This policy describes how TrueCoach, Inc. collects, uses, and shares personal information.
Types Of Information We Collect
The following provides examples of the type of information that we collect from you and how we use that information.
|Context||Types of Data||Primary Use of Data|
|Account Registration||We collect your name and contact information when you create an account. We also collect information relating to the actions that you perform while logged into your account.||We have a legitimate interest in providing account relating functionalities to our users. Accounts can be used for easy to save your preferences and transaction history.|
|Client and Coach Information||We collect the name, and contact information, of our clients and their coaches with whom we may interact.||We have a legitimate interest in contacting our clients and coaches to communicate with them concerning normal business administration such as projects, services, and billing.|
|Demographic Information||We collect personal information, such as your age or location.||We have a legitimate interest in understanding our users and providing tailored services.|
|Distance Information||When you use one of our Apps we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location.||We have a legitimate interest in understanding our users and providing tailored services. In some contexts our use is also based upon your consent to provide us with geolocation information.|
|Email Interconnectivity||If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.||We have a legitimate interest in understanding how you interact with our communications to you.|
|Employment||If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.||We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and work force operations.|
|Feedback/Support||If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply. We have a legitimate interest in receiving, and acting upon, your feedback or issues. Fitness Information We collect information about users fitness and diet.||We collect this information with the users consent in order to provide services to them.|
|Mailing List||When you sign up for one of our mailing lists we collect your email address or postal address.||We have a legitimate interest in sharing information about our products or services.|
|Mobile Devices||We collect information from your mobile device such as unique identifying information broadcast from your device.||We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.|
|Payment||We collect your name, billing address, e-mail address, phone number, and credit card number when you make a payment.||We use your information to perform our contract to provide services.|
|Website Interactions||We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms.||We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful.|
|Web Logs||We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.||We have a legitimate interest in monitoring our networks and the visitors to our websites.|
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.
Use And Processing Of Information
In addition to the purposes and uses described above, we use information in the following ways:
- To identify you when you visit our website.
- To provide services.
- To improve our services and offerings.
- To streamline the payment process.
- To conduct analytics.
- To respond to inquiries related to support, employment opportunities, or other requests.
- To send marketing and promotional materials, including information relating to our services.
- For internal administrative purposes, as well as to manage our relationships.
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, we may collect your information to perform our contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about our services. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.
Sharing Of Information
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
- Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires our company, business, or our assets, we will also share information with that company.
- Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
- Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
- Public. We may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on these pages, that information may be publically available.
- Service Providers. We share your information with service providers. Among other things service providers help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of transactions.
You can make the following choices regarding your personal information:
- Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
- Access To Your Personal Information. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. You may request access to your personal information by contacting us at the address described below.
- Changes To Your Personal Information. We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. Note that we may keep historical information in our backup files as permitted by law. If our website does not permit you to update or correct certain information contact us at the address described below.
- Deletion Of Your Personal Information. Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. In addition, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.
- Revocation Of Consent. If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.
- Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.
- California Residents. California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing. If you are a California resident and would like a copy of such notice, please submit a written request to us using the information in the “Contact Information” section below.
How We Protect Personal Information
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
The following additional information relates to our privacy practices:
- Transmission of Information To Other Countries. Your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.
- Third Party Applications/Websites. We have no control over the privacy practices of websites or applications that we do not own.
If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.
If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.
Last Revised: 10/16/2018