Data Protection Information Notice To Users

AMENDED February 2021
‍Data Protection Policy (GDPR)
 
This data policy is for Coaching Evolution International Ltd (hereinafter, "the Academy", “we”, “our” or “us”) which currently operates the following sites:
·coachingevolution.org
·coachingevolutionacademy.org
·coachingevolutionacademy.com
·pamelacaravas.com·coachgo.org
·pr-brandifesto.com

We respect your privacy and are committed to protecting your information. The data policy below discloses our practices regarding information collection and usage for the above sites, applies for current operating sites, and may apply also to other relevant brand products deriving from Coaching Evolution International Ltd. This Data Policy (“Policy”) defines the basic details of the relationship between the personal data of users, visitors and generally those interacting with this website and aims to inform them concerning how and why we collect, store, disclose and use your personal data as well as the controls, rights and options, that are available to you in terms of time and manner of choosing to disclose your personal data (please check pages with additional information for the complete picture).

We would like to thank you for your cooperation and to assure you that we are committed to protecting the security, accuracy and confidentiality of personal data and to inform you of the following:

1. WHAT PERSONAL DATA DO WE COLLECT AND PROCESS?

Your provision of your personal information to us is completely voluntary. “Personal information” is information that can specifically identify you. We do not collect personal information unless you submit that information to us.

Depending on the purpose for which we process your data from time to time, we need to process one or more of your data, which will generally be, as appropriate, the following:
(i) your identity data (for example, your name, surname, language and country from which you interact with us, contact information, etc.)
(ii) financial information and transaction information (for example, payment or card details, purchase information, orders, refunds, etc.)
(iii) login data, geographic location, and internet browsing (if you contact us, for example, with your mobile)
(iv) Profile Data, which includes your username and password, avatar (if you upload one) and other information you share with us on our Websites (Site).
(iv) Commercial information (for example, if you have subscribed to our newsletter), information about your tastes and preferences.

Please notice that when we ask you to fill in your personal data to access any function or service of the Site, we will point out certain fields as mandatory, as these are data we need to be able to provide the service or give you access in this function. Please keep in mind that if you decide not to provide this information to us, you may not be able to complete your registration as a user or you may not be able to enjoy the services or features.

2. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

Depending on how you interact with our Site, e.g. depending on the services, products, or features you want to receive, we will process your personal data for the following purposes:
2.1. To manage your registration as a user of the Site.
If you decide to register as a user on our Site, we need to process your data to recognise you as a user of the website and to give you access to the various features, products and services which are available to you due to your status as a registered user. You can cancel your registered user account by contacting us through our Client Concierge Service.
2.2. For the development, fulfillment and performance of the sales or service contract you have entered into with us on the website.
This purpose includes processing your data, mainly to: (a) Communicate with you about the updates or informational notifications related to the contract-related functions, products or services, including the sending of quality surveys and in order to determine the client’s satisfaction degree with the service provided, to request marketing material to be sent to you; or give us feedback. (b) Manage the payment for the products and / or services you buy, regardless of the payment process that isused. For example: If you choose to enable the storage of your card data for future purchases when you buy one of our products through the website, we need to process the data indicated to activate and develop that feature. Consent to enabling this feature allows automated payment data to appear on subsequent purchases so you do not have tore-enter them in each new process and these data will be considered valid and active for future purchases. You can modify or cancel your cards at any timethrough the section corresponding to the payment information.

By submitting your paymentinformation through our websites, to the extent permitted by applicable law,you expressly consent to the sharing of your information with third-partypayment processors, and other third-party service providers. Third parties towhom we may choose to sell, transfer, or merge parts of our business or ourassets. Alternatively, we may seek to acquire other businesses or merge withthem, if we are part of a bankruptcy proceeding or other change in control.Third parties to whom we need to share your information to investigatesuspected fraud, harassment or other violations of any law, rule or regulation,or the policies for the website.(c) Activate the necessarymechanisms to avoid possible fraud against you and against us during thepurchase process.If we believe the transactionmay be fraudulent, this processing may result in blocking the transaction.(d) Manage potential returnsonce you have made a purchase and manage requests for product availability,product booking via the platform, or to provide you with services related toPersonal Tailoring, depending on the availability of these options.(e) For pricing purposes and tomake available to you tickets and invoices for purchases made through thewebsite.2.3. Respond to requests andapplications you submit via Client Concierge Service channels.We only process personal datathat is absolutely necessary to manage or resolve your request or application,to answer your questions and, if you wish, to send you personalisedcommunications.2.4. For marketing purposes.We strive to provide you withchoices regarding certain personal data uses, particularly around marketing andadvertising. This purpose includes processing your data, mainly: While yousubscribe to our Newsletter, we will process your personal information tomanage your registration, including sending personalised information about ourproducts or services through various means (such as email or SMS). We may alsoprovide you with this information via push notifications if you have themactivated on your personal computer, tablet, mobile device or other electronicdevice you use to access these services. Respectively, keep in mind that thisdata processing involves analysing your profile as a user or client todetermine what your preferences are and, therefore, which products and servicesmost fit your style when sending information to you. For example, based on yourpurchases and your browsing history (i.e. depending on the products you clickedon), we will make suggestions for products that we believe may be of interestto you and, if you are a registered user, we will provide you with “basketretrieval”.Keep in mind that you canunsubscribe from the newsletter at any time and at no cost through theNewsletter section of the Site and through the instructions provided for eachupdate. If you do not want to receive push notifications, you can disable thisoption on your mobile device, tablet or PC.We conduct promotions (forexample, to organise competitions or to send a list of products you have savedto the email address you specify). By participating in any promotional action,you authorise us to process the personal data you have shared with us accordingto the promotional action and we may share it through various means such associal networks or the Site itself. In any promotional action you participate,you will be provided with the terms and conditions where we will provide youwith more detailed information about processing your data. The same applies forall our Brands, as per the present  company’s terms and conditions.

2.5. Usability and qualityanalysis to improve our services.
By entering our Site, we informyou that we will process your browsing data for purposes of analysis andstatistical purposes, that is, to understand how users interact with our Siteand so that we can make improvements to it. Additionally, we sometimes carryout quality surveys and actions aimed at knowing the degree of satisfaction ofour clients and users and identifying those areas where we can improve.

3. CHANGE OF PURPOSE

We will only use your personaldata for the purposes for which we collected it, unless we reasonably considerthat we need to use it for another reason and that reason is compatible withthe original purpose. If you wish to get an explanation as to how theprocessing for the new purpose is compatible with the original purpose, pleasecontact us at concierge@coachingevolution.org . If we need to use your personal data for an unrelatedpurpose, we will notify you and we will explain the legal basis which allows usto do so. Please note that we may process your personal data without yourknowledge or consent, in compliance with the above rules, where this isrequired or permitted by law.

4. COLLECTION OF PERSONAL DATA FROM THIRD PARTY SOURCES

We also collect personal dataabout you from various third parties and public sources. If you register forour services using Learnworlds or any other social media fora,like Facebook, Twitter or other social media sites, we will import yourinformation from those social media sites.

5. INFORMATION YOU SHARE

Please keep in mind thatwhenever you voluntarily make your Personal Information available to thirdparties — for example on message boards or web logs; through email; duringwebinars, classes, telephone conferences, or coaching calls; or in comment orchat areas — that information can be seen, collected, heard, and/or used byothers besides us. We cannot be responsible for any unauthorised third-partyuse of such information.

6. HOW WE PROTECT THE INFORMATION

We take commercially reasonablesteps to protect the Information from loss, misuse, and unauthorised access,disclosure, alteration, or destruction. Please understand, however, that nosecurity system is impenetrable. We cannot guarantee the security of ourdatabases, nor can we guarantee that the Information that you supply will notbe intercepted while being transmitted to and from us over the Internet. Inparticular, e-mail sent to or from the Websites may not be secure, and youshould, therefore, take special care in deciding what information you send tous via email.

7. WHAT ARE THE LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA?

We collect, process and storeyour personal data primarily for (a) the satisfactory performance of the salesor service contract, (b) the compliance of the Company with its legalobligations, (c) the legitimate interests pursued by the Supervising Authorityor any other third party, legally entitled to access or request your data.The legal basis for processingyour personal data also depends on the purpose for which we process them.Particularly:i. In order to manage yourregistration as a user of the Site, we process your data because it isnecessary to implement the terms governing the use of the website. In otherwords, in order to be able to register you as a user on the website, we need toprocess your personal data, otherwise we would not be able to manage yourregistration.ii. For the purpose ofdeveloping, performing and executing the purchase or service contract. Weprocess your data because it is necessary to perform the contract of purchaseor service with you. Some data processing related to the purchase process isonly triggered because you request or approve it, such as storing payment datafor future purchases or to provide you with the Coming soon / Back soon. Inthese cases, processing your data is based on your own consent.We believe that we have alegitimate interest in conducting the necessary checks to detect and preventpossible fraud when making a purchase. We understand that processing this datais a positive sign for all parties involved when paying for a purchase,especially for you, as this allows us to take action to protect you fromattempts of fraud by third parties.iii. For the purpose of ClientConcierge ServiceWe believe that we have alegitimate interest in responding to requests or queries raised by you throughthe various existing communication channels. We understand that processing thisdata is also beneficial to you as long as it allows us to help you adequatelyand answer the queries you raise. When you contact us, especially to manageevents related to your order or to the product / service acquired via the Site,processing your data is necessary for the performance of the purchase contractor the service. When your query relates to the exercise of your rights forwhich we inform you below or claims about our products or services, we arelegally qualified to process your data in order to comply with our legalobligations.iv. In terms of marketingpurposesWe are legally authorised toprocess your data for marketing purposes because of your consent, for example,when you agree to receive personalised information through a variety of media,when you authorise us to send push notifications to your mobile device, tabletand/or PC, or when you accept the legal terms and conditions to participate ina promotional action. In order to show you personalised information, we believethat we have a legitimate interest in setting up a profile with the informationwe have about you (such as your browsing, preferences, or purchase history) andthe personal data you gave us, such as the range age or language since weunderstand that processing this data is also beneficial to you because itallows you to improve your user experience and access information according toyour preferences.v. Usability and qualityanalysisWe believe that we have a legitimateinterest in analysing the usability of the Site and the degree of usersatisfaction as we understand that processing this data is also beneficial toyou because its purpose is to improve user experience and provide higherquality service.

8. WHAT RIGHTS DO YOU HAVE?

The rights granted to you underthe applicable law are as follows:– Right of accessYou have the right to beinformed and request access to your personal data that we are processing.– Right to rectificationYou have the right to request tomodify or update your personal data if it is inaccurate or incomplete.In any case, you should keep inmind that by actively providing your personal data to us in any way, youwarrant that these are true and accurate and you agree to notify us of anychange or modification. Exclusive responsibility for any losses or damagescaused to the Site or the person responsible for the Site or any third party,due to filling in incorrect, inaccurate or incomplete information on theregistration forms, shall be borne by the user. Please notice that as a generalrule you should only provide your own personal data, not third party data,except to the extent permitted by this Privacy Policy and Cookies.– Right to deleteYou have the right to ask us todelete your personal data to the extent that it is no longer necessary for thepurpose for which we must continue to process it as we have already statedabove or when we are no longer legally qualified to process it.– Right of limitationYou have the right to ask us tocancel or restrict the processing of your personal data, which means that insome cases you may ask us to temporarily suspend the processing of the data orto keep it beyond the required time when you need it.– Right to withdraw consentIf you have given us yourconsent to process your data for any purpose, you also have the right towithdraw it at any time.– Right of objection(i) You have the right to objectat any time to our processing of your personal data, based on reasons relatingto your personal circumstances.(ii) You have the right tooppose the processing of your personal data for direct marketing purposes.– Data portabilityYou have the right to request acopy of your personal data in electronic form and to transfer this personaldata to a third party’s service.– Right not to be subject to automated decision-makingYou have the right not to besubject to a decision-based solely on automated decision-making, such asprofiling, if the decision would have legal implications for you or otherequally important implications.

9. HOW TO EXERCISE YOUR RIGHTS

i. The above rights may beexercised by telephone or by sending a letter or e-mail to the Company’s DataProtection Officer, whose contact details are listed above.– Right to lodge a complaintIf you believe that your Privacyis in violation of the law, you have the right to lodge a complaint with therelevant regulatory authority.If you are situated in the EUand have any complaints regarding our privacy practices, you have the right tomake a complaint at any time to your local Supervisory Authority. We would,however, appreciate the chance to address any of your concerns before youapproach your Supervisory Authority, so please contact us in the first instanceat info@coachingevolution.org. If you are situated in the EU and have a complaint, pleasecontact our privacy manager at concierge@coachingevolution.orgii. You will not have to pay afee to access your personal data (or to exercise any of the other rights).However, we may charge a reasonable fee if your request is clearly unfounded,repetitive or excessive. Alternatively, we may refuse to comply with yourrequest in these circumstances.iii. We may need to requestspecific information from you to help us confirm your identity and ensure yourright 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 anyperson who has no right to receive it. We may also contact you to ask you forfurther information in relation to your request to speed up our response.We try to respond to alllegitimate requests within one month. Occasionally it may take us longer than amonth if your request is particularly complex or you have made a number ofrequests. In this case, we will notify you and keep you updated. To exerciseyour rights, please contact us at concierge@coachingevolution.org.

10. OPTING OUT

To opt-out of any futurepromotional messages from us, you should send an unsubscribe request to usto concierge@coachingevolution.org or click on the unsubscribe indicationon the Site or in the newsletters. If you do not want your personalinformation or personal data shared with any third party who may use suchinformation for direct marketing purposes, then you may opt out of suchdisclosures by sending an email to concierge@coachingevolution.org using the subject title“opting out”. We will process your request within a reasonable time afterreceipt. Please note that if you opt out in this manner, certain aspects of theSite may no longer be available to you.Opting out of CookiesIf you want to stop or restrictthe placement of cookies or flush any cookies that may already be on yourcomputer or device, please refer to and adjust your web browser preferences. Bydeleting our cookies or disabling future cookies you may not be able to accesscertain areas or features of our Site or some of its functionality may beaffected. Cookies and similar items are not used by us to automaticallyretrieve personally identifiable information from your device without yourknowledge.

11. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

We retain your personal dataonly for as long as it is necessary to provide you with our services as well asfor legitimate and meaningful business purposes such as making businessdecisions based on data about new features and offers to comply with our legalobligations and to resolve disputes.In particular, the retentiontime of your data will depend on the purposes for which we process it:i. As to the purpose of managingyour registration as a user of the website.We will process your data forthe time you remain a registered user (i.e., until you decide to unsubscribe).ii. For the purpose ofdeveloping, performing and executing the purchase or service contract.We will process your data forthe length of time required to manage the purchase of the products or servicesyou have acquired, including any refunds, complaints or claims relating to thepurchase of the particular product or service. Sometimes we will process thedata only until you decide, as is the case with the payment data (card) youhave requested to store for future purchases.iii. For the purpose of ClientConcierge Service.We will process your data for aslong as we need to meet your request or application.iv. In terms of marketingpurposes.We will process your data untilyou unsubscribe or cancel your subscription to the Newsletter. If youparticipate in promotions, we will retain your data for a period of 6 monthsafter the end of the action.v. For the purpose of usabilityand quality analysis.We will process your data duringthe period in which we will perform an action or a specific quality survey oruntil we have rendered your browsing data anonymous.Regardless of how we processyour data, and regardless of the fact that we process your data only for theamount of time strictly necessary to achieve the intended purpose, we will keepit properly stored and protected for the length of time during which dataprocessing issues could arise, in accordance with the legislation in force onthe aforementioned length of time. As soon as the limitation period for eachclaim expires, we will delete the personal data.If you request it, we willdelete or render anonymous your personal information so that we can no longeridentify you unless the law permits otherwise or requires us to retain certainpersonal data, including cases such as:– If there is an unresolved problem with your account, a pendingcredit in your account, or a claim or dispute that has not been resolved, wewill maintain the necessary personal data until the problem is resolved.– Since we have to maintain your personal data for legal, tax,audit, and accounting purposes, we will maintain the necessary personal datafor the period required by applicable law.– Wherenecessary for our legitimate business interests, such as preventing fraud ormaintaining the safety of our users.

12. TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?

For the purposes of our Privacy Policy andCookies, it is necessary to provide access to your personal information tothird parties who provide us with support for the services we offer, namely:

  • Financial Institutions,

  • Fraud detection and prevention agencies,

  • Technological service providers,

  • Associates and service providers, transport and delivery,

  • Service Providers related to Client Concierge Service,

  • Partners and Service Providers related to Marketing and Advertising.

    13. THIRD-PARTY LINKS AND SOCIAL NETWORKING SERVICES

    This Site may include links tothird-party websites, plug-ins and applications. Clicking on those links orenabling those connections may allow third parties to collect or share dataabout you. We do not control these third-party websites and are not responsiblefor their privacy statements. When you leave our website, we encourage you toread the privacy policy of every website you visit.The Site may integrate withsocial networking services. You understand that we do not control such servicesand are not liable for the manner in which they operate. While we may provideyou with the ability to use such services in connection with our Site, we aredoing so merely as an accommodation and, like you, are relying upon thosethird-party services to operate properly and fairly.You should be aware thatinformation which you voluntarily include and transmit online in a publiclyaccessible blog, social network or otherwise online may be viewed and used byothers. We are unable to control such uses of your information, and by usingsuch services you assume the risk that the information provided by you may beviewed and used by third parties.

    14. COOKIES, INTEREST BASED ADVERTISING, CLICKSTREAM DATA

    We use cookies and similardevices / instruments to make it easier for you to browse the Site tounderstand how you interact with us and, in some cases, to be able to show youads based on your browsing habits. Herein via our Cookies Policy we help youunderstand in more detail the cookies and similar devices we use, their purposeand other information that may interest you.Cookies and similarinstruments and technologies: The Site may use cookies, a type of technology thatinstalls a small amount of information on a website user’s computer or otherdevice to permit a website to, for example, recognise future visits using thatcomputer or device. The website may use other similar technologies (including,without limitation, tracking pixels, as described further below, and otheranonymous identifiers) to gather information about you, such as IP addressesand location data, to customise your visit, to enable us to enhance ourservice, or for other purposes. We use the following cookies: (i) Strictlynecessary / technical cookies that are required for the operation of our Site,including log-in, shopping cart and e-billing. (ii) Analytical / performancecookies to see how users interact with our Site so that we may improvefunctionality. (iii) Functional cookies to recognise you when you return and topersonalise content. (iv) Targeting / advertising cookies to tailor advertisingto you based on how you interact with our Site.Interest-BasedAdvertising: We may engage third-party vendors to use your informationin connection with their own information to deliver targeted advertising to youwhen you visit our Site or other websites. Cookies, described above, may beused in this process. For example, if you are searching for information on aparticular product, our vendor may cause an advertisement to appear on otherwebsites you view with information on that product. This form of advertising iscalled “behavioural advertising”. We believe that such advertising is helpfulbecause you will see ads that are relevant to your interests. However, if youwould like to opt out of these interest-based advertisements, please see theOpt-Out section above.ClickstreamData:As you use the Internet, a trail ofelectronic information is left at each website you visit. This information,sometimes referred to as “clickstream data,” can be collected and stored by awebsite’s server. For example, clickstream data can tell the type of computerand browsing software you use and the address of the website from which youlinked to the website. The website may collect and use clickstream data as aform of aggregate information to anonymously determine how much time visitorsspend on each page of our website, how visitors navigate throughout the Siteand how we may tailor our Site to better meet the needs of visitors. Thisinformation often will be used to improve our Site and our services. Anycollection or use of clickstream data will be anonymous and aggregated and willnot intentionally contain any personal information.

    15. DATA RELATING TO CHILDREN

    Our Site is designed for those 16 years of ageand older. We do not knowingly collect information from anyone under the age of13 (or such other age as may be restricted under local law). If we are madeaware that we have received such information, or any information in violationof our policy, we will make reasonable efforts to locate and remove that informationfrom our records.

    16. UPDATES IN PRIVACY POLICY AND COOKIES

    We reserve the right, at our discretion, tochange, modify, add, or remove portions from this privacy policy at any time.We may modify the information contained in this Privacy Policy and Cookies whenwe deem it necessary. If we do, we will notify you in various ways via the Site(for example, via a banner, pop-up window, or push alert), or we may even sendyou a notification to your email address when this change is important for yourprivacy, so that you can review changes, evaluate them and, if necessary,oppose or unsubscribe from a service or feature. In any case, we encourage youto review this Privacy Policy and Cookies from time to time if we make minorchanges or introduce some interactive improvement by taking advantage of thepossibility that you will always find it as a permanent point of information onour website.

    CONTACT US

    If there are any questionsregarding this privacy policy, you may email them at concierge@coachingevolution.org or send them by registered letter to 71-75 Shelton St,London, WC2 H9JQ UK.

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