Privacy Policy

Introduction

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.

This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information.

Our Privacy Policy explains how Strategic Coach collects, uses, protects and discloses information about you. The terms “Strategic Coach,” “we,” “us,” and “our” include The Strategic Coach UK Limited, The Strategic Coach Inc., The Strategic Coach USA Inc. and our affiliates. We use the terms “member,” “you,” and “your” to mean any person using our Platform or attending related events, including any organization or person using the Platform on an organization’s behalf. Strategic Coach® is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this privacy statement.

This Privacy Policy applies to the processing of information about members and other individuals that we collect when you use our “Platform,” which means any website, application, or services we offer or when you communicate with us. For information about choices that we offer under this policy, please see “Your Choices” below. This Privacy Policy does not apply to the information that you may provide to third parties such as members and others with whom you may share information about yourself. For more information about the scope of our Privacy Policy, please see Section 4.

To make this Privacy Policy easier to understand, we have provided summaries at the beginning of each section. These summaries are not part of the official policy. Even though we have provided summaries, it is important for you to read the entire policy carefully.

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.

Any modifications to this Privacy Policy will be posted on our website, so please check the “last modified” date of the Privacy Policy periodically. This Privacy Policy was last modified on May 1, 2018.

1. Collection Of Information

Summary: We collect information about you when you:
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.
  • Information Collected By Cookies And Other Tracking Technologies: We and our service providers collect information using various technologies, including cookies. Cookies are small data files stored on your hard drive or in device memory that help us improve our Platform and your experience, and track usage of our Platform. You can learn more about the types of cookies we and our service providers use by reading our Cookie Policy.

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 about new products, special offers, or other information that we think you may find interesting using the email address that you have provided;
  • Contact you from time to time for market research purposes by email, phone, fax, or mail. We may use the information to customize the website according to your interests and personalize content.

2.1 Operating Our Platform
We may use information about you for various purposes related to operating our Platform, including to:

  1. Provide, maintain, and improve our Platform, including to process transactions, develop new products and services, and manage the performance of our Platform;
  2. Display information about you, for instance, your list of interests, which will be visible on your profile;
  3. 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);
  4. 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;
  5. Monitor and analyze trends, usage, and activities in connection with our Platform;
  6. 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;
  7. Perform accounting and administrative tasks, and enforce or manage legal claims;
  8. 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
  9. 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®.

2.2 Communicating With You
We may use information about you for various purposes related to communicating with you, including to:

  1. Respond to your comments, questions, and requests, and provide customer service;
  2. 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;
  3. Notify you about communications of other members, in accordance with the communication preferences that you indicate in your account; and
  4. Send you technical notices, updates, security alerts and support, and administrative messages.

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.

  1. We process information about you in order to provide our services in accordance with our Terms of Use, for example, to allow you to join The Strategic Coach® Program, or to display your profile to other Strategic Coach® participants in your workshop, and to allow us to send you important service updates.
  2. 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).
  3. 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.
  4. 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.
  5. We may also process information to comply with a legal requirement or to perform a contract.
  6. 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).
  7. We also store, record, hold, refer to, and collect data of the nature referred to in Section 1.
  8. We also alter data if you give us permission to do so.

3. Sharing Of Information

Summary: We do not share information about you in any way other than as described in this Privacy Policy.
We may disclose information about you:

  •  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.

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 legalinfo@strategiccoach.com.

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.

4. Additional Details

Summary:

  • 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.
  • This Privacy Policy is periodically updated and does not apply to third parties.
  • 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
With your permission, we may allow others to use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Strategic Coach® website and other websites and online services. See our Cookie Policy for details about these technologies and the information that they collect, use, or share, including how you may be able to control or disable these services.

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.

Strategic Coach® is based in Canada, the United States, and the United Kingdom. Information about you will be transferred to, and processed in, Canada, the U.S., and countries other than the country in which you are a resident. These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective. We have taken appropriate safeguards to require that your information will remain protected in accordance with this Privacy Policy.

4.3 Security
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
This Privacy Policy does not apply to information that you provide to third parties, such as other participants in The Strategic Coach® Program. Our website may direct you to a third-party service, such as social media services, or a portion of our website may be controlled by a third party (typically through the use of a frame or pop-up window separate from other content on our Platform). Disclosure of information to these third parties is subject to the relevant third party’s privacy policy. We are not responsible for the third-party privacy policy or content, even if we link to those services from our website or if we share information with these third parties.
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
We may modify this Privacy Policy from time to time. When we do, we will provide notice to you by publishing the most current version on our Platform at www.strategiccoach/privacy and revising the date at the top of this page. If we make any material change to this policy, we will provide additional notice to you, such as by sending you an email or displaying a prominent notice on our Platform.

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

Summary:

  • 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 legalinfo@strategiccoach.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 legalinfo@strategiccoach.com.

5.3 Your Choices: Cookies
We may use and allow others to use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Platform and other websites and online services. See our Cookie Policy for details about these technologies and the information that they collect, use, or share, including how you may be able to control or disable these services.

5.4 Some Information About The Use Of Cookies On Our Website
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:

  • You may refuse cookies entirely by setting an option in the Privacy section in Preferences.

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 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

Summary:

  • 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 legalinfo@strategiccaoch.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.
  • 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.
  • 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.

7. Contact Us

Summary:
If you have any questions, you can contact us at legalinfo@strategiccoach.com. 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 legalinfo@strategiccoach.com. If you have any questions or complaints about this Privacy Policy or how we use your information, please contact legalinfo@strategiccoach.com.