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Privacy Policy

Last Updated: October 21, 2025

At Osmo, we value your privacy and are committed to protecting your personal information.

This Privacy Policy (this "Privacy Policy") describes the practices of Thrivium Inc. doing business as "Osmo" ("Osmo," "we," "our," and "us") with respect to the personal information we collect from or about you when you use our website, www.osmo.coach, platform, proprietary web-based system, app.osmo.coach, and related technology and tools (collectively, the "Platform") and services we offer through our Platform (collectively, the "Services"), as a coach, client, or website visitor. Our goal is to be clear, respectful, and transparent in how we handle your information. This commitment to privacy is a core value of our organization and guides all our data processing activities.

This Privacy Policy is part of our Terms of Use available here.

1. Overview

Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information and how we will treat it before you start to use the Platform or access the Services. By accessing or using the Services or the Platform, you accept and agree to be bound and abide by this Privacy Policy. If you do not agree with our policies and practices outlined in this Privacy Policy, you may not access or use the Services or the Platform.

We reserve the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the bottom of this Privacy Policy. Your continued use of the Platform and Services following posting of changes constitutes your acceptance of such changes.

2. Information We Collect and How We Collect It

We collect information to provide and improve our Services and the Platform, ensure security, meet contractual obligations, and enhance user experience. This information may be collected from you when you provide it to Osmo, the Platform, or the Services, automatically when you use the Services or the Platform (including, without limitation, your consent to participation in coaching session recordings and AI-generated notes and summaries), and/or from third parties used to provide you with the Services and Platform.

The information we may collect includes:

a. Account Information

b. Coaching and Platform Use Data

c. Payment and Billing

d. Technical Information

e. Marketing and Communication Preferences

f. Optional AI and Analytics Data

Osmo may use AI tools to assist with note-taking, trend identification, and insights. All such data is de-identified before use in AI models and is never sold or shared for advertising purposes.

In some countries, including countries in the European Economic Area (the "EEA"), the information referenced above in this Privacy Policy may be considered personal information under applicable data protection laws. If you do not want us to collect this information, do not use the Platform or the Services.

A Note about User Contributions:

You may provide information (including User Data, as defined in our Terms of Use) to be published or displayed (hereinafter, "posted") on public areas of the Platform, or transmitted to us, other users of the Platform (including your coach or client), or third parties (collectively, "User Contributions"). Your User Contributions are only posted within your or your coach or client's associated Platform account, so they can only be viewed by users who have been given access, but they are still posted and transmitted to others at your own risk. We cannot control the actions of other users of the Platform with whom you may choose to share your User Contributions. We cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

We reserve the right, at Osmo's sole discretion, to remove, either temporarily or permanently, any User Contribution for any reason whatsoever. However, our right to remove any User Contribution does not obligate Osmo to police, review, or verify User Contributions in any way. You understand and acknowledge that you are responsible for any User Contributions posted, and you, not Osmo, have full responsibility for such content, including its legality, reliability, accuracy, and appropriateness. Osmo is not liable for any User Contributions.

3. How We Use Your Information

We use your data to:

Aggregated or De-Identified Information:

We may aggregate or de-identify personal information so that it can no longer be used to identify you. We may use this aggregated information to improve our AI systems or services, conduct market research about coaching relationship, and for other legitimate business purposes. We may also share aggregated information with partners and advertisers.

All the data we collect on the Platform is necessary for Osmo to deliver the Platform and the Services to you and other users. The amount of data we collect has been minimized wherever possible to respect your privacy.

You can withdraw your consent at any time by discontinuing use of the Platform or Services, or contacting us at support@thrivium.com to delete your account and information.

4. Legal Basis for Processing

We process personal data only where we have a legal basis to do so, including:

If we rely on consent and your country requires parental approval, we may ask for a parent's consent before collecting or using your information.

5. How We Share Information; Disclosure of Personal Information

We do not sell personal data. We may share limited information only in the following cases:

a. Service Providers

With trusted partners that support hosting, payments, analytics, communications, and email marketing — bound by confidentiality agreements.

b. Legal and Safety Requirements

When necessary to comply with law, respond to legal requests, or protect our rights, safety, or users.

c. Business Transfers

In case of a merger, acquisition, or restructuring, your data may transfer to a successor entity under similar protections.

d. With Your Consent

When you choose to connect with third-party services or opt in to data-sharing features.

Without limiting the foregoing, we may disclose aggregated information about our users or based on the information provided to us through a user's use of the Platform and Services, and information that does not identify any individual, without restriction. Additionally, we may disclose personal information to the following third parties or in the following circumstances:

Affiliates: We may disclose personal information to our affiliated entities and subsidiaries for business operations and to deliver Services.

Vendors and Service Providers: We may disclose personal information to vendors and contractors who provide services on our behalf, including AI technology providers, data analytics companies, cloud hosting services, payment processors, customer support services, and marketing platforms. Our current vendors and services providers are found below, and you can view their privacy policies linked to better understand how these vendors and service providers may process and use your personal information.

You may access and provide information to our vendors and service providers or third-party integration and access to our services, including but not by way of limitation, LinkedIn, Google, iCalendar, Google Calendar, Outlook calendar. You are encouraged to consult with their privacy policies prior to linking or integrating these services into your use or access of the Services and the Platform.

Safety and Protection: We may disclose personal information to protect the rights, safety, or property of Osmo, our users, or others, including to defend against legal claims.

Legal Requirements: We may disclose personal information to comply with legal obligations, respond to lawful requests from government authorities, or as required by court orders or regulatory requirements.

Business Transfers: We may disclose personal information in connection with any merger, acquisition, or sale of our business or assets.

Consent: We may disclose personal information to third parties when you give us consent to do so.

6. Data Retention

We retain personal data when we have an ongoing legitimate business need to do so (for example, as outlined in Section 4) and only as long as necessary for the purposes described in this Policy, considering:

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. Children's Privacy

Our Service is not intended for children under 13 years of age. We do not knowingly collect personal information from children under age 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at our website at https://www.osmo.coach.

If you are based in the EEA, you may only use the Platform if you are over the age at which you can provide consent to data processing under the laws of your country or if verifiable parental consent for your use of the Platform has been provided to us.

8. Cookies and Tracking Technologies

Osmo, and our analytics providers, use cookies, pixel tags, and similar tracking technologies to:

These technologies help us understand user behavior, personalize AI funding recommendations, perform analytics, and improve the Services. You can manage or disable cookies in your browser settings. Some features may not function properly without them. By using the Services and Platform, you consent to our usage of cookies and third-party services outlined in this Privacy Policy on the Platform, and agree that Osmo may collect your usage data under a unique identifier, for purposes of tracking, analyzing, and improving our services. You may withdraw your consent at any time through the cookie manager available to you through the Platform.

The Platform uses third-party analysis and tracking services to track the performance of our Platform and Services, understand how you use the Platform and our Services, and offer you an improved and safer experience. By using these third-party services, Osmo is necessarily sharing your information with these third-party analysis and tracking service companies to receive their services.

Information on your usage of our Services may be collected and processed by Osmo or a third party engaged by Osmo using a unique identification number assigned to you. Such usage information will be deleted as soon as practicable after this information is no longer required for the purpose collected.

Cookies:

Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser's settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Platform and our Services may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You may withdraw your consent at any time through the cookie manager available to you through the Platform.

Amplitude:

The Platform may use Amplitude, a products and user analytics platform, to help us analyze how the Platform is being accessed and used and to capture user session data to understand how users are using the Platform and the Services. With Amplitude, Osmo may track feature usage analytics, run experiments, and measure user engagement and retention metrics. You can learn more about Amplitude cookies here and about how Amplitude protects your data here. To opt-out of Amplitude's analytics, you can adjust your browsers cookie setting or contact us to have Amplitude tracking disabled for your use.

Advertising Choices:

You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, and/or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites below:

In addition, some of the companies we work with may offer their own opt-out mechanisms. For example, to learn more about how Google uses data here (and to opt-out of ad personalization by Google, you can click here).

Many of the opt-out preferences described here must be set on each device and/or browser for which you want them to apply. Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive some cookies and interest-based ads from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Do Not Track:

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

9. Marketing and Communications

We send marketing communications only if you have opted in.

You can unsubscribe at any time by clicking the "unsubscribe" link in our emails or updating your preferences in your account settings.

We do not use your coaching session data or notes for marketing.

10. AI, Insights, and Data Ethics

AI-driven insights in Osmo are designed to support coaches and clients, not replace human interaction.

All AI-related data is de-identified, aggregated, and never used for advertising.

You can opt out of AI-related data use on the Osmo Platform.

We implement appropriate safeguards to protect your information during AI processing and ensure that AI-generated insights maintain user privacy and confidentiality and will never be shared with other customers, users, organization, or third parties without your consent.

Osmo currently utilizes MeetingBaas and ChatGPT. You can learn more about how MeetingBaas and ChatGPT process your personal information by accessing the following links to their respective privacy policies.

11. Your Rights Regarding Personal Information

You have options in relation to the information and data that we have about you. To exercise any of the options discussed below, please contact us in writing at the contact information provided below. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

EEA Users

As an EEA user of the Platform, you may exercise your user rights to:

  1. Request information on your personal data processed by Osmo. Upon your request, this information will be provided to you electronically. If you reside in the EU or Switzerland, you may access your information by sending a request to Osmo at the address specified in "Contact Us" section below. Such requests must be submitted in writing using the email address in the "Contact Us" section below.
  2. Gain access to your information by requesting a backup of your data in a format that is readable by other companies or organizations (data portability). We will make an effort to share this information with you within a reasonable time.
  3. Correct or delete your information in your profile settings available through the Platform.
  4. Withdraw your consent from data processing at any time by deleting your account. You may also contact us at the email address in the "Contact Us" section below. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  5. Request the complete deletion of your data, including all past data sent to third-party services used for tracking and analysis, by reaching out to the email address in the "Contact Us" section below. Your data will be deleted within 30 days. We will not delete any posts or comments you've written and shared publicly, including on social media.
  6. Log a complaint with the relevant supervising authority if you believe Osmo is processing your personal data under violation of applicable data protection regulations. For more information, please contact your local data protection authority.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To illustrate, California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

The exact scope of these rights may vary by state. For example, if you reside in California and have provided your personally identifiable information to us, you may request information once per calendar year about our disclosures of certain categories of your personally identifiable information to third parties for their direct marketing purposes.

Any such request pursuant to this section must be sent to the email address listed under the "Contact Us" section below with "Exercising My Data Rights" in the subject line. The request must include your name, street address, city, state, and ZIP code and an attestation that you are a resident of the applicable state. We are not responsible for requests that are not labeled or sent properly, or that do not have complete information.

12. Accessing and Correcting Your Information

You can review and change your personal information by logging into the Platform and visiting your account profile page. You may also send us an email at the contact information provided below to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you delete personal information that you have publicly posted or shared from the Platform, copies of such information may remain viewable in cached and archived pages, or might have been copied or stored by other Platform users.

13. Third-Party Links and Services

Our Services may contain links to third-party websites or services. When you click on a link to any other website, mobile application or online service, you will leave our Platform and go to another site, and another entity may collect personal information or anonymous data from you. In addition, our content may be included on other online services that are not associated with us. We have no control over, do not review, and are not responsible for, these third-party online services or for their content or actions. Other online services follow different rules regarding the collection, use and sharing of your personal information. This Privacy Policy does not apply to third-party services. We encourage you to read the privacy policies of other online services that you visit or use. The links to third party online services are for your convenience and do not signify our endorsement of, or affiliation with, any third party or its services.

14. International Data Transfers

Osmo is headquartered in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing, which may include such transfer and processing outside of your home country, including in the United States, and the collection, use, and disclosure set forth herein or in any applicable terms of service.

The privacy protections and the rights of authorities to access your information in other countries may not be the same as in your home country. We take additional measures when information is transferred from the EEA. This includes having standard clauses approved by the European Commission in our contracts with parties that receive information outside the EEA. We also rely on European Commission adequacy decisions about certain countries, as applicable, for data transfers to countries outside the EEA.

15. Security

We use a combination of administrative, technical, and physical safeguards to protect your information, including:

While no system can guarantee 100% security, we continuously improve our safeguards to protect user information, and use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition. Notwithstanding, we cannot guarantee the security of your personal information. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy setting or security measures contained on the Platform.

16. Health Information Disclaimer

Osmo is not a medical or health service provider and is not a Covered Entity under HIPAA.

Information shared through coaching or notes should not be considered medical data or protected health information.

17. Contact Us

If you have any questions, concerns, or requests related to the Terms of Use and Privacy Policy, please contact us by visiting our website at: https://www.osmo.coach or by emailing us at support@thrivium.com.