Privacy

CoachSource Data Security/Privacy Policy

Last updated on April 25, 2019
 
CoachSource believes in the importance of thoughtfully handling personal information and is committed to privacy practices that are transparent and compliant. This Privacy Policy sets out how CoachSource uses the personal information we collect and receive about you.

Types of Personal Information

CoachSource collects personal information in support of its mission to provide executive coaching and coaching project management. This personal information is collected through a variety of ways. For example, we collect personal information during the professional engagements between our coaches and clients or through the registration and use of our internal software and cloud-based service. We also collect personal information when you use or visit CoachSource websites, attend a CoachSource hosted or sponsored event, or participate in a CoachSource community. We may receive your personal information if you are a CoachSource supplier or partner. We may also receive your information from third party partners. If you have other agreements with CoachSource, then those agreements control with regard to the subject matter they cover.

The type of information we collect will depend on your interactions with CoachSource. It may include:

Contact and Log-In Information. Name, employer, title, email address, physical address, phone number, and similar contact info, and user names and passwords for CoachSource systems.

Payment Information. Credit card number, banking information and billing address.

Demographic Information. Employment status, occupation, region. CoachSource may collect other demographic information, such as gender, race and age.

Registration Information. Product registration information, product interest information, and transaction information. We may also collect registration information related to your attendance at CoachSource events, including travel information, scheduling information, food preferences or allergies, accessibility requests and others.

Usage and Geographic Data. CoachSource collects personal information related to your use of our products, services and websites so that we can analyze and improve. CoachSource may use aggregated, non-personally identifiable usage data for external training and marketing purposes. In some instances, CoachSource may provide administrative functionality that allows you to opt out of the collection of some usage data.

Usage data may include information about your computer's or mobile device's operating system and browser type, device type, details about how you are using our products (but not including the underlying data), view your Internet Protocol (IP) address, geographic areas derived from your IP address, networking connection data, CoachSource cookie information, file information, metadata, time stamped logs regarding access times and duration of visits, and other usage data relating to your activities on our Sites, including the pages you request. We may link this information to the personal information you provide for purposes described in this Privacy Policy and may provide targeted product information back to users based on their user data.

Third Party Data. We may receive your personal information from third party suppliers or partners. If you connect with CoachSource accounts on third party social networking sites, we may receive information about your social networking accounts, for example, your name, user name or display name, public profile, and email address. We may combine information you provide with data we collect automatically and with data we receive from third parties. Certain third parties, including analytics companies, advertisers and ad networks, may automatically collect information about you through our websites using cookies, Web beacons, and device identifiers, including personal information about your online activities over time and across different websites, devices, online channels and applications.

If you decline to provide your personal information or ask us to delete it, we may be unable to continue to provide or support our products or services.

Ways We Use Personal Information

We use the personal information we collect for the purposes described in this Privacy Policy, as covered in any agreement that incorporates this Policy, or as disclosed to you in connection with our websites. For example, we will use your information to:

  • Provide and deliver our products or services;
  • Operate and improve our operations, systems, products, and services;
  • Understand you and your preferences to enhance your experience;
  • Respond to your comments and questions and provide customer service;
  • Send you service-related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
  • Link or combine information about you with other personal information we get from third parties, to help understand your needs and provide you with better and more personalized service;
  • Enforce our terms and conditions or protect our business, partners, or users; or
  • Protect against, investigate, and deter fraudulent, unauthorized, or illegal activity

Reasons for Using Your Information

When we process your personal information, we will only do so where at least one of the following applies:

  • We need to use your personal information to perform our responsibilities under our contract with you and to provide you with tools and services;
  • We have a legitimate reason to use your personal information. For example, it is in our legitimate interests to use your personal information to improve our products and services; to tell you about changes to this Privacy Policy and other policies; to tell you about new products, services and events or changes to our products, services or websites; for business reasons (for example to develop and expand our business); and to tell you about offers or promotions we are running;
  • You have given consent to use your personal information. You may withdraw consent by "opting out" where we give you the opportunity to do so, or by contacting us using the contact details below.
  • If it is necessary for us to use your personal information in order to comply with a legal obligation; or
  • You have chosen to make the information public. You should not share any personal information which you wish to keep confidential or private.

Sharing of Personal Information

CoachSource works to keep your personal information confidential and secure and does not sell your personal data. In some circumstances CoachSource may share your information with third parties, for example:

  • We provide personal information to trusted partners who work on behalf of or with CoachSource to provide us with services, for example, our training and certification partners, and our data storage and marketing vendors and software providers. These companies may use your personal information to perform services and to help CoachSource communicate with you about offers from CoachSource and our marketing partners. CoachSource maintains contracts with these companies restricting their access, use and disclosure of personal information in compliance with this Privacy Policy and any legal obligations;
  • We will disclose your personal information to comply with legal requirements, for example, in response to a court order or a subpoena. We also may disclose your personal information in response to a law enforcement agency's request, or where we believe it is necessary to investigate, verify, prevent, enforce compliance with, or take action regarding illegal or suspected illegal activities; suspected fraud; situations involving potential threats to the physical safety of any person; protection of the rights and property of CoachSource, our agents, customers, or others; violations or suspected violations of our agreements and policies; or as otherwise required or permitted by law or consistent with legal requirements.

Storage and Security of Your Personal Information

We have reasonable and appropriate physical, electronic, and managerial procedures in place to help safeguard your personal information. However, you should know that no company, including CoachSource, can fully eliminate security risks associated with personal information. To help protect yourself, use a strong password, do not use the same passwords to access your CoachSource accounts that you use with other accounts or services, and protect your user names and passwords to help prevent others from accessing your accounts and services.

Information collected by CoachSource or on our behalf may be stored on your computers, on your mobile devices, or on our servers, and may be transferred to, accessed from, or stored and processed in, the United States and our EU service provider facilities or support centers (a list of CoachSource offices can be found on our contact page). We will protect all personal information we obtain in accordance with this Privacy Policy and take reasonable steps to ensure that it is treated lawfully.

In certain circumstances we may retain your personal information after you have closed your account or are no longer actively engaged with CoachSource. For example:

  • We may retain your personal information after you have closed your account so that we can send you information about products, services and future engagements we think you may be interested in. You can "unsubscribe" to receiving such messages or tell us you are no longer interested;
  • We may retain your personal information in order to protect our legal rights, or those of third parties, or to comply with the law; and
  • If you purchase products or services from us, we may retain your personal information for as long as we need to in order to provide you with customer service, or for compliance purposes, for example, in order to comply with our record keeping requirements.

Controlling Your Personal Information

Our marketing emails permit you to "opt-out" of receiving further marketing emails. You may contact us at optout@coachsource.com at any time to let us know that you no longer wish to receive further marketing emails. If you opt-out, we may still send you transactional emails. Transactional emails include emails about your accounts and our business dealings with you, such as renewals and updates, and, as allowed by applicable law, requests for your participation in surveys.

When you use our websites, you can usually choose to set your browser to remove cookies and to reject cookies from our servers. If you choose to remove or reject cookies, this could affect certain features or services of our websites. For information about how to remove or manage cookies please read our cookie policy.

You may have the right, depending on which country you reside in, to ask us to provide a copy of the personal information we hold about you (provided that we may ask you for proof of your identity). You may also have the right to ask us to correct any inaccuracies in your personal information or to ask us to delete it. We will consider these requests regardless of where you live.

In addition, if you are based in the EU and accessing our Sites, then you also have the right to ask us to:

  • Confirm whether or not personal information about you is being processed;
  • Provide you with details about how we process your personal information;
  • Consider your valid objection to the processing of your personal information (including the right to object to processing on grounds relating to your particular situation where we are relying on our legitimate interests as a legal basis for processing your personal information);
  • Update or delete personal information which we hold about you;
  • Restrict the way we process your personal information;
  • Consider your valid request to transfer your personal information to a third party provider of services (data portability); and
  • Ask us to treat your consent as withdrawn if you have previously provided us with consent to process your personal information and we rely on it as our legal basis for processing.

If you need help or wish to exercise any of the above rights or have questions about them, please contact us at privacy@coachsource.com. We will consider all such requests and provide our response as soon as we can. Please note, however, that personal information may be exempt from such requests in certain circumstances, which may include circumstances where we need to keep processing your personal information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity.

Cookies and Web Beacons

Our websites may use various software technologies including “cookies,” “web beacons” and “pixel tags.” “Cookies” are small text files that we and others may place in visitors' computer browsers to store their preferences. "Web beacons" or “Pixel tags” are small pieces of code placed on a web page or within the body of an email to monitor the behavior and collect data about the visitors viewing a web page or viewing or opening an email. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

How to Contact Us

If you have any questions about how we use your personal information, or if you have any other privacy-related questions, please contact us at privacy@coachsource.com or at CoachSource, LLC., Attn: CoachSource Legal, 673 Dakota Trail, Franklin Lakes, NJ 07417, USA.

International Transfers

CoachSource is a US company and stores your information within its fully hosted data centers in the United States or, in limited cases, in the Netherlands. CoachSource may transfer your personal information to a country other than the country in which you live. Whenever CoachSource transfers personal information originating from the EEA or Switzerland to another country not deemed adequate under applicable data protection law, it will do so on the basis of the Privacy Shield Frameworks or EU Standard Contractual Clauses.
 
To comply with European Union and Swiss data protection laws, CoachSource wholly hosts its services and data within Liquid Web, who is self-certified under the EU-US Privacy Shield and the Swiss-US Privacy Shield, as administered by the U.S. Department of Commerce. Under the terms of Liquid Web’s Privacy Shield, and by extension of its Data Processing Addendum with CoachSource our data and services fall under their protection and adhere to the data protection requirements as defined by the Privacy Shield Framework.
 
These frameworks were created to enable companies to comply with data protection requirements when transferring personal information from the EEA and Switzerland to the United States. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Frameworks, the Privacy Shield Frameworks shall govern.
 
Covered European residents should direct any questions, concerns or complaints regarding CoachSource’s compliance with the Privacy Shield to CoachSource as described in the “How to Contact Us” statement of this Privacy Policy. CoachSource will attempt to answer your questions and satisfy your concerns in a timely and complete manner as soon as possible. 

Updates

From time to time, we will update this Privacy Policy. In the event there are material changes to our information practices, we will note those changes on this web page, and in some cases send a notification of changes via email.

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