5. DO WE USE COOKIES AND OTHER TRACKING
TECHNOLOGIES?
In
Short: We may use cookies and
other tracking technologies to collect and store your
information.
We may use cookies and
similar tracking technologies (like web beacons and
pixels) to gather information when you interact with our
Services. Some online tracking technologies help us
maintain the security of our Services and your account, prevent
crashes, fix bugs, save your preferences, and assist
with basic site functions.
We also permit third
parties and service providers to use online tracking
technologies on our Services for analytics and
advertising, including to help manage and display
advertisements, to tailor advertisements to your
interests, or to send abandoned shopping cart reminders
(depending on your communication preferences). The third
parties and service providers use their technology to
provide advertising about products and services tailored
to your interests which may appear either on our
Services or on other websites.
To the extent these online
tracking technologies are deemed to be a 'sale'/'sharing' (which includes targeted
advertising, as defined under the applicable laws) under
applicable US state laws, you can opt out of these online
tracking technologies by submitting a request as described
below under section '
DO
UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
'
6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED
PRODUCTS?
In
Short: We offer products,
features, or tools powered by artificial intelligence,
machine learning, or similar
technologies.
As part of our Services, we
offer products, features, or tools powered by artificial
intelligence, machine learning, or similar technologies
(collectively, 'AI Products'
). These tools are designed to enhance your
experience and provide you with innovative solutions. The
terms in this Privacy Notice govern your use of the AI
Products within our Services.
Use of AI
Technologies
We provide the AI Products
through third-party service providers ('
AI Service Providers
'), including
OpenAI
. As outlined in this
Privacy Notice, your input, output, and personal
information will be shared with and processed by these AI
Service Providers to enable your use of our AI Products
for purposes outlined in
'
WHAT
LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL
INFORMATION?
' You must not use the AI
Products in any way that violates the terms or policies of
any AI Service Provider.
Our AI
Products
Our AI Products are designed
for the following functions:
-
Natural language
processing
How We Process Your Data
Using AI
All personal information
processed using our AI Products is handled in line with
our Privacy Notice and our agreement with third parties.
This ensures high security and safeguards your personal
information throughout the process, giving you peace of
mind about your data's safety.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
In
Short: We keep your information
for as long as necessary to fulfil the purposes outlined in
this Privacy Notice unless otherwise required by
law.
We will only keep your
personal information for as long as it is necessary for
the purposes set out in this Privacy Notice, unless a
longer retention period is required or permitted by law
(such as tax, accounting, or other legal requirements).
No purpose in this
notice will require us keeping your personal information
for longer than
the period of time in
which users have an account with us
.
When we have no ongoing
legitimate business need to process your personal
information, we will either delete or anonymise such information, or, if
this is not possible (for example, because your personal
information has been stored in backup archives), then we
will securely store your personal information and
isolate it from any further processing until deletion is
possible.
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
In
Short: We aim to protect your
personal information through a system of organisational and technical security
measures.
We have implemented
appropriate and reasonable technical and organisational security measures designed
to protect the security of any personal information we
process. However, despite our safeguards and efforts to
secure your information, no electronic transmission over
the Internet or information storage technology can be
guaranteed to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or other unauthorised third parties will not be
able to defeat our security and improperly collect,
access, steal, or modify your information. Although we
will do our best to protect your personal information,
transmission of personal information to and from our
Services is at your own risk. You should only access the
Services within a secure environment.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In
Short:
Depending on your
state of residence in the US or in some regions, such as the European Economic
Area (EEA), United Kingdom (UK), Switzerland, and
Canada, you have
rights that allow you greater access to and control
over your personal information.
You may review,
change, or terminate your account at any time,
depending on your country, province, or state of
residence.
In some regions (like the EEA, UK,
Switzerland, and Canada
), you have certain rights under applicable data
protection laws. These may include the right (i) to
request access and obtain a copy of your personal
information, (ii) to request rectification or erasure;
(iii) to restrict the processing of your personal
information; (iv) if applicable, to data portability;
and (v) not to be subject to automated decision-making.
If a decision that
produces legal or similarly significant effects is made
solely by automated means, we will inform you, explain
the main factors, and offer a simple way to request
human review.
In certain circumstances, you may also have the
right to object to the processing of your personal
information. You can make such a request by contacting
us by using the contact details provided in the section
'HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?
' below.
We will consider and act
upon any request in accordance with applicable data
protection laws.
Withdrawing
your consent: If we are relying on your
consent to process your personal information, which may be express
and/or implied consent depending on the applicable law,
you have
the right to withdraw your consent at any time. You can
withdraw your consent at any time by contacting us by
using the contact details provided in the section 'HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?
' below.
However, please note that
this will not affect the lawfulness of the processing
before its withdrawal nor,
when applicable law allows, will it affect
the processing of your personal information conducted in
reliance on lawful processing grounds other than consent.
Opting out of
marketing and promotional
communications: You can
unsubscribe from our marketing and promotional
communications at any time by
clicking on the unsubscribe link in the emails that
we send,
or by contacting us
using the details provided in the section '
HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?
' below. You will then be
removed from the marketing lists. However, we may still
communicate with you — for example, to send you
service-related messages that are necessary for the
administration and use of your account, to respond to
service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to
review or change the information in your account or
terminate your account, you can:
-
Contact us using the contact
information provided.
Upon your request to
terminate your account, we will deactivate or delete your
account and information from our active databases.
However, we may retain some information in our files to
prevent fraud, troubleshoot problems, assist with any
investigations, enforce our legal terms and/or comply with
applicable legal requirements.
Cookies and
similar technologies: Most Web browsers
are set to accept cookies by default. If you prefer, you
can usually choose to set your browser to remove cookies
and to reject cookies. If you choose to remove cookies
or reject cookies, this could affect certain features or
services of our Services.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some
mobile operating systems and mobile applications include
a Do-Not-Track ('DNT'
) feature or setting you
can activate to signal your privacy preference not to
have data about your online browsing activities
monitored and collected. At this stage, no uniform
technology standard for
recognising and
implementing DNT signals has been finalised. As such, we do not
currently respond to DNT browser signals or any other
mechanism that automatically communicates your choice
not to be tracked online. If a standard for online
tracking is adopted that we must follow in the future,
we will inform you about that practice in a revised
version of this Privacy Notice.
California law requires us
to let you know how we respond to web browser DNT signals.
Because there currently is not an industry or legal
standard for
recognising or honouring DNT signals, we do not respond
to them at this time.
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC
PRIVACY RIGHTS?
In
Short: If you are a resident of
California,
Colorado, Connecticut, Delaware, Florida, Indiana,
Iowa, Kentucky, Maryland, Minnesota, Montana,
Nebraska, New Hampshire, New Jersey, Oregon, Rhode
Island, Tennessee, Texas, Utah, or Virginia, you may have the right to
request access to and receive details about the
personal information we maintain about you and how we
have processed it, correct inaccuracies, get a copy
of, or delete your personal information. You may also
have the right to withdraw your consent to our
processing of your personal information. These rights
may be limited in some circumstances by applicable
law. More information is provided
below.
Categories of Personal Information We Collect
The
table below shows the categories of personal information
we have collected in the past twelve (12) months. The
table includes illustrative examples of each category
and does not reflect the personal information we collect
from you. For a comprehensive inventory of all personal
information we process, please refer to the section 'WHAT INFORMATION DO WE
COLLECT?
'
|
Category
|
Examples
|
Collected
|
|
A.
Identifiers
|
Contact details,
such as real name, alias, postal address,
telephone or mobile contact number, unique
personal identifier, online identifier, Internet
Protocol address, email address, and account
name
|
YES
|
|
B. Personal
information as defined in the California
Customer Records statute
|
Name, contact
information, education, employment, employment
history, and financial
information
|
YES
|
|
C. Protected
classification characteristics under state or
federal law
|
Gender, age, date
of birth, race and ethnicity, national origin,
marital status, and other demographic
data
|
NO
|
|
D. Commercial
information
|
Transaction
information, purchase history, financial
details, and payment
information
|
NO
|
|
E. Biometric
information
|
Fingerprints and
voiceprints
|
NO
|
|
F. Internet or other
similar network activity
|
Browsing history,
search history, online behaviour, interest data, and
interactions with our and other websites,
applications, systems, and
advertisements
|
NO
|
|
G. Geolocation data
|
Device
location
|
NO
|
|
H. Audio, electronic,
sensory, or similar information
|
Images and audio,
video or call recordings created in connection
with our business
activities
|
NO
|
|
I. Professional or
employment-related information
|
Business contact
details in order to provide you our Services at
a business level or job title, work history, and
professional qualifications if you apply for a
job with us
|
NO
|
|
J. Education
Information
|
Student records
and directory information
|
NO
|
|
K. Inferences drawn
from collected personal information
|
Inferences drawn
from any of the collected personal information
listed above to create a profile or summary
about, for example, an individual’s preferences
and characteristics
|
NO
|
|
L. Sensitive personal
Information
|
|
NO
|
We may also collect other
personal information outside of these categories through
instances where you interact with us in person, online, or
by phone or mail in the context of:
-
Receiving help through our
customer support channels;
- Participation in customer surveys
or contests; and
- Facilitation in the delivery of
our Services and to respond to your inquiries.
We will use and retain the
collected personal information as needed to provide the
Services or for:
-
Category A - As long as the user has an account with
us
-
Category B - As long as the user has an account with
us
Will
your information be shared with
anyone
else?
We may
use your personal information for
our own business purposes, such as
for undertaking internal research
for technological development and
demonstration. This is not
considered to be
'selling'
of your personal
information.
We
have not disclosed, sold, or shared
any personal information to third
parties for a business or commercial
purpose in the preceding twelve (12)
months. We will
not sell or share personal
information in the future belonging
to website visitors, users, and
other consumers.
Your Rights
You have
rights under certain US state data
protection laws. However, these rights
are not absolute, and in certain
cases, we may decline your request as
permitted by law. These rights
include:
- Right
to know whether or not we
are processing your personal data
- Right
to access your personal
data
- Right
to correct inaccuracies in
your personal data
- Right
to request the deletion of
your personal data
- Right
to obtain a copy of the
personal data you previously shared
with us
- Right
to non-discrimination for
exercising your rights
- Right
to opt out of the
processing of your personal data if it
is used for targeted advertising (or
sharing as defined under California’s
privacy law)
, the sale of personal data, or
profiling in furtherance of decisions
that produce legal or similarly
significant effects (
'profiling'
)
Depending
upon the state where you live, you may
also have the following rights:
- Right to
access the categories of personal data
being processed (as permitted by
applicable law, including the privacy
law in Minnesota)
- Right to
obtain a list of the categories of
third parties to which we have
disclosed personal data (as permitted
by applicable law, including the
privacy law in
California, Delaware, and Maryland
)
- Right to
obtain a list of specific third
parties to which we have disclosed
personal data (as permitted by
applicable law, including the privacy
law in
Minnesota and Oregon)
-
Right to obtain a list of third parties
to which we have sold personal data (as
permitted by applicable law, including
the privacy law in Connecticut)
- Right to
review, understand, question, and
depending on where you live, correct
how personal data has been profiled
(as permitted by applicable law,
including the privacy law in
Connecticut and Minnesota)
- Right to
limit use and disclosure of sensitive
personal data (as permitted by
applicable law, including the privacy
law in California)
- Right to opt
out of the collection of sensitive
data and personal data collected
through the operation of a voice or
facial recognition feature (as
permitted by applicable law, including
the privacy law in Florida)
How to Exercise Your Rights
To
exercise these rights, you can
contact us by
visiting
www.clevercoach.training/contact
,
or by
referring to the contact details at the
bottom of this
document.
Under
certain US state data protection laws,
you can designate an
authorised
agent to make a request on your
behalf. We may deny a request from an
authorised
agent that does not submit
proof that they have been validly
authorised
to act on your behalf in
accordance with applicable
laws.
Request Verification
Upon
receiving your request, we will need
to verify your identity to determine
you are the same person about whom we
have the information in our system. We
will only use personal information
provided in your request to verify
your identity or authority to make the
request. However, if we cannot verify
your identity from the information
already maintained by us, we may
request that you provide additional
information for the purposes of
verifying your identity and for
security or fraud-prevention
purposes.
If you
submit the request through an
authorised
agent, we may need to collect
additional information to verify your
identity before processing your
request and the agent will need to
provide a written and signed
permission from you to submit such
request on your behalf.
Appeals
Under
certain US state data protection laws,
if we decline to take action regarding
your request, you may appeal our
decision by emailing us at
info@clevercoachtech.com
. We
will inform you in writing of any
action taken or not taken in response
to the appeal, including a written
explanation of the reasons for the
decisions. If your appeal is denied,
you may submit a complaint to your
state attorney general.
California
'Shine The Light' Law
California
Civil Code Section 1798.83, also known
as the
'Shine The Light' law,
permits our users who are California
residents to request and obtain from
us, once a year and free of charge,
information about categories of
personal information (if any) we
disclosed to third parties for direct
marketing purposes and the names and
addresses of all third parties with
which we shared personal information
in the immediately preceding calendar
year. If you are a California resident
and would like to make such a request,
please submit your request in writing
to us by using the contact details
provided in the section '
HOW
CAN YOU CONTACT US ABOUT THIS
NOTICE?
'
12. DO OTHER REGIONS HAVE
SPECIFIC PRIVACY RIGHTS?
In
Short: You
may have additional rights based on
the country you reside
in.
Australia
We
collect and process your personal
information under the obligations and
conditions set by
Australia's Privacy Act 1988
(Privacy Act).
This
Privacy Notice satisfies the notice
requirements defined in the
Privacy Act
, in particular: what personal
information we collect from you, from
which sources, for which purposes, and
other recipients of your personal
information.
If you
do not wish to provide the personal
information necessary to fulfil
their
applicable purpose, it may affect our
ability to provide our services, in
particular:
- offer
you the products or services that
you want
- respond
to or help with your requests
- manage
your account with us
- confirm
your identity and protect your
account
13. DO WE MAKE UPDATES
TO THIS NOTICE?
In
Short: Yes, we will
update this notice as necessary to
stay compliant with relevant
laws.
We may
update this Privacy Notice from time
to time. The updated version will be
indicated by an updated
'Revised'
date at the top of this
Privacy Notice. If we make material
changes to this Privacy Notice, we
may notify you either by prominently
posting a notice of such changes or
by directly sending you a
notification. We encourage you to
review this Privacy Notice
frequently to be informed of how we
are protecting your
information.
CleverCoach Training
Australia
15. HOW CAN YOU REVIEW,
UPDATE, OR DELETE THE DATA
WE COLLECT FROM YOU?
Based on the applicable laws of your
country
or state of residence in the
US
, you may
have
the right to request access to
the personal information we
collect from you, details about
how we have processed it,
correct inaccuracies, or delete
your personal information. You
may also have the right to
withdraw your consent to our
processing of your personal
information. These rights may be
limited in some circumstances by
applicable law. To request to
review, update, or delete your
personal information, please
visit:
www.clevercoach.training/contact
.