Data Protection Information Notice To Users

1. What Personal Data Do We Collect And Process?

The provision of your personal information to us is completely voluntary. “Personal information” is information that can specifically identify you. We do not collect personal information unless you submit that information to us.

Depending on the purpose for which we process your data from time to time, we need to process one or more of your data, which will generally be, as appropriate, the following:

(i) your identity data (for example, your name, surname, language and country from which you interact with us, contact information, etc.)

(ii) financial information and transaction information (for example, payment or card details, purchase information, orders, refunds, etc.)

(iii) login data, geographic location, and internet browsing (if you contact us, for example, with your mobile)

(iv) Profile Data, which includes your username and password, avatar (if you upload one) and other info you share with us on our Websites (Site).

(iv) Commercial information (for example, if you have subscribed to our newsletter), information about your tastes and preferences.

Please notice that when we ask you to fill in your personal data to access any function or service of the Site, we will point out certain fields as mandatory, as these are data we need to be able to provide the service or give you access in this function. Please keep in mind that if you decide not to provide this information to us, you may not be able to complete your registration as a user or you may not be able to enjoy these services or features.

2. For What Purposes Do We Process Your Personal Data?

Depending on how you interact with our Site, e.g. depending on the services, products, or features you want to receive, we will process your personal data for the following purposes:

2.1. To manage your registration as a user of the Site.

If you decide to register as a user on our Site, we need to process your data to recognise you as a user of the website and to give you access to the various features, products and services which are available to you due to your status as a registered user. You can cancel your registered user account by contacting us through our Client Concierge Service.

2.2. For the development, fulfillment and performance of the sales or service contract you have entered into with us on the website.

This purpose includes processing your data, mainly to:

(a) Communicate with you about the updates or informational notifications related to the contract-related functions, products or services, including the sending of quality surveys and in order to determine the client’s satisfaction degree with the service provided, to request marketing material to be sent to you; or give us feedback.

(b) Manage the payment for the products and / or services you buy, regardless of the payment process that is used.

For example: If you choose to enable the storage of your card data for future purchases when you buy one of our products through the website, we need to process the data indicated to activate and develop that feature. Consent to enabling this feature allows automated payment data to appear on subsequent purchases so you do not have to re-enter them in each new process and these data will be considered valid and active for future purchases. You can modify or cancel your cards at any time through the section corresponding to the payment information.

By submitting your payment information through our websites, to the extent permitted by applicable law, you expressly consent to the sharing of your information with third-party payment processors, and other third-party service providers.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them, if we are part of a bankruptcy proceeding or other change in control. Third parties to whom we need to share your information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the policies for the website.

(c) Activate the necessary mechanisms to avoid possible fraud against you and against us during the purchase process.

If we believe the transaction may be fraudulent, this processing may result in blocking the transaction.

(d) Manage potential returns once you have made a purchase and manage requests for product availability, product booking via the platform, or to provide you with services related to Personal Tailoring, depending on the availability of these options.

(e) For pricing purposes and to make available to you tickets and invoices for purchases made through the website.

2.3. Respond to requests and applications you submit via Client Concierge Service channels.

We only process personal data that is absolutely necessary to manage or resolve your request or application, to answer your questions and, if you wish, to send you personalised communications.

2.4. For marketing purposes.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. This purpose includes processing your data, mainly: While you subscribe to our Newsletter, we will process your personal information to manage your registration, including sending personalised information about our products or services through various means (such as email or SMS). We may also provide you with this information via push notifications if you have them activated on your personal computer, tablet, mobile device or other electronic device you use to access these services. Respectively, keep in mind that this data processing involves analysing your profile as a user or client to determine what your preferences are and, therefore, which products and services most fit your style when sending information to you. For example, based on your purchases and your browsing history (i.e. depending on the products you clicked on), we will make suggestions for products that we believe may be of interest to you and, if you are a registered user, we will provide you with “basket retrieval”.

Keep in mind that you can unsubscribe from the newsletter at any time and at no cost through the Newsletter section of the Site and through the instructions provided for each update. If you do not want to receive push notifications, you can disable this option on your mobile device, tablet or PC.

We conduct promotions (for example, to organise competitions or to send a list of products you have saved to the email address you specify). By participating in any promotional action, you authorise us to process the personal data you have shared with us according to the promotional action and we may share it through various means such as social networks or the Site itself. In any promotional action you participate, you will be provided with the terms and conditions where we will provide you with more detailed information about processing your data. The same applies for all our Brands, as per the present  company’s terms and conditions.

2.5. Usability and quality analysis to improve our services.

By entering our Site, we inform you that we will process your browsing data for purposes of analysis and statistical purposes, that is, to understand how users interact with our Site and so that we can make improvements to it. Additionally, we sometimes carry out quality surveys and actions aimed at knowing the degree of satisfaction of our clients and users and identifying those areas where we can improve.

3. Change Of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at concierge@coachingevolution.org . If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Collection Of Personal Data From Third-Party Sources

We also collect personal data about you from various third parties and public sources. If you register for our services using Learnworlds or any other social media fora, like Facebook, Twitter or other social media sites, we will import your information from those social media sites.

5. Information You Share

Please keep in mind that whenever you voluntarily make your Personal Information available to third parties — for example on message boards or web logs; through email; during webinars, classes, telephone conferences, or coaching calls; or in comment or chat areas — that information can be seen, collected, heard, and/or used by others besides us. We cannot be responsible for any unauthorised third-party use of such information.

6. How We Protect The Information

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorised access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Websites may not be secure, and you should, therefore, take special care in deciding what information you send to us via email.

7. What Are The Legal Bases For Processing Your Personal Data?

We collect, process and store your personal data primarily for (a) the satisfactory performance of the sales or service contract, (b) the compliance of the Company with its legal obligations, (c) the legitimate interests pursued by the Supervising Authority or any other third party, legally entitled to access or request your data.

The legal basis for processing your personal data also depends on the purpose for which we process them.

Particularly:

i. In order to manage your registration as a user of the Site, we process your data because it is

necessary to implement the terms governing the use of the website. In other words, in order to be able to register you as a user on the website, we need to process your personal data, otherwise we would not be able to manage your registration.

ii. For the purpose of developing, performing and executing the purchase or service contract. We process your data because it is necessary to perform the contract of purchase or service with you. Some data processing related to the purchase process is only triggered because you request or approve it, such as storing payment data for future purchases or to provide you with the Coming soon / Back soon. In these cases, processing your data is based on your own consent.

We believe that we have a legitimate interest in conducting the necessary checks to detect and prevent possible fraud when making a purchase. We understand that processing this data is a positive sign for all parties involved when paying for a purchase, especially for you, as this allows us to take action to protect you from attempts of fraud by third parties.

iii. For the purpose of Client Concierge Service

We believe that we have a legitimate interest in responding to requests or queries raised by you through the various existing communication channels. We understand that processing this data is also beneficial to you as long as it allows us to help you adequately and answer the queries you raise. When you contact us, especially to manage events related to your order or to the product / service acquired via the Site, processing your data is necessary for the performance of the purchase contract or the service. When your query relates to the exercise of your rights for which we inform you below or claims about our products or services, we are legally qualified to process your data in order to comply with our legal obligations.

iv. In terms of marketing purposes

We are legally authorised to process your data for marketing purposes because of your consent, for example, when you agree to receive personalised information through a variety of media, when you authorise us to send push notifications to your mobile device, tablet and/or PC, or when you accept the legal terms and conditions to participate in a promotional action. In order to show you personalised information, we believe that we have a legitimate interest in setting up a profile with the information we have about you (such as your browsing, preferences, or purchase history) and the personal data you gave us, such as the range age or language since we understand that processing this data is also beneficial to you because it allows you to improve your user experience and access information according to your preferences.

v. Usability and quality analysis

We believe that we have a legitimate interest in analysing the usability of the Site and the degree of user satisfaction as we understand that processing this data is also beneficial to you because its purpose is to improve user experience and provide higher quality service.

8. How Long Do We Retain Your Personal Data?

We retain your personal data only for as long as it is necessary to provide you with our services as well as for legitimate and meaningful business purposes such as making business decisions based on data about new features and offers to comply with our legal obligations and to resolve disputes.

In particular, the retention time of your data will depend on the purposes for which we process it:

i. As to the purpose of managing your registration as a user of the website.

We will process your data for the time you remain a registered user (i.e., until you decide to unsubscribe).

ii. For the purpose of developing, performing and executing the purchase or service contract.

We will process your data for the length of time required to manage the purchase of the products or services you have acquired, including any refunds, complaints or claims relating to the purchase of the particular product or service. Sometimes we will process the data only until you decide, as is the case with the payment data (card) you have requested to store for future purchases.

iii. For the purpose of Client Concierge Service.

We will process your data for as long as we need to meet your request or application.

iv. In terms of marketing purposes.

We will process your data until you unsubscribe or cancel your subscription to the Newsletter. If you

participate in promotions, we will retain your data for a period of 6 months after the end of the action.

v. For the purpose of usability and quality analysis.

We will process your data during the period in which we will perform an action or a specific quality survey or until we have rendered your browsing data anonymous.

Regardless of how we process your data, and regardless of the fact that we process your data only for the amount of time strictly necessary to achieve the intended purpose, we will keep it properly stored and protected for the length of time during which data processing issues could arise, in accordance with the legislation in force on the aforementioned length of time. As soon as the limitation period for each claim expires, we will delete the personal data.

If you request it, we will delete or render anonymous your personal information so that we can no longer identify you unless the law permits otherwise or requires us to retain certain personal data, including cases such as:

– If there is an unresolved problem with your account, a pending credit in your account, or a claim or dispute that has not been resolved, we will maintain the necessary personal data until the problem is resolved.

– Since we have to maintain your personal data for legal, tax, audit, and accounting purposes, we will maintain the necessary personal data for the period required by applicable law.

– Where necessary for our legitimate business interests, such as preventing fraud or maintaining the safety of our users.

9. To Whom Do We Disclose Your Personal Data?

For the purposes of our Privacy Policy and Cookies, it is necessary to provide access to your personal information to third parties who provide us with support for the services we offer, namely:

·Financial Institutions,

·Fraud detection and prevention agencies,

·Technological service providers,

·Associates and service providers, transport and delivery,

·Service Providers related to Client Concierge Service,

·Partners and Service Providers related to Marketing and Advertising.

10. Third-Party Links And Social Networking Services

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The Site may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Site, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.

You should be aware that information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by

others. We are unable to control such uses of your information, and by using such services you assume the risk that the information provided by you may be viewed and used by third parties.

11. Data Relating To Children

Our Site is designed for those 16 years of age and older. We do not knowingly collect information from anyone under the age of 13 (or such other age as may be restricted under local law). If we are made aware that we have received such information, or any information in violation of our policy, we will make reasonable efforts to locate and remove that information from our records.

12. Updates In Data Policy And Cookies

We reserve the right, at our discretion, to change, modify, add, or remove portions from this privacy policy at any time. We may modify the information contained in this Data Policy and Cookies when we deem it necessary. If we do, we will notify you in various ways via the Site (for example, via a banner, pop-up window, or push alert), or we may even send you a notification to your email address when this change is important for your privacy, so that you can review changes, evaluate them and, if necessary, oppose or unsubscribe from a service or feature. In any case, we encourage you to review this Data Policy and Cookies from time to time if we make minor changes or introduce some interactive improvement by taking advantage of the possibility that you will always find it as a permanent point of information on our website.

Contact Us

If there are any questions regarding this privacy policy, you may email them at concierge@coachingevolution.org or send them by registered letter to 71-75 Shelton St, London, WC2 H9JQ UK.