CONSUMER HEALTH DATA PRIVACY POLICY
Virago Coaching
Effective date: September 4, 2026
Last updated: September 4, 2026
ABOUT THIS POLICY
This policy applies only to consumer health data as that term is defined by Washington's My Health My Data Act, RCW 19.373. It is separate from any other privacy policy published by Virago Coaching and describes only what that Act requires.
The business responsible for the data described here is I Am Virago, LLC, doing business as Virago Coaching, 9732 Densmore Ave N, Seattle, WA 98103.
Virago Coaching is a small business as that term is defined in the Act.
Virago Coaching provides executive leadership coaching. It is not a health care provider, and coaching is not therapy, counseling, or medical treatment. Coaching conversations sometimes touch on stress, burnout, wellbeing, or mental health, and information of that kind may fall within the Act's definition of consumer health data. This policy explains how that information is handled.
1. CONSUMER HEALTH DATA COLLECTED, AND WHY
Categories of consumer health data collected:
- Information you share during coaching sessions or between sessions that relates to your physical or mental health status, including stress, burnout, energy, sleep, wellbeing, and any health condition, treatment, or care you choose to mention.
- Audio recordings of coaching sessions, and transcripts generated from them, where you have consented to recording.
- Session notes and summaries prepared by Coach, including notes generated with the assistance of AI tools.
- Information you enter into Virago AI.
- Information you provide in intake forms, pre-session and post-session forms, and messages sent through the client management platform.
Purposes for which this data is collected and how it is used:
- To deliver coaching services to you.
- To prepare for sessions and maintain continuity across an engagement, including reviewing themes from prior sessions.
- To create written records of sessions.
- To meet coaching supervision, professional development, and credentialing requirements under the ICF Code of Ethics. Personally identifying information is removed before session content is used for these purposes.
Virago Coaching does not use consumer health data for advertising, marketing, or profiling. The service providers described in section 4 are configured so that this information is not used to train AI models or for any purpose of their own.
2. SOURCES OF CONSUMER HEALTH DATA
- Directly from you: coaching sessions, intake and session forms, text messages, email, the client management platform, and Virago AI.
- Generated by Virago Coaching: session notes, summaries, and transcripts derived from your sessions.
Consumer health data is not purchased, and is not collected from data brokers, public records, or other outside sources.
3. CONSUMER HEALTH DATA THAT IS SHARED
Categories of consumer health data shared:
- Session audio and transcripts, shared with transcription and AI service providers, only where you have consented to recording and AI processing.
- Session content in written form, shared with the client management platform used to deliver coaching and store records.
- De-identified session content, shared with coaching supervisors and mentor coaches for professional development and credentialing. Names, employers, roles, and identifying personal details are removed or altered before sharing.
- Any data whose disclosure is required by law, subpoena, or court order, or where there is an imminent risk of serious harm, or where abuse or neglect of a child or vulnerable adult is reasonably suspected.
Virago Coaching does not sell consumer health data. It has never sold consumer health data, and it will not sell consumer health data.
Selling consumer health data would require your separate written authorization, signed in advance and valid for no more than one year. Virago Coaching does not seek that authorization and will not seek it.
4. THIRD PARTIES AND AFFILIATES
Categories of third parties with whom consumer health data is shared:
- Video conferencing service providers
- AI transcription and summarization service providers
- AI language model providers
- Client management and scheduling platform providers
- Coaching supervisors and mentor coaches, using de-identified content only
Specific affiliates with whom consumer health data is shared:
None. I Am Virago, LLC has no affiliates.
You may request the current list of named service providers at any time using the contact details in section 6.
5. YOUR RIGHTS
If you are a Washington consumer, you have the right to:
- Confirm whether Virago Coaching collects, shares, or sells your consumer health data, and to access that data, including a list of all third parties with whom it has been shared and contact information for each.
- Withdraw your consent to the collection and sharing of your consumer health data.
- Have your consumer health data deleted.
How to make a request
Send your request by email to janice@viragocoaching.com with the subject line "Consumer Health Data Request." Describe what you are asking for. You may be asked to confirm your identity before a request is processed.
Response times
Requests are answered within 45 days of receipt. If more time is needed, you will be notified within that 45-day period and given up to 45 additional days, along with the reason for the extension.
If a request is denied
You will be told why, and how to appeal. Appeals are answered within 45 days with a written explanation of the decision. If an appeal is denied, you may submit a complaint to the Washington State Attorney General at www.atg.wa.gov/file-complaint.
Deletion
When a deletion request is granted, your consumer health data is deleted from Virago Coaching's records and systems, and service providers holding that data on Virago Coaching's behalf are notified to delete it as well. Records that must be kept for legal, tax, or credentialing purposes, such as the signed coaching agreement, invoices, and a log of session dates, contain no consumer health data and are not affected.
6. CONTACT
I Am Virago, LLC, doing business as Virago Coaching
9732 Densmore Ave N
Seattle, WA 98103
7. CHANGES TO THIS POLICY
If this policy changes, the updated version will be posted here with a new "last updated" date. Consumer health data already collected will not be shared for a purpose not disclosed at the time of collection without your consent.