CoachVantage Private Limited (we, us, our) complies with the Personal Data Protection Act 2012 (the PDPA) and other applicable privacy and data protection laws when dealing with personal data. Personal data is information about an identifiable individual (a natural person).
This policy sets out how we will collect, use, disclose and protect your personal data when you access and use our website https://www.coachvantage.com/ or services or have other dealings with us.
This policy does not limit or exclude any of your rights under the PDPA and other applicable laws. If you wish to seek further information on the PDPA, see https://www.pdpc.gov.sg.
CHANGES TO THIS POLICY
We may change this policy by uploading a revised policy onto the website. The change will apply from the date that we upload the revised policy.
This policy was last updated on 1 January 2021.
WHAT PERSONAL DATA DO WE COLLECT
We collect, hold and process two categories of personal data:
▲ Account and Marketing Data is personal data that we collect about you:
- in connection with the creation or administration of a customer account
- if you ask to receive information about us or our services or sign up to our newsletter
- when you sign up to or access or use our services
- when you contact us directly (e.g. telephone call, website enquiry form, email or through your user dashboard) or visit our website
- if you participate in customer feedback surveys
The Account and Marketing Data we collect may include company/personal names, usernames, phone numbers, email addresses and any other contact information you provide to us, your location, billing information, purchase history, information about how you use our website or services (for example, traffic volumes, navigation, mouse clicks, time spent on pages), your IP address and/or other device identifying data, information contained in your correspondence with us or survey responses and other information required to provide a service or information you have requested from us.
▲ personal data that forms part of the Data (as defined in our Terms of Service) (Client Data). This may include any personal data collected by our clients, including our clients’ team members, personnel or other end users’ names, addresses and contact details.
We will not collect or process Client Data except as provided in our Terms of Service and/or other agreements with our clients that govern the processing of Client Data (as applicable) and we require our clients to comply with applicable privacy and data protection laws.
WHO DO WE COLLECT YOUR PERSONAL DATA FROM
We collect personal data about you from:
- you, when you provide that personal data to us, including via our website and services through any registration or subscription process, through any contact with us (e.g. telephone call or email) or when you access or use our services; and
- third parties where you have authorised this (e.g. by integrating your account with third party providers including as Stripe, PayPal, Zoom, External Calendars (including iCloud, Google, Outlook, Office 365, Microsoft Exchange) and also Affiliate Management Software (Tapfiliate) or the information is publicly available. If possible, we will collect personal data from you directly.
- when you visit or use our website or services, we may collect information about you:
- by recording clickstream data, which is information that is recorded when you click anywhere on a webpage and is used for the purposes of collecting, analysing and reporting data about how you use our website and related services; and
HOW WE USE YOUR PERSONAL DATA
We may use your personal data:
- to verify your identity
- to provide the website and our services to you
- to market our services to you, including contacting you electronically (e.g. by text or email for this purpose). You can stop receiving our marketing emails by following the unsubscribe instructions included in those emails
- to improve the services that we provide to you
- to undertake credit checks of you (if necessary)
- to bill you and to collect money that you owe us, including authorising and processing credit card transactions
- to respond to communications from you, including enquiries, support tickets and complaints
- to conduct research and statistical analysis (on an anonymised basis)
- to tailor content or advertisements to you
- to protect and/or enforce our legal rights and interests, including defending any claim
- for any other purpose authorised by you, the PDPA or other applicable law
- to respond to lawful requests by public authorities, including to meet law enforcement requirements.
We may transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.
DISCLOSING YOUR PERSONAL DATA
We may disclose your personal data to:
- another company within our group
- any business that supports our services, including any person that hosts or maintains any underlying IT system or data centre that we use to provide our website or services or that we use to process payments.
- other third parties (for anonymised statistical information)
- a person who can require us to supply your personal data (e.g. a regulatory authority);
- any other person authorised by the PDPA or other applicable law (e.g. a law enforcement agency)
- professional advisers e.g accountants, lawyers, auditors
- any other person authorised by you
- any other company in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.
TRANSFERS OF PERSONAL DATA
A business that supports our website or services may be located outside the European Economic Area (EEA) or Singapore. This may mean your personal data is held and processed outside the EEA or Singapore. Please see the GDPR Addendum for further information about personal data transfers from the EEA.
PROTECTING YOUR PERSONAL DATA
We will take reasonable steps to keep your personal data safe from loss, unauthorised activity, or other misuse. We implement appropriate technical and organisational measures to ensure a level of security appropriate to risks inherent in processing personal data.
You can play an important role in keeping your personal data secure by maintaining the confidentiality of any password and accounts used in relation to our services. Please do not disclose your password to third parties. Please notify us immediately if there is any unauthorised use of your account or any other breach of security.
ACCESSING AND CORRECTING YOUR PERSONAL DATA
Subject to certain grounds for refusal set out in the PDPA or other applicable law, you have the right to access your readily retrievable personal data that we hold and to request a correction to your personal data. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal data relates.
In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal data, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the personal data that you requested the correction.
If you want to exercise either of the above rights, email us at firstname.lastname@example.org Your email should provide evidence of who you are and set out the details of your request (e.g. the personal data, or the correction, that you are requesting).
While we take reasonable steps to maintain secure internet connections, if you provide us with personal data over the internet, the provision of that information is at your own risk.
PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS
Effective January 1, 2020, the California Consumer Protection Act (the CCPA) requires us to provide California consumers with certain information about the processing of their personal information and rights available to them with respect to such information.
This policy sets out the personal information we collect and disclose for a business purpose. We do not sell your personal information for money. In certain instances, we will share personal information among our affiliated companies and with third parties who provide valuable services to us as described in this policy.
California law gives consumers the right to make the following requests, up to twice every 12 months:
- the right to request a copy of the personal information that we have collected about you in the prior 12 months
- the right to request details about the categories of personal information we collect, the categories of sources, the business or commercial purposes for collecting information, and the categories of third parties with which we share information
- the right to request deletion of the personal information that we have collected about you, subject to certain exemptions
- the right to opt-out of sale of your personal information.
You can exercise these rights by emailing us at email@example.com
The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information, unless the different prices, rates, or quality of goods or services are reasonably related to the value of the consumer’s data. We do not discriminate against consumers when they exercise their CCPA rights.
This GDPR Addendum was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal data. However, we are happy to provide any additional information or explanation needed. Any requests for further information should be sent to firstname.lastname@example.org
For the purposes of the GDPR:
- we are the data controller (as defined in the GDPR) when processing Account and Marketing Data; and
- our clients are the data controller when processing Client Data.
We will not process Client Data except as provided in our Terms of Service and/or other agreements with our clients that govern the processing of Client Data (as applicable) and we require our clients to comply with applicable privacy and data protection laws. If we receive any data subject requests relating to Client Data, such as requests to access personal data, we will forward this request to the relevant client.
The remainder of this GDPR Addendum applies to Account and Marketing Data only, and does not apply to Client Data.
PROCESSING PERSONAL DATA
The legal basis for our processing of Account and Marketing Data is your consent.
Despite the above, we may process any of your personal data where such processing is necessary for compliance with applicable laws.
We may process special categories of personal data. This data includes personal data revealing racial or ethnic origins, political opinions, religious or philosophical beliefs, genetic data, data concerning health or data concerning your sex life or sexual orientation. We will collect this data from you. This data may be processed for providing our services to you. The legal basis for this processing is consent.
You do not have to provide us with your name and email address to access and use the website. However, you must provide us with your name and email addresses when using some of our services such as signing up for a demo or setting up an account. The consequence of not providing the personal data is that we will not be able to provide all of our services to you.
Your rights in relation to your personal data under the GDPR include:
- right of access - if you ask us, we will confirm whether we are processing your personal data and provide you with a copy of that personal data.
- right to rectification - if the personal data we hold about you is inaccurate or incomplete, you have the right to have it rectified or completed. We will take every reasonable step to ensure personal data which is inaccurate is rectified. If we have shared your personal data with any third parties, we will tell them about the rectification where possible.
- right to erasure - we delete your personal data when it is no longer needed for the purposes for which you provided it. You may request that we delete your personal data and we will do so if deletion does not contravene any applicable laws. If we have shared your personal data with any third parties, we will take reasonable steps to inform those third parties to delete such personal data.
- right to withdraw consent - if the basis of our processing of your personal data is consent, you can withdraw that consent at any time.
- right to restrict processing - you may request that we restrict or block the processing of your personal data in certain circumstances. If we have shared your personal data with third parties, we will tell them about this request where possible.
- right to object to processing - you may request that we stop processing your personal data at any time and we will do so to the extent required by the GDPR.
- right to data portability - you may obtain your personal data from us that you have consented to give us or that is necessary to perform a contract with you. We will provide this personal data in a commonly used, machine-readable and interoperable format to enable data portability to another data controller. Where technically feasible, and at your request, we will transmit your personal data directly to another data controller.
the right to complain to a supervisory authority - you can report any concerns you have about our privacy practices to the relevant data protection supervisory authority.
Where personal data is processed for the purposes of direct marketing, you have the right to object to such processing, including profiling related to direct marketing.
If you would like to exercise any of your above rights, please contact us at email@example.com. If you are not satisfied by the way your query is dealt with by our data protection officer, you may refer your query to your local data protection supervisory authority e.g. in the United Kingdom, this is the Information Commissioner’s Office.
We may collect personal data about children aged under 16, where you submit that personal data to us.
Cookies are text files containing small amounts of information which are downloaded to your browsing device, e.g. a computer or smartphone, when you visit a website. Cookies can be recognised by the website that downloaded them, or other websites that use the same cookies. This helps websites know if the browsing device has visited them before.
Cookies do lots of things, like helping us understand how the website is being used, letting users navigate between pages effectively, remembering your preferences, and generally improving your browsing experience.
The types of cookies used by us and most websites can generally be put into the following categories: strictly necessary, performance, functionality, tailored content and targeting (described further below).
Strictly necessary cookies
These cookies are essential for the full functionality of our website. They enable you to navigate around our website and use their features, such as accessing secure areas. Without these cookies, you may not be able to access all the functions of our website.
These cookies collect information about how you use our website, e.g. which pages are the most visited and if you receive any error messages from any pages. These cookies do not gather information that identifies you. All information these cookies collect is anonymous and only used to improve how our website works.
These cookies allow our website to remember the choices you make, e.g. your user name, language or your region. These cookies can also be used to remember the changes you made to text size, font, and other parts of pages that you can customise. They may also be used to provide services you have requested, e.g. watching a video. The information these cookies collect may be anonymous and they cannot track your browsing activity on other websites. To refuse these cookies, please follow the instructions under the heading below “how to control and delete cookies through your browser”.
Tailored content cookies
These cookies help our website provide enhanced features and display content in a way that is relevant to you. They help determine what information is shown on our website based on how you have used our website previously. These cookies also track your browsing activity on other websites.
These cookies are used to deliver advertisements that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information may be shared with other organisations such as advertisers. This means that after you have been to our website, you may see some advertisements about our services elsewhere on the Internet.
[insert provider e.g. Google Adwords] presents advertising relevant to your interests when you access the website or our services, generated from data relating to your access and use of the website or our services. [insert e.g. Google Adwords] places cookies on your browser to collect information about your past use of the website and then places ads on sites across the Internet that are more likely to be of interest to you. If you would like to customise or opt out of [insert e.g. Google Adword’s] behavioural advertising, you can visit [insert e.g Google’s Adwords] settings at [insert link to provider’s opt out page e.g. https://adssettings.google.com/authenticated.]
You may also opt-out of targeted advertising at https://www.youronlinechoices.eu/. You can learn more about interest-based advertising and opt out of interest-based advertising from participating online advertising companies at the following links:
Network Advertising Initiative (NAI) – https://optout.networkadvertising.org/
Digital Advertising Alliance (DAA) – https://optout.aboutads.info/
Digital Advertising Alliance EU (EDAA) – https://www.youronlinechoices.com/
DAA AppChoices page – https://www.aboutads.info/appchoices
Please note that opting out of interest-based advertising does not mean you will no longer be served advertising. You will continue to receive generic ads.
You may opt-out of targeted advertising at https://www.youronlinechoices.eu. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
How to control or delete cookies through your browser
You can control and/or delete cookies as you wish. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit our website and attempt to use our services, you may not be able to access certain parts of our website or services, and some functionalities may not work. You can find out more information about how to change your browser cookie settings at https://www.aboutcookies.org.uk.
Third party website cookies
Other websites may use different cookies from those we use. You acknowledge and agree that we are not responsible for any third party websites or applications and you access third party websites and applications at your own risk. Please understand other websites and applications are independent from us so you must inform yourself of their separate cookie policies.
Cookies we use at the date of this GDPR Addendum 1 March 2021
|Type of cookie||Who serves these cookies||How to turn these off and further information|
|Strictly necessary cookies||CoachVantage||These cookies are essential for our website to work in the way you have requested. These cookies are used to identify trusted web traffic. Because these cookies are strictly necessary to deliver the website to you, you cannot refuse them. You can block or delete them by changing your browser settings as described in the instructions under the heading "how to control or delete cookies through your browser", however, blocking them entirely will prevent certain parts of the website from operating as intended, e.g. access to certain parts of the website.|
|Functionality cookies||Groovehq, Mouseflow||These cookies are used to enhance the performance of our website but are non-essential to its use. However, without these cookies, certain functionality like in-app support may become unavailable. To refuse these cookies, please follow the instructions under the heading "how to control or delete cookies through your browser".|
|Tailored content cookies||Google Analytics||These cookies help our website provide enhanced features and display content in a way that is relevant to you. They help determine what information is shown on our website based on how you have used our website previously. These cookies also track your browsing activity on other websites. To refuse these cookies, please follow the instructions under the heading "how to control and delete cookies through your browser".|
INTERNATIONAL TRANSFER OF DATA
The Account and Marketing Data we collect through our website and/or the provision of services may be transferred to, and stored in, a country operating outside the European Economic Area (EEA). Under the GDPR, the transfer of personal data to a country outside the EEA may take place where the European Commission has decided that the country ensures an adequate level of protection. In the absence of an adequacy decision, we may transfer personal data provided appropriate safeguards are in place.
Some of the Account and Marketing Data we collect is processed in Singapore (where our operations are located).
DATA RETENTION POLICY
Account and Marketing Data that we collect and process will not be kept longer than necessary for the purposes for which it is collected, or for the duration required for compliance with applicable law, whichever is longer.
The contact details of our Data Protection Officer is firstname.lastname@example.org