Privacy Policy

Your privacy is important to CoachEm, Inc. (“CoachEm”, “we,” or “us”). This Privacy Policy describes the information practices of CoachEm in connection with the CoachEm Site and the CoachEm Platform, including what type of information is gathered and tracked, how the information is used, and with whom the information is shared. As described below, this Privacy Policy applies to your interactions with the CoachEm Site and the CoachEm Platform as well as other interactions with CoachEm.

BY USING THE COACHEM SITE OR THE COACHEM PLATFORM, YOU INDICATE YOUR UNDERSTANDING AND ACCEPTANCE OF THESE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT ACCEPT THESE TERMS, DO NOT USE THE COACHEM SITE OR THE COACHEM PLATFORM.

Please carefully read this Privacy Policy as it may have changed since your last visit to the CoachEm Site or CoachEm Platform. Continued use of the CoachEm Site or CoachEm Platform indicates your understanding and acceptance of any changes made to this Privacy Policy and posted to the CoachEm Site. This Privacy Policy does not cover the privacy practices of any Customer Systems or third-party websites to which the CoachEm Site may link.

Definitions

  • “CoachEm Platform” means the software-as-a-service sales management training platform provided by CoachEm.
  •  “CoachEm Site” means https://coachem.io.
  • “Customer” means an entity receiving Services from CoachEm.
  • “Customer Systems” means any supported collaboration, CRM, and other systems implemented and used by Customers in connection with the Services.
  • “End User” means an individual authorized by a Customer to access and use the CoachEm Platform.
  • “Personal Information” means data that reasonably can be used to identify or describe an individual, such as your name, business affiliation, postal address, telephone number, or email address.
  • “Services” means the CoachEm Platform and associated implementation and training services provided by CoachEm to Customers.
  • “Site Form” means any tool or form available on the CoachEm Site that can be used to request a demonstration, contact CoachEm, or submit information to CoachEm for any other purpose.
  • “Visitor” means any person who uses the CoachEm Site, which includes browsing the CoachEm Site or submitting a Site Form.

Applicability

This Privacy Policy applies to: (1) information collected from End Users through the CoachEm Platform, and (2) information collected from Visitors through the CoachEm Site. In connection with the Services, Customers may elect to use Customer Systems to permit Customer and/or End Users to input or make available information, including Personal Information, to CoachEm. Except for information provided by End Users through the CoachEm Platform or Customer Systems, this Privacy Policy does not cover information provided by End Users to Customers.
Please note that information provided through Customer Systems may also be subject to the Customer System’s privacy policy, and we encourage you to review such policies.

INFORMATION WE COLLECT

We collect your information when you use the CoachEm Platform (in which case you are an End User) and/or visit or use the CoachEm Site (in which case you are a Visitor). The information we collect from you may include Personal Information, however, we only collect Personal Information when you voluntarily provide it to us. You do not need to provide Personal Information to simply browse the CoachEm Site.

We may collect your Personal Information when you:

  • use the CoachEm Platform;
  • use Customer Systems;
  • use the CoachEm Site;
  • submit a Site Form;
  • subscribe to marketing communications from CoachEm;
  • participate in surveys and evaluations;
  • request information or materials;
  • apply for a position, or submit your resume to CoachEm;
  • submit questions or comments to CoachEm;
  • submit any information to CoachEm; or
  • contact CoachEm by any means using information available on the CoachEm Site.

The types of Personal Information we collect may include (but are not limited to):

  • first and last names;
  • home, billing, or other physical addresses (including street name, city/town, state/province, postal code);
  • email addresses;
  • telephone numbers; and
  • any identifier that permits CoachEm to make physical or online contact with you.

HOW WE USE YOUR INFORMATION

CoachEm collects and uses your information, including Personal Information, to operate and improve the CoachEm Site and CoachEm Platform, and to provide the Services to Customers. These uses may include making the CoachEm Site or CoachEm Platform easier to use by eliminating the need for you to repeatedly enter the same information; performing research and analysis aimed at improving our products, services, and technologies; and displaying content and advertising that are customized to your interests and preferences. We also use your Personal Information to communicate with you. We may send certain mandatory service communications such as welcome letters, information updates, information on technical service issues, and security announcements. We may also contact you to inform you of other products or services available from CoachEm and its affiliates.

SHARING OF PERSONAL INFORMATION

CoachEm will not sell, rent, or lease your information, including your Personal Information, to others. CoachEm shares Personal Information with other companies working on our behalf. Except as described in this Privacy Policy, we will not disclose your Personal Information to third parties for their own marketing purposes unless you have provided consent.

Sharing with third-party providers: In some cases, we use third parties to collect, use, analyze, and otherwise process information, including Personal Information, on our behalf. This includes our use of certain products and services provided by third parties for the purposes of enabling certain features on the CoachEm Site, such as Site Forms. We occasionally hire other third parties to provide limited services on our behalf, such as handling the processing and delivery of mailings, providing customer support, hosting CoachEm Sites, processing transactions, or performing statistical analysis of our products and services. Service providers will be permitted to obtain only the Personal Information they need to deliver the service. They are required to maintain adequate safeguards to protect the confidentiality of the information and are prohibited from using your information for any other purpose.

Sharing with our partners: Some CoachEm products or services may be co-branded and offered in conjunction with another company. If you register for or use such co-branded offering, both CoachEm and the other company may receive information collected as part of the co-branded offering. If so, the privacy policy of such other company shall apply to that company’s use of this information. CoachEm may also team up with carefully selected CoachEm partners to participate in limited marketing campaigns solely to promote CoachEm’s products and services, or the partner’s products and services, to you. You may opt-out of receiving these marketing messages at any time by following the instructions in the email message. If you request something from the CoachEm Site (for example, a product or service, a callback, demonstration, or specific marketing materials), we will use the information you provide to fulfill your request or inquiry. To help us do this, we may share Personal Information with our partners.

Compelled disclosures: We may access or disclose your information, including your Personal Information, if we believe such action is necessary to: (a) comply with the law or legal process served on CoachEm or the CoachEm Site; (b) protect and defend the rights or property of CoachEm (including the enforcement of our agreements); or (c) act in urgent circumstances to protect the personal safety of users of CoachEm services or members of the public.

YOUR CHOICES

Opting Out: CoachEm provides a number of ways for you to “opt-out” of receiving additional information from us, or having us provide your Personal Information to our partners. We may offer you these choices at the time you give us your Personal Information. If you do not wish to continue receiving certain marketing materials (e.g., email messages), you can opt-out of receiving these materials by following the instructions provided in the materials. This option does not apply to communications primarily for the purpose of administering orders, contracts, support, software updates, or other administrative and transactional notices.

How to update your information: To modify the contact information that you have provided to us, you can contact us at privacy@coachem.io or by mailing us at 177 Pulpit Rock Road, Woodstock, CT 06281.

COOKIES AND BROWSER INFORMATION

CoachEm uses cookies for a variety of purposes. Cookies are small text files placed on the hard drive of the Visitor’s device. Cookies are commonly used to track web activity and provide an enhanced experience when using the internet. CoachEm may use cookies to collect non-personally identifiable information from Visitors. We use cookies to help us better understand CoachEm Site usage in the aggregate so that we know what areas of the CoachEm Site Visitors prefer. If you simply want to browse, you do not have to accept cookies from the CoachEm Site. Most browsers are defaulted to accept and maintain cookies. If you do not want websites to be able to use cookies, you can alter the configuration of your browser to not accept cookies. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you direct your browser to our CoachEm Site. Third party vendors (e.g., Google) may use cookies to serve ads to you while you are using the CoachEm Site based on your prior visits. These cookies are not tied to your Personal Information.

With or without cookies, the CoachEm Site keeps track of usage data, such as the source address from which a page request originates (i.e., your IP address, domain name), date and time of the page request, the referring website (if any), and other parameters in the URL (e.g., search criteria). We use this data to better understand CoachEm Site usage in the aggregate so that we know what areas of the CoachEm Site Visitors prefer (e.g., based on the number of visits to those areas). This information is stored in log files and is used for aggregated and statistical reporting. It is not attributed to you as an individual.

SAFEGUARDING YOUR INFORMATION

In order to protect your information, including your Personal Information, from improper disclosure, CoachEm uses commercially reasonable efforts to maintain a secure operating environment to protect any information we collect. Browsers offer varying degrees of security, particularly in regard to encryption. Even the same version of a browser can come with different levels of encryption. Review your browser’s settings for more information. While we are committed to protecting your privacy, please be aware that no transaction over the internet can be completely secure.

ADDITIONAL NOTICES FOR MINORS, CALIFORNIA RESIDENTS, AND INTERNATIONAL RESIDENTS

Notice to Minors and their Parents or Legal Guardians: The CoachEm Site and CoachEm Platform are intended for adults. We do not knowingly or intentionally collect information from anyone under the age of eighteen (18). IF YOU ARE UNDER THE AGE OF 18, PLEASE DO NOT PROVIDE ANY PERSONAL INFORMATION TO COACHEM. CoachEm cannot control what Visitors submit through the CoachEm Site. In the event CoachEm receives information from a minor, it is CoachEm’s practice to immediately delete such information upon discovery that such information is in CoachEm’s possession. If you know of a minor who has provided us with information, please contact us immediately.

Specific Provisions for California Residents: This section of the Privacy Policy applies only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) and provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing Personal Information to provide notices and means to exercise rights. For Purposes of this section, “Personal Information” has the definition set forth in the CCPA.

California Notice of Collection: In the past twelve (12) months, we or our service providers have collected the following categories of information enumerated in the CCPA in connection with the CoachEm Site and CoachEm Platform:

  • First and last name, home, billing or other physical address (including street name, city/town, state/province, postal code, and country of origin), e-mail address, and telephone number, to the extent you are interacting with our CoachEm Site, CoachEm Platform or Customer Systems;
  • Information, services and products considered, accepted, rejected and other use data;
  • Any other identifier that permits us to make physical or online contact with you;
  • Internet activity, including history of visiting and interacting with the CoachEm Site or CoachEm Platform, browser type, browser language and other information collected automatically; and
  • Any other information you have chosen to provide to us through the CoachEm Site, CoachEm Platform, or Customer Systems.

We do not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA would be interpreted to include any of the activities described in the “Sharing of Personal Information” section above, we will comply with applicable law as to such activity.

Right to Know and Delete: If you are a California resident, you have the right to delete Personal Information we have collected from you and you have the right to know certain information about our data practices in the preceding twelve (12) months. In particular, you have the right to request the following:

  • Categories of Personal Information we have collected about you;
  • Categories of sources from which the Personal Information was collected;
  • Categories of Personal Information about you we disclosed for a business purpose or sold;
  • Categories of third parties to whom the Personal Information was sold or disclosed for a business purpose;
  • Business or commercial purpose for collecting or selling the Personal Information; and
  • Specific pieces of Personal Information we have collected about you.

To exercise any of these rights, please submit a request to us at privacy@coachem.io. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within ten (10) days. We may require specific information from you to help us verify your identity and process your request. Please note that, in many instances, we do not collect types of information that enable us to identify you, or we do not retain such information. As such, if we do not have information that permits us to verify your identity, we may deny your requests to know or delete. A request for access can be made by you only twice within a twelve (12) month period.

Right to Opt Out: Under the CCPA, you have the right to opt out of the sale of your Personal Information to third parties at any time. CoachEm does not “sell” your Personal Information as it is currently defined under the CCPA. You may contact us by emailing us at privacy@coachem.io if you have any questions or concerns.

Authorized Agent: You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of any your rights.

California Do-Not-Track Notice: We do not track End Users or Visitors over time and across third party websites. Accordingly, we do not respond to Do Not Track (DNT) signals.

Notice to International Residents: CoachEm is established in the United States and has operations and service providers in the United States and throughout the world. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide levels of data protection equivalent to those in your country of residence. We are committed to protecting the privacy and confidentiality of Personal Information when it is transferred.

Additional Information for Residents in the European Economic Area and United Kingdom: CoachEm and our service providers may receive and/or access your Personal Information in the United States, Israel, and other jurisdictions that may not provide levels of data protection equivalent to those in your country of residence. By using the CoachEm Site or CoachEm Platform, or otherwise interacting with us, regardless of where you live or where you provide information to us, you consent to our use and our service providers’ use of your Personal Information worldwide and to the transfer of your Personal Information to countries outside of your country of residence, including the United States and Israel. In certain circumstances, courts, regulatory agencies, law enforcement agencies, or security authorities in those other countries may be entitled to access your Personal Information.

CoachEm will take adequate measures designed to protect the transfer of Personal Information of individuals in the European Economic Area (EU Member States, Iceland, Liechtenstein and Norway) (“EEA”), such as relying on the European Commission-approved Standard Contractual Clauses (“EU SCCs”), as may be updated from time to time, as a legal mechanism for such transfer, or other adequate transfer mechanism as required under relevant data protection laws, as well as additional safeguards, where appropriate. A copy of these clauses may be obtained by contacting us at the email address provided herein.

For transfers to or from the United Kingdom (“UK”), we make use of the EU SCCs, as modified by the UK’s International Data Transfer Addendum (collectively the “UK SCCs”). For individuals located in the EEA or the UK, the term “Personal Information,” as used in this section, is equivalent to “personal data” under applicable European and UK data protection legislation.

If you are located in the EEA, the UK, or Switzerland, you have certain rights and protections under applicable law regarding the processing of your Personal Information, as defined by the General Data Protection Regulation (“GDPR”), and the following notices apply to you:

Legal Basis for Processing: When we process your Personal Information, we will do so in reliance on the following lawful bases:

  • To perform our responsibilities under our contract with you (e.g., providing the services you requested).
  • When we have a legitimate interest in processing your Personal Information to operate our business or protect our interests (e.g., to provide, maintain, and improve our services, conduct data analytics, and communicate with you).
  • To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of non-administrative communications).
  • When we have your consent to do so (e.g., when you opt in to receive non-administrative communications from us). When consent is the legal basis for our processing your Personal Information, you may withdraw such consent at any time.

Data Retention: We store Personal Information for 18 months, unless reasonably necessary to comply with our legal, regulatory, or other compliance obligations. We store other data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Your Rights: For individuals in the European Union, according to the GDPR, you have the following statutory rights:

  • Information. At the point where Personal Information is collected from the data subject, as defined by the GDPR, or obtained from another source, there is a requirement to inform the data subject about our use of that Personal Information and the rights of data subjects over it. Compliance with this right is provided within this Privacy Policy.
  • Access. You have the right to obtain confirmation as to whether or not Personal Information concerning you is being processed, and, where that is the case, all necessary information to make the process transparent. You also have the right to obtain a copy of your Personal Information being processed.
  • Rectification. You have the right to require rectification of inaccurate data about you.
  • Erasure. You have the right to ask for the deletion of your data in certain circumstances.
  • Restrict processing. You have the right to restrict processing of data under certain specified circumstances.
  • Data portability. You have the right to request for the receipt or the transfer to another organization, in a machine-readable form, of your Personal Information.
  • Object to processing. You have the right to ask us to stop using all or some of your Personal Information under certain specified circumstances.
  • Right to withdraw consent. When you have given your explicit consent for the processing of your data, you can withdraw it at any time without justification. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

If would like to exercise your rights, please let us know by sending an email at privacy@coachem.io.

You also have the right to lodge a complaint with your local Data Protection Authority or to the Data Protection Authority where the alleged infringement took place.

MISCELLANEOUS

Changes to this Privacy Policy: CoachEm reserves the right to change this Privacy Policy from time to time. If we do make changes, the revised Privacy Policy will be posted on the CoachEm Site.

Enforcement: CoachEm regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this statement or CoachEm Site treatment of Personal Information by contacting us at the addresses indicated below.

Links to Other Sites: The CoachEm Site may provide links to third-party websites, such as those of our business partners and online advertisers. You should review their privacy policies to learn more about what, why, and how they collect and use personally identifiable information.

For Questions or Concerns: If you have questions or concerns regarding this statement, you should first contact privacy@coachem.io. Other correspondence may be sent to:

CoachEm, Inc.
177 Pulpit Rock Road
Woodstock, CT 06281

This Privacy Policy was last amended on December 15, 2022.