Privacy Policy
Last Updated: May 20, 2025
Policy Table of Contents
I. Introduction & Definitions
II. What Data We Collect
III. How We Use Data
IV. How We Share Data
V. Your Choices, Rights, and Obligations
VI. Other Important Information
I. Introduction and Definitions
Wingman Mental Health DOES NOT SELL YOUR PERSONAL DATA UNDER ANY CIRCUMSTANCES.
Wingman Mental Health Cares About Your Privacy.
Transparency and honesty are a huge part of our mission at Wingman Mental Health. We care about your privacy and especially about the psychological safety of the coaching environment. As such, whether you are a coach providing services on our platform, a user of our platform, or a visitor to our website, we want you to know how we collect, use, and share your data. We want to communicate this in plain language as much as possible.
You may be working with us in other contexts not specifically described in this policy and while
we do not address privacy for all stakeholders and situations in this privacy policy, our
philosophy applies to those other contexts as well. Depending on the products, features, or
experiences you use, we may provide additional privacy notices.
This privacy policy describes our privacy practices relevant to the Site, Services, and Platform
and the impact these practices have on Coaches, Users, and Job Applicants. Each term is defined below. Let’s start with a brief overview of what we do, how and where we might be collecting data, and then define some relevant terms.
Wingman Mental Health is a Coaching platform dedicated to create a more approachable, interactive, and effective wellness support option for men.
We will refer to people to whom we provide Services directly as “Users.” We also collect data from individuals delivering support (“Coaches”) who typically contract with us to
provide services to Users via the Platform and from visitors (“Visitors”) to our website:
www.wingmanmentalhealth.com and its subdomains (the “Site”).
Should you apply for a job with Wingman Mental Health you will be known as an “Applicant”. To the extent data is associated with an identified or identifiable natural person and is protected as personal information (or substantially equivalent terms) under applicable data protection laws, we will refer to this as “Personal Data”. Please understand that certain local laws may refer to personal information rather than Personal Data and in the context of this Policy, Wingman Mental Health intends these terms to be interchangeable.
II. Data We Collect
2.1 Data You Provide to Us
Data From Our Website
If you are a visitor to our public website, www.wingmanmentalhealth.com and its subdomains, we and trusted third parties acting on our behalf will collect certain information. We use cookies and similar technologies (e.g., web beacons, pixels, and ad tags) to collect data (e.g., device IDs) from our public Site to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Site. We also allow third parties to use cookies as the Cookie Policy describes, including to assist in our marketing and advertising campaigns.
We may also collect (or rely on others who collect) data about your device where you have not engaged with our Site (e.g., ad ID, IP address, operating system, and browser data) so we can provide our Visitors with a better user experience. You can opt out from our use of data from
cookies and similar technologies that track your behavior on the sites of others for ad targeting and other ad-related purposes. Please review the Cookie Policy for all relevant details.
Data From Applicants
We collect information if you apply for a job (“Applicant”) with Wingman Mental Health. We will need to collect certain personal information from you in order to process your application, such as your name, email address, phone number, location, and work history. This information is used to evaluate your experience and communicate with you. Wingman Mental Health may work with third party vendors to assist in the application process and, where those systems will have access to your personal information, Wingman Mental Health will provide the appropriate disclosures. If any of these systems require highly sensitive personal information or request session recordings, you will be notified at that time.
If you are an Applicant based in California, please review the Applicant Privacy Notice which includes information about: what personal information we collect; how we collect, use and disclose that information and the legal grounds for us doing this; and your rights in respect of your personal information.
Data From Coaches
If you are a Coach, we collect data when you submit an inquiry to provide coaching services for us, when you use the Platform, when you request technical support, and when you otherwise initiate communication with us.
We never require Coaches to provide us any sensitive Personal Data (e.g., financial data),
although we may request demographic or other personal data from Coaches when we are
testing a new tool or feature, staffing a specific program for customers, or conducting research
studies. The type of demographic or personal data we may request may include gender, race,
ethnicity, licensure, specialized skills, or for federal programs, your citizenship.
When asking for demographic data, Wingman Mental Health does so because we believe it will improve the services for our Users and Coaches; however, providing such personal information shall remain optional.
As a Coach, we may ask you to provide data to improve your experience on the Platform. For example, we may ask Coaches to review coaching and Platform experience as well as personal preferences such as preferred language and pronouns.
In all circumstances, your decision to provide Wingman Mental Health with Personal Data has no impact on your role as a Coach, and you may withdraw consent at any time by emailing team@wingmanmentalhealth.com.
Data From Users
If you are a User, we collect data when you register for the Platform and when you access the
Services via the Platform. We require certain Personal Data in order to initiate services,
such as:
Your name
Date of birth
Your email address
Your phone number
Preferences
Background information
Experience with professional support
Wellness goals
Background information
Emergency contact
We require this data for at least the following reasons: 1) to ensure you are matched with an appropriate coach and 2) ensure we have minimum location data to honor your specific privacy rights.
We collect data to provide and improve your experience on the Platform. For example, we may
ask Users to complete surveys to help us match you with a Coach that aligns with your
coaching goals; complete an assessment that will allow you to gain insight into your strengths and weaknesses by asking you a series of questions about general wellbeing, work-life
balance, and stress; review your coaching and Platform experience; and enter your personal preferences within your User or Coach profile, such as preferred pronouns and preferred language.
Prior to your kickoff call, you also will need to complete a short series of intake forms to assess your mental health & well-being. These forms will not be used, and will never be used, to provide any diagnoses. This information will be reviewed by your Coach in order to provide them with the information needed to ensure your safety, that you are receiving the appropriate level of care, and to optimize kickoff call efficiency. This may include:
· PHQ-9, GAD-7, and/or similar assessment forms
· Biopsychosocial assessment questions
Any and all Protected Health Information provided by Users will be stored in accordance with HIPAA guidelines and policies. This includes Business Associate Agreements (BAAs) signed by Coaches and with software providers storing data (e.g., Google forms and Google Drive). To learn more about the Google Workspace HIPAA Business Associate Addendum you can select here.
We collect usage data from Users accessing the Platform, such as which programs you respond to and attend, your session ratings, when you attend a coaching session, and any other usage data you share with us.
In certain cases, the Platform may integrate with third party systems to manage data and gain insights about the value of the platform. If you as a User have concerns about this data collected from third parties, please email us at team@wingmanmentalhealth.com.
2.2 Aggregated Data from Use of Platform
Whether you are a Coach or User, we may aggregate and de-identify the data related to your
use of the Platform apart from what has been detailed above. We may analyze your usage data
and content when it is uploaded, sent, received, or stored. We may use your data, activity logs,
and direct feedback to improve our Platform and Services.
2.3 Cookies and Similar Technologies
First, while we use similar technologies within our Platform, they are separate and apart from
the cookies and similar technology used on our public website, www.wingmanmentalhealth.com, which are all disclosed within our Cookie Policy. In order to provide specific functionality within our Platform, there is limited use of tracking technology within our Platform, as also disclosed within our Cookie Policy. Users may manage their Cookie preferences within their User Profile in the Platform.
2.4 Your Device and Location
We do collect data from Platform Visitors such as data about your device and location via IP address, the type of browser you use, amount of time you spend on the Platform, pages viewed, forms submitted, and the digital channel that brought you to the Platform. Wingman Mental Health will not request precise geo-location data from our Users. If you access the Platform via a mobile device or have downloaded our mobile application, we may collect data such as the first time the mobile application is opened, mobile carrier, and the type of device that is being used.
2.5 Audio & Video Data
We may record coaching sessions on the Platform with the express consent of both Coach and User (each a “Recording”). If you have consented to a Recording, it will be used to inform analyses on the quality and effectiveness of your coaching session. The session recording may
be used in the following ways:
Analysis of aggregate call statistics such as number of speaker turns
Text analysis including full transcript, key words, themes, and sentiment of words
Audio analysis
Video analysis which may include facial expressions and body language
Any derived insights from recorded videos will be collected in a de-identified manner and used to improve your experience and our Platform and Services. When Wingman Mental Health uses the term “de-identified” we understand this is useful as a data minimization technique and included within this term is a commitment not to re-identify the data unless necessary to provide Service to You.
Wingman Mental Health is constantly looking for ways to level up our services and to find ways to improve your coaching journey. Occasionally in our pursuit of the best tools to provide the analysis we need to serve our Users, we may use third party vendors to
assist with analyzing this data.
When working with third party vendors, Wingman Mental Health’s priority is to provide data in a deidentified manner and will ensure that your data remains confidential to your experience with Wingman Mental Health. Wingman Mental Health requires all third-party vendors to certify via contract they will never sell data and will maintain strict privacy and security controls for all data they may have access to as a result of working with Wingman Mental Health. Occasionally, the third-party vendors providing analysis of this data may utilize Artificial Intelligence. That means, in addition to the contractual protections noted above, any data received from Wingman Mental Health cannot be used to train their algorithms or data models and must be immediately deleted after providing the requested analysis. Any data shared with our third-party vendors remains encrypted in transit. The Recordings will be securely stored in our data center in the United States and our employees can access them on a need-to-know basis only. Recordings will never be shared elsewhere.
2.6 Health Information
Any Protected Health Information collected by Wingman Mental Health will be stored in compliance with Health Insurance Portability and Accountability Act (“HIPAA”) standards.
Wingman Mental Health acknowledges and understands the definition of health information is more expansive under GDPR and other privacy regulations, to include general well-being and any data relating to a person’s physical or mental health; therefore, Wingman Mental Health handles all health information as sensitive and has implemented additional security and privacy protocols for all health-related Information.
III. How We Use Your Data
3.1 Services
At the core of Wingman Mental Health is our belief that consistent support from a qualified wellness coach, supported by tangible progress tracking, can make a material difference in men’s quality of life, stress, balance, happiness, fulfillment, success, relationships, and overall health. To do so, Wingman Mental Health will use your data to drive these insights and analytics to serve you, our Users. The primary manner in which we use all data is to provide the Services and help us improve the Site, the Platform, and the quality of our Services. As described in Section 2, we request sensitive Personal Data only under very limited circumstances, providing it is always voluntary, and you may revoke permission at any time.
3.2 Communicate With Users and Coaches
We require certain Personal Data from both Users and Coaches for routine communication with
each and to facilitate the relationship between them.
3.3 Market To You
As further described in the Cookie Policy and in Section 2, we collect certain data from Site Visitors for marketing and advertising purposes. Site Visitors may also need to provide data to schedule a demo or interact with a bot on the Site to get what information you need from us more efficiently. We may also use this information to communicate with You about products, services, offers, promotions, rewards, and events offered by Wingman Mental Health or others; provide news and information we think will be of interest to You or your User Organization; and deliver and measure advertisements on other media and third-party websites. You have control over what information is collected and used, per our Cookie Policy.
3.4 Provide Customer Support
You may provide data via the Site or Platform that we use to provide a better customer support experience to you. For instance, if you were to email team@wingmanmentalhealth.com our team will request specific information for verification purposes and as necessary to address your concerns.
IV. How We Share Data with Third Parties
AS REFERENCED ABOVE, WINGMAN MENTAL HEALTH DOES NOT SELL YOUR PERSONAL DATA.
We share certain Personal Data about Users with Coaches (and vice versa) such as contact information and responses to surveys to facilitate the ability for Coaches to provide services to
Users.
Section 2 discusses how third parties may access your data. We may also share opinions, feedback, or reviews you voluntarily provide to us as a User to your Coach on a de-identified basis, for quality or educational purposes.
If you are a Visitor to our public site or an individual User of Wingman Mental Health (www.wingmanmentalhealth.com), we may share data about your interactions with the Site and the Services (such as whether you purchased a subscription) with our marketing and
advertising service partners to help us create and administer campaigns, target and deliver relevant advertisements on third-party websites, and measure and optimize their effectiveness.
To opt-out of sharing your data for these purposes, please opt out via the provided links or
manage within your cookie preferences. If you are a Visitor, Coach, or User, we may also share data about you as follows:
With vendors, consultants, and other service providers (including Coaches) who need access to such data to carry out work on our behalf, on a need-to-know basis;
In response to a request for data if we believe disclosure is in accordance with any legitimate law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;
If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, to protect the rights, property, and safety of others;
In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company; and
With your consent or at your direction, including if we notify you through the Site, Services or Platform that certain data you provide will be shared in a particular manner and you choose to provide this data.
V. Your Choices, Rights and Obligations
5.1 Data Retention
We store Personal Data for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory,
or other compliance obligations.
5.2 Your Choices About Data Generally
You may update, correct, or delete Personal Data at any time by contacting us at team@wingmanmentalhealth.com. Please note that we may retain certain data as required by law or for legitimate business purposes. We may also retain cached or archived copies of data about you for a certain period.
5.3 Your Choices About Email Subscriptions
You may opt out of receiving email communications from us by following the unsubscribe link
within those communications or by emailing us at team@wingmanmentalhealth.com.
5.4 Your Choices About Promotional Communication
You may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at team@wingmanmentalhealth.com. If you opt out, we may still send you non-promotional communications specifically related to your use of the Platform.
5.5 Your Jurisdiction-specific Rights
A. Your Rights under State level privacy laws
At this time, the United States is seeing a handful of states passing comprehensive privacy legislation. We understand each state is doing their best to protect the individual privacy rights for their own citizens, which is why Wingman Mental Health has taken the approach of honoring all privacy rights such as the generally accepted principles of right of access, deletion, and correction for all our Users and will honor the rights described within this Privacy Policy as well as all rights afforded you under your local state laws.
B. Your Rights under the California Consumer Privacy Act (“CCPA”)
If you are a California resident, you are entitled to learn what data we collect about you, ask to
delete your data and ask us not to sell it. You may request what personal information we have about you. If you make this request, we will return to you:
(i) The categories of personal information (as defined by the CCPA) we have collected about
you.
(ii) The categories of sources from which we collect your personal information.
(iii) The business or commercial purpose for collecting or selling your personal information.
(iv) The categories of third parties with whom we share personal information.
(v) The specific pieces of personal information we have collected about you.
(vi) A list of categories of personal information that we have sold, along with the category of
any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.
(vii) A list of categories of personal information that we have disclosed for a business purpose,
along with the category of any other company we shared it with.
If you request that we delete your data pursuant to the CCPA, we will delete the personal
information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate. We will not discriminate against you under any circumstances for exercising your rights in connection with the CCPA. To exercise your California data protection rights described above, please send a request to team@wingmanmentalhealth.com.
VI. Other Important Information
6.1 Wingman Mental Health, Machine Learning and AI
In the future, we may leverage Machine Learning (ML) and Artificial Intelligence (AI) to deliver ideal coach matches for our members and to drive a better user experience.
These Services rely on User actions and inputs including your decision to accept or reject the proposed coaches or the insights provided. AI is a tool — like a pencil or a calculator – that can help us do our jobs better and faster and is here to enable our Users to connect better with a Coach.
Wingman Mental Health believes that responsibly designed technology will enhance the coaching experience. Wingman Mental Health recognizes the use of these technologies can raise new privacy and security concerns. This is why, for example, Wingman Mental Health allows Users to override Your coach recommendations by requesting a new match.
It is also why Wingman Mental Health provides additional disclosures, such as describing a feature as “AI-assisted” throughout our product experience where AI-powered insights may be provided so you may have insight into when your coaching experience has been enhanced with AI-powered technologies.
6.2 Wingman Mental Health’s Commitment to Children’s Privacy
At Wingman Mental Health we take children’s privacy very seriously. The Platform and Services are designed for individuals over the age of 18 and we do not intentionally collect any data from persons under the age of 18 (each a “Child”). If you believe that Wingman Mental Health may have
directly collected Personal Data about a Child and wish to have us remove that Personal Data,
please contact us at team@wingmanmentalhealth.com to let us know. We’ll work with you to make sure that data is removed from our Site and Services, as applicable. In the event that Wingman Mental Health discovers we may have collected Personal Data about a Child inadvertently, we will proactively remove that Information.
6.3 Is Wingman Mental Health a Data Controller or a Data Processor?
Certain data protection laws distinguish between data processors and data controllers,
depending on how the data is collected and shared. Wingman Mental Health is a Controller and a Business with respect to our direct relationship with Users within our Platform.
6.4 How Do You Communicate Changes to This Privacy Policy?
If we make changes to this Privacy Policy, we will notify you by revising the date at the top of
the policy. In some cases, such as a material change in our practices, we may provide you with
additional notice, such as adding a statement to our homepage or sending you an email notification. We encourage you to review the Privacy Policy whenever you access the Site,
Platform or Services to stay informed about our data practices and the ways you can help protect your privacy.
6.5 How Can I Contact Wingman Mental Health About This Privacy Policy?
email: team@wingmanmentalhealth.com