Coaching Privacy Statement

INTRODUCTION

Drew Linsalata (“Drew” or “I”) has prepared this Privacy Statement to inform recipients of our coaching services (“user” or “you”) about how we collect, use and disclose their personally identifiable information (“Personal Information”).

BY RECEIVING MY COACHING SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THIS PRIVACY STATEMENT, AGREE TO BE BOUND BY MY TERMS OF SERVICE, AND CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS SET OUT IN THIS PRIVACY STATEMENT.

WHAT INFORMATION DO I COLLECT?

I may collect the following types of Personal Information in connection with my delivery of coaching services to you:

  • When you receive coaching services from me I collect any Personal Information that you submit through my pre-qualification and intake forms, including your name, email address, mailing address, phone number, payment information, and any other Personal Information you voluntarily submit through these forms (your “Account Data”).
  • When I provide coaching services to you, I collect any Personal Information that you submit through my intake form or otherwise voluntarily provide to me including information about your personal goals and circumstances including current or past use of any medications and/or engagement with healthcare providers or mental health professionals (your “Coaching Data”).

I may also collect Personal Information that you voluntarily provide to me when you contact us with a question or comment about my services.

HOW DO I USE INFORMATION I COLLECT?

PERSONAL INFORMATION

  • Account Data to manage your account, communicate with you in relation to your account, process transactions, and deliver and monitor the performance of my service;
  • Coaching Data to understand your personal objectives and circumstances, help you develop and execute strategies to overcome your challenges and achieve your goals, evaluate the quality and progress of my coaching program, and optimize my coaching services.

I also use the Personal Information you provide me to respond to your comments and questions and personalize my services for you.

I may use your Personal Information to provide you with service information and marketing communications. I will only do so with your expressed consent and only as permitted by law.

AGGREGATE INFORMATION

I create statistical, aggregate data (“Aggregate Information”) about our my base for analytical purposes. Aggregate Information includes data derived from Personal Information and obtained by my from other sources in aggregated, anonymous form. Aggregate Information cannot reasonably be used to identify any individual.

LEGAL EXCEPTIONS

Under certain circumstances, Personal Information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders. As such, notwithstanding the above, I may in any event use Personal Information to the extent required or permitted by applicable law to resolve disputes, to enforce my agreements (including the Terms of Service) with you, or as reasonably necessary to protect my legal rights, to protect you against self-harm, or to protect third parties.

WHAT INFORMATION DO I DISCLOSE TO THIRD PARTIES?

I will not disclose your Personal Information to any third party except as follows:

  • I may disclose your Personal Information to third parties who provide services on my behalf, such processing payment transactions. I will take all reasonable and practical steps to  require them to use the Personal Information they receive only to perform such services for me.
  • Subject to applicable law, I may disclose your Personal Information to any law enforcement, judicial authority, or governmental or regulatory authority, to the extent required by law or if in our reasonable discretion disclosure is necessary to enforce or protect my legal rights, to protect you, or to protect others.
  • I may otherwise disclose your Personal Information when I have your prior consent to share the information. In such cases, I will have written contracts in place with the third parties requiring them to comply with terms of confidentiality similar to the applicable terms of this Privacy Statement as well as all applicable statutes, regulations and laws pertaining to the protection of such Personal Information.
  • I may share anonymized Aggregate Information with third parties where permitted by applicable law. Such information will be in a form that can not be used to identify you in any way.

INFORMATION SECURITY

I have implemented technical and administrative security measures to protect the security and integrity of your Personal Information in accordance with this Privacy Statement and applicable law. Such measures include restricting access to Personal Data on a “need-to-know” basis. I secure information using industry standard administrative, physical, and technical safeguards including encryption of information that is stored and transmitted. While I endeavor to always protect my systems, sites, operations and information against unauthorized access, use, modification and disclosure, it is important for you to know that, despite using these current industry-recommended practices, I cannot guarantee against breaches in security.

You have an important role in protecting Personal Information. You are responsible for maintaining the security and confidentiality of the information you share with me.  I am not responsible if any party obtains information about you or your communication with me through  your actions.

LINKS

As part of providing coaching services to you, I may provide you with links to websites and/or applications owned and/or operated by third parties. I am not responsible for the privacy practices or the content of those websites and/or applications. You are encouraged to review the privacy statements of each third party website and/or application. This Privacy Policy applies solely to information collected by me.

CHILDREN

I do not knowingly collect or maintain personally identifiable information from persons under 18 years of age, and no part of the Service is directed at persons under 18.

ACCESSING AND UPDATING YOUR INFORMATION

You have the right to review, amend, or correct your Account Data or other Personal Information held in my database.

Subject to certain exceptions, you have the following rights:

  • to request a copy of your Personal Information
  • to have me correct or amend any inaccurate Personal Information
  • to request that I erase Personal Information that weIprocess about you
  • to request that I restrict the processing of your Personal Information
  • to object to the processing of your Personal Information
  • to send me a complaint regarding our handling of your Personal information

To exercise these rights please contact me by sending an email to [email protected] with a clear description of your request. I will respond to try to comply with your request as soon as reasonably practicable and always under the timeframes set forth by applicable laws. You may have additional statutory rights under applicable regional law. If you are in the European Economic Area (EEA) you also have the right to request that I transmit your data to another data controller and you have the right to withdraw your consent at any time. You also have the right to lodge a complaint with the local data protection authority if you believe that I have not complied with applicable data protection laws.

RETENTION OF YOUR DATA

I store your Account Data and Personal Information for as long as I need it to provide you our services, to serve the purpose(s) for which your personal information was processed, or as necessary to comply with my contractual and legal obligations, resolve disputes, or enforce my agreements to the extent permitted by law. If you would like your Account Data or other Personal Information permanently removed from my database, please contact me at [email protected] I will then terminate your coaching services, you will no longer be able to use my services, and you will no longer receive emails from me. Subject to applicable law and necessary record retention requirements, your identifying Personal Information shall be deleted from my records. Please note that I may need to retain certain information for record keeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or authorized by law.

CROSS-BORDER TRANSFERS

Your information, including your Personal Information, is processed at my office and data centers in the United States of America. In connection with your access and use of my services, your Personal Information will be transferred to and processed in the United States, which may have different privacy protections compared to your jurisdiction, If you are located in the European Economic Area (“EEA”), please note that I implement standard contractual clauses approved by the European Commission and take all necessary measures to ensure that transfers of your Personal Information out of the EEA are adequately protected as required by applicable data protection law.

CHANGES

I may modify or amend this Privacy Statement from time to time. If I make any material changes in the way in which Personal Information is collected, used or transferred, this Privacy Statement will be revised to reflect such changes. I will post the updated Privacy Statement and ask for your consent if legally required. The effective date appears at the top of this Privacy Statement.

QUESTIONS

You may contact me if you have any questions about this Privacy Statement. Please contact us at [email protected]