to the responsible adult or institution.
  • The child may use physical or offline materials under appropriate adult supervision.

MDS may create an Identity & Success Report or provide a Companion Workbook relating to a child when the information is submitted and authorized by a parent, legal guardian, or institution with legal authority.

MDS does not use personal information relating to a child for:

  • Targeted advertising
  • Behavioral advertising
  • Unrelated marketing
  • Profiling for legal or similarly significant decisions
  • Commercial purposes outside the authorized service

If MDS changes its services to permit direct online collection from a child under 13, MDS will implement any required parental notice, verifiable parental consent, access, deletion, data-minimization, security, and retention process before collection begins.

C. Parent, guardian, and institutional requests

A parent, guardian, or authorized institution may contact MDS to:

  • Request access to information relating to a child.
  • Correct inaccurate information.
  • Request deletion where applicable.
  • Withdraw authorization for future processing.
  • Ask questions about service providers and data practices.

Institution-sponsored requests should ordinarily be submitted through the sponsoring institution so that MDS can verify authority and comply with the applicable agreement.

13. Schools and Educational Programs

MDS may provide outsourced services to schools and educational institutions.

Under MDS’s standard process:

  • An institution may provide limited participant contact information.
  • The participant, parent, guardian, or authorized facilitator provides the information required for the personalized service.
  • MDS does not request extensive educational records through standard onboarding.
  • MDS uses school-provided information only for the contracted program.
  • MDS does not use identifiable school-provided information for unrelated marketing or advertising.
  • MDS does not provide participant reports to an institution without appropriate authorization.

When required, MDS will enter into:

  • A data-processing agreement
  • A student-data privacy agreement
  • An institutional service agreement
  • Another appropriate written agreement

Those agreements may address:

  • Permitted uses
  • Security
  • Access restrictions
  • Retention
  • Deletion
  • Redisclosure
  • Incident response
  • Parent or participant rights
  • Institutional control over education records

The school or sponsoring institution is responsible for obtaining required participant, parent, guardian, or institutional permissions unless a signed agreement assigns a specific responsibility to MDS.

14. Marketing Communications

MDS may send:

  • Newsletters
  • Promotional emails
  • Product announcements
  • Event invitations
  • Abandoned-checkout reminders
  • Marketing text messages
  • Telephone marketing
  • Direct mail

MDS sends marketing communications according to applicable consent, disclosure, and opt-out requirements.

Transactional communications are communications reasonably necessary to:

  • Confirm a purchase.
  • Deliver a product or report.
  • Provide account access.
  • Administer a program.
  • Send a program reminder.
  • Communicate about billing.
  • Communicate about security.
  • Provide support.
  • Communicate a policy or service change.

An institution-provided participant roster will not be added automatically to unrelated MDS marketing campaigns.

An institutional participant will receive marketing communications only when the participant separately opts in or another lawful basis permits the communication.

Email opt-out

You may unsubscribe from marketing email by:

  • Using the unsubscribe link in the message.
  • Contacting MDS at support@mydigitalself.co.

Text-message opt-out

You may stop marketing text messages by replying STOP or using another opt-out method stated in the message.

Message and data rates may apply.

Opting out of marketing does not prevent MDS from sending necessary transactional or service-related communications.

15. Data Retention

MDS retains personal information only for as long as reasonably necessary for:

  • Providing services
  • Account administration
  • Program administration
  • Legal compliance
  • Security
  • Fraud prevention
  • Audits
  • Disputes
  • Contract enforcement
  • The purposes described in this Privacy Policy

Unless a law, signed agreement, legal hold, or service-specific requirement establishes another period, MDS generally follows these retention periods:

Customer account information

Retained while the account is active and for up to four years after account closure or the last transaction.

Assessment responses

Retained for up to four years after report delivery or program completion.

Identity & Success Reports

Retained for up to four years after delivery or program completion.

Intake forms

Retained for up to four years after delivery or program completion.

Digital Truth App information

Retained during the active access period and for up to two years afterward.

GPT conversations controlled by MDS

Retained for up to 90 days unless:

  • The user intentionally saves the conversation.
  • Longer retention is reasonably necessary to provide the service.
  • A legal or contractual requirement applies.

Third-party AI providers may apply their own retention practices.

Institutional rosters

Deleted or de-identified within approximately 90 days after program completion unless a signed agreement requires another period.

De-identified and aggregate reports

May be retained indefinitely.

Payment and transaction records

Retained for up to seven years or longer when required by law.

Email and support records

Retained for up to four years after the matter closes.

Zoom and session recordings

Retained for approximately 90 days unless a longer period is disclosed and reasonably justified.

Marketing contacts

Retained until the person unsubscribes, withdraws consent, or requests deletion, subject to retention of a limited suppression record to prevent future unwanted marketing.

Physical-order and shipping records

Retained for up to seven years.

System backups

Generally maintained on a rolling basis for approximately 90 days.

Legal, fraud, dispute, audit, or investigation records

Retained for as long as reasonably necessary for the applicable matter.

Deleting an account does not necessarily result in immediate deletion of every record.

MDS may retain records reasonably necessary for:

  • Transactions
  • Accounting
  • Legal compliance
  • Audits
  • Fraud prevention
  • Security
  • Contract enforcement
  • Institutional obligations
  • Dispute resolution

Information may remain temporarily in secured backups until the backup is overwritten or deleted.

MDS may retain de-identified information after identifiable information has been deleted.

16. Security

MDS uses reasonable administrative, technical, and organizational safeguards appropriate to the nature of the information processed.

MDS also relies on service providers for platform hosting, payment security, application security, storage, communications, and other technical services.

Safeguards may include:

  • Password-protected systems
  • Multifactor authentication where available
  • Access restrictions
  • Confidentiality obligations
  • Vendor controls
  • System monitoring
  • Backups
  • Security updates
  • Incident-response procedures

No website, application, transmission method, storage system, or electronic process can be guaranteed completely secure.

You are responsible for:

  • Protecting your account credentials.
  • Using secure devices and networks.
  • Not sharing passwords or access links.
  • Reporting suspected unauthorized access promptly.
  • Avoiding submission of information MDS has not requested.

Report a suspected privacy or security incident to:

support@mydigitalself.co

17. Privacy Rights

Depending on your state of residence and whether an applicable privacy law governs MDS or a specific processing activity, you may have the right to:

  • Confirm whether MDS processes your personal information.
  • Access personal information maintained about you.
  • Correct inaccurate information.
  • Request deletion.
  • Obtain a portable copy of information you provided.
  • Opt out of targeted advertising.
  • Opt out of the sale or sharing of personal information.
  • Opt out of certain profiling producing legal or similarly significant effects.
  • Limit certain uses of sensitive personal information.
  • Withdraw consent where processing is based on consent.
  • Appeal a decision concerning a privacy request.
  • Use an authorized agent.
  • Exercise applicable rights without unlawful discrimination or retaliation.

Privacy rights are subject to exceptions.

For example, MDS may retain or continue processing information when reasonably necessary to:

  • Complete a transaction.
  • Provide a requested service.
  • Maintain security.
  • Detect fraud.
  • Exercise or defend legal rights.
  • Comply with tax, accounting, legal, contractual, or audit obligations.
  • Protect another person’s rights.
  • Maintain a marketing-suppression record.

MDS does not use automated processing to make final decisions producing legal or similarly significant effects.

18. Submitting a Privacy Request

You may submit a privacy request by:

  • Emailing support@mydigitalself.co.
  • Using the privacy or contact form provided on the MDS website.

Include:

  • Your name
  • The email associated with the applicable account or program
  • Your state of residence
  • The type of request
  • The relevant product, service, or institution
  • Enough information for MDS to locate the applicable record

Do not send:

  • A Social Security number
  • A complete payment-card number
  • A password
  • Government identification

unless MDS specifically requests it through an appropriate verification process.

Identity verification

MDS may take reasonable steps to verify your identity and authority before:

  • Disclosing personal information
  • Correcting personal information
  • Deleting personal information
  • Completing another protected request

MDS may request additional information when reasonably necessary to prevent unauthorized access, disclosure, correction, or deletion.

Institution-sponsored participants

A participant in an institution-sponsored program should ordinarily submit the request through the purchasing institution.

MDS may coordinate with the institution to verify the request and comply with the applicable agreement.

This does not prevent a person from submitting a request directly when applicable law requires MDS to accept it.

Authorized agents

An authorized agent may submit a request where permitted by law.

MDS may require:

  • Proof of authorization
  • Verification of the requester’s identity
  • Direct confirmation from the consumer

Response period

MDS will respond to a verified request within 45 days when required by applicable law.

When legally permitted, MDS may extend the response period by an additional 45 days. MDS will provide notice of the extension and the reason for it.

Appeals

When applicable law provides an appeal right, you may appeal by replying to the decision email and clearly stating that you are submitting a privacy appeal.

An MDS-appointed representative will review the appeal.

When legally required, a denied appeal response will explain how to submit a complaint to the appropriate state authority.

19. Additional United States Privacy Disclosures

Where applicable, state privacy laws may classify advertising-pixel disclosures as the sale or sharing of personal information, even when no money is exchanged.

During the preceding 12 months, MDS may have processed the following categories:

  • Identifiers
  • Customer-record information
  • Demographic information
  • Commercial information
  • Internet and device activity
  • Approximate geolocation
  • Audio, visual, and electronic information
  • Professional and employment information
  • Education and training information
  • Inferences and profiles
  • Sensitive personal information

MDS may disclose identifiers, commercial information, internet activity, and device information to analytics and advertising providers for business purposes and targeted advertising.

MDS does not sell personal information for money.

MDS does not intentionally disclose sensitive assessment information for targeted advertising.

You may opt out of targeted advertising or legally defined sale or sharing through:

  • The website’s cookie or privacy-preference tool.
  • A valid Global Privacy Control signal.
  • A request sent to support@mydigitalself.co.

MDS will not unlawfully discriminate against a person for exercising an applicable privacy right.

20. Third-Party Websites and Services

MDS websites and communications may contain links to third-party:

  • Websites
  • Applications
  • Payment services
  • Social-media platforms
  • Scheduling systems
  • Other online services

MDS does not control those parties’ privacy, security, content, or operational practices.

Information you submit directly to a third party is governed by that party’s privacy policy and terms.

Review the third party’s policies before submitting personal information.

21. Processing in the United States

MDS directs its services primarily to users in the United States.

MDS and its providers generally process information in the United States. Certain providers may also process information in other jurisdictions according to their infrastructure and policies.

A person accessing MDS services from outside the United States acknowledges that information may be transferred to and processed in the United States, where privacy laws may differ from those in the person’s location.

Where legally required, MDS will address applicable international privacy rights and data-transfer requirements.

22. Changes to This Privacy Policy

MDS may update this Privacy Policy to reflect changes in:

  • Services
  • Technology
  • Providers
  • Information practices
  • Security practices
  • Legal requirements
  • Business operations

The updated version will display a revised effective date.

When a change is material, MDS may provide additional notice through:

  • The MDS website
  • Email
  • An account notification
  • An institutional contact
  • Another appropriate method

Where additional consent is legally required, continued use alone will not replace that consent.

23. Contact Information

Questions, privacy requests, appeals, complaints, and suspected privacy or security incidents may be directed to:

My Digital Self, LLC
Doing business as My Digital Self and My Digital Self Coaching Solutions
3333 Preston Blvd., Ste. 300, #1016
Frisco, Texas 75034
United States

Privacy and Support Email: support@mydigitalself.co
Website: www.mdself.com

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