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Privacy Notice for California Residents

Last Revised on: April 6, 2026

This Privacy Notice for California Residents supplements the information contained in AIIR Consulting, LLC’s Privacy and Data Usage Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). AIIR Consulting, LLC and its sister company AIIR Analytics, LLC (collectively, “Company” or “we”) adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA”), and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Our AIIR Sites collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). In particular, the Company’s website at https://aiirconsulting.com, the Coaching Zone platform available at https://coachingzone.com, the AIIR Analytics website at https://aiiranalytics.com, the AIIR Analytics application at https://app.aiiranalytics.com, and any other associated software applications (collectively, the “AIIR Sites”) has collected the following categories of personal information from its consumers within the last twelve (12) months:

CategoryExamplesCollectedA. Identifiers.A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.YESB. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.YESC. Protected classification characteristics under California or federal law.Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).YESD. Commercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.YESE. Biometric information.Physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as sleep, health, or exercise data.NOF. Internet or other similar network activity.Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement, including interactions with AI-powered features and tools.YESG. Geolocation data.Physical location or movements.NOH. Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.NOI. Professional or employment-related information.Current or past job history or performance evaluations.YESJ. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.NOK. Inferences drawn from other personal information.Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, including inferences generated through AI and machine learning technologies.YESL. Sensitive personal information.Account log-in credentials (username and password combinations). The Company does not collect or process other categories of sensitive personal information as defined under the CCPA.YES

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase or otherwise utilize via the AIIR Sites, including your interactions with AI-assisted coaching tools and other AI-powered features.
  • Indirectly from you. For example, from observing your actions on our AIIR Sites.
  • From third parties. For example, from your employer (to the extent your employer has enrolled you in our services), analytics providers, advertising networks, and data brokers, as further described in our Privacy Policy.

Use of Personal Information

We may use, or disclose the personal information we collect for the purposes set forth in our Privacy Policy, including to power and improve AI-assisted features and tools within the AIIR Sites. Company will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Use of Artificial Intelligence

The Company uses artificial intelligence (“AI”) and machine learning technologies in connection with the AIIR Sites and the services we provide, including AI-assisted coaching features within the Coaching Zone platform, assessment analysis, and service improvement. When AI is used to process your personal information, the safeguards described in our Privacy Policy apply, including human review of AI-generated outputs that inform material decisions and restrictions on the use of your personal data for third-party AI model training without your explicit consent. You may contact us at info@aiirconsulting.com to inquire about the role AI plays in any aspect of the services you receive.

Sharing Personal Information

Company may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. This includes third-party AI service providers who process data on our behalf.

We share your personal information with the following categories of third parties:

  • Service providers.
  • Third-party AI service providers (acting as service providers on our behalf).

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

  • Category A: Identifiers.
  • Category B: California Customer Records personal information categories.
  • Category C: Protected classification characteristics under California or federal law.
  • Category D: Commercial information.
  • Category F: Internet or other similar network activity.
  • Category I: Professional or employment-related information.
  • Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.

Sales and Sharing of Personal Information

In the preceding twelve (12) months, Company has not sold personal information of any category. In the preceding twelve (12) months, Company has not shared personal information for cross-context behavioral advertising purposes.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that Company disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting, selling, or sharing that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or shared your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Right to Delete

You have the right to request that Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Correct

You have the right to request that Company correct inaccurate personal information that we maintain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct the inaccurate personal information.

Right to Limit Use of Sensitive Personal Information

To the extent Company processes sensitive personal information (such as account log-in credentials) for purposes beyond those authorized under the CCPA, you have the right to request that we limit our use of your sensitive personal information to only those uses that are necessary to perform the services or provide the goods you have requested, or as otherwise authorized by law. Currently, the Company does not use or disclose sensitive personal information for purposes that would require offering this right of limitation under the CCPA.

Right to Opt-Out of Sale or Sharing

You have the right to direct us to not sell or share your personal information at any time (the “right to opt-out”). The Company does not currently sell or share personal information as those terms are defined under the CCPA. If this practice changes in the future, we will update this notice and provide you with an opt-out mechanism.

We do not sell or share the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age.

Exercising Your Rights

To exercise the rights described above, please submit a verifiable consumer request to us by either:

Only you, or an authorized agent registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

Company reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the AIIR Sites and update the notice’s effective date. Your continued use of our AIIR Sites following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Company collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 215-337-4939
Website: https://aiiranalytics.com
Email: info@aiirconsulting.com
Postal Address:
AIIR Consulting, LLC
50 Monument Rd #205, Bala Cynwyd, PA 19004

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