Prelude

Personal identifiable information, other than the amount of sessions, from Authorized Users of Coachello will never be shared with our Customers. Coaching is a confidential and private matter.

Introduction

Coachello is committed to protecting your personal data. We tried to write down this Privacy Policy in the most clear and plain language possible. Likewise, we tried to provide you with our privacy commitments in a transparent and easily accessible way. That said, we hope you will get all needed details to be assured your personal data is safe with us.

Before you give us your consent on the processing of your personal data or provide us with your personal data within any form on our website, we kindly ask you to read this Privacy Policy, so we can be sure that you completely understand the conditions under which we would cooperate.

This Privacy Policy applies to your use of the Services, as defined in our Terms and Conditions, of Coachello. Whenever possible, Coachello provides options concerning data we process, use and share.

This Privacy Policy explains when, where, and why we process personal data about people who use Coachello, how we use it, the conditions under which we may disclose it to others, your rights in respect of your personal data, as well as how we keep it secure.

What information we collect

As a visitor on our website

Anyone can access our Website without the necessity to register an account. Therefore, limited use of the Services is always possible without the provision of your personal details (for example, browse the Website, check how Coachello works, read the Coachello Blog, review the variety of services etc.). However, whenever you access the Website we collect log information and put cookies on your device, by which we track your activity on the Website. You can always opt out from cookies except from those, without which the Website cannot work.

Directly from you, as an Authorized User, when your register and interact with the Services

When acceding Coachello through a Third Party Service (like Outlook or Gmail), the Third Party Service will share certain information with Coachello in accordance with your privacy settings that is necessary for authentication and account registration, such as your name, email, and social network ID (MS Teams and Slack), time zone, interface language, as well, that may be processed by Coachello for its Services.

Indirectly, when you interact with the Services Coachello provides:

Coachello collects and processes information you provide when using our Services. For example, when you ask questions through our application or get advice from a coach when using Coachello’s asynchronous coaching module. In addition, prior to booking your coaching session you may take an assessment. We use your responses to this assessment to create an assessment report and, in combination with other personal information, Coachello’s algorithm helps you select the best coach for your objectives.

Furthermore, Coachello processes the personal information your coach (and you) provide after a coaching session. This personal information will be transmitted in a coaching report, this report will be made accessible to you in your application. Anything you discuss with your coach orally or in writing remains confidential.

Finally, Coachello uses cookies and similar technologies to collect a variety of information about how you interact with the Services so that we can deliver a better and more relevant experience for you. This includes, for example: device-related information such as IP address, browser language, the state or country from which you accessed the Services (based on IP address), company names, software and hardware attributes (including device IDs, operating system, and browser type); referring and exit URLs. For more information on our use of cookies and similar technologies, please see our Cookie Policy.

How we use your information

Coachello uses your information only as it relates to our interests in operating our business and providing the Services. More specifically, we use your information as follows:

Provide the Services to Customers and their Authorized Users

Coachello uses personal information to provide the Services to you:

• We may use information to prepare reports and other information to you and your coach (if authorized by you).
• If you use the asynchornous coaching module in the Coachello application
• If you request customer support, we may use information to respond and help resolve the support issue.
• We may use information to provide anonymized insights to our customers as part of our enterprise-grade solutions.
• We may also use information to provide service notifications.

Legal Basis: We process such information only in accordance with our Terms of Service and the instructions of our Customers

Account Management

We use information to create and administer Coachello accounts. We may send you service, technical, legal, and other administrative emails, messages, and notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them.

Legal Basis: Legitimate interests

Security and Performance

We use information to monitor, investigate, research, and enhance the security and performance of our Services. This includes using information to prevent or address security or technical issues, analyze and monitor usage, and other similar activities.

Legal Basis: Legitimate interests; Legal obligation

Analytics and Product Development

We use information to analyze, develop, and improve the Services. For example, we may use information to analyze what coaching topics a group of employees work on, how they progress and generate anonymized insights. We may also use information to develop new features or functionality for the Services. We may also use information to develop new products or services.

Legal Basis: Legitimate interests; Terms of Service

How we share your information

In order to provide high-quality services, Coachello hires people, enters into the agreements with independent contractors as well as cooperates with other services providers, companies and organizations strictly under the data processing agreement (DPA). For those reasons, some of your personal data can be passed to the persons mentioned if you engage in a relationship with this person. E.g. When you book a session with your coach, your coach will receive information about you and your organization in order to understand the context of your upcoming coaching session.

Our Customers will have access to the amount of sessions of Authorized Users. Coachello doesn’t share any other personal identifiable information with its Customers, or any third party, without your prior consent.

How long we keep your information

Your personal data will be stored by Coachello no longer than is necessary for the purposes for which the personal data is processed.

Generally, Coachello retains your personal data as long as your account is active. In case your account expires after the end of a coaching program, Coachello retains your personal data no longer than 30 days after the account expires. Furthermore, Coachello will delete your personal data within 14 days after having received a request thereto from an Authorized User on legal@coachello.io.

International Transfers

The Coachello Services are designed and delivered primarily in the European Union (“E.U.”) and the USA. As such, Coachello may need to transfer your information to countries other than the one in which you live. Coachello’s data servers are based in Paris, France. All personal data that Coachello obtains will be stored on these servers. When your information is transferred, stored, or processed by us, we take all necessary steps to protect your information in accordance with this Privacy Policy and applicable laws. By providing us with your information, you acknowledge any such transfer, storage, or processing.

If you have any concerns or complaints about our data processing activities, we urge you to first try to resolve such issues directly with us. However, if applicable, you may make a complaint to the data protection supervisory authority in the country where you are based, or seek a remedy through local courts if you believe your rights have been breached.

Your rights with respect to your information

As a data subject you have certain rights with respect to your information, such as the right to be informed of processing activities, the right to correct inaccurate information, the right to erasure, the right to restrict processing, and the right to receive from Coachello a structured, common and machine-readable copy of the information we process about you.

If you wish to exercise your data subject rights, please contact us at: legal@coachello.io. If you are an Authorized User at Coachello, we may redirect your request in whole or in part to your organization for handling, in accordance with applicable laws and our agreements with Customers. Otherwise, please note that, pursuant to applicable law, we must be able to verify your identity to process your data subject rights request. We cannot respond to your request or provide you with the information you seek if we cannot verify your identity or authority to make the request and confirm the request relates to you and your information.

If you have any questions about Coachello’s policies or procedures related to data subject rights, please contact us at: legal@coachello.io.

SECURITY

Coachello places great importance on the security of the Services. We have adopted a variety of administrative, technical, physical, and organizational measures to protect the Services against accidental or unlawful destruction, loss, alteration, disclosure or access (a “Security Incident”) (collectively our “Security Measures”)

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CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be modified from time to time in our sole discretion. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our Services that necessitate such changes. If that happens, we will promptly post the revised Privacy Policy to the Services and update the “last updated” date at the top of the Privacy Policy. If we make changes that materially alter your privacy rights, Coachello will provide additional notice in accordance with applicable legal requirements, such as via email or through the Services. By continuing to access and use the Services after the effective date, you agree to be bound by the revised Privacy Policy. If you disagree with the revised Privacy Policy, do not use the Services.

CONTACT US

Coachello is committed to transparency about our collection, use, transfer and disclosure of your information. Please direct any inquiries, comments or questions regarding this Privacy Policy or our processing of your information to: legal@coachello.io.

California Privacy Rights

In case you are a resident of California, the California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal data by Coachello, Inc. or its subsidiaries to a third party for the third party's direct marketing purposes. This right granted to California residents applies only to their activities within the State of California.

To make such a request, please send an email to legal@coachello.io.

Legal Matters

Coachello considers your use of its Service to be private. However, we may disclose your personal data stored in our databases, in order to comply with the law or legal process served on us.

Complaints and dispute resolution

Coachello is committed to resolve complaints about your privacy and our collection, use, transfer or disclosure of your information. Any inquiries or complaints regarding this Privacy Policy should be directed to: legal@coachello.io.

Governing law

This Privacy Policy is governed by and construed with the laws of France, and, when applicable, Regulation 2016/679 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”), effective as of 25 May 2018.

We hope this Privacy Policy helps you to understand how your personal data will be dealt here at Coachello. We will take care of your personal data, so you can use our Services and not be concerned over your privacy. Should you have anything to tell us, e-mail us at legal@coachello.io We will be happy to receive any information or comment from you to make our platform better for our users.

Your Coachello Team