Privacy policy

Effective Date: 04/23/2026
Last Updated: 04/23/2026

DD Doyle MD LLC (“Company,” “we,” “us,” or “our”) is a Texas-based leadership and
executive coaching practice serving organizations and professionals in the healthcare,
education, and information technology sectors. We are committed to protecting the privacy,
confidentiality, and security of personal and business information entrusted to us.

1. Introduction

This Privacy Policy explains how we collect, use, disclose, and safeguard information in
compliance with applicable U.S. and Texas laws and, where applicable, the Health Insurance
Portability and Accountability Act of 1996 (“HIPAA”).

2. Scope and Applicability

This Privacy Policy applies to:

• Visitors to our website
• Individual coaching clients
• Organizational clients and their employees
• Prospective clients and business partners

This Policy should be read in conjunction with the following, as applicable:

• Client Service Agreements
• Coaching Engagement Contracts
• The Company’s Operating Agreement
• Any applicable Business Associate Agreement (“BAA”)

In the event of a conflict, the controlling written contract will govern.

3. Information We Collect

3.1 Personal Information

• Name, email address, phone number
• Employer, title, and professional details
• Billing and payment information

3.2 Coaching and Professional Information

• Leadership assessments and results
• Coaching goals, progress notes, and feedback
• Organizational insights and performance-related data

3.3 Sensitive Information

We do not intentionally collect Protected Health Information (“PHI”) or student education
records protected by law unless expressly required under a written agreement and governed by
appropriate contractual safeguards, including a signed Business Associate Agreement where
applicable.

3.4 Automatically Collected Data

• IP address
• Device and browser type
• Website usage data collected through cookies or analytics tools

4. How We Use Information

We may use collected information to:

• Deliver coaching services and leadership development programs
• Customize and improve client outcomes
• Communicate regarding services, scheduling, and updates
• Process payments and maintain business records
• Fulfill contractual obligations
• Comply with legal and regulatory requirements

5. Confidentiality and Coaching Privacy

Consistent with professional coaching standards and Company agreements, coaching sessions
are treated as confidential. Individual-level disclosures are not shared with organizational
sponsors without consent, except where required by law, where there is a risk of harm or
illegal activity, or where the client has provided written authorization.

Organizational reporting is limited to one or more of the following, as agreed in writing:

• Aggregated data
• Pre-approved metrics
• Non-identifiable summaries

6. HIPAA Compliance

6.1 Role of the Company

The Company is not a Covered Entity under HIPAA. In certain engagements, however, we may act
as a Business Associate if we receive, use, maintain, or transmit Protected Health
Information on behalf of a Covered Entity or another Business Associate.

6.2 Protected Health Information (PHI)

We will only receive, use, or maintain PHI when a valid Business Associate Agreement has
been executed and the information is necessary to perform contracted services.

6.3 HIPAA Safeguards

When acting as a Business Associate, we will:

• Use PHI only for permitted contractual purposes
• Implement reasonable administrative, physical, and technical safeguards
• Limit access to PHI to authorized personnel only
• Report breaches or unauthorized disclosures as required by applicable law and contract
• Require subcontractors, if any, to agree to equivalent restrictions and safeguards

6.4 Client Responsibility

Clients should not disclose PHI unless a Business Associate Agreement is in place and such
disclosure is necessary, authorized, and consistent with applicable law.

7. Texas Privacy Law Compliance

We implement reasonable procedures designed to protect sensitive personal information from
unlawful use or disclosure in accordance with applicable Texas law.

In the event of a data breach involving sensitive personal information, we will provide
notice to affected Texas residents as required by applicable Texas breach notification laws
and without unreasonable delay, subject to lawful exceptions.

8. Information Sharing and Disclosure

We do not sell personal information. We may disclose information in the following
circumstances:

8.1 Service Providers

• Payment processors
• IT and cloud storage providers
• Scheduling and communication platforms

These providers are expected to maintain appropriate confidentiality and security measures.

8.2 Organizational Clients

Only as defined in written agreements, including:

• Progress summaries
• Aggregated insights
• Non-confidential deliverables

8.3 Legal Obligations

We may disclose information to comply with legal processes, enforce contractual rights, or
protect safety, rights, or property.

9. Data Security

We maintain reasonable administrative, technical, and physical safeguards, which may include:

• Secure digital storage systems
• Access controls and authentication protocols
• Encrypted communications where appropriate
• Periodic review of security practices

No method of transmission or storage is completely secure, and absolute security cannot be
guaranteed.

10. Data Retention

We retain personal and business information only as long as reasonably necessary to fulfill
coaching engagements, maintain business records, comply with contractual obligations, and
satisfy legal requirements.

Unless otherwise specified in a written agreement, coaching records may be retained for
approximately three to seven years.

11. Your Rights

Subject to applicable law, you may have the right to:

• Request access to your personal information
• Request corrections or updates
• Request deletion, subject to legal and contractual obligations
• Withdraw consent where applicable

To make a privacy-related request, contact us using the information listed below.

12. Cookies and Website Tracking

Our website may use cookies and similar technologies to improve functionality, analyze site
performance, and enhance user experience. You may disable cookies through your browser
settings, though some features of the site may not function properly as a result.

13. Intellectual Property & Data Use Alignment

In alignment with the Company’s Operating Agreement and client contracts, coaching
materials, frameworks, tools, and methodologies remain the intellectual property of the
Company unless otherwise agreed in writing.

Client-provided data remains client-owned. We may use de-identified and aggregated
information for internal research, service improvement, and thought leadership purposes,
provided that no identifiable client information is disclosed without appropriate
authorization.

14. Third-Party Services

Our website or services may include links to third-party platforms or tools. We are not
responsible for the privacy or security practices of those third parties.

15. Children’s Privacy

Our services are not directed to individuals under the age of 18, and we do not knowingly
collect personal information from minors.

16. Changes to This Policy

We may revise this Privacy Policy from time to time. Any updates will be posted on this page
with a revised “Last Updated” date.

17. Contact Information

DD Doyle MD LLC

[Registered Business Address]
[City], Texas [ZIP Code]

Email: [Insert Email]
Phone: [Insert Phone]

Legal Review Notes

This version is formatted for website use and internal legal review. Attorney review
should focus on:

• Whether your services trigger Business Associate status under HIPAA
• Whether any client-specific education or healthcare data provisions should be
  expanded
• Whether your service agreements, operating agreement, and website disclosures use
  matching definitions and remedies
• Whether any additional Texas, federal, or sector-specific notice language should be
  added