Orion Privacy Policy

Last Updated: January 2026 Owned and operated by Cognitive Edge LLC ("Cognitive Edge," "we," "our," or "us")

Cognitive Edge LLC operates the Orion coaching platform available at https://orion.executivesignal.ai. This Privacy Policy explains how we collect, use, share, and protect your information when you use Orion (the "Service"), our software platform for coaches and coachees.

By using the Service, you consent to this Privacy Policy.

For questions about this Privacy Policy or your personal data, contact us at: ernesto.humpierres@executivesignal.ai

Our Commitment

Orion does not sell your personal data under any circumstances. We do not share personal information with third parties for their own marketing or advertising purposes.

1. Information We Collect

We collect information in the following ways:

a. Information You Provide

Account Information: When you sign up, we collect your name, email, and password (hashed).
Profile Information: Optional details such as photo, title, or focus area.
User Content: Text, files, or notes you upload, enter, or generate in the platform (e.g., coaching goals, notes, AI-generated prompts).
Communications: Messages you send to our support team or feedback you provide.

b. Automatically Collected Information

When you use Orion, we automatically collect:

Usage Data (pages visited, session duration, app interactions).
Device Information (browser type, operating system, IP address).
Cookies or Local Storage to maintain login sessions and preferences.

c. Information from Integrations

If you connect third-party services (e.g., Google Docs or calendar integrations), we may receive limited data necessary to enable those features, following your authorization.

2. How We Use Your Information

We use your information to:

Provide and improve the Service.
Personalize your coaching experience.
Operate AI-powered features (e.g., contextual insights, prompt generation).
Communicate important updates and respond to support requests.
Ensure platform security and prevent abuse.
Comply with legal obligations.

We do not sell your personal information to third parties.

Aggregate and De-identified Data

We may aggregate and de-identify personal information for research, analytics, and product improvement purposes. Once data is de-identified, it is no longer considered personal information and may be used to:

Identify common coaching themes and challenges
Improve our AI coaching responses
Generate insights about coaching effectiveness
Publish research on coaching outcomes (without individual identification)

3. AI and Data Processing

Some Orion features use artificial intelligence services to process and generate content. When you use these features:

Transient processing (OpenAI): We send prompts and selected context (e.g., relevant document excerpts, goals, recent conversation) to OpenAI to generate a response. Our AI providers are contractually prohibited from using your data to train their models. Data is processed transiently and is not retained by AI providers beyond what is necessary to generate a response. In limited coach workflows, contextual fields may include identifiers like a coachee email if present in profile context.
Persistent memory (Mem0): If enabled for your workspace, we store snippets of chat content and related metadata with Mem0 to provide long‑term context across sessions. These memories are retained until removed as part of account/data deletion. Mem0 is also contractually prohibited from using your data to train models.
Derived data (embeddings): When you or your coach upload documents, we create vector embeddings from the text to power retrieval and search. These embeddings are stored in our database and do not include the full original text.

We do not use your data to train our own or any underlying AI models. We aim to minimize identifiable information in AI requests where feasible while still delivering the functionality you expect. Do not include highly sensitive personal or regulated data in prompts or documents unless you have appropriate consent and safeguards.

Memory and Personalization

Our AI remembers context from your previous conversations to provide more relevant and personalized coaching support. This memory is stored securely and accessible only to you and your assigned coach (where sharing is enabled).

4. Data Storage and Security

Your data is securely stored in managed cloud environments (Supabase on AWS infrastructure) with AES-256 encryption at rest and TLS 1.2+ encryption in transit.
Access is restricted using authentication and role-based permissions enforced at the database level.
We employ industry-standard measures to protect against unauthorized access, loss, or misuse.
However, no online system is 100% secure, and we cannot guarantee absolute protection.

Operational logging

We maintain application logs to keep the Service reliable and secure. These logs may include limited metadata such as user IDs, emails, timestamps, request identifiers, and error messages. Logs are used for debugging, fraud prevention, and abuse detection and are retained for a limited period.

5. Data Retention

We retain data only as long as necessary to provide the Service and comply with legal obligations. You may request deletion of your account and data at any time (see Section 10). Upon receiving a valid deletion request, we will remove your data within 30 days, except where retention is required by law or for legitimate business purposes (e.g., fraud prevention).

6. Sharing of Information

With Your Coach

Your assigned coach has access to:

Information you provide through the platform
AI coaching conversation transcripts (where you have enabled sharing)
Assessment results and progress data

This access enables your coach to provide personalized support during your sessions.

With Your Sponsoring Organization (If Applicable)

If your employer or another organization sponsors your access to Orion, they may receive:

Aggregate, de-identified data only — Such as overall program participation rates and coaching themes across their organization
Individual engagement metrics — Such as whether you have activated your account and number of sessions completed

Your sponsoring organization does not receive:

Individual coaching session content
AI conversation transcripts
Specific topics you discuss with your coach

With Service Providers (Subprocessors)

We share data with carefully selected service providers who help us operate our platform. All subprocessors:

Are evaluated for their security and privacy practices
Sign Data Processing Agreements with us
Are contractually prohibited from using your data for their own purposes

A current list is available at /security/subprocessors. We will provide 30 days advance notice before engaging new subprocessors. Current processors include:

Supabase (authentication, database, storage, email delivery)
OpenAI (LLM generation and embeddings)
Mem0 (long‑term memory for chat context, if enabled)
Render (application hosting)

As Required by Law

We may disclose your information if required by law, regulation, legal process, or governmental request.

We do not sell your personal information and we do not share your User Content with advertisers or unrelated third parties.

7. Cookies and Tracking Technologies

We use cookies and local storage to:

Keep you logged in and maintain session security.
Remember preferences.
Optionally measure basic product analytics (we may use privacy‑respecting tools such as Plausible or an equivalent). We do not use advertising pixels or cross‑site tracking.

You can control or delete cookies in your browser settings, though some features may stop working properly.

8. International Data Transfers

If you access Orion outside the United States, your data may be processed or stored in the U.S. or other locations where our service providers operate. We implement safeguards consistent with GDPR requirements for international transfers.

9. Children’s Privacy

Orion is intended for users aged 18 or older. We do not knowingly collect data from children under 13 (or under 16 in the EU). If we learn a child’s data has been collected, we will promptly delete it.

10. Your Rights

Depending on your location, you may have the right to:

Access the personal data we hold about you.
Request correction or deletion.
Request data portability.
Object to or restrict processing.
Withdraw consent at any time (where applicable).

To exercise these rights, contact us at ernesto.humpierres@executivesignal.ai. We will verify your identity before fulfilling any request.

11. CCPA Notice (California Residents)

Under the California Consumer Privacy Act (CCPA), you have the right to:

Know what personal data we collect and how we use it.
Request deletion of your data.
Opt out of the sale of personal data (we do not sell data).

To make a request, contact us at ernesto.humpierres@executivesignal.ai.

12. GDPR Notice (European Users)

If you are in the European Economic Area (EEA), Cognitive Edge LLC is the data controller for your information. We process data under the following legal bases:

Contractual necessity – to provide the Service.
Legitimate interests – to improve and secure Orion.
Consent – for optional features or marketing communications.

You may lodge a complaint with your local data protection authority if you believe we have not complied with GDPR.

13. Changes to This Policy

We may update this Privacy Policy periodically. We will post the updated version with a new “Last Updated” date. Continued use of Orion after changes means you accept the revised policy.

14. Contact Us

If you have questions or concerns about this Privacy Policy or your data, contact us at:

📧 ernesto.humpierres@executivesignal.ai 🏢 Cognitive Edge LLC Washington State, USA