Privacy Policy

Updated June 19, 2024

Coacher Inc (referred to as “Coacher,” “we,” “us,” or “our” in this Privacy Policy) respects your privacy and is committed to protecting your Personal Data. This Privacy Policy (the “Privacy Policy”) is designed to inform you as to how we handle your Personal Data in connection with your use of our Platform (including our website, available at: https://www.coacher.co – the “Website”) and notify you about your privacy rights and how the law protects such rights.

“Personal Data” means any information about an individual from which that person can be identified and includes General Personal Data, Coach’s Personal Data, and Coachee’s Personal Data (as such terms are defined below). For the purposes of this Privacy Policy, any reference to the Platform shall include the Website as well.

To the extent that the European General Data Protection Regulation (“GDPR”) or the United Kingdom General Data Protection Regulation (“UK GDPR”) apply to Personal Data that we process in accordance with this Privacy Policy, we act as act as a “data controller” with respect to such processing. To the extent that the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”) applies, we act as a “business.”

Capitalized terms used but not otherwise defined in this Privacy Policy shall have the meanings ascribed to such terms in the Terms of Service.

We encourage you to read this Privacy Policy carefully and to regularly check this page to review any changes we might make to the terms of this Privacy Policy. This Privacy Policy supplements other policies we may provide as part of our interactions with you or policies you may have received from other controllers and is not intended to override such policies.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out in the navigation menu to the left.

1. The Data We Collect About You
2. How We Collect Your Personal Data
3. How We Use Your Personal Data
4. Sharing Your Personal Data with Third Parties
5. Minors
6. International Transfers
7. Data Security
8. Data Retention
9. Your Rights
10. Accessibility
11. Contact Details
12. Changes to this Privacy Policy

If you are a resident of the state of California, please read the Privacy Notice for California Residents.

1. The Data We Collect About You

   • We collect the following types of Personal Data on all types of users (“General Personal Data”):

   • Identity Data includes first and last name.
   • Contact Data includes email address, postal address, and telephone number.
   • Photograph includes the Coach’s or the Coachee’s photograph uploaded by them.
   • Usage Data includes information about how you use our Platform (such as, when you entered the Platform and how long you stayed on the Platform or on a specific page).
   • Technical Data includes information on your internet connection (such as your IP address and internet service provider name), on the device and software that you are using to access the Platform (e.g., your web browser type and computer operating system).
   • Additional Inquiry Data includes additional information that you may provide when you contact us through the Platform.

   • When you use the Platform as a Coach, we may collect additional information to help us match the best Coachee for you, such as your field of training, accreditation and certifications, work experience, biography, coaching preferences, messages, content, and videos created by the Coach, and the Coach’s training availability (“Coach Personal Data”).

   • When you use the Platform as a Coachee, we may collect additional information to help us match the best Coach for you and allow you Coach to track your progress, such as the field of training, goals of training and difficulties, training preferences, completion of tasks given by the Coach, self-reported activity information, messages, content, and videos created by the Coachee, etc. (“Coachee Personal Data”).

   • We also use the aforementioned data in aggregated and anonymized form to improve Platform features and to inform strategy and marketing. Such information does not reveal your identity and therefore is not considered Personal Data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature available through the Platform, or to direct broad marketing efforts at certain segments.

   • Protecting the Privacy Rights of Third Parties

   • If you provide to us any Personal Data relating to others, you must make sure you have permission to do so.

2. How We Collect Your Personal Data

   • We use different methods to collect data from and about you including through:

   • Direct interactions. When you register to use our Services by creating an Account on the Platform, or otherwise provide your Personal Data directly to us, you will be asked to provide us with your Identity Data, Contact Data, Photograph, Coach Personal Data and Coachee Personal Data (as applicable) so that we can provide the Services to you, respond to your questions or requests, or otherwise contact you. You may also provide Additional Inquiry Data to us when you contact us.
   • Automated technologies or interactions. As you interact with our Platform, we automatically collect the applicable Technical Data and Usage Data. We collect this data by using cookies, server logs, and other similar technologies.
   • Third parties or publicly available sources. We may receive Technical Data and Usage Data about you from third parties, such as Usage Data and Technical Data that we may receive from analytics providers, and from advertising and marketing partners, or public sources.
3. How We Use Your Personal Data

   • We will only use your Personal Data when permitted by law. We will commonly use your Personal Data in the following circumstances:

   • Where the processing is necessary in connection with the performance of any contract we have entered into with you or where it is necessary for taking steps at your request prior to entering a contract.
   • Where the processing is necessary for our legitimate interests (or those of a third party), and such legitimate interests are not overridden by your interests, fundamental rights, or freedoms. Legitimate interest means our interest in managing and conducting our business.
   • Where the processing is necessary for compliance with a legal or regulatory obligation.
   • Where you have provided your consent for such processing. Such consent can be revoked at any time.

   • Purposes for Which We Use Your Personal Data

   • Below is a description of the ways we use your Personal Data. To the extent that the GDPR and UK GDPR apply, we have mentioned the legal bases we rely on to use your Personal Data, and identified what our legitimate interests are where appropriate:

   • We use your Identity Data, Contact Data, Photograph, Coach Personal Data and/or Coachee Personal Data to enter into a contract or to perform a contract with you.
   • We use your Identity Data, Contact Data, Coach and/or Coachee Personal Data, and Additional Inquiry Data to respond to your requests or questions, and to manage our relationship with you, including by notifying you about changes to our Terms of Service or Privacy Policy. We do so for the performance of a contract with you, if it is necessary to comply with a legal obligation or if it is necessary for our legitimate interests.
   • We use Personal Data for providing the Services to Coaches and Coachees, as part of the performance of a contact with you. In that regard, your Personal Data may be available as follows:
     • Certain Coach Personal Data, together with the Coach’s Identity Data and Photograph may be available to Coachees with whom the Coach was matched in order to allow the Coachee to engage with Coaches. If a Coach chooses to share content (such as an article or video) with other platform users, we will request the Coach’s consent to make their Coach Identity Data available to all platform users, together with select elements of their Coach Personal Data, such as their field of training, biography, accreditations and certifications, and work experience.
     • The Coachee’s Personal Data will be available to the Coach with whom the Coachee chose to engage, to enable communication between both parties.
   • We use your Usage Data, Technical Data, and Contact Data to deliver relevant and personalized content to you, send service messages (for example, for security purposes), and to measure or understand the effectiveness of our marketing efforts. We do so where it is necessary for our legitimate interests (to grow our business, to inform our marketing strategy, and to maintain and secure the services); or if we have obtained your prior consent (where laws require consent for such communications).
   • We use your Usage Data and Technical Data to improve our Platform, products, services, marketing, customer relationships, and experiences, including by personalizing and customizing our content. We do so where it is necessary for our legitimate interests (to keep the Platform updated and relevant, to develop our business and to inform our marketing strategy).
   • In the event of a legal dispute between you (and/or a party on your behalf) to us (and/or a party on our behalf), we may use your Personal Data to the extent necessary in connection with handling such dispute. We do so where it is necessary for our legitimate interests (to defend and enforce our legal rights).
   • We may also use your Personal Data if: (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our Terms of Service, to maintain security of the Platform, and prevent fraudulent or illegal activity; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates. We do so based on our legitimate interest (to defend and enforce our legal rights and to protect and ensure the continuous operation of our Platform).

   • Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data.

   • Promotional Offers

   • You may receive in-Platform and email marketing communications from us if you have opted to receive marketing communications, and for a long as you have not opted-out.

   • If you wish to stop receiving marketing communications from us, you may ask us to stop sending you marketing communications at any time by following the opt-out or unsubscribe link on any marketing message sent to you.

   • Cookies and Other Tracking Technologies

   • Our Platform uses cookies. A cookie is a small piece of data or a text file that is downloaded to your computer or mobile device when you access certain websites. Cookies may contain text that can be read by the web server that delivered the cookie to you. The text contained in the cookie generally consists of a sequence of letters and numbers that uniquely identifies your computer or mobile device; it may contain other information as well. By agreeing to accept our use of cookies, you are giving us, and third parties we partner with, permission to place, store, and access some or all the cookies described below on your computer.

   • Please note that Coacher does NOT use Advertising, Social Media, or Targeting Cookies.

   • Types of cookies:

   • Essential Cookies. These cookies are necessary for proper functioning of the Platform, such as displaying content, logging in, validating your session, responding to your request for services, and other functions.
   • Performance Cookies. These cookies collect information about the use of the Platform, such as pages visited, traffic sources, users’ interests, content management, and other website measurements.
   • Functional Cookies. These cookies enable the Platform to remember a user’s choices – such as their language, user name, and other personal choices – while using the Platform. They can also be used to deliver services, such as letting a user make a blog post, listen to audio, or watch videos on the Platform.
   • Session Cookies. These cookies allow websites to link the actions of a user during a browser session. Session cookies permit users to be recognized as they navigate a website so that any item or page changes they make are remembered from page to page. Session cookies expire after a browser session; thus, they are not stored long term.
   • Persistent Cookies. These cookies are stored on a user’s device in between browser sessions, which allows the user’s preferences or actions across a site (or, in some cases, across different sites) to be remembered. Persistent cookies may be used for a variety of purposes, including remembering users’ choices and preferences when using a website or to target advertising to them.

   • Most web browsers can be set to disable the use of cookies. However, if you disable cookies, you may not be able to access features on our Platform correctly or at all. Further details on how to disable cookies in different web browsers can be found here:

   • Internet Explorer: http://windows.microsoft.com/en-GB/internet-explorer/delete-manage-cookies

   • Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

   • Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

   • Safari: http://help.apple.com/safari/mac/8.0/#/sfri11471

   • For example, our Platform may use Google Analytics to collect information about the use of our Platform. Google Analytics collects information from users such as age, gender, interests, demographics, how often they visit our website, what pages they visit, and what other websites they have used before coming to our website. We may use the information we get from Google Analytics to analyze traffic, improve our marketing, advertising, and to improve our Platform. For more information on how Google collects and processes your data, visit https://www.google.com/policies/privacy/partners/. You can prevent Google Analytics from using your information by opting out at this link: https://tools.google.com/dlpage/gaoptout.

   • We may also use a technology called web beacons to collect general information about your use of our Platform and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behavior of our customers, members, and visitors.

   • Third-Party Links

   • The Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or interacting with such content may allow your data to be shared with the relevant third-party. We do not control these third-party websites and are not responsible for their privacy statements; we therefore recommend that you read the Privacy Policy of every website you visit.

4. Sharing Your Personal Data with Third Parties

   • We share Personal Data with third party service providers that provide us services in connection with the purposes listed above.

   • For example, we may share your applicable Identity Data, Contact Data, Usage Data and Technical Data with web analytics providers, email and marketing service providers, and other vendors that assist us in maintaining the Platform. Please also see the description above in the section titled Cookies and Other Tracking Technologies. We may also share your applicable Identity Data and Contact Data with third parties to confirm your identity and/or to process payments made by users of the Platform.

   • We may also share your Personal Data with legal and regulatory authorities to the extent required by applicable law our professional advisors (e.g. lawyers, accountants) to the extent necessary for the provision of their services to us; and third parties to whom we may choose to sell, transfer, or merge our business (or parts thereof) or our assets, or parties whose business we wish to acquire.

5. Minors

   • In order to use the Platform, you must be at least 18 years of age, or older, if otherwise required by the laws of the country in which you reside. Our Platform is not designed for use by anyone under the age of 18 and we do not knowingly collect Personal Data from children under the age of 18.

   • If you are a parent or legal guardian and have concerns about your child’s privacy, or if you believe that your child may have provided us with their Personal Data, please contact us using the Contact Details below. When you approach us as a parent or legal guardian, we may request that you provide certain information needed to confirm your identity, in order to prevent malicious removal of account information.

6. International Transfers

   • We may transfer your Personal Data to countries outside of the country in which you reside (including outside of the European Economic Area (EEA) or the United Kingdom (UK)), that do not necessarily provide the same level of data protection as the country in which you reside and are not recognized by the European Commission and/or the applicable UK authority as providing an adequate level of data protection.

   • Our international transfers of Personal Data are done for the performance of a contract or implementation of pre-contractual relations with you, based on your consent, or subject to safeguards that ensure the protection of your Personal Data, such as standard contractual clauses approved by the European Commission and/or the applicable UK authority (when the transfer is outside of the EEA or the UK).

7. Data Security

   • We have put in place security measures intended to prevent your Personal Data from accidental or unlawful loss, use, alteration, or disclosure. We also maintain reasonable technical and physical safeguards to protect your Personal Data. Unfortunately, we cannot guarantee against the loss or misuse of your Personal Data or secure data transmission over the Internet because of its nature.

8. Data Retention

   • We retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for legal or reporting requirements.

   • In order to determine the appropriate retention period for Personal Data, we consider the following criteria: the volume, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of Personal Data, the purposes for which we collect and process Personal Data, the timeframe during which we may require such Personal Data in connection with potential litigation, and applicable legal requirements.

9. Your Rights

   • Certain privacy laws, including the GDPR and UK GDPR, provide users with rights related to their Personal Data. To the extent that such laws apply to your Personal Data, you may have the following rights:

   • Request access. This means that you may receive a copy of the Personal Data we hold about you.
   • Request correction. This means that you may ask us to correct or complete inaccurate or incomplete data that we hold about you.
   • Request erasure. This means that you may ask us to delete or remove Personal Data that we hold about you. If we are unable to comply with such request, we will notify you of the specific legal reasons for our decision.
   • Object to processing. This means that you may object to the processing of your Personal Data where it is used for direct marketing purposes, or where we are relying on a legitimate interest and you feel that such interest is overridden by your rights and freedoms.
   • Request restriction of processing. This means that you may ask us to suspend the processing of your Personal Data if you believe that such data is inaccurate, if our processing is unlawful, or if we no longer need to process such data for a particular purpose, but you need us to continue to hold the data.
   • Data Portability. This means that you may request that we transfer your Personal Data to you or to a third party. This right applies where we have obtained and processed the data from you based on your consent or where we used the information to perform a contract with you.
   • Withdraw consent at any time. This means that you may withdraw your consent where we are processing your Personal Data based on your consent.

   • If you wish to exercise any of the rights set out above, please contact us.

   • What We May Need From You

   • When you approach us with a request to exercise one of your rights, we may request that you provide us with information needed to confirm your identity as a security measure to ensure that your Personal Data is not disclosed to any person who has no right to receive it.

   • Time Limit to Respond

   • We try to respond to all legitimate requests within one month or less, if required by law. Where it takes us more than one month to respond (for example, where your request is particularly complicated or where you have made a number of requests) we will notify you and keep you updated.

10. Accessibility

    • If you have a disability and would like to access this Privacy Policy in an alternative format, please contact us via our Contact Details listed below.

11. Contact Details

    • If you have any questions or concerns, please contact us at:

    • Email: privacy@coacher.co

    • Postal address:

    • You have the right to make a complaint at any time to data protection authorities. We would, however, appreciate the chance to address your concerns before you approach a data protection authority, so please contact us in the first instance.

12. Changes to this Privacy Policy

    • We reserve the right to change this Privacy Policy at any time. If we do so, we will post an updated version of this Privacy Policy so that our users and customers are always aware of what information we collect, use, and disclose. Your continued use of the Platform and/or Services after any change to this Privacy Policy will constitute your acceptance of such change.

    • This version was last updated on August 3, 2023.

Privacy Notice for California Residents

Personal Information Category	Business Purpose	Source	Disclosure to third parties
Identifiers, such as name, email address, postal address, and IP address	Enter into a contract or to perform a contract with you Respond to your requests or questions and to manage our relationship with you, including by notifying you about changes to our Terms of Service or Privacy Policy (“Relationship Management and Response to Requests”) Marketing purposes, to deliver relevant and personalized content to you, send service messages, and to measure or understand the effectiveness of our marketing efforts (“Marketing Purposes”). In the event of a legal dispute between you (and/or a party on your behalf) to us (and/or a party on our behalf), in connection with handling such dispute (“Handling of Disputes”) Compliance related purposes, including: (a) as required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our Terms & Conditions, to maintain security of the Platform, and prevent fraudulent or illegal activity; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates (“Compliance Purposes”).	When you contact us through the Platform, subscribe to our communications, or otherwise provide such information directly to us (“Direct Interactions”) As you interact with our Platform, we automatically collect your IP address. We collect this data by using cookies, server logs, and other similar technologies (“Automated Interactions”).	Third party service providers that provide services to us in connection with the aforementioned business purposes, such as providers of cloud storage, payment processing, etc. (“Service Providers”) Web analytics providers, email and marketing service providers and other vendors that assist us in maintaining the Platform Legal and regulatory authorities, to the extent required by applicable law (“Authorities”) Professional advisors (e.g. lawyers, accountants), to the extent necessary for the provision of their services to us Third parties to whom we may choose to sell, transfer, or merge our business (or parts thereof) or our assets, or parties whose business we wish to acquire (“M&A Counterparts”)
Internet or other electronic network activity information, including, but not limited to, information regarding your interaction with the Platform or marketing content	Marketing Purposes Improve our Platform, services, products, marketing, and customer relationships and experiences, including by personalizing and customizing our content Handling of Disputes Compliance Purposes	Automated Interactions. We may receive such information from third parties, such as analytics providers and advertising or marketing partners, or from publicly available sources (“Third Parties”).		Third party service providers that provide services to us in connection with the aforementioned business purposes, such as providers of cloud storage, payment processing, etc. (“Service Providers”) Web analytics providers, email and marketing service providers and other vendors that assist us in maintaining the Platform Legal and regulatory authorities, to the extent required by applicable law (“Authorities”) Professional advisors (e.g. lawyers, accountants), to the extent necessary for the provision of their services to us Third parties to whom we may choose to sell, transfer, or merge our business (or parts thereof) or our assets, or parties whose business we wish to acquire (“M&A Counterparts”)
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, postal address, telephone number, physical characteristics or description (when applicable), education, and employment (if you are a Coach)	Enter into a contract or to perform a contract with you Relationship Management and Response to Requests Marketing Purposes Handling of Disputes Compliance Purposes	Direct Interactions			Third party service providers that provide services to us in connection with the aforementioned business purposes, such as providers of cloud storage, payment processing, etc. (“Service Providers”) Web analytics providers, email and marketing service providers and other vendors that assist us in maintaining the Platform Legal and regulatory authorities, to the extent required by applicable law (“Authorities”) Professional advisors (e.g. lawyers, accountants), to the extent necessary for the provision of their services to us Third parties to whom we may choose to sell, transfer, or merge our business (or parts thereof) or our assets, or parties whose business we wish to acquire (“M&A Counterparts”)
Audio and visual information, such as your picture and videos uploaded by Coaches and Coachees	Enter into a contract or to perform a contract with you Enable communications between Coaches and Coachees Displaying content to other users on the Platform (if a Coach chooses to share content)	Third party service providers that provide services to us in connection with the aforementioned business purposes, such as providers of cloud storage, payment processing, etc. (“Service Providers”) Web analytics providers, email and marketing service providers and other vendors that assist us in maintaining the Platform Legal and regulatory authorities, to the extent required by applicable law (“Authorities”) Professional advisors (e.g. lawyers, accountants), to the extent necessary for the provision of their services to us Third parties to whom we may choose to sell, transfer, or merge our business (or parts thereof) or our assets, or parties whose business we wish to acquire (“M&A Counterparts”)
Inferences drawn from other Personal Information, such as a profile of a person’s preferences	Marketing Purposes Improve our Platform, services, marketing, customer relationships and experiences, including by personalizing and customizing our content Handling of Disputes Compliance Purposes					Automated Interactions Third Parties	Third party service providers that provide services to us in connection with the aforementioned business purposes, such as providers of cloud storage, payment processing, etc. (“Service Providers”) Web analytics providers, email and marketing service providers and other vendors that assist us in maintaining the Platform Legal and regulatory authorities, to the extent required by applicable law (“Authorities”) Professional advisors (e.g. lawyers, accountants), to the extent necessary for the provision of their services to us Third parties to whom we may choose to sell, transfer, or merge our business (or parts thereof) or our assets, or parties whose business we wish to acquire (“M&A Counterparts”)
Professional or employment related information (relevant to Coaches), such as work experience and biography	Enter into a contract or to perform a contract with you Handling of Disputes Compliance Purposes		Direct Interactions Reference providers, such as past employers, and publicly available sources			Service Providers Authorities Professional advisors M&A Counterparts
Education Information (relevant to Coaches), such as certifications and accreditation				Enter into a contract or to perform a contract with you Handling of Disputes Compliance Purposes				Direct Interactions Reference providers, such as past employers, and publicly available sources	Service Providers Authorities Professional advisors M&A Counterparts

This section describes our current practices and our practices during the 12 months preceding the “Last Updated” date of this Policy.

If you provide us any Personal Information relating to others, you must make sure that you have permission to do so.

This version was last updated on August 3, 2023.