1.General principle
Inside-Out Coaching shall comply with the Swiss Federal Act on Data Protection when collecting, using, sharing with third parties or otherwise treating personal data.
2.What data we collect
We and/or our service providers may collect certain data from you directly, like information you enter yourself. When you create an account and use the Services, we collect the data you provide, including:
⎯ Account data and profile data: In order to use certain features (like the purchase of Modules and the use of Services), you need to create a user account. When you create or update your account, we collect and store the data you provide, like your email address, password, gender, and date of birth (the “Account Data”).
⎯ Shared content: Parts of the Services let you interact with other users or share content publicly, including by posting reviews on a Module, asking or answering questions, sending messages to Inside-Out Coaching. Such shared content may be publicly viewable by others depending on where it is posted.
⎯ Payment data: If you make purchases, we or our payment processing partners collect certain data about your purchase as necessary to process your order. You must provide certain payment and billing data directly to our payment processing partners, including your name, credit card information, billing address, and zip code.
⎯ Communications and support: If you contact us for support or to report a problem or concern (regardless of whether you have created an account) regarding the Services, the Inside-Out Coaching ACADEMY Site or for any other reason, we may collect and store your contact information, messages, and other data about you like your name, email address, location, operating system, IP address, and any other data you provide or that we collect through automated means. We use this data to respond to you and research your question or concern, in accordance with this Agreement.
We and/or our service providers also collect some data automatically, like information about your device. When you access the Services (including browsing courses), we collect certain data by automated means, including:
⎯ System data: Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types (“System Data”)
⎯ Usage data: Usage statistics about your interactions, including Modules accessed, time spent on the Services, pages visited, date and time, and other data regarding your use of the Services (“Usage Data”).
⎯ Geographic data: An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.
The data listed above is collected through the use of server log files and tracking technologies. It is stored by us or our service providers and associated with your account.
3.How we get data about you
We use tools like cookies, web beacons, analytics services, and advertising providers to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.
⎯ Cookies and data collection tools: We and our service providers (like Google Analytics and third party advertisers) may use server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (together, “Data Collection Tools”) when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data when you use the Services. In some cases, we tie data gathered through those Data Collection Tools to other data that we collect as described in this privacy policy. We may use cookies for things like analyzing your use of the Services, personalizing your experience, making it easier to log into the Services, and recognizing you when you return. We use web beacons (small objects that allow us to measure the actions of visitors and users using the Services) for things like identifying whether a page was visited, identifying whether an email was opened, and advertising more efficiently by excluding current users from certain promotional messages or identifying the source of a new mobile app download.
⎯ Analytics: We may use third-party browser and mobile analytics services like Google Analytics on the Services. These services use de-identified Data Collection Tools to help us analyze your use of the Services, including information like the third-party website you arrive from, how often you visit, events within the Services, usage and performance data, and where the application was downloaded from. We use this data to improve the Services, better understand how the Services perform on different devices, and provide information that may be of interest to you.
⎯ Online advertising: We may use third-party advertising services like Facebook, Google’s ad services to deliver advertising about our Services on other websites and applications you use. The ads may be based on things we know about you, like your Usage Data and System Data, and things that these ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services, and may be tailored to your interests. Depending on the types of advertising services we use, they may place cookies or other tracking technologies on your computer, phone, or other device to collect data about your use of our Services, and may access those tracking technologies in order to serve these tailored advertisements to you.
4.What we use your data for
We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, and as required by law or necessary for safety.
In particular, we use the data we collect through your use of the Services to:
- – Provide and administer the Services, including to facilitate communication with other users;
- – Process your requests and orders for services, including Modules and Services;
- – Communicate with you about your account by:
- Responding to your questions and concerns;
- Sending you administrative messages and information, notifications about changes to our Services;
- Sending you information about your progress in the Modules, and other information relating to the Services;
- – Manage your account preferences;
- – Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;
- – Solicit feedback from participants;
- – Identify unique users across devices;
- – Improve our Services and develop new products, services, and features;
- – Analyze trends and traffic, track purchases, and track usage data;
- – Advertise the Services on third-party websites and applications; or
- – As required or permitted by law.
5.With whom we share data
We may share certain data about you with our employees, consultants and service providers performing services for us, our business partners, analytics and data enrichment providers in connection with the Services. We may share personal data with providers located outside Switzerland, in accordance with and subject to the limitations set by the Swiss Federal Act on Data Protection. We may also share your data as needed for security or legal compliance. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.
In particular, we may share your data with third parties under the following circumstances or as otherwise described in this privacy policy:
– With other participants: If you ask a question on the questions & answers platform or if you use the Chat Services, your information may also be publicly viewable by other users depending on your settings;
– With service providers: We share your data with third-party companies who perform services on our behalf, like payment processing, data analysis, marketing and advertising services, email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
– With business partners: We may enter into agreements with other websites and platforms to distribute our Services;
– With analytics and data enrichment services: As part of our use of third-party analytics tools like Google Analytics and data enrichment services, we may share certain contact information, Account Data, System Data, Usage Data, or de-identified data as needed.
– For Security and legal compliance: We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is permitted or required by law; requested as part of a judicial or administrative legal inquiry, order, or proceeding; necessary to enforce the Agreement, this privacy policy or and other agreement to which we are party; we may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy.
– During a restructuring or transaction: If Inside-Out Coaching undergoes a business transaction like a merger, acquisition or a sale of assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
– After Aggregation/De-identification: we can disclose or use aggregate or de-identified data for any purpose.
– With your Permission: with your consent, we may share data to third parties outside the scope of this privacy policy.
Recipients of your personal data may also be located abroad – even outside the EU or EEA, namely in the USA [to be supplemented if necessary]. The countries concerned may not have laws that protect your personal data to the same extent as in Switzerland. If we transfer your personal data to such a country, we will ensure that your personal data is adequately protected.
One means of ensuring an appropriate level of data protection is, for example, concluding data transfer agreements with the recipients of your personal data in third countries which ensure the necessary data protection. These include contractual clauses that have been approved, issued or recognised by the Federal Data Protection and Information Commissioner, so-called standard contractual clauses. The transfer of data to recipients who are subject to the Swiss-US Privacy Shield Program is also permitted. Please contact us if you would like a copy or further information on the data transfer agreements we have concluded or other appropriate guarantees we apply to data transfers abroad. Transfer to countries without adequate protection may also be permitted in other cases, e.g. based on express consent or for the purpose of asserting, exercising or defending legal claims.
6.Security
We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorized access, so it’s important to protect your password and to contact us if you suspect any unauthorized access to your account.
7.Your rights
You have certain rights around the use of your data. You can update or terminate your account from within our Services, and can also contact us for individual requests about your personal data.
You can access and update your personal data that we collect and maintain as follows:
⎯ To update data you provide directly: log into your account and update your account at any time.
⎯ To terminate your account: please send an e-mail to admin@inside-out-coaching.com. Note that even after your account is terminated, some or all of your data may still be visible to others, including without limitation any data that has been shared or disseminated by you or others (including in your shared content and the Chat Service). Even after your account is terminated, we retain your data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data pursuant to this privacy Policy after your account has been terminated.
To request to access, correct, or delete your personal data, please email admin@inside-out-coaching.com in every case please.