About Your Privacy
(Last Updated: Aug 2018)
Advantage Coaching & Training, Inc. is committed to protecting and appropriately handling private and personal information and takes your privacy very seriously. We are publishing this Privacy Statement to let you know how we collect, process, use and share your personal information.
The definition of “personal information” will differ depending upon applicable law. In Europe it will include all information that directly or indirectly relates to you, and includes “personal data” as defined by the General Data Protection Regulation (GDPR). Where GDPR or other EU privacy laws apply to you, this Privacy Statement details how you can exercise your rights.
We may, from time-to-time, update this Privacy Statement, so we encourage you to review it periodically.
- Using our Website
- How we use your personal information
We will generally only collect and use your personal information when it is necessary to achieve our legitimate interests of providing information, products and/or services on coaching and training offered by Advantage Coaching & Training, Inc.
We set out below a table where we describe each of the ways in which we use your Personal Information, the types of Personal Information that we use and the legal basis that applies to that use. Where the legal basis is “legitimate interest” we also set out some further details.
The legal basis and details of the legitimate interests detailed in the table below only apply where we are subject to the GDPR or other EU privacy laws.
|How we use your Personal Information||The types of Personal Information involved||Legal Basis||Legitimate Interest|
|To allow you to register and attend an event and to follow up with you after the event||Identity data; contact details; marketing/communication data||Consent when you register|
|For electronic newsletter||Identity data; contact details (email, etc);||Consent or Legitimate Interest where it follows something you have bought, given or attended||When you engage with us (for example, financially or by requesting our newsletter) the law permits us to send you relevant email marketing/news information|
|For physical communication and non-marketing electronic communication||Identity data; contact details; marketing/communication data||Legitimate Interests||To keep you informed of our offerings; to send you company information and resources which we believe you are interested in; to collect information from you to establish details for an event|
|For contact management||Identity data; contact details; marketing/communication data; requests and preferences; demographics||Legitimate Interests||To manage interest in our company products and services and manage relationships with clients and interested parties|
|To Produce Assessment Reports/Tools||Identity data; contact details; information about your personality and how you interact with others||Legitimate Interests||To provide requested assessment reports to promote growth and development|
|To deliver goods and services||Financial data; financial transaction data; contact details||Consent or Legitimate Interest where it follows something you have bought||To provide products or services you have requested|
|To respond to complaints and requests||Identity data; contact details; historical transaction data; application data||Legal obligation and Legitimate Interests||To ensure that your concerns are addressed|
You can find more information on the data types we collect in section 4 below.
- How we collect personal information
We obtain personal information about you via:
Direct interactions: when you inquire about our activities, engage in an activity with us, register for a class, order a product or service, or otherwise give us your personal information.
Third parties [or other publicly available sources]: we may from time to time obtain personal information about you from third parties [and public sources] (e.g. US Census Data). We will only collect personal information from third parties if they have obtained that information in a legal and proper way.
Referral of information by individuals: Your name and contact details may have been passed to us by someone you know, who indicated that you might be interested in hearing about our company, according to the chart in section 2.
- Types of personal information that we collect
We collect the following types of personal information:
Contact details including name, postal address, email, telephone number;
Financial data including credit card information;
Financial transaction data including details about payments from you and details of products and services you have purchased from us and activities you have participated in;
Historical transaction data including communication history, purchases, and interactions with us;
Identity data including name, date of birth, gender;
Information about your personality, characteristics and how you interact with others;
Location data that is information about your physical location, including IP address;
Marketing and communication data including your preferences in receiving marketing from us and communication preferences;
Requests and preferences including communication preferences and interests;
- How/when we disclose personal information
Generally, we will not disclose or share your personal information (including your email address) with anyone outside our company without your permission. However we may need to use or share your information with our partners and agents who provide goods and services to you on our behalf. Your information may be disclosed:
- To other parts of our Company;
- To public or regulatory authorities;
- To third party service providers, including:
- Affiliate coaches who will assist in providing coaching or training services;
- Cloud service providers for the hosting of our site;
- Direct and email marketing service providers (e.g. Constant Contact);
- Companies that assist us in processing your payments for products and services;
- Companies that assist us in the production of assessment reports; and
- Organizations that provide credentialing after applicable classes and coursework are completed
We take steps to safeguard your information and we have provisions requiring all third party service providers to respect the security of your personal data and to treat it in accordance with our data protection policies and all applicable laws. We will not allow third party service providers to use your personal information for their own purposes and they will only be allowed to process your personal information in accordance with our instructions.
- Your Rights
The following rights under the GDPR are available to you if you are located in the EEA. If you wish to exercise any of these rights, please email firstname.lastname@example.org. We will respond to your request within 30 days of accepting it. Before accepting your request we may need to ask for some identity documentation from you, to make sure we don’t inadvertently provide your personal information to someone else.
If you are not in the EU, you can still apply for one of these rights, and we will comply where the request is reasonable in our discretion.
a. Editing and updating personal information
If you find that your personal information needs to be edited or updated, or you wish to update the personal information we otherwise hold about you, you can ask us to update it by contacting us at email@example.com, or using the Contact Us page on this site. Please make sure to provide us with all the information we need to be able to address your request, including both the old and new information.
b. Accessing personal information
You can request details of your personal information we hold. We will confirm whether we are processing your personal information and provide additional details including what kind of information we have about you, how we use it, how long we expect to keep it and the safeguards regarding data transfers to non-EEA countries, subject to the limitations set out in applicable laws and regulations.
If you ask us, we will provide you with a copy of your personal information free of charge. We may charge you a fee to cover our administrative costs if you request multiple copies of the same information or if the requests are manifestly unfounded or excessive.
c. Deletion of personal information
At your request, we will delete your personal information if:
- It’s no longer necessary to retain your personal information;
- You withdraw the consent which formed the basis of your personal information processing;
- You have successfully objected to the processing of your personal information (see below);
- Your personal information was processed unlawfully; or
- We are required to delete your personal information to comply with our legal obligations
We will review requests on a case-by-case basis and we might not be able to comply with your request if we need to process your personal information:
- For exercising the right of freedom of expression and information;
- To comply with our legal obligations;
- To establish, exercise or defend a legal claim; or
- To perform a task in the public interest
If this is the case, we will notify you of the reasons your request was rejected.
d. Restriction of processing of personal information
You have the right to request us to limit the processing of your personal information if:
- You dispute the accuracy of your personal information;
- Your personal information was processed unlawfully and you request a limitation on processing, rather than a deletion of your personal information;
- We no longer need to process your personal information, but you need your personal information in connection with a legal claim; or
- You object to the processing of your personal information based on our legitimate interests pending verification as to whether we have an overriding legitimate ground for such processing
To the extent needed, we may still keep some of your data to ensure we comply with your request to limit processing, or for other legal purposes.
e. Objecting to certain types of processing including automated decision making
Where we process your personal information based upon our legitimate interests, you have the right to object to this processing on grounds relating to your particular situation if you feel it impacts on your fundamental rights and freedoms.
Where we process your personal information based upon our legitimate interests and where decisions are made by automated processing which has a legal or other significant effect on you, you may also object to such automated decision making.
f. Portability of personal information
You can request us to send you your personal information in a structured, commonly used, machine-readable format so that it can easily be transferred and used by a third party if:
- You provided us with the personal information;
- The processing of your personal information is based on your consent or required for the performance of a contract; or
- The processing is carried out by automated means.
g. Withdrawing consent
We primarily rely on legitimate business interests to process your data, but to the extent we use consent to process your data, you have the right to withdraw any consent you may have given us at any time. We will comply with your request promptly.
If you withdraw your consent, we might not be able to provide some of our products and services to you. At any point, you have the right to object to processing of your personal information for direct marketing purposes and we will promptly comply with your request.
h. Filing a complaint with a data protection authority
We will try to resolve any problems that you have but you are always able to contact your local data protection authority for assistance or to make a complaint.
- International transfer of your personal information
We conduct business internationally and we might need to transfer your personal information to other countries. If you are in the European Economic Area (EEA), please be aware that we may need to transfer your data to countries outside the EEA to process it. We will only transfer your personal information outside the EEA with adequate safeguards in place and in full compliance with applicable laws.
We have put in place appropriate security measures to protect your personal information from being accidentally lost, misused or accessed in an unauthorized way, altered or disclosed. These include technical, administrative and physical security measures to ensure that any information we collect is stored and processed securely.
Network and Server Security practices include:
- A firewall with a stateful packet inspection;
- Layered infrastructure access control credentials;
- Software enforced data access policies;
- SSL encryption of sensitive server data communication;
- Current server and workstation OS software
All credit card payments are processed using PCI compliant technology, to ensure that your credit card number is securely passed to the merchant/service provider.
We have procedures to deal with any suspected personal data breach and we will promptly notify you and any applicable regulator of a breach in accordance with our legal obligations.
We cannot guarantee that the security measures we implement in connection with the operation of the site will absolutely prevent others from accessing or acquiring any information that you provide while using the site.
- Cookies and information collected by technology
- How long we keep your personal information
We keep your information as long as it is needed to achieve our purposes listed above, as well as for the amount of time necessary to meet any legal, tax, or reporting requirements. We will ensure that your privacy continues to be protected and only use it for these purposes.
- Third party sites and information
If you have any questions about this policy or the way we use your personal information, you may contact:
Phone: +1 (630) 293-0210
Advantage Coaching & Training, Inc.
122 N. Wheaton Ave.
PO Box 1529
Wheaton, IL 60187