Privacy Policy for InterviewCoach.AI

Effective Date: September 16, 2025

1. SCOPE

This Privacy Policy explains how we collect, store, use, and share your personal data.

This Privacy Policy applies to XTrain AI Inc. DBA InterviewCoach.AI ("InterviewCoach.AI," "we," "our," "Company") as well as your use of our website, InterviewCoach.ai, and any other InterviewCoach.AI products and services (collectively, the "Services"). Our Services may link to or utilize features from other companies that operate independently from InterviewCoach.AI. This Privacy Policy does not apply to such companies and is subject to the disclosures of those companies.

When using InterviewCoach.AI within an organization, this document will be considered amended by that separate Subscription Agreement and/or Service Order (collectively referred to herein as a "Service Agreement").

2. INFORMATION WE COLLECT

When you use the Services, we collect certain information from you. This information can be broken down into four categories: (A) information you give us; (B) information we receive from other sources; (C) information we collect automatically; and (D) information we create or generate.

Information You Give Us

When you use our Services, you may provide us some or all of the following information:

• Registration information, such as your name, username, password, email, and phone number.
• Payment information, such as payment card numbers or other financial information used to make payments directly with us. This information may be provided through a third-party payment provider.
• Information in correspondence you send to us, our customer care team, or with other users.
• Information you share through surveys conducted by us or on behalf of us and InterviewCoach-sponsored events you participate in.
• If you choose to connect your calendar with our Services, we will collect information about meetings on your calendar, the contact information of attendees, the subject of the meeting, the duration, and any other information that may be included in the meeting invitation (“Meeting Information”).
• Information you choose to connect to your InterviewCoach account, such as your public profile information from other platforms like Google.

Information We Receive From Other Sources

We may receive your information from other sources, such as:

• Other Users. We may receive information about you from other users, such as an email address if another user includes you on a customer service inquiry.
• From accounts you may use to log in. If you choose to create your InterviewCoach account using credentials from another platform, such as Google or Microsoft, we collect your name, e-mail, and profile picture associated with that account.
• Third Parties. We may collect information about you from third-party services, such as advertising partners, data providers, and analytics providers.
• Public Sources. We may collect information about you from other publicly available sources.

Information We Collect Automatically

When you use our Services, we automatically collect information about which features you've used, how you've used them, and the devices you use to access the Services.

• Usage Information. We collect information regarding your use of the Services (e.g., date and time you log in, features you use, searches, clicks, advertising that you click on) and any content that you generate through it, such as audio or video recordings that you enable on our Services, or information that you upload to it.
• ****Device Information. We collect information from and about the device(s) you use to access our Services, including:
• ****Hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs, browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address).
• ****Information on your wireless and mobile network connection, like your service provider and signal strength.
• Interactions With Other Users. We collect and process information about how you interact with other users whenever you compose, send, or receive messages through the Services (e.g. time and date of your exchanges).
• Cookies. We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). Cookies are small data files stored on your hard drive or in device memory that help us improve the Services and your experience, see which areas and features of the Services are popular, and count visits. Please be aware that removing or rejecting cookies could affect the availability and functionality of the Services. Please see Section 9 for more information describing why we use it and how you can control their use. To learn how to disable Cookies, see the “Control Over Your Information” section below.

We may aggregate or de-identify the information described above. Aggregated or de-identified data is not subject to this Privacy Policy.

Information We Create or Generate

We infer or generate new information from other personal data we collect, including to provide you with the Services you request. For example, we analyze recordings that you enable through our Services in order to provide analytics on your visual, verbal, and vocal delivery.

When you are asked to provide personal data, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional.

You may decline to provide personal data, but certain features may not be available without it.

3. HOW WE USE YOUR INFORMATION

We generally use the information we collect for the following business purposes:

• Product and service delivery. To provide and deliver our services, including troubleshooting, improving, and personalizing those services.
• Business operations. To operate our business, such as billing, accounting, improving our internal operations, maintaining your account, engaging in collections, securing our systems, detecting fraudulent or illegal activity, engaging in analytics, and meeting our legal obligations.
• Personalization. To understand you and your preferences to customize and enhance your experience using our services.
• Product improvement, development, and research. To improve our services, develop new services or features, and conduct research.
• Customer support. To provide customer support and respond to your questions.
• Communications. To send you information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
• Marketing. To communicate with you about new services, offers, promotions, rewards, contests, upcoming events, and other information about our services and those of our selected partners (see the “Choice and Control” section of this statement for information about how to change your preferences for promotional). Note that customers who use InterviewCoach as part of an organization will have their preferences automatically set to be opted out of these communications.
• Advertising. To display advertising to you. Note that we will only display targeted advertisements to you based on activity in your account, when you are signed in, as permitted by your settings (see the “Cookies” section of this statement for information about personalized advertising and your advertising choices). Customers who use InterviewCoach as part of an organization will have their preferences automatically set to be opted out of advertising.
• Comply with legal obligations. To comply with legal obligations including to comply with valid legal process and applicable law, and to respond to requests from law enforcement or other governmental authorities, bodies, or agencies.

4. HOW WE SHARE YOUR INFORMATION

We do not sell your personal data to third parties but we may share certain information with service providers, our partners, and, in certain circumstances, with legal authorities. Read on to understand when and with whom we may share the information we collect.

Service Providers and Partners. We use vendors to help us operate and improve the Services. These vendors assist us with various tasks, including research, payment processing and transaction fulfillment, database maintenance, sending communications, technology services, advertising, analytics, measurement, data storage and hosting, disaster recovery, search engine optimization, marketing, and data processing. These vendors may include:

• Marketing and analytics vendors, who may receive the information you choose to provide, the information we obtain from other sources, and the information we collect automatically, but would not receive your payment information or have access to content you generate through or upload to the Services.
• Research providers, who may receive the information you choose to provide, the information we obtain from other sources, and the information we collect automatically but would not receive your payment information or have access to content you generate through or upload to the Services.
• Payment processors and transaction fulfillment providers, who may receive the information you choose to provide, the information we obtain from other sources, and the information we collect automatically but who will not have access to content you generate through or upload to the Services.
• Customer and technical support providers, who may receive the information you choose to provide, the information we obtain from other sources, and the information we collect automatically.

Within Our Corporate Group. We may share the information we collect within our corporate group, including a parent, subsidiary, or other affiliate of our corporate group. InterviewCoach employees are authorized to access personal data only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.

For Corporate Transactions. We may share the information we collect in connection with a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control.

For Legal Reasons. We may disclose any of the information we collect to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries, and to protect and defend the rights, interests, safety, and security of InterviewCoach, the Services, our affiliates, users, or the public. We may also share any of the information we collect to enforce any terms applicable to the Services, to exercise or defend any legal claims, comply with any applicable law, and to investigate, prevent, or take other action regarding illegal activity or other wrongdoing.

Security, safety, and protecting rights. We will disclose personal data if we believe it is necessary to:

• Protect our customers and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone;
• Operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks;
• Protect the rights or property of ourselves or others, including enforcing our agreements, terms, and policies.

With Your Consent. We may share your personal data for other purposes pursuant to your consent or at your direction.

If you access third-party services, such as Google, to login to the Services, these third-party services may be able to collect information about you, including information about your activity on the Services, and they may notify your connections on the third-party services about your use of the Services, in accordance with their privacy policies. If you choose to allow a third-party service to access your account, we will share certain information about you with the third party. Depending on the permissions you grant, the third party may be able to obtain your account information and other information you choose to provide. We are not responsible or liable for any third parties’ terms, policies, or actions.

Please be aware that any information you make public on our Services can be accessed by other users and that neither you nor we have any control over how others will use that information. We are not responsible for the information you choose to make public.

5. CONTROL OVER YOUR INFORMATION

We strive to provide you with choices regarding the information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.

Access and Correction. Our Services allow you to access and edit most of your basic account information directly. You can also contact us at support@InterviewCoach.ai to request a copy of your information or to update it. Because your privacy is important to us, we will ask you to verify your identity or provide additional information before we answer the above requests. We may also reject your request to access or update your personal data for a number of reasons, including, for example, if the request is unlawful.

Deletion. You may submit a request to delete the information we have collected about you by sending your request to us at support@InterviewCoach.ai. You may also terminate and/or delete your account at any time, for any reason, by emailing support@InterviewCoach.ai.

If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format.

If the processing of personal data is based on your consent, you can withdraw consent for future processing at any time; you can object to, or obtain a restriction of, the processing of personal data under certain circumstances.

You may elect to opt-out of our use of data to improve our conversational AI algorithms by changing the settings in your profile.

Advertising Preferences. If you would like to modify the information we and our advertising partners use to select personalized ads for you or to opt out of us and our partners using such information, you may do so by contacting us at support@InterviewCoach.ai. If you do not want us to share your personal data with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by contacting us at support@InterviewCoach.ai. You can also opt out of marketing or advertising emails by using the “unsubscribe” link or mechanism noted in marketing or advertising emails.

For EU, UK and Swiss residents only

You also have the right to lodge a complaint with your supervisory authority, but we encourage you to first contact us with any questions or concerns.

We rely on different legal bases for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.

Purpose	Legal Basis for Processing	Categories of Personal Data (by references to the categories in the section titled “Information we Collect”
To provide and deliver the Services; to process payments for Services; to engage in collections; to send you Service-related communications such as confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.	When we have a contract with you; Legitimate interest We have a legitimate interest in using your personal data to ensure we can perform basic business functions.	Registration information, payment information, social media information (when you link accounts), usage information (including audio or video you enable on our services or information you upload), device information; interactions with other users; cookies; information we generate or create
To operate our business, such as billing, accounting, improving our internal operations; to maintain your account	Legitimate interest We have a legitimate interest in using your personal data to ensure we can perform basic business functions.	Registration information, payment information, social media information (when you link accounts), usage information (including audio or video you enable on our services or information you upload), and device information.
To provide customer support and respond to your questions.	Legitimate interest. We have a legitimate interest in using your personal data to assist you with your inquiry, to ensure that we are responding to your request.	Registration information, payment information, social media information (when you link accounts), usage information (including audio or video you enable on our services or information you upload), device information; cookies; information we generate or create
To secure our systems; to detect and take action to prevent fraudulent or illegal activity	Legitimate Interest We have a legitimate interest in using your personal data to ensure we keep our platform safe, to secure our systems, and to ensure that we have the ability to detect and take action to prevent fraudulent or illegal activity.	Registration information, payment information, social media information (when you link accounts), usage information (including audio or video you enable on our services or information you upload), device information; interactions with other users; cookies; information we generate or create
Improve and develop our Services and conduct product development; engaging in analytics.	Legitimate interest We have a legitimate interest in using your personal data to improve our Services to continue to better the Services for our customers.	Registration information, social media information (when you link accounts), usage information (including audio or video you enable on our services or information you upload), device information; interactions with other users; cookies; information you share through surveys or InterviewCoach-sponsored events you participate in; information we generate or create
Send you marketing information about our events, offers, products, and services; to advertise to you	Legitimate interest or, where required, with your consent	Registration information, usage information (including audio or video you enable on our services or information you upload), device information; information you share through surveys or InterviewCoach-sponsored events you participate in; third parties; public sources; information we generate or create
To enforce our terms; to comply with legal obligations including to comply with valid legal process and applicable law, and to respond to requests from law enforcement or other governmental authorities, bodies, or agencies.	To comply with legal obligations; legitimate interest in cases where there may not be a strict legal obligation	Registration information, payment information, social media information (when you link accounts), usage information (including audio or video you enable on our services or information you upload), device information; interactions with other users; cookies; information you share through surveys or InterviewCoach-sponsored events you participate in; information we generate or create; any other information referenced in the “information we collect” section that may be relevant to comply with a legal obligation or to enforce our terms.
To engage in corporate transactions as such transactions may arise (e.g., merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.)	Legitimate interest If we were to engage in a corporate transaction that required the transfer or processing of your personal data, we would have a legitimate interest in doing so.	Registration information, payment information, social media information (when you link accounts), usage information (including audio or video you enable on our services or information you upload), device information; interactions with other users; cookies; information you share through surveys or InterviewCoach-sponsored events you participate in; information we generate or create; any other information referenced in the “information we collect” section that may be relevant to such corporate transaction.

6. SECURITY

We use commercially reasonable measures to help protect information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. However, please be aware that, despite our measures, no data security measures or method of transmission over the Internet or means of electronic or physical storage, is guaranteed to be absolutely secure. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

7. CHILDREN

Our Services are not intended for children under the age of 16. We do not knowingly collect information from children. If we learn that we have collected personal data on our Services from a child under age 16, we will delete that information promptly. If you believe that we might have any information from a child under 16, please contact us at support@InterviewCoach.ai.

8. HOW LONG WE RETAIN YOUR INFORMATION

Any personal data that is required for the purposes of enforcing and executing agreements with users (for example, subscription packages to access advanced features) will be held for the duration of the contractual relationship and may be held for (a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or (b) a shorter period where you object to the processing of your personal data and there is no longer a legitimate business purpose to retain it.

All other personal data will be retained for as long as necessary for record retention and legal compliance purposes.

9. COOKIES AND SIMILAR TECHNOLOGIES

We and our third party service providers use cookies and other similar technologies to track information about your use of our Services. We may combine this information with other personal data we collect from you (and our third party service providers may do so on our behalf). If you do not want to receive cookies, you can change your browser settings on your computer or other device you are using to access our Services. Please be aware that removing or rejecting cookies could affect the availability and functionality of the Services. Most browsers also provide functionality that lets you review and delete cookies, including cookies from us.

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others allow us to track your activities at our Services. There are two types of cookies: session and persistent cookies.

Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session. This allows us to process your online transactions and requests and verify your identity as you move through our Services.

Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, and to display advertising on third-party sites.

Clear GIFs, pixel tags and other similar technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Services to, among other things, track the activities of site visitors, help us manage content, and compile statistics about site usage. We also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

10. LOCATION OF PERSONAL DATA

The personal data we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers process data, some of which may have laws that offer different levels of data protection than the country in which you reside. The storage location(s) are chosen to operate efficiently and improve performance. We take steps to process and protect personal data as described in this statement wherever the data is located.

11. PRIVACY POLICY CHANGES

This Privacy Policy is effective as of the Effective Date provided above. We may update this Privacy Policy from time to time and include a “Last Updated” date at the top of this policy. When we update the Privacy Policy, we will post the new Privacy Policy, and provide any other notice required by applicable law. We recommend that you review the Privacy Policy each time you visit the Services to stay informed of our privacy practices. By continuing to use our Services you agree to the “Last Updated” version of this policy.

Location of Processing European Personal Data. We transfer personal data from the European Economic Area (EEA), United Kingdom (UK), and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal data protections, please visit https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en

12. CONTACTING US

You may contact us with questions, comments, or concerns about our services and this Privacy Policy or our privacy practices, or to request access to or correction of your information by submitting your requests or inquiries at support@interviewcoach.ai

13. ADDITIONAL PRIVACY DISCLOSURES

A. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you may have certain rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to:

• Request to know the categories and specific pieces of personal data we collect, use, disclose, or sell about you.
• Request deletion of your personal data.
• Correct inaccurate personal data.
• Opt-out of the sale or sharing of personal data (if applicable).
• Limit the use of sensitive personal information (if applicable).

To exercise your rights, please email us at support@interviewcoach.ai. We may verify your identity before fulfilling your request, which could involve requesting additional information.

InterviewCoach.AI does not sell personal data in the conventional sense, but we may share data for targeted advertising purposes in accordance with your preferences.

Information for Residents of California: Your California Privacy Rights

If you are a California resident, the California Consumer Privacy Act ("CCPA") may provide you with rights that are in addition to those set forth elsewhere in this Privacy Policy regarding our use of your personal information. The CCPA Notice applies to "Consumers" as defined by the law. This section describes your CCPA rights as a California Consumer and explains how to exercise those rights. See Sections1-4 above to learn what information we collect from you and how it is collected, used and shared.

Access to Information and Data Portability Rights

You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

• The categories of personal information we have collected about you.
• The categories of sources from which we collected your personal information.
• The business or commercial purposes for our collecting or selling your personal information.
• The categories of third parties to whom we have shared your personal information.
• The specific pieces of personal information we have collected about you.
• A list of the categories of personal information disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
• A list of the categories of personal information sold about you in the prior 12 months, or that no sale occurred. If we sold your personal information, we will explain:
  • The categories of your personal information we have sold.
  • The categories of third parties to which we sold personal information, by categories of personal information sold for each third party.

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information that we have collected in the period that is 12 months prior to the request date and are maintaining.

Data Deletion Rights

Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Note also that we are not required to delete your personal information that we did not collect directly from you.

Exercising Your Rights

To make a request for access, portability or deletion according to your rights under CCPA, mail your request for the attention of the Privacy / Legal Department to Xtrain AI Inc., (ADDRESS). California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. 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 that the personal information relates to you. Any request you submit to us is subject to an identification and residency verification process ("Verifiable Consumer Request").

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; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumer's personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.

We will make commercially reasonable efforts to identify Consumer personal information that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

Opt-Out

There is not yet a consensus as to whether third party cookies and tracking devices associated with our websites and mobile apps may constitute a "sale" of your PI as defined by the CCPA. To make a request to opt-out of sale under CCPA, please click here. See Section 9: Online Privacy Choices and Rights to learn how you can exercise your rights regarding interest-based advertising.

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale and retention and use of your personal information as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.

California's "Shine the Light" law, Civil Code § 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. As discussed above, if we share Personal Information with third parties for their marketing purposes you will be able to elect for us not to do so by submitting your request here (please include your name, mailing address, and email address).

To find out more about our "do not track" practices under Cal. Bus. & Prof. Code § 22575, see the "Do Not Track Disclosures" section of this Privacy Policy.

B. Sensitive Personal Information

We do not knowingly collect or process sensitive personal information unless you explicitly provide it and consent to its use for specific features within the Services. Sensitive personal information may include information such as biometric identifiers, racial or ethnic origin, health data, or other legally protected categories. If such information is collected or inferred, it will be used solely for the purposes described in this Privacy Policy and in accordance with applicable law.

C. Data Breach Notification

We maintain safeguards intended to protect your personal data. In the unlikely event of a data breach that affects your information and creates a risk of harm, we will notify you without undue delay, and in accordance with applicable law, of the nature of the breach and the steps we have taken or plan to take in response.

D. Automated Decision-Making and AI Inferences

Our Services use artificial intelligence to generate automated insights and feedback based on user inputs such as audio, video, or text responses during or before the practice interviews. These features are designed to assist you in improving communication skills and do not make decisions that have legal or similarly significant effects on you. You may choose to opt-out of having your data used to further train or enhance these AI models by updating your settings or contacting us directly.

E. Identity Verification for Rights Requests

To protect your privacy, we may require you to verify your identity when you submit certain requests related to your personal data (such as access, correction, or deletion). This process may include confirming your email address or providing additional identifying information, depending on the sensitivity of the request and the data involved.