Privacy Policy.

Who We Are

This Privacy Policy applies to Shaun Surgener Coaching, operated by Shaun Surgener as a sole proprietorship doing business in the State of Tennessee, United States. References to "we," "us," "our," or "the business" refer to Shaun Surgener Coaching.

This Privacy Policy covers personal information we collect through:

• The website at shaunsurgener.com and all associated subdomains, landing pages, and funnels
• 1-on-1 coaching engagements (Peak Performance, Surge Effect Fitness, and Surge Effect Wealth)
• Self-paced digital programs (Surge Effect Body, Surge Effect Life, and any future programs)
• Email marketing, newsletters, and lead magnets (such as The Inner Game Reset and Fat Loss Masterclass)
• SMS marketing and text-based communication (when offered)
• Phone calls, video calls, and in-person interactions
• Social media accounts operated by Shaun Surgener Coaching

If you have questions about this Policy or about how we handle your personal information, contact us using the information in Section 19.

Information We Collect

We collect information in three main ways: (1) information you provide directly, (2) information collected automatically when you use our website, and (3) information from third parties.

2.1 Information You Provide Directly

• Identity and contact information: Your full name, email address, phone number, mailing address, and date of birth (when relevant).
• Account information: Username, password (encrypted), and account preferences for accessing programs and member content.
• Coaching-related information: Goals, current circumstances, progress, challenges, health background, financial background, and any other information you share during the coaching engagement. This information may include sensitive personal details about your body, finances, relationships, mental and emotional state, and life direction.
• Payment information: When you purchase services or programs, payment information (such as credit card numbers) is collected and processed by our payment processors. We do not store full payment card details on our systems.
• Communications: The content of emails, text messages, voicemails, and other communications you send to us or that we exchange during the coaching relationship.
• Application and intake forms: Information you provide when applying for Strategy Sessions, Elite tier coaching, or completing intake questionnaires.

2.2 Information Collected Automatically

• Device and browser information: IP address, browser type and version, operating system, device identifiers, and screen resolution.
• Usage information: Pages visited, time spent on pages, links clicked, referring website, and navigation patterns.
• Location information: Approximate geographic location based on IP address (city/region level).
• Cookies and tracking technologies: See Section 4 for full details.

2.3 Information from Third Parties

• Advertising and analytics platforms: Aggregated data from Google, Meta (Facebook and Instagram), and similar platforms about how visitors interact with our advertisements.
• Payment processors: Confirmation of transactions, partial payment information needed for record-keeping, and dispute information.
• Referrals: If you were referred by another client, that referral source may be noted in our records.

How We Use Your Information

We use the personal information we collect for the following purposes:

• To deliver coaching services: Personalize coaching plans, track progress, schedule sessions, communicate with you, and provide the services you've purchased.
• To process payments and manage your account: Process transactions, send receipts, manage subscriptions and payment plans, and handle disputes or refund requests.
• To communicate with you: Respond to inquiries, send service updates, deliver scheduled communications related to your coaching engagement, and provide customer support.
• For marketing communications: Send newsletters, promotional emails, SMS messages (when you've opted in), and content related to our services. You can opt out at any time. See Section 6.
• To improve our services: Analyze how visitors use the website and how clients respond to coaching approaches, so we can improve content, programs, and the client experience.
• For advertising: Run targeted advertising campaigns on Google, Meta (Facebook and Instagram), and other platforms, including retargeting visitors who've engaged with our content. See Section 5.
• For legal and security purposes: Comply with legal obligations, prevent fraud, protect our rights and the rights of others, and respond to lawful requests from authorities.
• To create anonymized case studies and marketing content: With your explicit consent, we may reference your general results or transformation in marketing materials. Specific identifying details (full name, photo) are never used without separate written consent. See Section 8.

Cookies & Tracking Technologies

Our website uses cookies and similar tracking technologies (web beacons, pixels, local storage) to make the site function properly, analyze how it's used, and deliver relevant content and ads.

4.1 Types of Cookies We Use

4.2 Managing Cookies

You have several options for controlling cookies:

• Browser settings: Most browsers allow you to block or delete cookies. Note that blocking strictly necessary cookies will prevent parts of the site from working.
• Opt-out tools: You can opt out of Google Analytics tracking at tools.google.com/dlpage/gaoptout.
• Industry opt-out: The Digital Advertising Alliance (DAA) provides opt-out tools at optout.aboutads.info.
• Meta opt-out: You can manage Meta advertising preferences in your Facebook or Instagram account settings.

Analytics & Advertising Pixels

To understand how visitors use our website and to deliver effective advertising, we use the following third-party analytics and advertising tools. Each operates under its own privacy policy.

5.1 Analytics Platforms

• Google Analytics: Tracks website usage, pageviews, traffic sources, and visitor behavior. Operated by Google LLC. (Google Privacy Policy)
• Kajabi platform analytics: Our website host (Kajabi) provides built-in analytics about course completion, page visits, and user activity within the platform. (Kajabi Privacy Policy)

5.2 Advertising Pixels & Tracking

• Meta Pixel: Tracks visitor activity to measure ad effectiveness and serve targeted ads on Facebook and Instagram. Operated by Meta Platforms, Inc. (Meta Privacy Policy)
• Google Ads conversion tracking: Tracks conversions from Google Ads campaigns. Operated by Google LLC.
• TikTok Pixel: If used, tracks conversions from TikTok advertising. Operated by TikTok Inc. (TikTok Privacy Policy)
• Other advertising platforms: We may add or change advertising platforms over time. The same general approach applies: each operates under its own privacy policy, and tracking is used to measure ad effectiveness and reach relevant audiences.

5.3 Your Choices

You can opt out of personalized advertising on most major platforms through their account settings or industry opt-out tools (see Section 4.2). Opting out doesn't stop all ads — it just makes them less targeted.

Email & SMS Marketing

6.1 Email Marketing

When you opt in (by downloading a free resource, subscribing to our newsletter, or purchasing a service), you'll receive emails from us. These may include:

• Welcome and onboarding sequences
• Content related to body, inner game, and wealth coaching topics
• Announcements about new programs, masterclasses, or coaching availability
• Promotional offers and time-limited opportunities
• Service-related notifications (account, payment, schedule updates)

Marketing emails are delivered through our email service provider (currently Kajabi, with possible migration to GoHighLevel or another platform in the future). Each marketing email contains a one-click unsubscribe link. Service emails related to active coaching engagements are not subject to unsubscribe and are part of the coaching service.

6.2 SMS Marketing

If you provide your phone number and opt in to SMS communications, we may send you text messages including:

• Appointment reminders and scheduling
• Coaching-related check-ins and nudges
• Promotional offers and announcements
• Updates about new programs or content

SMS messages are delivered through Twilio (or a similar SMS gateway service). You can opt out of SMS at any time by replying "STOP" to any text message. Message and data rates may apply, depending on your carrier and plan. Message frequency varies.

6.3 Opting Out

• Email: Click the unsubscribe link in any marketing email.
• SMS: Reply STOP to any text message.
• All marketing: Email us at [email protected] with the subject "Opt Out" and we'll remove you from all marketing lists.

Payment Processing

When you purchase coaching services, programs, or other products, your payment is processed by one or more of the following third-party payment processors:

• Kajabi Payments (powered by Stripe) — primary checkout for online purchases. (Kajabi, Stripe)
• Stripe (direct) — for invoiced or custom-billed engagements.
• PayPal — available for some transactions. (PayPal Privacy)
• Venmo — available for certain transactions. (Venmo Privacy)
• Apple Pay — available where supported. (Apple Privacy)
• Zelle, Cash App, and Chime — available for certain direct-billed transactions.

We do not store full credit card numbers, debit card numbers, or bank account details on our systems. Payment information is transmitted directly to the processor through their secure systems. Each payment processor operates under its own privacy policy. We receive only the information needed to confirm and reconcile your transaction (such as confirmation of payment, partial card information for record-keeping, and dispute information).

Coaching Calls, Recordings & Testimonials

8.1 Coaching Call Recordings

Coaching calls (audio or video) may be recorded for the following purposes:

• Service quality and coaching review — so we can review the session and improve the coaching experience.
• Training and professional development — internal review of coaching technique.
• Marketing or promotional content — only with your explicit written consent, and only with the level of anonymization you approve.

If you do not wish your sessions to be recorded, you may opt out at the beginning of any session. We will respect that decision without affecting your coaching experience.

8.2 Testimonials & Case Studies

From time to time, we may publish testimonials or case studies in marketing materials. This is always done with your explicit prior consent — usually in writing — and at the level of anonymization you approve.

Default treatment for testimonials and case studies is full anonymity (initials or generic identifier only). We will only use your full name, photo, or specific identifying details if you give us separate, specific written permission.

If you've previously consented to a testimonial and want to withdraw consent, contact us at [email protected] and we will remove the relevant materials from active use.

8.3 Text Messages and Written Feedback

Text messages, voice memos, or written feedback you send us may be used in marketing or testimonials, but only in anonymized form (initials or generic identifier), and only with your express consent. You can withdraw consent at any time.

Third-Party Service Providers

We work with the following categories of trusted third-party service providers to operate the business. Each operates under its own privacy policy and is contractually required to handle your data securely.

This list may change as our tech stack evolves. We use the minimum number of providers required to operate the business and choose providers with strong privacy and security practices.

Aside from the service providers listed above and as required by law (see Section 9.1), we do not share your personal data with anyone.

9.1 When We May Disclose Information Without Your Consent

• Legal compliance: If required by law, court order, subpoena, or other legal process.
• Safety: If we have a reasonable belief that disclosure is necessary to prevent imminent serious harm to you or others.
• Legal defense: If necessary to defend our rights, business, or interests in legal proceedings.
• Business transfer: If the business is sold, merged, or acquired, your data may be transferred to the successor entity. You'll be notified of any change in ownership.

How We Protect Your Data

We take the security of your personal information seriously and use industry-standard practices to protect it:

• SSL/TLS encryption on all pages of the website that collect personal information.
• Encrypted storage of sensitive data through our trusted third-party providers (Kajabi, Stripe, etc.).
• Access controls — personal information is accessible only to Shaun Surgener and authorized contractors who need it to provide services.
• Strong password policies for accounts and systems we control.
• Regular review of security practices and provider agreements.

Despite our efforts, no method of transmission or storage is 100% secure. If we discover a security incident affecting your personal information, we will notify you and take appropriate action consistent with applicable law.

Data Retention

We retain your personal information only as long as needed for the purposes described in this Policy and to comply with our legal obligations.

You can request earlier deletion of your data at any time. See Section 12. Some data must be retained even after a deletion request to comply with legal obligations (e.g., financial records for tax purposes).

Your Rights — All Users

Regardless of where you live, you have the following rights regarding your personal information:

• Right to access: You may request a copy of the personal information we hold about you.
• Right to correction: You may request corrections to inaccurate or incomplete information.
• Right to deletion: You may request that we delete your personal information, subject to legal retention requirements.
• Right to opt out: You may opt out of marketing emails, SMS, or other communications at any time.
• Right to withdraw consent: Where you've given consent (such as for coaching call recordings or testimonials), you may withdraw it at any time.
• Right to portability: You may request your personal information in a structured, machine-readable format.

To exercise any of these rights, contact us at [email protected] with the subject line "Privacy Request." We will respond within 30 days (sooner where required by law).

California Privacy Rights (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) give you additional rights regarding your personal information.

13.1 Your California Rights

• Right to know: The categories and specific pieces of personal information we've collected about you in the past 12 months, the sources, the business purpose, and the categories of third parties with whom we've shared it.
• Right to delete: Your personal information, subject to certain legal exceptions.
• Right to correct: Inaccurate personal information we hold about you.
• Right to opt out of the sale or sharing of personal information: We do not sell your personal information. However, we use advertising platforms (Meta, Google) that may be considered "sharing" under CPRA's broad definition. You can opt out of this sharing by following the cookie management options in Section 4.
• Right to limit the use of sensitive personal information: We do not use sensitive personal information for purposes that require this opt-out.
• Right to non-discrimination: We will not deny you services, charge you different prices, or provide a different level or quality of service for exercising your California privacy rights.

13.2 How to Exercise California Rights

Submit a request by email to [email protected] with the subject "California Privacy Request." We will verify your identity (typically by confirming information we already have on file) and respond within 45 days, with the possibility of a 45-day extension if needed.

You may also designate an authorized agent to make requests on your behalf. Agents must provide written authorization from you and verifiable identification.

European Privacy Rights (GDPR)

If you are a resident of the European Economic Area (EEA), the United Kingdom, or Switzerland, the General Data Protection Regulation (GDPR) gives you the following rights regarding your personal information.

14.1 Your GDPR Rights

• Right of access — obtain a copy of your personal data.
• Right to rectification — correct inaccurate or incomplete data.
• Right to erasure ("right to be forgotten") — have your data deleted, subject to legal retention requirements.
• Right to restrict processing — limit how we process your data.
• Right to data portability — receive your data in a structured, machine-readable format.
• Right to object — object to processing based on legitimate interest or direct marketing.
• Right to withdraw consent — at any time, where processing is based on consent.
• Right to lodge a complaint — with a supervisory authority in your country of residence.

14.2 Legal Basis for Processing

We process your personal data under the following legal bases:

• Consent — for marketing, recordings, and optional features.
• Contractual necessity — to deliver coaching services you've purchased.
• Legal obligation — for tax records, financial recordkeeping, and lawful requests.
• Legitimate interest — for analytics, fraud prevention, and improving services.

14.3 How to Exercise GDPR Rights

Submit a request by email to [email protected] with the subject "GDPR Request." We will respond within 30 days.

Children's Privacy (COPPA)

Our services are intended for adults aged 18 and older. We do not knowingly collect personal information from children under 13, in compliance with the Children's Online Privacy Protection Act (COPPA).

If you are a parent or guardian and believe your child under 13 has provided us with personal information, please contact us at [email protected] and we will promptly delete that information.

For coaching of clients aged 13-17 (with parental consent and involvement), we treat their data with the same protections described in this Policy and limit collection to what's necessary for the coaching engagement.

International Data Transfers

Shaun Surgener Coaching operates from the United States. If you are accessing our services from outside the United States, your personal information will be transferred to, stored in, and processed in the United States.

The United States may not provide the same level of data protection as your country of residence. By using our services, you consent to the transfer of your data to the United States and acknowledge this difference in legal protection.

For EEA, UK, and Swiss residents: where required by GDPR, we rely on appropriate safeguards (such as Standard Contractual Clauses) for international data transfers through our third-party providers.

Do Not Track Signals

Some web browsers offer a "Do Not Track" (DNT) signal that tells websites you don't want to be tracked. There is currently no industry standard for how to respond to DNT signals.

Our website does not currently respond to DNT signals. However, you can manage tracking through the cookie controls described in Section 4.2, and you can opt out of marketing communications as described in Section 6.3.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, our technology, legal requirements, or other factors. When we do:

• We will update the "Effective Date" at the top of this Policy.
• For material changes (changes that significantly affect how we handle your data), we will notify active clients and email subscribers by email at least 30 days before the change takes effect.
• For non-material changes (clarifications, formatting, additions of new service providers), we will simply post the updated Policy.

We encourage you to review this Policy periodically. Your continued use of our services after a change takes effect constitutes acceptance of the updated Policy.

How to Contact Us

If you have questions about this Privacy Policy, want to exercise any of your rights, or have concerns about how your data is handled, contact us:

• Email: [email protected]
• Phone: 740-258-0377
• Mailing address: Available upon written request via email

For specific request types, please use these subject lines:

• "Privacy Request" — for general privacy questions or requests.
• "California Privacy Request" — for CCPA/CPRA requests.
• "GDPR Request" — for European privacy requests.
• "Opt Out" — to be removed from all marketing.

We respond to all privacy-related inquiries within 30 days (45 days for California requests; sooner where required by law).