Privacy Policy for Pinnacle Coaches & Clients
Pinnacle Enterprises, Inc.
Effective Date: September 12, 2026
Version 3.0
Introduction
Pinnacle Enterprises, Inc. (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and protect your information when you use our MyCoach247 mobile application (the “App”) or our website at pinnacleenterprises.org (the “Website”), including our online intake form. By using the App or the Website, you agree to the terms of this Privacy Policy.
Pinnacle operates in California and Arizona. Where the privacy laws of those states impose different obligations, Pinnacle applies the stricter applicable standard.
This policy is the public statement of practices set out in Pinnacle’s internal Privacy Policy (Version 3.0), the document clients and coaches acknowledge at intake. The two documents are maintained as a single version set and are reviewed and updated together.
1. Information We Collect Through the MyCoach247 App
Profile Information (Display Only):
Your name, contact details, and profile information are collected when Pinnacle enrolls you in services — through our intake form or by Pinnacle administrators — and are displayed in the App. The App cannot create or edit this information; profile and contact information is managed by Pinnacle administrators in our backend systems. Your email address and phone number are displayed by the App but never transmitted by it.
Messages, Care Notes, and Photos:
Messages and care notes you write, which are sent with your name so your care team knows who wrote them, and photos you choose to attach in chat. Profile pictures are display-only and are not uploaded by the App.
Medication and Health Information:
Where it is relevant to the services requested, Pinnacle may collect medication information and other health or disability information — through the intake form, from the client, or in the course of care coordination. Providing medication information is the client’s choice. Declining may limit Pinnacle’s ability to coordinate services or to respond to certain health or safety situations, but it does not affect a client’s eligibility for services or standing with Pinnacle, and no Pinnacle workforce member will discourage that choice.
Location Data (Visit Verification and Client Safety):
With your permission, the App collects precise location, including in the background, in two situations only: (1) for coaches, while clocked in to a scheduled in-home shift, to verify the visit occurred at the client’s home — location collection stops at clock-out; and (2) for clients, where location safety monitoring has been enabled, to support wellbeing checks and help coaches respond to individuals who may need assistance.
A client may have location services turned off, or turned back on, at any time and without giving a reason. The request may be made by emailing admin@pinnacleenterprises.org or by telling the assigned coach or supervisor, who will pass it to the Pinnacle Administrator the same day. Pinnacle will act on the request within five (5) business days and confirm it in writing. Turning location services off does not affect a client’s eligibility for services or standing with Pinnacle.
By design, the App has no in-app switch for location monitoring, and coaches and supervisors cannot change the setting — only the Pinnacle Administrator can. This prevents the setting from being changed by accident or by anyone other than the person authorized to act on the client’s request. Separately, and in addition to that right, location permission can be declined or revoked at the operating-system level in your own device settings at any time. The App remains functional with location disabled, though disabling it means Pinnacle will not be able to locate a client in an emergency, during a welfare concern, or when the client is out of contact.
Contacts:
The App can read your device’s contacts to help you call or message your care team. Contact information is used on your device only and is never transmitted to our servers.
Device and Technical Information:
Device identifiers needed to deliver push notifications, and standard server-log information such as device type and IP address, used to maintain security and keep the App working.
We do not collect your data for advertising, sell it, share it with data brokers, or use it to train AI systems. The App contains no ads and no analytics-based tracking.
2. Information We Collect Through the Website
Our public Website does not collect personal information, and does not use cookies or similar technologies beyond those strictly necessary for it to function.
When our online intake form is available, information you choose to submit through it — such as contact details for prospective clients, family members, or coaches, and health or disability information relevant to the services requested — is used solely to evaluate and process your inquiry or enrollment, and is protected under the same standards described in this policy. The intake form is the collection point for the profile and contact information later displayed in the App.
3. How We Use Your Information
We use the information we collect — including location data — for the following purposes:
To provide and improve the App’s functionality and coaching services.
To support safety monitoring features, including verifying client wellbeing, responding to concerns, or guiding coaches to individuals who may need assistance.
To verify that scheduled in-home visits occurred, and for the payroll and quality assurance purposes that follow from that verification.
To communicate with you about updates, features, or customer support.
To maintain the security of the App and our systems.
Pinnacle collects only the minimum information reasonably necessary to support safe, effective, and person-centered services.
4. Sharing Your Information
No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.
All stated categories in this privacy policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
We do not sell your personal information. We may share your data only with:
Service providers that assist us with App operations (see Section 11).
Legal authorities, or others, in the limited circumstances described in Section 5.
Location data is never shared with third parties except as required for the purposes listed above. It is never shared with family members, guardians, employers, or any other party outside Pinnacle, as described in Section 6.
5. Limits of Confidentiality
Pinnacle protects client information, but confidentiality is not absolute. Pinnacle may disclose client information without the client’s consent in the following circumstances:
When required by mandated reporting laws concerning suspected abuse, neglect, or financial exploitation of a dependent adult. Pinnacle workforce members are trained to report as required by applicable state law, and reporting is never delayed for internal review.
When there is an imminent risk of serious harm to the client or to another person.
In a medical emergency, to the extent necessary to obtain care.
When required by a court order, subpoena, or other legal process.
Coaches explain these limits to clients plainly and will not promise confidentiality they cannot provide. Where a coach must make a disclosure, the coach will tell the client what was disclosed and to whom, unless doing so would create a safety risk or is prohibited by law.
6. Family Members and Authorized Representatives
Pinnacle serves adults. An adult client’s information belongs to the client, and a family relationship alone does not create a right of access.
Pinnacle may share client information with a family member only when the family member is a conservator, guardian, or other legally authorized representative acting within the scope of that authority; when the client has given specific, documented consent identifying what may be shared and with whom; when disclosure is necessary to respond to an emergency threatening the client’s health or safety; or when disclosure is required by law. A client’s consent to share information with a family member may be narrowed or withdrawn by the client at any time.
Location information is treated differently. Pinnacle does not provide family members, guardians, employers, or any other party outside Pinnacle with access to the App, the Pinnacle portal, or a client’s location information, and offers no feature that would allow it. This applies regardless of a family member’s role or legal authority. A client’s location may be shared outside Pinnacle only in an emergency involving the client’s health or safety, or where required by law.
A conservator, guardian, or other legally authorized representative may ask Pinnacle to turn a client’s location services off or on, to the extent of their legal authority, and may exercise the other rights in Section 8 on the client’s behalf. Pinnacle will still explain the choice to the client directly and will document the client’s own view. Making that request does not give the representative access to the location information itself.
7. Data Security
We use appropriate physical, technical, and administrative measures to protect your information, including location data. These include encryption of data in transit and at rest, role-based access controls, user authentication, audit logging of record access, secure backup and disposal procedures, workforce access monitoring, and a documented incident and breach response plan. However, no method of transmission or electronic storage is 100% secure.
8. Your Rights
Clients, and authorized representatives acting within their authority, may:
Choose whether to provide medication information.
Have location services turned off, or turned back on, at any time and without giving a reason, as described in Section 1.
Request access to the medication, location, and service information Pinnacle maintains about them.
Request updates or corrections to their information.
Request deletion of their information, as described in Section 9.
Ask who has accessed their information, including who has viewed their location and when.
Revoke authorizations for disclosure, subject to applicable legal limitations.
Decide whether family members may receive information about them, and change that decision at any time. Location information is never shared with family members or other outside parties, as described in Section 6.
Receive information about their rights in a format they can understand.
Ask questions regarding Pinnacle’s privacy practices.
Raise a concern or complaint about privacy without any effect on their services.
A request may be made by emailing admin@pinnacleenterprises.org, by speaking with an assigned coach or supervisor who will document it the same day, or by writing to the Privacy Officer at the address below. Pinnacle will acknowledge a request in writing and respond within a reasonable period, and no later than thirty (30) days, unless a longer period is permitted by law. Requests to turn location services off or on are acted on sooner — within five (5) business days. A client who needs help making a request may ask their coach for assistance, and the coach will provide it without discouraging the request.
9. How Long We Keep Information, and How to Delete It
Client service records — including care notes, visit verification records, and audit logs — are retained for seven (7) years after services end, and are then securely destroyed. Location information is retained on the same schedule as all other client service records. Information that is not subject to that retention obligation is deleted when it is no longer needed.
You may request access to, correction of, or deletion of your information at any time by contacting us at admin@pinnacleenterprises.org. Records we are required to retain are kept for the retention period described above and then securely destroyed; anything outside that obligation is deleted on request. Accounts are created and closed by Pinnacle Enterprises; when an account is closed, associated data outside our retention obligations is deleted.
10. Regulatory Posture
Pinnacle’s information systems are built to standards consistent with the HIPAA Security Rule, including encryption, role-based access, audit logging, and a documented retention schedule.
Whether Pinnacle is a HIPAA covered entity or a business associate depends on the services it delivers and the payer relationships it holds, and is evaluated on an ongoing basis with counsel. Regardless of that determination, Pinnacle protects client health information to the standards described in this policy. Pinnacle also recognizes that state law, including the California Confidentiality of Medical Information Act, may impose obligations independent of HIPAA, and Pinnacle applies the stricter applicable standard.
11. Service Providers
We use a small number of infrastructure providers to operate the platform, under agreements — including Business Associate Agreements where applicable — that require them to protect your information to the same standard we do. They process data only on our behalf and may not use it for their own purposes. Our providers currently include: DigitalOcean (hosting and file storage), RespiteTrack (scheduling, timekeeping, and login credentials), Google Firebase (messaging and push notifications), and Dialpad (phone and video calls). This list may change as our providers change; the current list is available on request.
Where location information is held: client location information is stored only within Pinnacle’s hosted record system at DigitalOcean. Coach visit-verification location is stored in that system and in RespiteTrack, which Pinnacle uses for scheduling and timekeeping. Pinnacle does not use a separate location-tracking product, a separate location database, or any other third-party location service. Keeping location within the systems that already hold service records means one set of access controls and one audit log, rather than an additional system that would expand the ways client information could be exposed.
12. Children’s Privacy
Our services are provided to adults age 18 and over. We do not knowingly collect personal information from anyone under 18. If you believe a person under 18 has provided us personal information, contact us and we will delete it.
13. Third-Party Services
Our App and Website may contain links to third-party services. We are not responsible for the privacy practices of these services.
14. Changes to This Policy
We may update this Privacy Policy periodically, and we review it at least annually and whenever our services, systems, payer relationships, or applicable law change. Clients are notified of material changes and, where a change affects a client’s choices, are given the opportunity to revisit those choices. We encourage you to review this policy regularly.
Contact Us
If you have questions or concerns about this Privacy Policy, contact:
Privacy Officer & Security Officer
Kenneth Tallo, President
Pinnacle Enterprises, Inc.
Email: admin@pinnacleenterprises.org
Phone: (916) 712-6302