Effective Date: June 22, 2026

This Privacy Policy explains how Clever Octopus, LLC (“we,” “us,” or “our”) collects, uses, and protects personal information through our website and professional services.

As a coaching and consulting practice, we are committed to operating in compliance with all applicable laws and regulations, including the International Coaching Federation (ICF) Code of Ethics.  

If you have questions about this Privacy Policy or how your information is handled, please contact [email protected].

This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you:

- Visit our website at Cleveroctopus.co (the “Site” or “website”)

- Schedule calls or sessions with us

- Communicate with us by email, phone, or other channels

- Engage our executive coaching or consulting services

By using the Site or otherwise providing personal information to us, you agree to the practices described in this Privacy Policy, as updated from time to time.

1. Information We Collect

We may collect the following categories of information, depending on how you interact with us.​

A. Information You Provide Directly

Contact details, including but not limited to, name, email address, phone number, job title, employer, industry, and similar professional information.

Information you provide when you inquire about, engage, or participate in coaching/consulting, such as background, goals, context about your role, and topics you wish to address.

Content of emails, messages, or other communications you send to us.

Limited information related to invoices and payments (for example, billing name, billing address), while payment card details are processed directly by our payment processor and are not stored by us.​

B. Information Collected Automatically

This website collects personal information to power our site analytics, including:

- Information about your browser, network, and device

- Web pages you visited prior to coming to this website

- Your IP address

This information may also include details about your use of this website, including:

- Clicks

- Internal links

- Pages visited

- Scrolling

- Searches

- Timestamps

We provide this information to DigitalMentors.io (https://digitalmentors.io/privacy), our website analytics provider, to learn about site traffic and activity.  This information may be collected through cookies and similar technologies. See “Cookies and Analytics” below.​

C. Information from Third Parties

We may receive limited information from third party providers we use in operating the business, including, but not limited to:

- Scheduling information from Digitalmentors.io (e.g., your name, email, and selected appointment time).

- Payment confirmation and limited billing details from Stripe.

- Hosting and analytics information from Digitalmentors.io and any analytics tools enabled through our Site.​

We may also receive information from publicly available third party sources, such as public databases or social media platforms.

2. How We Use Personal Information

We use personal information for the following purposes:

- To respond to your inquiries and communicate with you about our services, including scheduling, follow-up, and related correspondence.

- To deliver coaching, consulting, facilitation, and related services that you have engaged or expressed interest in.

- To process payments and manage billing, invoices, and related financial transactions.

- To send you updates, newsletters, program announcements, or other marketing communications, where you have opted in or where permitted by applicable law. You may opt out at any time.

- To operate, maintain, improve, and analyze the performance of our Site, including through analytics tools.

- To comply with applicable legal, tax, and regulatory obligations, and to enforce our agreements and protect our legal rights.

- To detect, prevent, and address fraud, security incidents, or other harmful or unlawful activity.

- For any other purpose described to you at the time the information is collected, or for which you have provided your consent.

3. How We Share Personal Information

We do not sell your personal information.  We share personal information only as reasonably necessary for the purposes described in this Policy, including with:​

- Service providers:

- Website host and related services (https://digitalmentors.io/privacy).

- Scheduling service (https://digitalmentors.io/privacy).

- Payment processor (https://stripe.com/privacy).

- Email and communication tools, cloud storage, and other vendors that support our operations.

- Professional advisers: Accountants, legal counsel, and other professional advisers, where necessary for business or legal reasons.

- Legal and compliance: If required to do so by law or legal process, or if we reasonably believe that such disclosure is necessary to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a government request.

Service providers are expected to handle personal information in accordance with applicable law and only for the purposes of providing services to us.

If we ever engage in a business reorganization (such as a merger, acquisition, or asset sale), personal information may be transferred as part of that transaction, subject to applicable law.

4. Coaching Confidentiality & Ethical Commitments

In accordance with the ICF Code of Ethics, we treat information shared within a coaching relationship as confidential.

- Coaching-related information is not disclosed without client consent, except where required by law.

- Confidentiality obligations apply to both written and verbal communications.

- Aggregate or anonymized information may be used for professional development or business improvement purposes without identifying individual clients.

Additional confidentiality terms may be set forth in a separate coaching agreement.

5. Lawful Basis for Processing (EU/UK Visitors)

If you are located in the European Union or the United Kingdom, personal data is processed only when a lawful basis applies, including:

- Your consent

- Performance of a contract or steps taken at your request

- Legitimate business interests that do not override your rights

We respect your right to withdraw consent at any time.

6. U.S. State Privacy Rights

Residents of certain U.S. states, including California, Colorado, Connecticut, Texas, Virginia, and others with comprehensive privacy laws, may have specific rights regarding their personal information under applicable state law. This section describes those rights and how to exercise them.

Depending on your state of residence and subject to applicable exceptions, you may have the right to:

- Know what personal information we have collected about you, including the categories of information, the purposes for which it is used, and the categories of third parties with whom it is shared.

- Access a copy of the personal information we hold about you.

- Request correction of inaccurate personal information.

- Request deletion of your personal information, subject to certain legal exceptions.

- Opt out of the sale or sharing of your personal information for targeted advertising purposes. We do not sell personal information or use it for targeted advertising as those terms are defined under applicable state privacy laws.

- Not be discriminated against for exercising any of these rights.

To submit a request to exercise any of these rights, please contact us using the information in the Contact Information section of this Policy. We will respond to verifiable requests within the timeframe required by applicable law. We may need to verify your identity before processing your request.

If you are a California resident, you may also designate an authorized agent to submit requests on your behalf. If you are dissatisfied with our response, you may have the right to appeal our decision or lodge a complaint with your state’s attorney general or applicable privacy regulator.

7. Payments

Payments for services are processed securely through Stripe. We do not store full payment card information. Your payment processor’s handling of payment data is governed by its own privacy policy, which you should review.

8. Cookies and Analytics

This website uses cookies and similar technologies, which are small files or pieces of text that download to a device when a visitor accesses a website or app. Cookies help us operate the Site and understand how it is used. For information about the cookies used on this Site, please refer to the documentation provided by Digitalmentors.io, our hosting platform, or review your browser settings. Certain necessary and required cookies are always used to allow our hosting platform to securely serve this website to you.

If you are located in the European Economic Area, the UK, or other regions where cookie consent is required, you may see a banner or notice asking for your consent to use certain cookies. You may withdraw or change your preferences at any time through your browser settings or any cookie management tools made available on the Site.

9. International Data Transfers

Our business is based in the United States, and the Site is hosted in the United States or other locations where our service providers operate. If you access the Site or work with us from outside the United States, your information may be processed and stored in the United States and in other countries, which may have different data protection laws than your country of residence.​

Where required by applicable law (for example, for individuals in the EEA or UK), appropriate safeguards—such as standard contractual clauses or equivalent mechanisms—may be used for cross-border transfers.

10. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, including:​

- To provide coaching/consulting services and manage our relationship with you.

- To comply with legal, tax, and accounting obligations.

- To resolve disputes and enforce agreements.

The specific retention period may vary based on the type of information and applicable legal requirements. When information is no longer needed, we may delete it, anonymize it, or securely store it until deletion is practicable.

11.  How We Protect Information

We use reasonable technical and organizational measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.​

These measures may include:

- Using secure, reputable service providers for hosting, scheduling, and payment processing.

- Restricting access to personal information to the business owners and limited trusted service providers.

- Using strong passwords and, where available, multi-factor authentication for accounts.

However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

12.  Your Privacy Rights

Your rights will depend on where you live and applicable law. Regardless of location, you generally have the ability to:

- Access and update your information by contacting us.

- Request that we correct inaccurate information.

- Opt out of marketing emails by using the unsubscribe link in those emails or by contacting us.

If you are located in certain jurisdictions (for example, the EEA, UK, or in some U.S. states), you may have additional rights over your personal information, such as:

- The right to request access to the personal information we hold about you.

- The right to request deletion of your personal information, subject to legal and contractual obligations.

- The right to object to or restrict certain processing.

- The right to data portability.

- The right to lodge a complaint with a data protection authority or regulator.

To exercise any of these rights, please contact us using the information found in the Contact Information section of this Policy. We may need to verify your identity before fulfilling certain requests and may be unable to comply where an exemption applies.

13. Email Communications

If you opt in to receive emails, you may unsubscribe at any time using the link included in each message or by contacting us directly.

We respect your communication preferences and consent choices.

14. SMS and Text Communications

If you provide your mobile phone number and consent to receive text messages from us, we may send you SMS or other text messages related to scheduling, session reminders, or other service-related communications. Message and data rates may apply. Message frequency will vary.

You may opt out of receiving text messages at any time by replying STOP to any message or by contacting us directly. After opting out, you may receive a single confirmation message. We will not share your mobile number with third parties for their marketing purposes. Your consent to receive text messages is not a condition of purchasing any service.

15. Use of Artificial Intelligence Tools

We may use artificial intelligence (“AI”) tools to support our business operations, including scheduling, administrative workflows, content development, session preparation, and note-taking or summary functions. Any use of AI tools in connection with active coaching engagements will be disclosed to you directly, consistent with our commitment to transparency and applicable professional ethics standards, including the ICF Code of Ethics.

We take reasonable steps to protect the confidentiality of information processed through AI tools. AI platforms operated by third parties are subject to their own terms and privacy practices, which we do not control. We do not input personally identifiable or sensitive client information into AI tools without authorization or in a manner inconsistent with our privacy obligations. AI tools support but do not replace the judgment and expertise of our coaches.

16. Children’s Privacy

Our website and services are not intended for individuals under the age of 18, and we do not knowingly collect personal information from children.

17. Governing Law

This Privacy Policy and any disputes arising out of or related to it or to our handling of your personal information shall be governed by the laws of Florida, without regard to its conflict-of-law principles.

18.  Third Party Websites

The Site may contain links to third party websites or services that are not operated by us. If you click a third party link, you will be directed to that third party’s site. This Privacy Policy does not apply to those external sites, and we encourage you to review their privacy policies.​

We are not responsible for the privacy practices or content of third party websites or services.

19. Updates to This Policy

This Privacy Policy may be updated periodically. The effective date will reflect the most recent version.  Your continued use of the Site or our services after any changes become effective constitutes your acknowledgement of the updated Policy.

20. Contact Information and Data Rights Requests

For questions about this Privacy Policy or to exercise privacy rights, please contact:  [email protected].

To submit a request to access, correct, or delete your personal information, please contact us at [email protected]. Please include your name, contact information, and a description of your request so we can verify your identity and respond appropriately. We will respond to verifiable requests within 45 days. Where additional time is needed, we will notify you within the initial 45-day period.