Privacy Notice

Last Updated: July 19, 2021

Introduction

This Privacy Policy governs the manner in which Coaching Genie collects, uses, maintains and discloses information collected from users (each, a “User”) of the https://coachinggenie.com/ website (“Site”). This Privacy Policy does not describe information collection practices on other websites, including those linked to or from our website.

Purpose of this Privacy Policy

The purpose of this privacy policy is to help you better understand how we store, collect, and process your personal data. This policy is meant to help you understand more about why we collect and use your data whether you’re a Coaching Genie customer or a student/subscriber to a Coaching Genie site who uses the Coaching Genie application or services (together known as, “The Services”), a participant in Coaching Genie’s partner or affiliate program, or even if you’re just visiting the Coaching Genie website.  

In particular, by visiting this website you consent to our collection and use of your personal information as described in this privacy policy, including any updates or revisions to this privacy policy. This policy does not apply to information collected by any third party, including through any application or content that can be accessible from this website. 

Changes to this Privacy Policy

Coaching Genie has the discretion to update this privacy policy at any time. When we do, we will revise the updated date. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Privacy Shield Framework

We participate in and comply with the EU-U.S. and Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Data transferred from European Economic Area (“EEA”) member countries, Switzerland and the United Kingdom (UK) to the United States.

This Privacy Policy sets forth our policy with respect to information that can be associated with or which relates to a person and/or could be used to identify a person (“Personal Data”) that is collected from Users on or through the Services.

CCPA Disclosure

Under the California Consumer Privacy Act of 2018 (CCPA), Coaching Genie must affirmatively inform California consumers of the categories of personal information collected about the consumer, the sources from which that information is collected, the commercial or business purpose for which the personal information is collected, the categories of third parties the information will be shared with, and specific pieces of personal information collected about the consumer.

Who We Are

We are a data Processor and Collector. We process data received from our website and services and take proportionate precaution in storing such information for short periods on our secure servers until permanently destroyed.

PURPOSE FOR USING YOUR INFORMATION

How we use collected information:

Coaching Genie collects and use user personal information for the following purposes: 

  1. To improve customer service 
  2. The information provided helps us respond to customer service requests and support needs more efficiently. 
  3. To personalize user experience 
  4. We use information in the aggregate to understand how our users as a group use the services and resources provided on our Site. 
  5. To improve our Site 
  6. We use feedback provided to improve our products and services. 
  7. To process payments 
  8. We use the information users provide about themselves when placing an order only to provide service to that order. We do not share this information with outside parties except to the extent necessary to provide the service. 
  9. To run a promotion, contest, survey or other Site feature 
  10. To send users information they agreed to receive about topics we think will be of interest to them. 
  11. To send periodic emails

PLEASE NOTE: We never email Coaches’ clients (other than to deliver a module or event reminder), share or use their information for ANY purposes.

We use the email address to send User information and updates pertaining to their order. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.  

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, our Platform has collected the following categories of personal information from its consumers within the last twelve (12) months:

1. Category A: Identifiers a. Examples: A real name, Internet Protocol address, email address, or other similar identifiers. b. Collected: YES 

2. Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). c. Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. d. Collected: YES 

3. Category C: Protected classification characteristics under California or federal law. e. Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). f. Collected: YES

We obtain the categories of personal information listed above from the following categories of sources: 

1. Directly from you. For example, from forms you complete on our Platform. 

2. Indirectly from you. For example, from observing your actions on our Platform or interactions with our advertisers.  

Required Personal Information

Where we are required to collect certain Personal Information by law or under the terms of a contract with you or your employer or prospective employer, and you fail to provide that data when requested, we will not be able to perform under the respective contract and will not be able to provide access to or use of the Services.

Cookies, Automatic Data Collection and Related Technologies

Our Site uses “cookies” to enhance User experience. A User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. Users choose to set their web browser to refuse cookies or to alert users when cookies are being sent. If this is done then note that some parts of the Site will not function properly. Our third-party advertisers use cookies to track your prior visits to our websites and elsewhere on the Internet in order to serve you targeted ads.

We collect cookies or similar tracking technologies. This means information that our website’s server transfers to your computer. This information can be used to track your session on our website. Cookies will also be used to customize our website content for you as an individual. If you are using one of the common Internet web browsers, you can set up your browser to either let you know when you receive a cookie or to deny cookie access to your computer. Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

We also use cookies to attribute visits to our websites to third-party sources and to serve targeted ads from Google, Facebook, Instagram and other third-party vendors. We use cookies to recognize your device and provide you with a personalized experience. We also use automated tracking methods on our websites, in communications with you, and in our products and services, to measure performance and engagement.  

Disabling Cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. Details on how to review your cookie settings and disable cookies on the most popular browsers are given on their respective websites.

Information We Share

We do not sell, trade, or rent a User’s personal identification information to others. We do share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We do not use third-party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We will share information with these third parties for those limited purposes provided that users have given us permission.

Payment Transactions

Financial transactions relating to our website and services will be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

We will disclose your personal data to any member of our group of companies, this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

We will disclose your inquiry data to one or more of those selected third-party suppliers of services via APIs identified on our website for the purpose of enabling them to connect your account with their Services. Each such third party will act as a data controller in relation to the inquiry data that we supply to it. Each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.  

Categories of Personal Information Coaching Genie Collects

Personally Identifiable Information is information that identifies a specific person. When you engage in certain activities via the Company Service, including but not limited to creating an account, sending feedback, or otherwise participating in the Company Service (collectively, “Identification Activities”), we will ask you to provide certain information about yourself. We also collect the following:

  • Identity Data 
  • Contact Data 
  • Technical Data 
  • Usage Data 
  • Transaction Data 
  • Financial Data 
  • Assessment Data 
  • Profile Data 
  • Marketing and Communications Data  

If you elect to engage in an Identification Activity we will ask you to provide us with certain personal information about yourself, such as your name, address (including zip code), email address, credit card information, telephone number and/or any other information you provide to us, to process your transaction, send communications about them to you, and populate forms for future transactions. When you enroll in the Company Service, we will also ask you to provide us with additional information, such as credit card information. Depending on the Identification Activity, some of the information we ask you to provide will be identified as mandatory and some identified as voluntary. If you do not provide mandatory information for an Identification Activity, you will not be permitted to engage in that Identification Activity with the Company Service. Depending on the Identification Activity, Company might not re-ask you for Personally Identifiable Information if such are already stored with us. If you enroll in the Company Service through a third party (such as Facebook or Google) then Company will receive Personally Identifiable Information from such third party and by using the Company Service, you consent to such receipt of Personally Identifiable Information and its use pursuant to this Privacy Policy by Company. 

Non-Personally Identifiable Information. Non-Personally Identifiable Information is information that does not identify a specific person. This type of information may include things like the Uniform Resource Locator (“URL”) of the website you visited before coming to the Company Service or otherwise participating in the Company Service, the URL of the website you visit after leaving the Company Service, the type of browser you are using, your Internet Protocol (“IP”) address, mobile carrier information, mobile device information, or general and/or aggregated location data that does constitute Personally Identifiable Information. We, and/or our authorized Third-Party Service Providers, may automatically collect this information when you visit or use the Company Service using electronic tools like Cookies and Web beacons or Pixel tags, as described below in this Privacy Policy. Most of the other information we collect for mobile, such as your mobile device identification and mobile device type, the request type, your mobile carrier, your mobile carrier user identification, and the content of your request, does not by itself identify you to Company, though it may be unique or consist of or contain information that you consider personal. We use Non-Personally Identifiable Information to troubleshoot, administer the Company Service, analyze trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We will also share this information with our authorized Third-Party Service Providers to measure the overall effectiveness of our products and services.

Data Transfers to the United States

Please note that as part of our service, we transfer your personal information to other regions, including to Canada and the United States. In order to exercise these rights, please reach out to us using the contact information below.

Voluntary Disclosure of Information to Third Parties Who Are Not Our Suppliers

You may choose to provide personal information to website visitors or other third parties who are not our suppliers. Please use caution when doing so. The privacy policies and customs of these third parties determine what is done with your information.

Data Retention

Our data retention policies and procedure are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall be kept until such time as we receive a request for deletion from you. This time period shall not exceed eighteen (18) months.

Notwithstanding the other provisions, we will retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Your Legal Rights

Your principal rights under data protection law are:
(a) The right to access;
(b) The right to rectification;
(c) The right to erasure;
(d) The right to restrict processing;
(e) The right to object to processing;
(f) The right to data portability;
(g) The right to complain to a supervisory authority; and
(h) The right to withdraw consent.

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting your profile when logged in. 

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. 

In some circumstances you have the right to the erasure of your personal data without undue delay, and at the latest within one month of receiving your valid request. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully process. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.  

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. 

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. 

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.  

To the extent that the legal basis for our processing of your personal data is: 

(a) Consent; or 

(b) That the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. 

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.  

How to Opt-Out of Future Communications

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and sending us a message. 

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request. 

Security of Your Information

You can access your Personally Identifiable Information via the Company Service with your password and username. This password is encrypted. We advise against sharing your password with anyone.  

If you access your account via a third-party site or service, you may have additional or different sign-in protections via that third-party site or service. You need to prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-in mechanism appropriately and limiting access to your computer, browser, or mobile device by signing off after you have finished accessing your account. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.  

If we believe that the security of your information may have been compromised, we may seek to notify you of that development. In addition, your Personally Identifiable Information resides on a secure server that only selected personnel and contractors have access to.  

We encrypt certain sensitive information using Secure Socket Layer (SSL) technology to ensure that your Personally Identifiable Information is safe as it is transmitted to us. However, no data transmission can be guaranteed to be 100% secure. As a result, while we employ commercially reasonable security measures to protect data and seek to partner with companies that do the same, we cannot guarantee the security of any information transmitted to or from or via the Company Service, and we are not responsible for the actions of any third parties that may receive any such information.

Children’s Privacy

If you are a minor, please do not provide us or other website visitors with any personal information and do not use this website. We do not knowingly provide services or sell products to children. If you are below the age of 16, you may use our website only with the permission and active involvement of a parent or legal guardian. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we have any information from or about a child under 13, please contact us at [email protected] 

External Links

Users will find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services will have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.

Notice to Job Applicants

If you apply to Job from our website, we will request that you give us personal information which will include but not limited to: name, personal email address, telephone number, postal address, education, employment history and any other information included in a resume, cover letter or personal LinkedIn profile, gender, race or ethnic origin, veteran status, disability status and information relating to references.

EU-US Privacy Shield Participation

The Company participates in the EU-U.S Privacy Shield Framework (“Privacy Shield”), and has self-certified with the U.S. Department of Commerce that we adhere to the Privacy Shield Principles. The Company is committed to applying the Privacy Shield Principles to all personal information received from countries in the European Economic Area (EEA) in reliance on the Privacy Shield. To learn more about the Privacy Shield, visit the U.S. Department of Commerce’s Privacy Shield website. 

Under the Privacy Shield, the Company is responsible for the processing of personal information it receives and subsequently transfers to a third party acting for or on its behalf. The Company is liable for ensuring that the third parties we engage support our Privacy Shield commitments. 

The U.S. Federal Trade Commission has regulatory enforcement authority over the Company’s processing of personal information received or transferred pursuant to the Privacy Shield Framework. 

To learn more about the Privacy Shield, visit the U.S. Department of Commerce’s Privacy Shield website. 

Anti-spam Policy

We hate unsolicited commercial e-mail as much as you do. Also known as Spam or junk e-mail, it is a disservice to the Internet community. If you subscribe to electronic newsletters or other communications from us or our website, you will always have an option to unsubscribe immediately. 

We fully endorse and comply with the requirements of Canada’s anti-spam legislation (CASL) and CAN-SPAM Act of 2003 (Controlling the Assault of Non-Solicited Pornography and Marketing Act), and all other applicable unsolicited commercial e-mail laws. 

Anti-spam Policy

We hate unsolicited commercial e-mail as much as you do. Also known as Spam or junk e-mail, it is a disservice to the Internet community. If you subscribe to electronic newsletters or other communications from us or our website, you will always have an option to unsubscribe immediately. 

We fully endorse and comply with the requirements of Canada’s anti-spam legislation (CASL) and CAN-SPAM Act of 2003 (Controlling the Assault of Non-Solicited Pornography and Marketing Act), and all other applicable unsolicited commercial e-mail laws. 

Complaints and Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Coaching Genie

Milana.com, LLC

2536 Eastern Blvd, Box 108

York, Pennsylvania 17402  

Email: [email protected]