Issued: June 7, 2022
When you use our services, you’re trusting us with your information. We understand this is a big responsibility and work hard to protect your information and put you in control.
The Bottom Line: WE DO NOT rent, sell, or otherwise disclose your personal information to third parties, except in the very limited circumstances set out below.
1. Collection Of Information
- Summary: We collect information about you when you visit our websites or use our services,
including the following:
- Sign up for The Strategic Coach® Program via website/paper
- Create an account;
- Use the Platform;
- Attend an event;
- Direct referrals from Strategic Coach current business associates;
- Download marketing content from our website;
- Visit our website; and
- Communicate with us.
We also collect information such as usage statistics by using cookies, server logs, and similar technologies.
If you elect to use certain features, we also collect information through other sources, such as social media services, invitations, and imported contacts.
1.1 Information You Provide To Us
We collect information that you provide directly to us. For example, we collect information that you provide when you create an account, fill out a form, or communicate with us. The types of information that we may collect include your name, username, password, email address, postal address, phone number, payment method data, photos, occupation, income range, spouse’s name, date of birth, kids’ names (if applicable), choices of interests and groups, and any other information that you choose to provide. Information about your gender and interests is optional. Your choice of groups is optional, but we are required to process this information in order to process your Program Application and place you in the right workshop, and to indicate that you are a member of the groups that you join. Section 2 explores how we will use the information that you provide to personalize our recommendations and other content to you.
On occasion, the information you give us when you download materials or join The Strategic Coach® Program may imply information about your beliefs, political views, personal and/or professional life; health conditions; or your sexual identity. This, and other kinds of sensitive information, is given special protection. Posting personal or sensitive information about yourself or others is against our commitment to you to ensure your information is kept secured and confidential.
1.2 Information We Collect Automatically When You Use The Platform
When you use our Platform, we automatically collect information about you, including:
- Log Information: We collect log information about your use of the Platform, including the type of browser that you use; the time, duration and frequency of your access; Platform pages viewed; your IP address; and the page you visited before visiting our Platform.
- Device Information: We collect information about the computer or mobile device that you use to access our Platform, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
- Location Information: We may collect information about the location of your device each time you use our Platform based on your consent to the collection of this information.
1.3 Information We Collect From Other Sources
We may collect information about you from other sources, such as through certain features on the Platform you elect to use, but only where these third parties either have your consent or are otherwise legally permitted or required to disclose your information to us. Examples include:
- Social Media Services. If you register or log into your account through a third-party social media service, we will have access to some of your third-party account information from that service, such as your name and other information in that account, and use it for purposes such as improving our Platform.
- Member Content. We may receive information about you when you or another member uploads photos or posts other content to the Platform. For further details about the rights over this information available to individuals, see Section 6.
- Information From Other Third-Party Sources. In order to provide you with more tailored recommendations, we may obtain information about you from publicly and commercially available sources and other third parties as permitted by law.
2. Use of Information
Summary: We use information about you to:
- Operate, improve, promote, and protect Strategic Coach® and our Platform;
- Communicate with you;
- Keep internal records;
- Improve our products and services;
- Periodically send promotional emails (commercial electronic messages) about new products, special offers, or other information that we think you may find interesting using the email address and mobile number that you have provided;
- Contact you from time to time for market research purposes by email, text (commercial electronic messages), phone, fax, or mail. We may use the information to customize the website according to your interests and personalize content.
We retain personal data to fulfill our legal or regulatory obligations and for our business purposes. We may retain personal data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your account becomes inactive, we may take steps to mask personal data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such personal data in accordance with this Privacy Statement.
2.1 Operating Our Platform
We may use information about you for various purposes related to operating our Platform, including to:
- Provide, maintain, and improve our Platform, including to process transactions, develop new products and services, and manage the performance of our Platform;
- Display information about you, for instance, your list of interests, which will be visible on your profile;
- Personalize the Platform, for example, to suggest content in which we think you may be interested (including content given special protection under EU law or that relates to sensitive topics such as health, political opinions, religion, and sexual identity);
- Allow you to share information about your use of the Platform through a third-party social media service, if you connect your account through that service (which you can turn off at any time), and to provide you with better recommendations;
- Monitor and analyze trends, usage, and activities in connection with our Platform;
- Detect, investigate, and prevent fraudulent transactions, abuse, and other illegal activities; to protect the rights, property, or safety of Strategic Coach® and others; to enforce compliance with our policies; and to comply with applicable law and government requests;
- Perform accounting and administrative tasks, and enforce or manage legal claims;
- Place you in the workshop most appropriate for you. By using your information in this way, we ensure that you get the most benefit out of your participation in the workshops; and
- Keep in contact with you regarding your progress throughout the quarter and to notify you of relevant new products, services, and features offered by Strategic Coach®.
- Manage our business needs, such as monitoring, analyzing, and improving the services and the websites’ performance and functionality. For example, we analyze user behavior and perform research about the way you use our services.
- Market to you about Strategic Coach products and services and the products and services of unaffiliated businesses. We may also process your personal data to tailor the marketing content and certain services or website experiences to better match your interests on Strategic Coach and other third-party websites.
2.2 Communicating With You
We may use information about you for various purposes related to communicating with you, including to:
- Respond to your comments, questions, and requests, and provide customer service;
- Communicate with you, in accordance with your account settings, about products, services, and events offered by us and others; to provide news and information that we think will be of interest to you; to conduct online surveys; to contact you about events on our Platform that are being held near your location; and to otherwise communicate with you in accordance with Section 2.3;
- Notify you about communications of other members, in accordance with the communication preferences that you indicate in your account; and
- Send you technical notices, updates, security alerts and support, and administrative messages via email, text (CEM) phone, fax or mail.
2.3 Legal Basis For Processing
Our legal basis for collecting and using the information described above will depend on the type of information and the specific context in which we collect it.
- We also process information about you where it is in our legitimate interests to do so and not overridden by your rights (for example, in some cases for direct marketing, fraud prevention, network and information systems security, responding to your communications, the operation of networks of groups by the network administrators, and improving our Platform).
- Sometimes you provide us with sensitive information about you, for instance, your health, religion, political views, or sexual identity – which is entirely voluntarily and done with your explicit consent.
- In some cases, we may also have a legal obligation to collect information about you or may otherwise need the information to protect your vital interests or those of another person.
- We may also process information to comply with a legal requirement or to perform a contract.
- We may also process and store data such as credit card information for accounting purposes (invoicing, paying workshop fees, and/or purchasing Knowledge Products from us).
- We also store, record, hold, refer to, and collect data of the nature referred to in Section 1.
- We also alter data if you give us permission to do so.
3 Sharing Of Information
- to members or social media services, subject to the choices you may make via the Platform;
- to our third-party service providers who help us to operate or improve our Platform;
- to authorities to comply with legal obligations and to protect and defend our rights and property; and
- to an affiliate, financial institution, or successor entity as part of a corporate transaction.
We may also share de-identified or aggregated information and we may share your personal data:
- With other companies that provide services to us: We may share personal data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with services, verify your identity, assist in processing transactions, send you advertisements for our products and services, or provide customer support.
- With other financial institutions: We may share personal data with other financial institutions that we have partnered with to jointly create and offer a product, such as with Stripe. We may also share personal data to process transactions, provide you with benefits associated with your eligible cards, and keep your financial information up to date.
- With the other parties to transactions when you use the services, such as other users, merchants, and their service providers: We may share information about you and your account with the other parties involved in processing your transactions. This includes other users you are sending or receiving funds from, and merchants and their service providers.
- With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for Strategic Coach’s business purposes or as permitted or required by law.
3.1 Through Your Participation In The Strategic Coach® Program
We share some of the information that we collect by displaying it on a Client Roster according to your profile and account settings.
Some information, such as name, company, and contact information, will be visible to other members of that Strategic Coach® group/series. We find it helpful to have access to the email addresses of organizers and other members of groups within their workshop series to easily communicate with. Therefore, we ask that if you do not want to share your contact information your group, please contact firstname.lastname@example.org.
3.2 With Our Service Providers
We may use service providers in connection with operating and improving the Platform to assist with certain functions, such as payment processing, email transmission, conducting surveys or contests, data hosting, managing our ads, and some aspects of our technical and customer support. We take measures to ensure that these service providers access, process, and store information about you only for the purposes we authorize, subject to confidentiality obligations.
3.3 Following The Law And Protecting Strategic Coach®
We may access, preserve, and disclose information about you to third parties, including the content of messages, if we believe disclosure is in accordance with, or required by, applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are inconsistent with our Terms of Service or related guidelines and policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of, Strategic Coach® or others.
3.4 Affiliate Sharing And Merger, Sale, Or Other Asset Transfers
If Strategic Coach® is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of our assets, information about you may be shared, sold, or transferred as part of that transaction. We may also share information about you with current or future corporate parents, subsidiaries, or affiliates.
3.5 Third Party Processing Payment Services.
4. Additional Details
- With your permission, we may allow others to use technologies that collect information about you to provide analytic services and to serve ads for Strategic Coach®. You may be able to disable the collection or use of this information at any time.
- Strategic Coach® is based in and governed by Canadian and U.S. law, and we will be processing, transferring, and storing information in and to the U.S. and other countries.
- We use commercially reasonable efforts to protect your personal information and have implemented technical and organizational measures in line with industry best practices. We cannot guarantee these controls will provide absolute security.
- Workshop sessions monitoring: Strategic Coach®may monitor and record your workshop sessions for quality assurance and staff training purposes. These recordings are voluntary and you are not required to participate in them.
4.1 Analytics And Advertising Services Provided By Others
4.2 Transfer Of Information To Canada, The U.S., And Other Countries
Given that the internet is a global environment, using the internet to collect and process personal data necessarily involves the transmission of data on an international basis. Personal information may be stored in servers hosted in countries outside Canada, including the United States. As such, your personal information may be subject to the laws of other countries, including the United States, where the data protection and other laws may not be as comprehensive as those in Canada. Personal information may be disclosed in response to inquiries or requests from government authorities in the United States or other countries in which we operate. Therefore, by browsing our website and communicating electronically with us, you acknowledge and agree to our processing of personal data in this way.
We employ technical and organizational measures designed to appropriately protect your information that is under our control and that we process on your behalf from unauthorized access collection, use, disclosure, copying, modification, or disposal, both during transmission and once we receive it. We store all information that you provide to us on secure servers. We train employees regarding our data privacy policies and procedures, and permit authorized employees to access information on a need-to-know basis, as required for their role. We use firewalls designed to protect against intruders and test for network vulnerabilities. However, no method of transmission over the internet or method of electronic storage is completely secure.
Where you have a password, which enables you to use our services, you are responsible for keeping this password complex, secure, and confidential. If you would like to update or change your password, you may select the “Forgot your password?” link on the login page. You will be sent an email that allows you to reset your password.
4.4 Safeguarding Data
Strategic Coach® takes all feasible and reasonable precautions to protect the personal information that we collect from you. Every staff member must sign a Confidentiality and Non-Disclosure Agreement wherein he/she agrees not to improperly use and/or disclose any personal information about clients or other individuals who have contacted Strategic Coach®. Also, your personal information is retained in a secure database, which is only accessible by password and is protected by the use of firewalls.
4.5 Data Retention
We retain certain information that we collect from you while you are a participant in The Strategic Coach® Program and on our website, and in certain cases where you have deleted your account, for the following reasons:
- To ensure that we do not communicate with you if you have asked us not to;
- To inform you about new products, services, and features offered by Strategic Coach®;
- To ease your renewal into the Program upon the completion of each workshop series year;
- To be better able to chart your progress through the workshops;
- To determine if a new client has been referred by a former or current client;
- To facilitate your re-registration into the Program after leaving the Program. We know from experience that former clients often seek to re-register for the Program either within several months or several years after leaving it.
- To provide you with a refund, if entitled;
- To provide accurate accounting information to you;
- To better understand the traffic to our website so that we can provide all members with the best possible experience;
- To detect and prevent abuse of our website, illegal activities, and breaches of our Terms of Service;
- To comply with applicable legal, tax, or accounting requirements; and
- To establish, exercise, and defend legal claims.
When we have no ongoing legitimate business need to process your information, we will either delete or anonymize it. We retain personal information collected from you when you request information, register an account, apply for a workshop, and/or order a product online for a period of 15 years thereafter.
4.6 Policy Scope
Strategic Coach® is directly responsible for complying with all requirements of applicable EU privacy laws in connection with the information that we obtain and process for the purposes of managing our contacts, or organizing groups, or administering networks.
4.7 Revisions To This Policy
4.8 Links To Other Websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over those other websites. Therefore, we cannot be responsible for the protection and privacy of any information that you provide while visiting such sites, and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
4.9 How Do We Use And Store Personal Information You Provide To Us When You Request Information, Register An Account, And/Or Order Products Online?
We will maintain your personal information in a secure database. We do not use the information in the database for any purposes other than facilitating your future orders, or to permit us to notify you of products, services, workshops, and features offered by Strategic Coach®. We do not store your credit card numbers or expiry dates in our database. Consequently, each time you choose to purchase an item, your name and shipping address will be pulled from the database, but you will have to re-enter your credit card information to complete the order.
4.10 Our Policy Regarding Sharing and Accessing Your Personal Information
Strategic Coach® does not sell, trade, or otherwise transfer the personal information you provide to us to third parties. We may allow authorized third-party service providers access to your personal information to perform services on our behalf. Our service providers are required to provide privacy protection comparable to ours and to limit their use of such information to providing services on our behalf. These service providers may be in another country, such as the United States, and the personal information may be subject to disclosure in accordance with the applicable laws of that jurisdiction, which may create a different privacy regime from your country of residence.
5. Your Choices
- You can review and change information about yourself or deactivate your account in your account settings, but we may retain certain information.
- You have the right to opt out of receiving Strategic Coach®’s promotional messages, but you may still receive other non-promotional communications.
5.1 Your Choices: Account Information
You may update, deactivate, or correct your account information by sending a request to email@example.com as described in Section 6. You will also be able to choose what information others see about you and who may contact you by using the Privacy Settings section in your Account.
5.2 Your Choices: Opting Out Of Receiving Communications From Us
If you do not wish to receive communications from Strategic Coach®, you can opt out of receiving such communications by either following the instructions in each such communication or by contacting the Strategic Coach® Privacy Office (email address below) at any time. It may take up to ten days to process a request received by email or telephone, and six to eight weeks to process a request received by mail. If you change your mind and would like to start receiving communications from us again, you can do so by emailing us at firstname.lastname@example.org.
5.3 Your Choices: Cookies
Our website uses per-session cookies, which are commonly used tools to facilitate the exchange of information between your browser and our server. These cookies allow us to present, and you to view, certain graphic elements on the website. Per-session cookies are stored in memory while you are visiting the website and are set to expire from your cache 120 days after leaving our website.
The per-session cookies do not provide our website with access to anything else on your system, including private information about you. Our website can only retrieve the per-session cookie. You can set your browser to detect and reject cookies by taking the following steps. However, please note that if you choose to reject cookies, you will not be able to view all graphic elements on our site.
For Internet Explorer:
- Choose Tools in the menu bar, then Internet Options
- Select the Security tab, then click the zone you would like to change, followed by the Custom button
- Scroll down to the header titled Cookies, and choose how you would like to handle cookies. You can choose to accept cookies from all sites, refuse to accept any, or be prompted whenever a site wants to send you a cookie.
For Firefox, Safari, and other Mozilla-based browsers:
The information we are collecting includes:
- The name of your Internet Service Provider, its Internet Protocol address, and the name of your Service Provider’s server. (Strategic Coach® makes no attempt to link these addresses with the identity of visitors to our website.)
- The length of each visit.
- The number of requests per visit.
- Your type of operating system, e.g., Windows, Mac, Unix, etc.
- Your browser type, e.g., Netscape Navigator, Internet Explorer, etc.
The information is collected by the server in an aggregate format so that we can assess those pages that are most frequented by visitors of our site. We do not link this information with the identity of any visitor to our website, to any of the information you voluntarily provide when you visit our site, or when you become a participant in the Program. Accordingly, Strategic Coach® will treat any information shared between your browser and our server as non-personal information.
5.5 Non-Solicitation of Clients
Your participation in The Strategic Coach® Program does not give you permission or grant you a right to solicit, directly or indirectly, on your own behalf or on behalf of any other person(s), any client of The Strategic Coach® Program, for the purpose of selling, marketing, or providing any product or service.
5.6 Your Choices: Promotional Communications
You can control messages that you receive from Strategic Coach®, other members, and third parties by selecting the unsubscribe link in the message that you receive, or by adjusting the communication preferences in your account settings. We will also send you a link to these settings when you first sign up and in subsequent messages. If you opt out, we may still send you non-promotional messages, such as those about your account or our ongoing business relations.
6. Data Rights
- You may have the right to exercise your data protection rights, including to request that Strategic Coach® deletes, amends, or provides you access to your information.
- You have the right to opt out of receiving Strategic Coach®’s promotional messages, but you may still receive other communications.
- You can complain to your local data protection authority about the use of your information.
We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. You can contact us by sending an email to email@example.com.
Rights that you may have, depending on the country in which you live, include:
- Accessing, correcting, updating, or requesting deletion of your information.
- Objecting to processing of your information, asking us to restrict processing of your information, or requesting the portability of your information.
- Opting out from receiving marketing communications that we send you at any time. You can exercise this right by selecting the “unsubscribe” or “opt out” link in the marketing emails we send you. Additionally, you may update your email preferences by changing the settings in your account. You can exercise your right to opt out of receiving text messages we send to you by replying “STOP” to our text messages.
- Withdrawing your consent at any time if we have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.
- Complaining to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority.
7. Additional GDPR Information
We collect information about our users in order to help us continually improve the products and services we offer and so that we can enter into commercial arrangements. Strategic Coach will take all reasonable steps to adhere to UK Data Protection Legislation, including but not limited to, the Data Protection Act 2018 and the UK GDPR.
How Long Do We Keep Your Personal Data? The personal data that you provide when registering using Strategic Coach websites is retained until you ask us to delete it. If you wish to delete your account, you can do so by emailing firstname.lastname@example.org. Download histories are retained indefinitely. We also retain records of subscriptions and transactions for accounting purposes. Personal data contained within emails sent to us will be retained for as long as we reasonably require it. Questions relating to our content along with our answers to those questions may be retained unless you ask us not to in order to facilitate answering similar queries in the future, whether from you or from others. We also retain certain communications to aid in the conduct of potential future legal claims.
As explained herein, certain personal data will be made accessible to our third-party providers, based outside of the UK and European Economic Area. Additional steps have therefore been taken to ensure that your personal data will be treated just as securely and safely as it would be in the UK and under the UK GDPR. We share your personal data with selected third parties exclusively to provide services to you. To the extent necessary for the purpose of providing our service, the personal data that you give us during the registration process, and data relating to the documents and forms downloaded by you, may be transferred to third parties whom we engage from time to time to provide us with any services (including, but not limited to, payment processing) that we use for the purpose of administering our business and providing our products and services to customers.
Your Rights Under The UK GDPR
Individual data subjects have the following rights under the UK GDPR, which we will always work to uphold:
- The right to access your personal data by means of a subject access request (see below).
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. You can do this by contacting us.
- The right to erasure (also known as the right to be forgotten). You can exercise this right by contacting us.
- The right to restrict or object to our processing of your personal data for particular purposes. Email preferences can be changed by emailing us at email@example.com.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us. Further information about your rights can be obtained from the Information Commissioner’s Office. In the United Kingdom, your local data protection authority is the Information Commissioner’s Office: www.ico.org.uk. We would ask that you contact us to give us the opportunity to review your complaint before you contact the ICO.
8. Contact Us
If you have any questions, you can contact us at firstname.lastname@example.org.
Under data protection law, the controller of your information is The Strategic Coach UK Limited, The Strategic Coach Inc., and The Strategic Coach USA Inc.
If you wish to have access to the personal information that we retain on file, or if you wish to correct, update, or delete any information on file, please call 416.583.7135 or 1.800.387.3206, ext. 7135, or email email@example.com.