The act of coaching is deeply personal. It commonly involves sharing intimate details of what people are dealing with, what their ambitions are, what problems arise, and much more.
We know full well that the expectation of privacy in a coaching relationship is essential. It is vital to the foundation of trust between coach and client that is so often necessary to do meaningful work in a coaching relationship.
AS SUCH we recognize that, for CoachAccountable to serve as the hub for communication and documentation of the coaching process, we need to have the utmost respect for privacy of coaches and the people they coach, and treat all data with care according to rigorous standards of confidentiality and security.
All of the information we collect in CoachAccountable is in one of three varieties.
This is the stuff of "who's who" in the system: coaches who sign up, the clients they add to the system, and the other coaches that are added to any given Team Edition account.
The information collected is, at minimum, name, username, email address, and a password.
(Well actually we only store a garbled up version of passwords through the groovy mathematical trick of one-way hashing--we have no idea what your real password is, but when you log in, we sure can compute whether or not you do!)
Additional user account information that CAN be optionally entered and store includes:
All user information is used exclusively for delivery the CoachAccountable application user experience. Specifically, this includes:
And that's it. It's just for CoachAccountable to communicate with users and the delivery of the CoachAccountable application itself.
This is automatically collected log information, including AND limited to:
This information is used exclusively by CA staff and exclusively for the purposes of aiding in support, troubleshooting, debugging, and performance tuning. When someone reports an issue it's super nice not to have to ask which browser they were using.
This is the real meat of why anyone would use CoachAccountable. "Coaching Data" encompasses anything that coach (or in many cases coachee) can set up in the course of using CA to support, document, or communicate within a coaching relationship, including but not limited to:
We don't. Ever. That's your business, not ours.
Technically, though, there is something we do do with it, and it is exactly what you'd expect. We capture and store coaching data, as entered by coaches and the people they coach, for the purpose of making it accessible to authorized users, including but not limited to:
In-app coaching data is retained until deleted. 3rd party app data is retained until the respective app is disconnected. Both in-app and 3rd party app data is subject to deletion for expired accounts, due to payment failure, cancelation, or expiration of trial period.
As a courtesy we are happy to retain coaching data for the exclusive future use of the data owner (it comes up a lot!). Also as a courtesy we are happy to delete data on request, see "Your Rights" below.
You have the right to be forgotten by CoachAccountable. This applies to both coach and clients. A coach is able to delete any and all client data within the system at any time. Upon request CoachAccountable will be happy to delete coach accounts, provided the request comes from a suitably authorized party and the request doesn't clash with the rights of others.
You have the right to correct your data stored within CoachAccountable. From the "My Account" page a user is free to update whatever account information. Coach and client are jointly empowered to rectify any coaching data.
You have the right of portability of your data stored by CoachAccountable. If you want to get your data out of CoachAccountable, you have options. HTML Client Export Files, numerous downloadable reports, and the raw dump of all account data in JSON each allow you to get your data out.
These rights are mandated by the GDPR for citizens of the European Union and the UK, but CoachAccountable is proud to extend these rights to EVERYONE, and is proud to have had these rights be in full effect since day one of our business. We feel these things are just the right thing to do, and we don't (and never did) require any given jurisdiction to twist our arm to make them available to all.
CoachAccountable owns the code, databases, and all rights to the CoachAccountable application. You retain all rights to your data. We use third party vendors to provide hosting, necessary hardware, software, financial processing, networking, storage, and related technology.
To protect the security of personal information submitted to us, CoachAccountable follows generally accepted industry standards both during transmission and after the information is received. All information you provide to us is stored on secure servers. All exchanges between you and the application via the internet are encrypted using TLS encryption.
Where you have chosen a password that enables you to access your account within the application you are responsible for keeping this password confidential. If you choose to share your password, i.e. with a virtual assistant, you do so at your own risk. You may change your password at any time by going to your My Account page.
No method of transmission over the Internet, or method of electronic storage, is 100% secure. We strive to use rigorously secure means to protect your personal information. However, we cannot guarantee its absolute security. CoachAccountable has no liability for disclosure of your information, whether due to errors, unauthorized and improper acts, or otherwise.
If a security breach causes an unauthorized intrusion into our system that materially affects you or your clients, then we will notify you as soon as possible and later report the action we took in response.
While we are the primary custodian and caretaker for your data as entered in to CoachAccountable, there are a few companies who will be handling certain parts of your data as a matter of course for us to provide the service. These companies are authorized to use your personal information only as necessary to provide these services to us, to which these services may include:
These third party companies are subject to strict data processing terms and are prohibited from using you data for any purpose other than as they have been specifically contracted for.
We are proud to charge for our product: actual real money by which we can run our business. As such, it's the CoachAccountable application that is the real product we traffic in: you (and your data) are NOT the product.
As such, to put your mind to rest, here are some things we DON'T do:
The information we collect is not shared with, rented or sold to others except under the following circumstances:
The Site and the Services are not directed to children under the age of 13, and CoachAccountable does not knowingly collect or use any information from children under the age of 13.
Coaches who are working with clients under the age of 13 (or otherwise under the age of consent as defined by the client's residential jurisdiction) are responsible for obtaining suitable parental or guardian consent.
If you know of or have reason to believe anyone under the age of 13 has provided us with any personal data without parental or guardian consent, please contact us. If we learn that CoachAccountable has collected information from a child under the age of 13 without parental or guardian consent we will delete that information as quickly as possible.
As stated in Section 2, you have the right to be forgotten meaning you can delete information from your account and we can delete your account for you upon request. As stated in Sections 1.6, 4, 5, and 6, we do NOT use or disclose your information with any other parties except for (1) as necessary for providing the service (e.g. sending emails) and (2) as required by law.
Our servers and offices are located in the United States, so your usage of CoachAccountable means your information will be transferred to and stored there. CoachAccountable participates in and has certified its compliance with both the EU-U.S. and Swiss-U.S. Data Privacy Framework Framework (this compliance also extends to users in the United Kingdom).
With respect to personal data received or transferred pursuant to the Data Privacy Framework Frameworks, CoachAccountable is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.
We are responsible for the processing of Personal Information we receives under each Data Privacy Framework and subsequent transfers to service provider third parties. We comply with the Data Privacy Framework Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
To learn more about the Data Privacy Framework, and to view our certification, visit the U.S. Department of Commerce’s Data Privacy Framework website: https://www.dataprivacyframework.gov/s/. A list of Data Privacy Framework participants is maintained by the Department of Commerce and is available at: https://www.dataprivacyframework.gov/s/participant-search. You can see CoachAccountable's listing as a participant in the Data Privacy Framework Program here.
To the extent that CoachAccountable processes any personal data on your behalf in providing the Service that is subject to the EU General Data Protection Regulation (“GDPR”), the terms of CoachAccountable's data processing addendum, which are hereby incorporated by reference, shall apply and the parties agree to comply with such terms.
In compliance with the Data Privacy Framework Principles, (and in compliance with being just plain decent human beings) CoachAccountable commits to resolve complaints about our collection or use of your personal information. If you have inquiries or complaints regarding our Data Privacy Framework policy or handling of your data in general, please first contact us directly:
John Larson, Owner and Founder, firstname.lastname@example.org.
We'll proudly do what we can to get the matter sorted promptly.
Our participation in the Data Privacy Framework gives you rights to recourse if you are not satisfied with how we handle any concern or issue you have regarding your privacy.
If you are a resident of the European Union or Switzerland and you have an unresolved privacy or data use concern, please contact our U.S.-based third party dispute resolution provider JAMS (free of charge to you) at https://www.jamsadr.com/dpf-dispute-resolution. Under certain conditions, more fully described on the Data Privacy Framework website, https://www.dataprivacyframework.gov/s/article/How-to-Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
If you are a citizen of the European Union or the UK and believe we maintain your personal data subject to the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority, the UK's Information Commissioner's Office:
CoachAccountable reserves the right to modify or update this Policy at any time. If we make significant changes to this Policy, we will notify you via the News tab within the CoachAccountable application, prominently displayed on the CoachAccountable website and/or via email, at least 30 days prior to the implementation of the changes.
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