CoachAccountable Privacy Policy.

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.

This Privacy Policy outlines what information we collect, how we use it, your rights, and our practices around that information.

1. The Information We Collect, and How We Use It

All of the information we collect in CoachAccountable is in one of three varieties.

1.1 User Account Information

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:

• Address
• Telephone number(s)
• Time zone
• Avatar image
• Gender

1.2 How We Use Account Information

All user information is used exclusively for delivery the CoachAccountable application user experience.  Specifically, this includes:

1. Proper identification and authentication to access the system based on login credentials (username and password).
2. In-app display of user activity (e.g. a name & head shot of who posted a comment).
3. Sending emails (including system-generated notifications, messages to and from system users, and messages from CA staff to system users).
4. Sending system-generated text messages to users with cell phone numbers in select countries.
5. Conversion of times (e.g. "Sent on:" dates) to a user's time zone.
6. Generation of gender specific language (e.g. using "his" or "her" rather than "their").
7. CA staff to identify users when assisting with support requests.
8. Management and processing of subscription payments for the CoachAccountable service.

And that's it.  It's just for CoachAccountable to communicate with users and the delivery of the CoachAccountable application itself.

1.3 Usage Data

This is automatically collected log information, including AND limited to:

1. Records of log in activity (who logged in, when, which browser, and from what IP address)
2. Records of in-app activity (who issued what request to the server in the course of using the application, when, and the CPU run time of processing the request)

1.4 How We Use Usage Data

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.

1.5 Coaching Data

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:

• Action items
• Metrics and data
• Worksheets
• Session Notes
• Journal Entries
• File uploads, links and embedded media
• Whiteboards
• Appointments and calendar data feeds
• Templates
• Courses
• Other in-app settings
• Data from connected 3rd party apps

1.6 How We Use Coaching Data

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:

• Data that can be accessed in app by the user who entered it.
• Data that can be accessed in app by other users who should see it (e.g. Action items set up by coach for a client, or Session Notes for a client that were NOT marked private).
• Data delivered by email to other parties as initiated by user action (e.g. a progress report set to send weekly to a designated email recipient).
• Appointment data privately made available for calendar system interchange.

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.

2. Your Rights

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 to know what data is processed about you by CoachAccountable.  Reading this very privacy policy amounts to you exercising this right.

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.

3. Data Storage and Security

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.

4. Data Sharing with Service Providers

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:

• Providing our hosting server infrastructure
• Payment processing
• Providing customer service
• Providing website visitor analytics
• Sending email & SMS communications

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.

5. Things We Proudly DON'T Do

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:

• We don't sell your data.
• We don't sell/rent/give your email to other parties for the purpose of marketing to you (or for anything else).
• We don't use your data to serve you ads.
• We don't use your data for research, machine learning, underhanded social engineering experiments, etc.
• We don't use your data to undermine democracy, or for any other terrible/Orwellian application.

6. Disclosure Under Legal Necessity

The information we collect is not shared with, rented or sold to others except under the following circumstances:

1. In order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of CoachAccountable's Terms of Service, or as otherwise required by law.
2. To comply with a governmental entity request or with any legal proceeding or process, or if we believe in good faith that such release is necessary in order to protect the rights, property or safety of CoachAccountable, our users or other third parties.
3. If CoachAccountable is acquired by or merged with another company. Not bloodly likely because that sounds terrible, but in this event, CoachAccountable will notify you via email, in-system alerts and/or with prominent notices on the CoachAccountable website before information about you is transferred and becomes subject to a different privacy policy.

7. Children

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.

8. Choices for Limiting Use and Disclosure

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.

9. Data Privacy Framework Program

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.

10. Data Processor Addendum

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.

11. Addressing Concerns and Complaints

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, john@coachaccountable.com.

We'll proudly do what we can to get the matter sorted promptly.

11.1. Further Recourse

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.

11.2 Data Protection Authority

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:

Walter Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
Phone: +44 1625 545 745
Email: international.team@ico.org.uk
Web: https://ico.org.uk

12. Changes to this Policy

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.

12. Contact Us

If you have any questions, concerns or complaints about our Privacy Policy we'd love to hear them!  Please email us at support@coachaccountable.com.