PRIVACY NOTICE
Last updated October 01, 2022
This privacy notice for How We Coach Ltd. ("Company," "we," "us," or "our"),
describes how and why we might collect, store, use, and/or share ("process") your information when you use our services
("Services"), such as when you:
How We Coach Ltd.
Nic Claassen
7a Abbey Business Park
Monks Walk
Farnham, Surrey GU9 8HT
United Kingdom
- Visit our website at howwecoach.com, or any website of ours that links to this privacy notice
- Download and use our mobile application (How We Coach), or any other application of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns?
Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our
policies and practices, please do not use our Services. If you still have any questions or
concerns, please contact us at info@howwecoach.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about
any of these topics by clicking the link following each key point or by using our table of
contents below to find the section you are looking for. You can also
click
here
to go directly to our
table
of contents.
What
personal information do we process?
When you visit, use, or navigate our Services, we
may
process personal information depending on how you interact with
How We Coach Ltd.
and the Services, the choices you make, and the products
and features you use. Click
here
to learn more.
Do we
process any sensitive personal information?
We may process sensitive personal information when necessary with
your consent or as otherwise permitted by applicable law. Click
here
to learn more.
Do we
receive any information from third parties?
We do not receive any information from third parties.
How do
we
process your information?
We process your information to provide, improve, and
administer
our Services, communicate with you, for security and fraud prevention, and to comply with law. We
may
also process your information for other purposes with your consent. We process your information only
when we have a valid legal reason to do so. Click
here
to learn more.
In
what
situations and with which parties do we share personal
information?
We may share information in specific situations and with specific third
parties. Click
here
to learn more.
How do
we
keep your information safe?
We have organizational and technical processes and
procedures
in place to protect
your personal information. However, no electronic transmission over the internet or information
storage
technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorized third parties will not be able to defeat our security and
improperly collect, access, steal, or modify your information. Click
here
to learn more.
What
are
your rights?
Depending on where you are located geographically, the applicable privacy
law
may mean you have certain rights regarding your personal information. Click
here
to learn more.
How do you exercise your rights?
The easiest way to exercise your rights is by contacting us at
privacy@howwecoach.com. To delete your account, see
howwecoach.com/delete-account. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn
more
about what
How We Coach Ltd.
does with any information we collect? Click
here
to review the notice in full.
TABLE OF CONTENTS
1. WHAT
INFORMATION
DO WE COLLECT?
Personal information you disclose to
us
In
Short:
We collect
personal information that you provide to
us.
We collect
personal
information that you voluntarily provide to us when you
register on the Services,
express an interest in obtaining
information
about us or our products and Services, when you participate in activities on the Services,
or
otherwise when you contact us.
Personal
Information Provided by You.
The personal information that we collect depends on
the
context of your interactions with us and the Services, the choices you make, and the products
and
features you use. The personal information we collect may include the following:
- names
- email addresses
- passwords
- usernames
- job titles
Sensitive Information.
When necessary, with your consent or as otherwise permitted by
applicable law, we process the following categories of sensitive information:
- data about a person's sex life or sexual orientation
- health data
- genetic data
Payment
Data.
We may collect data necessary to process your payment if you make purchases,
such
as your payment instrument number (such as a credit card number), and the security code
associated
with your payment instrument. All payment data is stored by
Apple Inc
,
Google
and
Stripe
Inc.
.
You
may
find
their
privacy
notice
link(s)
here:
https://www.apple.com/legal/privacy/en-ww/
,
https://policies.google.com/privacy?hl=en-US
and
https://stripe.com/gb/privacy
.
Social
Media Login Data.
We may provide you with the option to register with us using
your existing social media account details, like your Facebook, Twitter, or other social media
account. If you choose to register in this way, we will collect the information described in the
section called "
HOW DO WE HANDLE YOUR SOCIAL
LOGINS?
" below.
Application Data. If you use our application(s), we also
may
collect the following information if you choose to provide us with access or
permission:
- Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
- Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, microphone, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
- Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
- Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.
This
information
is primarily needed to maintain the security and operation of our application(s), for
troubleshooting,
and for our internal analytics and reporting purposes.
All personal
information that you provide to us must be true, complete, and accurate, and you must notify us
of
any changes to such personal information.
Information automatically collected
In
Short:
Some
information —
such as your Internet Protocol (IP) address and/or browser and device
characteristics — is collected automatically when you visit our
Services.
We
automatically
collect certain information when you visit, use, or navigate the Services. This information does
not
reveal your specific identity (like your name or contact information) but may include device and
usage information, such as your IP address, browser and device characteristics, operating
system,
language preferences, referring URLs, device name, country, location, information about how and
when
you use our Services, and other technical information. This information is primarily needed to
maintain the security and operation of our Services, and for our internal analytics and
reporting
purposes.
Like many
businesses, we also collect information through cookies and similar technologies.
The information
we
collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps" ), and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
- Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
2. HOW DO WE
PROCESS YOUR INFORMATION?
In Short:
We
process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with
law.
We may also process your information for other purposes with your
consent.
We
process
your personal information for a variety of reasons, depending on how you interact with our
Services, including:
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
- To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
- To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
- To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
- To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see " WHAT ARE YOUR PRIVACY RIGHTS? " below).
- To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
- To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
- To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
- To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
- To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL
BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In
Short:
We only process
your
personal information when we believe it is
necessary and we have a valid legal reason
(i.e.,
legal basis) to do so under applicable law,
like
with your consent, to comply with laws, to
provide you with services to enter into or
fulfill
our contractual obligations, to protect your
rights, or to
fulfill
our legitimate business
interests.
If
you
are located in the EU or UK, this
section applies to
you.
The General Data
Protection Regulation (GDPR) and UK GDPR require
us
to explain the valid legal bases we rely on in
order
to process your personal information. As such,
we
may rely on the following legal bases to process
your personal information:
- Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Click here to learn more.
- Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- Send users information about special offers and discounts on our products and services
- Develop and display personalized and relevant advertising content for our users
- Analyze how our services are used so we can improve them to engage and retain users
- Support our marketing activities
- Diagnose problems and/or prevent fraudulent activities
- Understand how our users use our products and services so we can improve user experience
-
Legal
Obligations.
We may process
your
information where we believe it is necessary
for
compliance with our legal obligations, such
as
to cooperate with a law enforcement body or
regulatory agency, exercise or defend our
legal
rights, or disclose your information as
evidence
in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you
are
located in Canada, this section
applies
to you.
We may process your
information if you have given us specific
permission
(i.e.,
express consent) to use your personal
information
for a specific purpose, or in situations where
your
permission can be inferred (i.e.,
implied consent). You can withdraw your consent
at
any time. Click
here
to learn
more.
In some exceptional
cases,
we may be legally permitted under applicable law
to
process your information without your consent,
including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
In
Short:
We may
share information in specific situations
described in this section and/or with
the
following
third
parties.
We may need to
share
your personal information in the following
situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to this link . We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. This includes: Training venues to know what session information to offer; and other similar information. A full list of what we use information for can be found in this section and in the previous section titled " HOW DO WE PROCESS YOUR INFORMATION? ". We obtain and store on your device ("cache") your location . You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. The Google Maps Platform APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein, and Norway) or the United Kingdom, please take a look at our Cookie Notice .
- Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
- Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
- Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.
- Offer Wall. Our application(s) may display a third-party hosted "offer wall." Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.
5. WHAT IS OUR
STANCE ON THIRD-PARTY
WEBSITES?
In
Short:
We are not
responsible for the safety of any
information
that you share with third parties that we
may
link to or who advertise on our Services,
but
are not affiliated with, our
Services.
The Services, including our
offer wall,
may
link to third-party websites, online services,
or
mobile applications and/or contain
advertisements
from third parties that are not affiliated with
us
and which may link to other websites, services,
or
applications. Accordingly, we do not make any
guarantee regarding any such third parties, and
we
will not be liable for any loss or damage caused
by
the use of such third-party websites, services,
or
applications. The inclusion of a link towards a
third-party website, service, or application
does
not imply an endorsement by us. We cannot
guarantee
the safety and privacy of data you provide to
any
third parties. Any data collected by third
parties
is not covered by this privacy notice. We are
not
responsible for the content or privacy and
security
practices and policies of any third parties,
including other websites, services, or
applications
that may be linked to or from the Services. You
should review the policies of such third parties
and
contact them directly to respond to your
questions.
In
Short:
We may
use
cookies and other tracking technologies
to
collect and store your
information.
We may use
cookies
and similar tracking technologies (like web
beacons and pixels) to access or store
information. Specific information about how
we
use such technologies and how you can refuse
certain cookies is set out in our Cookie
Notice
.
In
Short:
If you
choose to register or log in to our
services
using a social media account, we may
have
access to certain information about
you.
Our Services
offer
you the ability to register and log in using
your third-party social media account
details
(like your Facebook or Twitter logins).
Where
you choose to do this, we will receive
certain
profile information about you from your
social
media provider. The profile information we
receive may vary depending on the social
media
provider concerned, but will often include
your
name, email address, friends list, and
profile
picture, as well as other information you
choose
to make public on such a social media
platform.
We will use
the
information we receive only for the purposes
that are described in this privacy notice or
that are otherwise made clear to you on the
relevant Services. Please note that we do
not
control, and are not responsible for, other
uses
of your personal information by your
third-party
social media provider. We recommend that you
review their privacy notice to understand
how
they collect, use, and share your personal
information, and how you can set your
privacy
preferences on their sites and apps.
8.
HOW LONG DO WE KEEP YOUR
INFORMATION?
In
Short:
We
keep
your information for as long as
necessary to
fulfill
the purposes outlined in this privacy
notice unless otherwise required by
law.
We will only
keep
your personal information for as long as it
is
necessary for the purposes set out in this
privacy notice, unless a longer retention
period
is required or permitted by law (such as
tax,
accounting, or other legal requirements). No
purpose in
this notice will require us keeping your
personal information for longer than
one (1) months past
the termination of the user's account
.
When we have
no
ongoing legitimate business need to process
your
personal information, we will either delete
or
anonymize such information, or, if this is
not
possible
(for example, because your personal
information
has been stored in backup archives), then we
will securely store your personal
information
and isolate it from any further processing
until
deletion is possible.
9.
HOW DO WE KEEP YOUR
INFORMATION
SAFE?
In
Short:
We aim
to
protect your personal information
through a
system of
organizational
and technical security
measures.
We have
implemented appropriate and reasonable
technical
and
organizational
security measures designed to protect the
security of any personal information we
process.
However, despite our safeguards and efforts
to
secure your information, no electronic
transmission over the Internet or
information
storage technology can be guaranteed to be
100%
secure, so we cannot promise or guarantee
that
hackers, cybercriminals, or other
unauthorized
third parties will not be able to defeat our
security and improperly collect, access,
steal,
or modify your information. Although we will
do
our best to protect your personal
information,
transmission of personal information to and
from
our Services is at your own risk. You should
only access the Services within a secure
environment.
10.
WHAT ARE YOUR PRIVACY
RIGHTS?
In
Short:
In
some regions, such as the
European Economic Area (EEA), United
Kingdom
(UK), and Canada, you have
rights that allow you greater access to
and
control over your personal
information.
You
may review, change, or terminate your
account at any time.
In some
regions
(like the
EEA, UK, and Canada
), you have certain rights under
applicable data protection laws. These may
include the right (i) to request access and
obtain a copy of your personal information,
(ii)
to request rectification or erasure; (iii)
to
restrict the processing of your personal
information; and (iv) if applicable, to data
portability. In certain circumstances, you
may
also have the right to object to the
processing
of your personal information. You can make
such
a request by contacting us by using the
contact
details provided in the section "
HOW CAN
YOU
CONTACT US ABOUT THIS
NOTICE?
"
below.
We will
consider
and act upon any request in accordance with
applicable data protection laws.
If you are
located
in the EEA or UK and you believe we are
unlawfully processing your personal
information,
you also have the right to complain to your
local data protection supervisory authority.
You
can find their contact details here:
https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
.
If you are
located
in Switzerland, the contact details for the
data
protection authorities are available here:
https://www.edoeb.admin.ch/edoeb/en/home.html
.
Withdrawing
your consent:
If we are
relying on your consent to process your
personal
information,
which may be express and/or implied consent
depending on the applicable law,
you have the right to withdraw your consent
at
any time. You can withdraw your consent at
any
time by contacting us by using the contact
details provided in the section "
HOW CAN
YOU
CONTACT US ABOUT THIS
NOTICE?
"
below or
updating your preferences.
However, please
note
that this will not affect the lawfulness of the
processing before its withdrawal nor, when
applicable
law allows,
will it affect the processing of your
personal information conducted in reliance on
lawful
processing grounds other than
consent.
Opting
out
of marketing and promotional
communications:
You
can unsubscribe from our marketing and
promotional
communications at any time by clicking on the
unsubscribe link in the emails that we send,
Updating communication
preferences from your profile pages.,
or by
contacting us using the details provided in the
section "
HOW CAN YOU
CONTACT US ABOUT THIS
NOTICE?
" below.
You will then be removed from the marketing
lists.
However, we may still communicate with you — for
example, to send you service-related messages
that
are necessary for the administration and use of
your
account, to respond to service requests, or for
other non-marketing purposes.
Account
Information
If you would at any
time
like to review or change the information in your
account or terminate your account, you
can:
- Contact us using the contact information provided.
- Log in to your account settings and update your user account.
Upon your request
to
terminate your account, we will deactivate or
delete
your account and information from our active
databases. However, we may retain some
information
in our files to prevent fraud, troubleshoot
problems, assist with any investigations,
enforce
our legal terms and/or comply with applicable
legal
requirements.
Cookies
and similar
technologies:
Most Web browsers are set to accept cookies
by
default. If you prefer, you can usually
choose
to set your browser to remove cookies and to
reject cookies. If you choose to remove
cookies
or reject cookies, this could affect certain
features or services of our Services. To opt
out
of interest-based advertising by advertisers
on
our Services visit
http://www.aboutads.info/choices/
.
If you have questions
or
comments about your privacy rights, you may
email us
at privacy@howwecoach.com
.
11.
CONTROLS FOR DO-NOT-TRACK
FEATURES
Most web
browsers
and some mobile operating systems and mobile
applications include a Do-Not-Track ("DNT")
feature or setting you can activate to
signal
your privacy preference not to have data
about
your online browsing activities monitored
and
collected. At this stage no uniform
technology
standard for
recognizing
and implementing DNT signals has been
finalized.
As such, we do not currently respond to DNT
browser signals or any other mechanism that
automatically communicates your choice not
to be
tracked online. If a standard for online
tracking is adopted that we must follow in
the
future, we will inform you about that
practice
in a revised version of this privacy
notice.
12.
DO CALIFORNIA RESIDENTS HAVE
SPECIFIC PRIVACY
RIGHTS?
In
Short:
Yes,
if
you are a resident of California, you
are
granted specific rights regarding access
to
your personal
information.
California
Civil
Code Section 1798.83, also known as the
"Shine
The
Light"
law, permits our users who are California
residents to request and obtain from us,
once a
year and free of charge, information about
categories of personal information (if any)
we
disclosed to third parties for direct
marketing
purposes and the names and addresses of all
third parties with which we shared personal
information in the immediately preceding
calendar year. If you are a California
resident
and would like to make such a request,
please
submit your request in writing to us using
the
contact information provided
below.
If you are
under
18 years of age, reside in California, and
have
a registered account with Services, you have
the
right to request removal of unwanted data
that
you publicly post on the Services. To
request
removal of such data, please contact us
using
the contact information provided below and
include the email address associated with
your
account and a statement that you reside in
California. We will make sure the data is
not
publicly displayed on the Services, but
please
be aware that the data may not be completely
or
comprehensively removed from all our systems
(e.g.,
backups, etc.).
CCPA Privacy
Notice
The
California Code of
Regulations
defines a
"resident"
as:
(1) every
individual who is in the State of California
for
other than a temporary or transitory purpose
and
(2) every
individual who is domiciled in the State of
California who is outside the State of
California for a temporary or transitory
purpose
All other
individuals are defined as
"non-residents."
If this
definition
of "resident"
applies to you, we must adhere to certain
rights
and obligations regarding your personal
information.
What
categories of personal information do we
collect?
We have
collected
the following categories of personal
information
in the past twelve (12) months:
| Category | Examples | Collected |
|
A.
Identifiers
|
Contact
details, such as real name,
alias, postal address,
telephone
or mobile contact number,
unique
personal identifier, online
identifier, Internet
Protocol
address, email address, and
account
name
|
YES
|
|
B.
Personal information
categories
listed in the California
Customer Records
statute
|
Name,
contact information,
education,
employment, employment
history,
and financial
information
|
YES
|
|
C.
Protected classification
characteristics under
California
or federal
law
|
Gender
and date of
birth
|
YES
|
|
D.
Commercial
information
|
Transaction
information, purchase
history,
financial details, and
payment
information
|
NO
|
|
E.
Biometric
information
|
Fingerprints
and
voiceprints
|
NO
|
|
F.
Internet or other similar
network
activity
|
Browsing
history, search history,
online
behavior, interest data, and
interactions with our and
other
websites, applications,
systems,
and
advertisements
|
NO
|
|
G.
Geolocation
data
|
Device
location
|
NO
|
|
H.
Audio, electronic, visual,
thermal, olfactory, or
similar
information
|
Images
and audio, video or call
recordings created in
connection
with our business
activities
|
YES
|
|
I.
Professional or
employment-related
information
|
Business
contact details in order to
provide you our Services at
a
business level or job title,
work history, and
professional
qualifications if you apply
for
a job with
us
|
NO
|
|
J.
Education
Information
|
Student
records and directory
information
|
NO
|
|
K.
Inferences drawn from other
personal
information
|
Inferences
drawn from any of the
collected
personal information listed
above to create a profile or
summary about, for example,
an
individual’s preferences and
characteristics
|
YES
|
We may also
collect other personal information outside
of
these categories through instances where you
interact with us in person, online, or by
phone
or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
How do
we
use and share your personal
information?
More
information about our data
collection and sharing practices
can
be found in this privacy notice
.
You may
contact us
by email
at
privacy@howwecoach.com,
or by referring to the
contact details at the bottom of this
document.
If you are
using
an authorized
agent to exercise your right to opt out we
may
deny a request if the authorized
agent does not submit proof that they have
been
validly
authorized to
act on your behalf.
Will
your
information be shared with anyone
else?
We may
disclose
your personal information with our service
providers pursuant to a written contract
between
us and each service provider. Each service
provider is a for-profit entity that
processes
the information on our
behalf.
We may use
your
personal information for our own business
purposes, such as for undertaking internal
research for technological development and
demonstration. This is not considered to be
"selling" of
your personal information.
How We Coach Ltd.
has
not disclosed or sold any personal
information
to third parties for a business or
commercial
purpose in the preceding twelve (12) months.
How We Coach
Ltd.
will not
sell
personal information in the future belonging
to
website visitors, users, and other
consumers.
Your
rights with respect to your personal
data
Right to
request deletion of the data — Request
to
delete
You can ask
for
the deletion of your personal information.
If
you ask us to delete your personal
information,
we will respect your request and delete your
personal information, subject to certain
exceptions provided by law, such as (but not
limited to) the exercise by another consumer
of
his or her right to free speech, our
compliance
requirements resulting from a legal
obligation,
or any processing that may be required to
protect against illegal
activities.
Right to be
informed — Request to
know
Depending on
the
circumstances, you have a right to
know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell your personal information to third parties;
- the categories of personal information that we sold or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- the business or commercial purpose for collecting or selling personal information.
In accordance
with
applicable law, we are not obligated to
provide
or delete consumer information that is
de-identified in response to a consumer
request
or to re-identify individual data to verify
a
consumer request.
Right to
Non-Discrimination for the Exercise of a
Consumer’s Privacy
Rights
We will not
discriminate against you if you exercise
your
privacy rights.
Verification
process
Upon receiving
your request, we will need to verify your
identity to determine you are the same
person
about whom we have the information in our
system. These verification efforts require
us to
ask you to provide information so that we
can
match it with information you have
previously
provided us. For instance, depending on the
type
of request you submit, we may ask you to
provide
certain information so that we can match the
information you provide with the information
we
already have on file, or we may contact you
through a communication method (e.g.,
phone or email) that you have previously
provided to us. We may also use other
verification methods as the circumstances
dictate.
We will only
use
personal information provided in your
request to
verify your identity or authority to make
the
request. To the extent possible, we will
avoid
requesting additional information from you
for
the purposes of verification. However, if we
cannot verify your identity from the
information
already maintained by us, we may request
that
you provide additional information for the
purposes of verifying your identity and for
security or fraud-prevention purposes. We
will
delete such additionally provided
information as
soon as we finish verifying
you.
Other
privacy
rights
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
- You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise
these
rights, you can contact us
by email at
privacy@howwecoach.com,
or by referring to the
contact details at the bottom of this document. If
you
have a complaint about how we handle your data, we
would
like to hear from you.
Financial
Incentives
"Financial
incentive"
means a program, benefit, or other offering,
including payments to consumers as
compensation,
for the disclosure, deletion, or sale of
personal information.
The law
permits
financial incentives or a price or service
difference if it is reasonably related to
the
value of the consumer’s data. A business
must be
able to explain how the financial incentive
or
price or service difference is reasonably
related to the value of the consumer’s data.
The
explanation must include:
- a good-faith estimate of the value of the consumer’s data that forms the basis for offering the financial incentive or price or service difference; and
- a description of the method the business used to calculate the value of the consumer’s data.
We may decide
to
offer a financial incentive (e.g.,
price or service difference) in exchange for
the
retention or sale of a consumer’s personal
information.
If we decide
to
offer a financial incentive, we will notify
you
of such financial incentive and explain the
price difference, as well as material terms
of
the financial incentive or price of service
difference, including the categories of
personal
information that are implicated by the
financial
incentive or price or service
difference.
If you choose
to
participate in the financial incentive you
can
withdraw from the financial incentive at any
time
by emailing us at
privacy@howwecoach.com,
or by referring to the
contact details at the bottom of this
document.
13.
DO WE MAKE UPDATES TO THIS
NOTICE?
In
Short:
Yes, we will
update
this notice as necessary to stay
compliant
with relevant
laws.
We may update
this
privacy notice from time to time. The
updated
version will be indicated by an updated
"Revised"
date and the updated version will be
effective
as soon as it is accessible. If we make
material
changes to this privacy notice, we may
notify
you either by prominently posting a notice
of
such changes or by directly sending you a
notification. We encourage you to review
this
privacy notice frequently to be informed of
how
we are protecting your
information.
14.
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you
may contact our Data Protection Officer (DPO),
by phone at +442081332676, or by post to:
How We Coach Ltd.
Nic Claassen
7a Abbey Business Park
Monks Walk
Farnham, Surrey GU9 8HT
United Kingdom
15.
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
You have the
right to request access to the personal
information we collect from you, change that
information, or delete it. To
request to review, update, or delete your
personal information, please
visit:
howwecoach.com/delete-account to delete your account,
or email privacy@howwecoach.com.