Privacy Policy

What we collect, what we do not sell, and how we handle account data.

01

What we collect

We collect four buckets of data:

  • Account info you give us. Name, email, password hash, billing address (collected by our payment providers; we never see full card numbers), and any profile information you add.
  • Service material you submit. Coaching applications, contact forms, messages, photos, profile drafts, support uploads, and other material you send so we can review it or provide a done-for-you service.
  • Usage signals. Pages you visit, articles you read, time-on-page, session metadata, IP address, browser user agent, and first-party browser or advertising identifiers when available. We use this to understand product health, improve the experience, and measure whether our own advertising works; we never sell it or route it to data brokers.
  • Information from other sources. We may supplement what you give us with information from data providers (for example, to verify contact details and better understand who we are serving) so we can respond to inquiries appropriately. We use it only to run and prioritize our own services, never for any eligibility decision.
02

How we use it

We use your data for five purposes:

  • Run the product (sign-in, billing, generation, support).
  • Process payment for what you bought through our payment providers.
  • Send you transactional email: receipts, password resets, coaching reminders. Not marketing blasts unless you opt in.
  • Improve the product. We look at aggregate usage to figure out which features are working and which to fix.
  • Measure whether our own advertising leads to visits, applications, and bookings. For payments, we measure each eligible successful one-time charge, plus only the initial successful subscription charge.
03

What we don't do

  • We don't sell your personal data or route it through data brokers.
  • We don't share your coaching applications, support uploads, or service materials with anyone outside our processors.
  • We don't train any public model on your private data.
  • We don't run third-party ad networks on the site. The only advertising technology we use is conversion measurement for our own campaigns. Contact identifiers are normalized and hashed before they leave our systems. Available IP address, browser user agent, and advertising click or browser cookie values are sent in raw form for attribution and matching.
  • We don't sell or rent your email.
04

Done-for-you services

AI Photos and Online Dating Concierge are done-for-you services. Photos, profiles, screenshots, or messages you submit are reviewed by our team for the service you requested. We do not use your private material to train public models, and we do not share it with other users.

05

Service providers

We share personal data only with the vetted service providers that run parts of the product on our behalf, each bound by its own data protection terms and used only for the purpose listed:

  • Payment providers for billing, charges, and refunds. Payment details go directly to the applicable provider; we never see or store full card numbers.
  • Database and application hosting providers that store and serve the product.
  • A product analytics provider, so we can see which pages and features are used.
  • A video delivery provider for course videos.
  • An email delivery provider for the messages we send you.
  • A scheduling provider for application-call booking.
  • A community platform for member community access.
  • Data verification providers that help us confirm and supplement contact information you give us.
  • An advertising analytics service, so we can measure whether our own ads lead to visits, applications, and bookings. For payments, we measure each eligible successful one-time charge, plus only the initial successful subscription charge. Contact identifiers are hashed; available IP address, browser user agent, and advertising click or browser cookie values are shared in raw form for attribution and matching.
  • AI service providers for support-ticket triage and content assistance. Private client material is never sold or used to train public models.

A current list of the specific providers is available on request at hello@coldapproach.io.

06

Data retention

We hold your account data for as long as your account is active. If you cancel and delete your account, we delete personal data within 30 days, except for billing and tax records we're legally required to retain.

Raw IP address, browser user agent, and advertising click or browser cookie values remain in our delivery queue only for server conversion delivery. We scrub them when delivery succeeds or retries end. If a record is still queued, a per-minute database cleanup terminalizes it and scrubs those values at or immediately after the 48-hour delivery deadline. Hashed contact identifiers and sanitized delivery records may be retained as needed for browser/server event matching, delivery audits, and campaign measurement.

07

Your rights

You can request a copy of your data, delete your account, or correct anything we have on file by emailing hello@coldapproach.io. We respond within 30 days. Where local law (GDPR, UK GDPR, CCPA, etc.) gives you specific rights, those rights apply on top of this policy regardless of what we say here.

08

Security

Passwords are stored as bcrypt hashes rather than plaintext. Communications use HTTPS. Database access is restricted to service-role keys held in our deploy infrastructure, and every database query is scoped with row-level security so users can only access their own records. No system is risk-free, but these controls are designed to keep account access scoped and auditable.

09

Children

Cold Approach is for adults. We do not knowingly collect data from anyone under 18. If you believe a minor has signed up, email us and we'll delete the account.

10

Cookies and analytics

Our product analytics store the same random visitor identifier in a first-party cookie and in your browser’s localStorage. You can clear either or both from your browser’s site-data settings. When we run ads for our own programs, an advertising analytics service may also set first-party cookies and receive server conversion events. You can block or clear advertising cookies without affecting core site functions, although server-side conversion reporting may still occur after an eligible action. The full picture lives in our Cookie Policy.

11

GDPR and CCPA rights

If you are a resident of the EU, UK, California, or another jurisdiction with data privacy laws, you have specific rights regarding your personal data. You can request access to your data, correction of inaccuracies, deletion, portability, or restriction of processing. To exercise these rights, email hello@coldapproach.io with your full request. We respond within 30 days.

12

International data transfers

Your data may be transferred to, stored in, and processed in the United States and other countries. By using Cold Approach, you consent to such transfers. We implement appropriate safeguards, including standard contractual clauses where applicable, to protect your data.

13

Payments and chargebacks

Payment processing is handled by our payment providers. All billing disputes, payment errors, and refund requests must be directed to hello@coldapproach.io before initiating any action with your payment account provider or bank. Chargebacks or payment disputes initiated without contacting us first may result in account suspension and recovery action. See the Terms of Service and Refund Policy for complete details.

14

Contact

For privacy questions, deletion requests, or to exercise any right under GDPR / CCPA / similar, email hello@coldapproach.io.

Need data removed?

Email hello@coldapproach.io from your account address. Account and personal data are deleted within 30 days; billing records are retained only as long as required by law.

Request deletion