CoachLogix EU-U.S. Privacy Shield Notice
CoachLogix, Inc. (“We”, “US”, “Our”) has certified with the EU-U.S. Privacy Shield with respect to the personal data we receive and process on behalf of our customers through our coaching management platform (the “Services”). CoachLogix certifies that it adheres to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement for personal data submitted by our customers in participating European countries through the Services, and our Privacy Shield certification will be available here. We may also process personal data our customers submit relating to individuals in the EU via other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses.
We provide the Services so that our customers can manage their coaching practices in an integrated platform. In providing these Services, we process data our customers submit to the Services or instruct us to process on their behalves in connection with the Services (“Customer Data”). While our customers decide what data to submit, Customer Data typically includes profile information, coaching engagement tracking, and goal planning.
Purposes of Data Processing
We process Customer Data submitted by customers for the purpose of providing the Services to customers. To fulfill these purposes, we may access data to provide the Services, to prevent or address service or technical problems, to respond to customer support matters, to follow the instructions of our customer who submitted the data, or in response to contractual requirements with our customers.
When providing our Cloud Services, our customers choose the types of Personal Information we process and the purposes of the processing. Accordingly, our customers are responsible for providing notice to individuals. In the event Personal Information is (i) to be used for a purpose that is materially different from the purposes for which the Personal Information was originally collected or subsequently authorized, or (ii) transferred to a third party acting as a data controller, individuals will be given, where practical and appropriate, an opportunity to opt out of having their Personal Information so used or transferred where it involves non-sensitive information. Where such use or transfer involves sensitive information, individuals must opt-in before such use or transfer.
Third Parties With Whom We May Share Customer Data
We use a limited number of third party providers to assist us in providing the Services to our customers. As of the date hereof, these third party providers perform technical operations such as database monitoring, data storage and hosting services and customer support software tools. These third parties may access, process or store personal data in the course of providing these services, but based on our instructions only. If we receive personal data subject to our certification under the Privacy Shield and then transfer it to a third-party service provider acting as an agent on our behalf, we have certain liability under the Privacy Shield if both (i) the agent processes the personal data in a manner inconsistent with the Privacy Shield and (ii) we are responsible for the event giving rise to the damage.
Questions or Complaints:
If you are a resident of a European country participating in the Privacy Shield and you believe we maintain your personal data within the scope of this Privacy Shield certification, you may direct any questions or complaints concerning our Privacy Shield compliance to firstname.lastname@example.org or at our mailing address:
311 4th Ave Suite 317
San Diego, CA 92101
If you are a resident of a European country participating in the Privacy Shield and you have not received timely response to your concern, or we have not addressed your concern to your satisfaction, you may seek further assistance, at no cost to you, from JAMS, which is an independent dispute resolution body in the United States. We also commit to cooperate with competent EU data protection authorities (DPAs) with regard to our customers end users’ human resources data transferred from a European country participating in the Privacy Shield in the context of the employment relationship.
You may also be able to invoke binding arbitration for unresolved complaints but prior to initiating such arbitration, a resident of a European country participating in the Privacy Shield must first: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from JAMS; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. If such a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident.
U.S. Federal Trade Commission Enforcement
Our Privacy Shield compliance is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Right of Access
Some international users (including those whose personal data is within the scope of this Privacy Shield certification) have certain legal rights to access certain personal data we hold about them and to obtain its correction, amendment or deletion. Please be advised that because our personnel have a limited ability to identify and access an individual user’s personal data that our a customer has submitted to the Services, if you wish to request access, to limit use, or to limit disclosure, we may first refer your request to the customer who submitted your personal data, and we will support them as needed in responding to your request.
Requirement to Disclose
We may disclose personal data when we have a good faith belief that such action is necessary to: conform to legal requirements or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; or to enforce our contractual obligations.