Information That CommonCoach Collects
We operate in accordance with applicable data protection legislation. We recognize the importance of protecting the privacy of Personal Information collected about our users. This Policy discloses what Personal Information we gather, how we use it, and how you can correct or change it. It is our intention to give you as much control over your Personal Information as possible to preserve your privacy, while still allowing us to utilize that Personal Information in the course of our business to provide you a valuable service.
Consent and Modification. By using the Service, you consent to the terms of this Policy and to our processing of Personal Information for the purposes set forth herein. If you do not agree to this Policy, please do not use the Site or Service. We reserve the right, at our discretion, to change this Policy at any time, which change will be effective ten (10) days following posting the revised Policy on the Site. Your continued use of the Service ten (10) days following such posting means you accept those changes.
Receipt and Collection of Information. We occasionally collect Personal Information from users. You may be entitled under data protection laws to access and review the Personal Information that we hold on you, if you provide the necessary consent and background information and pay any mandated fee. All such communications regarding access to your personal data should be addressed to: firstname.lastname@example.org. Such enquiries should clearly be marked as data protection queries and as being time sensitive.
In particular, we receive and/or collect Personal Information from you in the following ways: We may collect and process Personal Information when you register for or use the Services and/or use the Site, interact with the Site, or otherwise contact CommonCoach. We may collect and process certain Personal Information from users such as the user’s name, e-mail address, mailing address, telephone number, user name, and password. We may also collect and process Personal Information relating to your use of the Services and any details of any e-mail correspondence or any other social media interactions that you have with us. We will collect only as much Personal Information as we need for the purposes specified in this Policy, for purposes specified at the time of collection of the Personal Information, or for other purposes that you consent to in the future.
Demographic & Non-Identifying Information
We may collect and process demographic information from or about you from time to time through your use of the Services, such as information about your gender, ethnicity, religious preference, birthplace and citizenship status (“Demographic Information”). We may collect this information through various forms and in various ways when you use the Services. To the extent that CommonCoach combines any non-personally identifiable Demographic Information with your Personal Information that CommonCoach collects directly from users, CommonCoach will treat the combined data as Personal Information under this Policy.
Information CommonCoach Collects or Stores as You Access and Use the Site and Service
In addition to any Personal Information or other information that you choose to submit to CommonCoach via the Site, CommonCoach and CommonCoach’s third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever users visit or interact with the Site (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to users’s personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever users visit or interact with the Site. To the extent we associate Usage Information with your Personal Information that we collect directly from you on the Site, we will treat it as Personal Information.
This Usage Information may include:
· Your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and our computers identify your Device by its Device Identifier;
· Your Device functionality (including browser, operating system, hardware, mobile network information);
· the URL that referred you to the Site;
· the areas within the Site that you visit and your activities there, including remembering you and your preferences;
· Your Device location;
· Your Device characteristics; and
· certain other Device data, including the time of day, among other information.
We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on Your Device. The Tracking Technologies that may be used are the following (and subsequent technology and methods later developed which perform a similar function):
· Cookies. A cookie is a data file placed on a Device when it is used to visit the Site. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by Participant to Participant’s Device. HTML5 cookies can be programmed through HTML5 local storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies go to Adobe’s web site www.adobe.com. Please be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies on your Device, some parts of our Site may not function properly, and that when you revisit our Site your ability to limit cookies is subject to your browser settings and limitations.
· Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Site’s pages and messages. Web beacons may be invisible to users, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
· Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while a user is connected to the Site, and is deactivated or deleted thereafter.
· ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
We may use Tracking Technologies for a variety of purposes, including:
There may be other Tracking Technologies now and later devised and used by us in connection with the Site. Further, third parties may use Tracking Technologies with our Site. We do not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third party Tracking Technologies in connection with use of the Site and the Services and accept that our statements under this Policy do not apply to the Tracking Technologies or practices of such third parties. You should check the third party websites to confirm how your information is collected and used.
Information Third Parties Provide About Users
We may, from time to time, supplement the information we collect directly from users with outside records from third parties for various purposes, including to enhance our ability to serve users, to tailor our content to users and to offer users opportunities that may be of interest to them. To the extent we combine any non-personally identifiable information we receive from those sources with user’s Personal Information we collect on the Site, it will be treated as Personal Information and we will apply this Policy to such combined information, unless we have disclosed otherwise.
Interactions with Third-Party Sites
The Site may include functionality that allows certain kinds of interactions between the Site and user’s account on a third-party web site or application. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, when a user registers with the Site, user may have an option to use user’s Facebook, Google or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process on the Site, or otherwise link accounts. If we offer and a user chooses to use this functionality to access our Site, the third-party site or application may send Personal Information about user to the Site. If so, we will then treat it as Personal Information under this Policy, since we are collecting it as a result of a user’s accessing of and interaction on our Site. In addition, we may provide third-party sites’ interfaces or links on the Site to facilitate user’s sending a communication from the Site. For example, we may use third parties to facilitate emails, text messages, blog postings, tweets or Facebook postings. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to this Policy. We may not control or have access to a user’s communications through these third parties. Further, when a user uses third-party sites or services, user is using their services and not our services and they, not us, are responsible for their practices. Users should review the applicable third-party privacy policies before using such third-party tools on our Site.
User-Generated Content and Public Information
The Service may permit you to submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, “User Content”), such as on blogs and message boards. CommonCoach or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Be aware that public postings are not confidential. Please note that we do not control who will have access to the information that users choose to make public, and cannot ensure that parties who have access to such publicly available information will respect user’s privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the Service or Site or what others do with information you share with them on the Service. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Service. We may also publish a user’s name, voice, likeness and other Personal Information that is part of user’s User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities, provided that we will not exercise such rights as to any user’s User Content which identifies user in a public manner unless user provides a separate consent to us in writing (email is sufficient) authorizing such use.
Use of Your Personal Information
CommonCoach collects and uses your Personal Information to operate and improve its Site and deliver the Services. These uses may include providing you with more effective customer service; making the Site or Services easier to use by eliminating the need for you to repeatedly enter the same information; performing research and analysis aimed at improving our products, services and technologies; and displaying content and advertising that are customized to your interests and preferences.
We also use your Personal Information to communicate with you, including to solicit your feedback on the Site and Services. We may send certain mandatory service communications such as welcome letters, billing reminders, information on technical service issues, and security announcements. Some CommonCoach services may send periodic member letters that are considered part of the Service. We may also contact you to inform you of other products or services available from CommonCoach and its affiliates.
Sharing of Your Personal Information
CommonCoach will not sell, rent or lease your Personal Information to others. CommonCoach shares Personal Information with companies working on our behalf. Except as described in this statement, we will not disclose your Personal Information to third parties for their own marketing purposes unless you have provided consent.
Some CommonCoach services may be co-branded and offered in conjunction with another company. If you register for or use such services, both CommonCoach and the other company may receive information collected as part of the co-branded services.
In some cases CommonCoach uses contractors to collect, use, analyze and otherwise process information on its behalf. It is CommonCoach’s practice to require such suppliers to handle information in a manner consistent with CommonCoach’s policies. CommonCoach may also allow carefully selected CommonCoach partners to participate in limited marketing campaigns solely to promote our products and services to you.
If you request something from the Site (for example, a product or service, a callback, or specific marketing materials), we will use the information you provide to fulfill your request. To help us do this, we may share information with others, such as our business partners or financial institutions, involved in fulfillment. As part of a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes.
We occasionally hire other companies to provide limited services on our behalf, such as handling the processing and delivery of mailings, providing customer support, hosting websites, processing transactions, or performing statistical analysis of our services. Those companies will be permitted to obtain only the Personal Information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose.
We may access or disclose your Personal Information or any information you submitted via the Site or Service if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce any applicable terms of service, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of CommonCoach, our users, yourself or the public.
Use of Anonymous Information
We may use Anonymous Information (as defined below), or disclose it to third party service providers, to provide and improve the Service. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners, for purposes including, but not limited to, targeting advertisements. "Anonymous Information" means information which does not enable identification of an individual user, such as aggregated information about use of the Site or Service.
If you do not wish to continue receiving certain marketing materials (e.g., e-mail messages), you can opt-out of receiving these materials by following the unsubscribe instructions provided in the materials. This option does not apply to communications primarily for the purpose of administering orders, contracts, support, software updates, or other administrative and transactional notices.
At all times, you may choose whether or not to provide or disclose Personal Information. The notices that we provide on the Site in circumstances where we collect Personal Information should help you to make this choice. If you choose not to provide the Personal Information we request, you may still use the Site and Service, but you may be unable to access certain programs and services that involve our interaction with you.
To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to delete or correct any other of your Personal Information that we may be storing, you may submit a request to us by sending an email to email@example.com. Your email should include adequate details of your request.
Collection of Information by Third-Party Sites
Links to Other Sites
The Site may contain links to third party websites that are not owned or controlled by us. We are not responsible for the privacy practices or the content of such other third party websites, and you visit them at your own risk.
The Service is neither directed to nor structured to attract children under the age of 13 years. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 13 years of age. If we learn that Personal Information of persons less than 13 years of age has been collected without verifiable parental consent, then we will take the appropriate steps to delete this information. To make such a request, please contact us firstname.lastname@example.org.
The security of your Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security, you can contact us at email@example.com.
Please be aware that certain Personal Information and other information provided by you in connection with your use of the Service may be stored on your Device (even if we do not collect that information). You are solely responsible for maintaining the security of your device from unauthorized access.
Merger, Sale or Bankruptcy
If we are acquired by or merged with a third party entity, or if we are subject to a bankruptcy or any comparable event, we reserve the right to transfer or assign Personal Information in connection therewith.
California Online Privacy Protection Act Notice
On September 27, 2013, California enacted A.B. 370, amending the California Online Privacy Protection Act to require website operators like us to disclose how we respond to "Do Not Track Signals"; and whether third parties collect personally identifiable information about users when they visit us.
(1) We do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
(2) We do not authorize the collection of personally identifiable information from our users for third party use through advertising technologies without separate user consent.
California Civil Code Section 1798.83 also permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org. Please note that we are only required to respond to one request per customer each year.
Our Accountability/Dispute Resolution
We use a self-assessment approach to assure compliance with this Policy and periodically verifiy that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the promises in this policy. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with this Policy.
International Site Visitors
Our Service is operated in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. U.S. law may not provide the degree of protection for Personal Information that is available in other countries. We take commercially reasonable steps to ensure that your data is treated securely, including entering into appropriate data transfer agreements. By using the Service or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Policy. If you do not consent to such transfer, you may not use the Site or Services.
We are committed to protecting your privacy. If you have any comments or questions regarding our Policy, or Personal Information that we may be storing and using, please contact us at email@example.com.