COLLECTION OF INFORMATION
We collect information you provide directly to us when using the Services. For example, we collect information when you download our mobile application(s), register for our Services, sign up for an account, complete a quiz, questionnaire or other form, participate in any interactive features of the Services including any video or audio call features we provide, apply for a job or to become a coach, request customer support, or otherwise communicate with us. The types of information we may collect include your name, email address, mailing and billing address, user ID, work experience and education, and payment information, and any other information you choose to provide.
In addition to the information above, you may provide us additional information to help us identify the best coach for you or in conjunction with your coaching sessions. For example, you may provide information about your title, employment details, language, gender, marital status, nationality, or other information about you and your personal or professional experiences. We also collect information about your use of the Services such as how often you use the coaching services, development programs planned and attended, engagement status, and session ratings.
When you access or use the Services, we automatically collect information about you, including the following:
-Log Information: We log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to the Services.
-Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
-Information Collected by Cookies and Other Tracking Technologies: We use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies, and how to disable them,
please see “Your Choices” below.
-Information We Collect From Other Sources
We may also obtain information from other sources, such as list providers and publicly available sources, and combine that with information we collect through the Services. We also may receive information about you from the coaches with whom you interact through the Services.
USE OF INFORMATION
We may use the information we collect to provide, maintain, and improve the Services, including to assess and improve the quality of the coaching services. We may also use the information we collect to:
SHARING OF INFORMATION
When you use the Services, we may share information about you with our coaches so that they can provide services to you. With your consent we may also share information relating to your use of the Services with your employer or other entity who has sponsored your use of the Services, such as the program you selected and how you used the Services (such as the number of sessions you attended) but only when we have your consent to do so or as necessary to protect the rights, property, or safety of others. In all other cases your use of the platform will be fully anonymous.
TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES
We are based in Europe, the United States and Asia and the information we collect is governed by the respective laws. In Europe we are governed by the GDPR laws as from 2018. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the United States and other countries, where you might not have the same rights and protections as you do under local law.
In connection with the processing of all personal data we receive from the EU or Switzerland (“European Data”), we adhere to the EU-U.S. Privacy Shield Framework Principles and the Swiss-U.S. Privacy Shield Framework Principles issued by the U.S. Department of Commerce (collectively, the “Principles”). For more information about the Principles, please visit the Department of Commerce’s Privacy Shield Website.
The General Data Protection Regulation (GDPR) is a set of laws due to be enacted in the EU in 2018. Privacy Shield is an agreement between the EU and US allowing for the transfer of personal data from the EU to US.
The GDPR has specific requirements regarding the transfer of data out of the EU. One of these requirements is that the transfer must only happen to countries deemed as having adequate data protection laws.
In general the EU does not list the US as one of the countries that meets this requirement. Privacy Shield is designed to create an program whereby participating companies are deemed as having adequate protection, and therefore facilitate the transfer of information.
In short, Privacy Shield allows US companies, or EU companies working with US companies, to meet this requirement of the GDPR.
Please direct any inquiries or complaints regarding our compliance with the Principles to the point of contact listed in the “Contact Us” section below. If we do not resolve your complaint, you may submit your complaint free of charge to https://www.jamsadr.com/eu-us-privacy-shield , our designated Privacy Shield dispute resolution provider. Under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. If we share European Data with a third-party service provider that processes the data solely on our behalf, then we will be liable for that third party’s processing of European Data in violation of the Principles, unless we can prove that we are not responsible for the event giving rise to the damage.
We store the info we collected about you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
You may update, correct or delete information about you at any time by contacting us at firstname.lastname@example.org . Please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period.
You may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us email@example.com . If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
If you are a European Resident, when we process your personal data we will only do so in the following situations:
We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the services you have requested).
We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our Services, and to provide, secure, and improve our Services.
You have provided consent for us to process your personal data.
Data Subject Requests
If you are a European Resident, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can log into your account. Alternatively, you may contact us as indicated below.
If you are a European Resident and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection- authorities/index_en.htm .
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