Last Updated May 23, 2020
Our Service does not address anyone under the age of 18 (“Children”). By providing us with your data, you warrant to us that you are at least 18 years of age.
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com or by updating your data in your account dashboard.
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small pieces of data stored on a User’s device.
Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.
Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
Data Subject is any living individual who is the subject of Personal Data.
The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
3.WHAT DATA DO WE COLLECT ABOUT YOU
We collect several different types of information for various purposes to provide and improve our Service. This may include:
- Psychometric Data may include the results of the following tests: Myers-Briggs Type Indicator, 16 Personalities, Jung Personality Test, Love Languages Test, Belbin Team Role Test, DISC, Ennegeagram.
- Identity Data may include your first name, maiden name, last name, username, marital status, title, date of
birth and gender.
- Contact Data may include your billing address, delivery address, email address and telephone numbers.
- Financial Data may include your bank account and payment card details.
- Transaction Data may include details about payments between us and other details of purchases made by you.
- Technical Data may include your login data, internet protocol addresses, browser type and version, browser
plug-in types and versions, time zone setting and location, operating system and platform and other technology
on the devices you use to access this site.
- Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback
and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and
our third parties and your communication preferences.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
During coaching sessions you or your coach may take notes and these may contain sensitive data which you have provided. We require your explicit consent to retain these and you will find in your account preferences there is a separate agreement indicator covering this point.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
4.HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through a variety of different methods including:
- Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us and /or your coach (if applicable) by mail, phone, email or otherwise, including when you:
- buy our products or services;
- sign up for a membership;
- create an account on our site;
- subscribe to our services or publications;
- request resources or marketing be sent to you;
- give us feedback.
- Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies.
- Third parties or publicly available sources: We may receive data from third parties (some or all of whom may be based outside the EU) including, by way of example: analytics providers such as Google, advertising networks such as Facebook search information providers such as Google , Yahoo, Bing, etc., and
providers of technical, payment and delivery services, such as data brokers or aggregators.
5.HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when legally permitted. The most common uses of your personal data are:
- To provide and maintain our Service;
- To notify you about changes to our Service;
- To allow you to participate in interactive features of our Service when you choose to do so;
- To provide customer support;
- To gather analysis or valuable information so that we can improve our Service;
- To monitor the usage of our Service;
- To detect, prevent and address technical issues;
- Where we need to perform the contract between us;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- Where we need to comply with a legal or regulatory obligation;
- To provide you with news, special offers and general information about other goods, services, subscriptions, and events which we
offer that are similar to those that you have already purchased or enquired about provided (if you are an EU resident) you have consented, or unless you have opted not to receive such information
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at firstname.lastname@example.org
Purposes for processing your personal data
We may process the following categories of personal data about you:
- We process Communication Data (which includes any communication that you send us whether through the contact form(s) on our website, through email, text, social media messaging, social media posting or any other means of communication) for the purposes of communicating with you, for fulfilling our contractual obligations to you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful bases for this processing are our contractual right and obligation, our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- We process Customer Data (including data such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details, and information relating to purchases of goods and/or services) in order to fulfill the terms of our contracts with you, to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful basis for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
- We process User Data (including data about how you use our website and any online services, together with whatever data you post for publication on our website or through other online services, to operate our website and ensure that useful, relevant content is provided to you, to ensure the security of our website,
to maintain backups of our website and/or databases and to enable publication and administration of our website and other online services and business. Our lawful basis for this processing is our legitimate interests to enable us to properly operate and manage our website and our business.
- We process Technical Data (including data gathered by our analytics tracking system about your use of our website and online services such as your IP address, your login data, browser details, duration of visits to pages on our site, page views and navigation paths, the number of times you use our website, time
zone settings and other data about the technology and devices used to access our website) to analyze use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful basis for this processing are our legitimate interests in properly operating and managing our website and our
business; in growing our business and in determining marketing and content strategies.
- We process Marketing Data (including data about your preferences in receiving marketing from us and our third parties and your communication preferences) to enable you to benefit from our offers, promotions, and incentive programs and to deliver useful, relevant website content and advertisements to you and measure or understand such advertising’s effectiveness. Our lawful bases for this processing are our legitimate interests
which in studying and analyzing how customers use our products and services, and to develop and grow our products, services, and our business and in determining our marketing strategies.
- We may use all of the above data types to deliver relevant website content and advertisements to you (including
Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests in assuring the stability, growth and success of our
We may process your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under applicable regulations, we may send marketing communications if you have made a purchase or asked for information from us about our goods or services or agreed to receive marketing communications provided that you have not subsequently opted out of receiving such communications. Further, if you are a business, we may send you marketing emails without your consent. You can opt out of receiving marketing emails from us at any time.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the system and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you or OR by emailing us at email@example.com at any time
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of purchases, warranty registration, or certain other transactions.
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
Change of Purpose
We will only use your personal data for the purposes for which we collected it, and other purposes for which we determine that we have a lawful basis to do so. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at firstname.lastname@example.org
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
6. DISCLOSURES OF YOUR PERSONAL DATA
From time to time, it may be necessary that we share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal,
insurance and accounting services.
- Tax, regulatory and other authorities who require reporting of processing activities in certain circumstances.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
7. INTERNATIONAL TRANSFERS
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside South Africa and choose to provide information to us, please note that we transfer the data, including Personal Data, to South Africa and process it there. We may also transfer to and process the data in the United States and other Jurisdictions where our servers, and processors are located.
8. DATA SECURITY
We have established appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, resolving disputes, and enforcing our legal agreements and policies.
We may also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for as much as six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
10. YOUR LEGAL RIGHTS
We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. When such functionality exists within our Service, you can update your Personal Data directly within your account settings dashboard. If you are unable to change your Personal Data, please contact us to make the required changes.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
Under certain circumstances, you have the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
- Right to data portability (i.e., to obtain a copy of your Personal Data in a commonly use electronic format so
that you can manage and move it)
If you wish to exercise any of the rights set out above, please email us at email@example.com
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the applicable local authority (if any), But please contact us first so that we can resolve it for you.
11. THIRD PARTY LINKS