LAST UPDATED – March 12, 2020
PRIVACY POLICY
INTRODUCTION
Your privacy and trust is very important to us. We are committed to maintaining the accuracy, confidentiality, and security of your personally identifiable information (“Personal Information”). Accordingly, Impact Coaching Inc. has developed this privacy policy in order for you to understand how we collect, use, and disclose your Personal Information. Our privacy policy complies with Canadian Federal and Provincial privacy laws and regulations including Canada’s Privacy Act and Personal Information and Electronic Documents Act.
Your use of our website signifies your acknowledgment and consent to our privacy policy. If you do not agree to this privacy policy, please do not continue to use our website. Your continued use of the website signifies your acceptance of these terms and any changes in effect at the time of use.
WHY WE COLLECT YOUR PERSONAL INFORMATION
We collect, use and disclose Personal Information to provide you with the product or service you have requested and to offer you additional products and services we believe you might be interested in.
PRIVACY GUIDING PRINCIPLES
We conduct our business in accordance with the following privacy principles in order to ensure that Personal Information is protected and maintained.
- Before or at the time of collecting Personal Information, we will identify the purposes for which information is being collected.
- We will collect and use Personal Information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
- We will collect Personal Information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
- We will maintain the accuracy and completeness of the Personal Information collected
- We will protect Personal Information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
- We will make readily available to customers information about our policies and practices relating to the management of Personal Information.
WHAT PERSONAL INFORMATION IS BEING COLLECTED
When we refer to the collection of “Personal Information” in this privacy policy, we are referring to both “Order Information” and “Device Information.”
Order Information is personal contact information such as your name or e-mail address, that you voluntarily provide when you request a product or service on the website (e.g. download an article, register for one of our courses, apply to become a member of our Coaching Circle Community of Practice). We may also ask you for personal contact information if you want to obtain additional services or information, participate in a survey or resolve complaints or concerns.
Additionally, when you make a purchase (e.g. for a document or a course) through our on-line store, we authorize certain third party providers to collect Order information from you on our behalf (e.g. your name, billing address, shipping address, email address and telephone number) so that we can fulfill your order. For example, we work with WooCommerce.com to provide us with the online e-commerce platform that allows us to sell our products and services to you. Our e-commerce platform does not collect or store your credit card data. All direct payments are conducted through Stripe.com, which adheres to the Payment Card Industry Data Security Standard (PCI-DSS), as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
Device Information including your web browser and IP address is automatically-collected when you visit the website. Additionally, as you browse the website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to our website, and information about how you interact with the website. This information is collected via Google Analytics and it not your personal information, but rather an aggregate set of data collected by Google on our website users navigational experience. We review reports that exclude your personal navigation of our website.
We collect Device Information using the following technologies:
- “Cookies” are data files that are commonly placed on your device and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Pixels” are electronic files used to record information about how you browse the website that we use for Facebook remarketing purposes.
WHAT WE DO WITH YOUR PERSONAL INFORMATION
We use the Order Information that we collect to communicate with you (e.g. respond to questions or offer other types of support) and provide you with information or advertising relating to our products or services.
Additionally, we authorize providers we work with, such as WooCommerce.com and Stripe.com, to collect Order Information from you to fulfill any purchase orders placed through the website. For example, WooCommerce.com uses this information to screen our orders for potential risk or fraud, track purchase orders, arrange for shipping, and provide you with invoices and/or order confirmations. Stripe.com uses your credit card information to process your payment.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our website (for example, by generating analytics about how our customers browse and interact with the website, and to assess the success of our marketing and advertising campaigns). The information we collect automatically with the use of “cookies” is used in the aggregate for statistical data and will not include personal information.
We only process Personal Information for these legitimate reasons after considering the potential risks to your privacy – for example, by providing clear transparency into our privacy practices, offering you control over your personal information where appropriate, limiting the information we keep, limiting what we do with your information, who we send your information to, how long we keep your information, or the technical measures we use to protect your information.
CREDIT CARD DATA
We do not collect or store your full credit card information when you make a payment online. All credit card transactions are processed securely through Stripe, and at no point does Impact Coaching receive your full credit card information or store this. Therefore, your card information is completely secure and protected by Stripe.com and none of our employees have any access to your full credit card number, payment platform profile or security code whatsoever.
SHARING YOUR PERSONAL INFORMATION
In general, the third-party providers used by us will only collect, use and disclose your Personal Information to the extent necessary to allow them to perform the services they provide to us. For example, we use payment gateways and payment transaction processors, such as WooCommerce.com and Stripe.com respectively, to power our online store. We also use Google Analytics to help us understand how our customers use the website. However, all third-party service providers, have their own privacy policies in respect to the information we share with them to facilitate your purchase-related and non-purchase related transactions on the website.
Once you leave our website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service. We are not responsible for the privacy practices of other websites and encourage you to read their privacy policies so you can understand the manner in which your personal information will be handled and protected.
Privacy policy links:
- Woocommerce.com https://woocommerce.com/gdpr/
- Stripe.com https://stripe.com/en-ca/privacy
- Google Analytics https://policies.google.com/privacy
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
BEHAVIOURAL ADVERTISING
Our lawful ground of processing your Personal Information to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under Canada’s Privacy and Electronic Communications Regulations, we may send you marketing communications if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt-out of receiving marketing emails from us.
You can ask us to stop sending you marketing messages at any time by clicking on the unsubscribe link at the bottom of our emails.
If you opt-out of receiving marketing communications this opt-out does not apply to Personal Information provided as a result of purchase related transactions.
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
Facebook remarketing service is provided to us 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/about/ads/#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
DATA RETENTION
When you place an order through the website, we will maintain your Order Information for our records unless and until you ask us to delete this information. However, please note that certain Order Information allows us to support you in case you lose your username and/or password.
CHANGES
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. Changes and clarifications will take effect immediately once posted to the website.
CONSENT
Knowledge and consent are required for the collection, use or disclosure of Personal Information except where required or permitted by law. The purposes for which we collect Personal Information will be identified before or at the time we collect the information. In certain circumstances, the purposes for which information is collected may be clear, and consent may be implied, such as where your name, email, address and payment information is provided as part of the order process.
Providing us with your Personal Information is always your choice. However, your decision not to provide certain information or later withdraw your consent for us to use your Personal Information may limit our ability to provide you with our products or services. We will not require you to consent to the collection, use, or disclosure of information as a condition to the supply of a product or service, except as required to be able to supply the product or service.
ACCESS TO YOUR PERSONAL INFORMATION
We believe you should be able to access and control your Personal Information. You may request access, updating and correcting of inaccuracies to the Personal Information we have in our custody or control by e-mailing or writing to us at the contact information set out below. At the time of your request, we may need further information from you to verify your identity, before we can provide you with the personal information we hold.
Also, if you buy something from our online store and wish to exercise your rights over the Personal Information you provided to third parties responsible for processing your transaction, including Woocommerce.com or Stripe.com, you need to directly contact the provider you interacted with. We act as a gateway to their service and cannot decide how to manage their information.
EUROPEAN VISITORS’ GDPR RIGHTS
If you are within the European Union, you are entitled to certain information and have certain rights under the General Data Protection Regulation. Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
A REQUEST FROM US TO YOU
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us. Thank you.
HOW YOU CAN REACH US
If you would like to ask about or make a request relating to how we process your Personal Information, you can contact us by email at info@coachingcircles.ca