PRIVACY POLICY
LAST UPDATED ON: [05/25/2022]
The Agile Coach values and respects your privacy and we’re committed to protecting it under this Privacy Policy. Please take the time to read this Privacy Policy which explains what information we collect about you, how we use it and your rights. The Agile Coach (“we”, or “us”) is the data controller of the personal data collected via or in connection with [https://theagilecoach.com/], our mobile application and software (collectively known as the “Site”).
1. What personal data do we collect about you?
We collect personal data from you when you provide it to us directly and through your use of the Site. This information may include: Information you provide to us when you use our Site (e.g. your name, phone number, address, email, education qualification, work experience, school name and grade or class, and any information which you add to your account profile); Transaction and billing information, if you make any purchases from us or using our Site (e.g. credit/debit card details and delivery information); Records of your interactions with us (e.g. if you contact our customer service team, interact with us on social media); Information you provide us when you enter a competition or participate in a survey; Information collected automatically, using cookies and other tracking technologies (e.g. which pages you viewed and whether you clicked on a link in one of our email updates). We may also collect information about the device you use to access our Site; and Other information necessary to provide the Site, for example, we may access your location if you give us your consent. When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout
2. What do we use this personal data for?
Depending on how you use our Site, your interactions with us, and the permissions you give us, the purposes for which we use your personal data include: To verify your account using the information you provide to us. To verify if Instructors are qualified for imparting knowledge to Learners and associated issues. To provide proper services and maintain your online account. To manage and respond to any queries or complaints to our customer service team. To personalize the Site to you and show you content we think you will be most interested in, based on your account information, your purchase history, and your browsing activity. To improve and maintain the Site and monitor its usage. For market research, e.g. we may contact you for feedback about our services. To send you service-related messages, promotions, and newsletters, and show you targeted advertising, where we have your consent or are otherwise permitted to do so. To provide you discount codes. To know your location. For analytics purposes. For security purposes, to investigate fraud and where necessary to protect ourselves and third parties. To comply with our legal and regulatory obligations. We rely on the following legal basis, under data protection law, to process your personal data: Because the processing is necessary to perform a contract with you or take steps prior to entering into a contract with you (e.g. where you have made a purchase with us, we use your personal data to process the payment and fulfill your order). Because we have obtained your consent (e.g. where you contact us with a query, where you add optional information to your account profile, or if you consent to receive marketing from us). We use information about you to tailor your view of the Site, to make it more interesting and relevant in respect of the products and offers on view.
3. Marketing
Depending upon your preferences for services, we may use your personal data to send you marketing messages by email, phone, or post. Some of these messages may be tailored to you, based on your previous browsing or purchase activity, and other information we hold about you. If you no longer want to receive marketing communications from us (or would like to opt back in!), you can change your preferences at any time by contacting us (details below), clicking on the ‘unsubscribe’ link in any email, or updating your settings in your account. If you unsubscribe from marketing, please note we may still contact you with service messages from time to time (e.g. order and delivery confirmations, and information about your legal rights). You may also see ads for our Site on third-party websites, including on social media. These ads may be tailored to you using cookies (which track your web activity, so enable us to serve ads to customers who have visited our Site). Where you see an ad on social media, this may be because we have engaged the social network to show ads to our customers, or users who match the demographic profile of our customers. In some cases, this may involve sharing your email address with the social network. If you no longer want to see tailored ads you can change your cookie and privacy settings on your browser and these third-party websites.
4. Who do we share this personal data with?
We share customers’ personal data with third parties in the following circumstances:
Otherwise where we have your consent or are otherwise legally permitted to do so.
5. Storage and Retention
We will keep your personal data for as long as you are active on the site, and so this period will vary depending on your interactions with us. After the deletion of your account, your data will be available with us for the next 6 months. For example, where you have made a purchase with us, we will keep a record of your purchase for the period necessary for invoicing, tax, and warranty purposes. We may also keep a record of correspondence with you (for example if you have made a complaint about a service) for as long as is necessary to protect us from a legal claim. Where we no longer have a need to keep your information, we will delete it. Please note that when you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in the future.
6. Data protection provisions about the application and use of Facebook
On this Site, the controller has integrated components of the enterprise Facebook. Facebook is a social network. A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests. The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. With each call-up to one of the individual pages of this Internet Site, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Facebook is made aware of what specific sub-site of our Site was visited by the data subject. If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our Site by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our Site, e.g. the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data. Facebook always receives, through the Facebook component, information about a visit to our Site by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our Site. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our Site is made. The data protection guideline published by Facebook, which is available at https://www.facebook.com/policy, provides information about the collection, processing, and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject.
7. Data protection provisions Facebook (Visitor Action Pixel)
We use the “visitor action pixels” from Facebook Inc (1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”)) on our Site. This allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/policy. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes. The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter of GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: www.facebook.com/help/109378269482053/?helpref=uf_share. Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation https://www.facebook.com/about/privacyshield.
8. Data protection provisions about the application and use of Google Analytics (with anonymisation function)
On this Site, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
For the web analytics through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application, the IP address of the Internet connection of the data subject is abridged by Google and anonymized when accessing our Site from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area. The purpose of the Google Analytics component is to analyze the traffic on our Site. Google uses the collected data and information, among other things, to evaluate the use of our Site and to provide online reports, which show the activities on our site and provide other services concerning the use of our Internet site for us. Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our Site. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements. The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our Site by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties. The data subject may, as stated above, prevent the setting of cookies through our Site at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs. In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this Site, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link: https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript that any data and information about the visits of Site may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons. Further information and the applicable data protection provisions of Google may be retrieved under: https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link: https://www.google.com/analytics/.
9. Payment Method: Data protection provisions about the use of Stripe as a payment processor
On this Site, the owner has used Stripe as an online service provider. Stripe’s security policy is further explained here and privacy policy here.
10. Security
This Site ensures that data is encrypted when leaving the Site. This process involves the conversion of information or data into a code to prevent unauthorised access. This Site follows this process and employs secure methods to ensure the protection of all credit and debit card transactions. Encryption methods such as SSL are utilised to protect customer data when in transit to and from this Site over a secure communications channel. Whilst we do everything within our power to ensure that personal data is protected at all times from our Site, we cannot guarantee the security and integrity of the information that has been transmitted to our Site.
11. Children
Our Site is not intended for, and should not be used by, children under the age of 18. We do not knowingly collect personal data from children under 18. Please make sure that you give permission to access and use the Site to minors under the age of 18. Please note that we cannot know if a user of the Site is of age of majority. Therefore, we shall not be responsible for any damages or disputes that may arise in this regard. We recommend you to keep monitoring the access and use of the Site whilst being used by your minor wards.
12. Cookies
We use cookies. Cookies are text files that are stored in a computer system via an Internet browser. Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Site and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognised and identified using the unique cookie ID. Through the use of cookies, The Agile Coach can provide the users of our Site with more user-friendly services that would not be possible without the cookie setting. We can manage sessions and there would be personalized services. By means of a cookie, the information and offers on our Site can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our Site users. The purpose of this recognition is to make it easier for users to utilize our Site. The Site user that uses cookies e.g. does not have to enter access data each time the Site is accessed, because this is taken over by the Site, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie. The data subject may, at any time, prevent the setting of cookies through our Site by employing a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our Site may be entirely usable.
13. Session Cookies
We use Session cookies, also known as 'temporary cookies', which help websites recognize users and the information provided when they navigate through a website. Session cookies only retain information about a user's activities for as long as they are on the website. Once the web browser is closed, the cookies are deleted.
14. Same Site Cookies
The SameSite attribute tells browsers when and how to fire cookies in first- or third-party situations. SameSite is used by a variety of browsers to identify whether or not to allow a cookie to be accessed.
15. User Rights
Users who are California residents have certain rights under the California Consumer Privacy Act, (“CCPA”). If you are an eligible California user, included in these rights are:
“Right to Know” — You have the right to request to know more about the categories and specific pieces of personal information that we have collected about you and access a copy of your personal information.
“Right to Deletion” — You have the right to request deletion of personal information that we have collected about you.
“Right to Non-Discrimination” — If you choose to exercise any of your rights under CCPA, The Agile Coach will treat you like all other users. In other words, there is no penalty for exercising your rights under CCPA.
“Right to Opt-Out” - You have the right to opt out of the sale of your personal information.
CCPA has a specific definition of a “sale” and while The Agile Coach does not, in the traditional sense, sell your personal information or the personal information of any of our users, we do use cookies that make non-personally identifiable information available to select third-parties. To opt out of such a “sale,” click on the “Do Not Sell My Personal Information” link at the bottom of this page.
If you would like to exercise any of your rights as described above and under the CCPA please:
Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification. Additionally, for more information about the personal information we collect and how we collect it, please see the sections above entitled “What Data We Get” and “How We Get Data About You.”To learn about the business and commercial purposes for which your personal information is collected and the categories of service providers who have access to your personal information, please see the sections above entitled “What We Use Your Data For” and “Who We Share Your Data With.”As a California resident, you also have the right to request certain details about what personal information we share with third parties for those third parties' direct marketing purposes. To submit your request, send an email to support@theagilecoach.com with the phrase “CCPA Data Request” and include your mailing address, state of residence, and email address. Since there is no widely accepted standard for the browser-initiated Do Not Track signal, we do not currently recognize or respond to Do Not Track signals.
Users in Nevada
The Agile Coach does not sell its users’ personal information or personal data. Nonetheless, Nevada residents have the right to submit a request that we do not sell your covered personal information, which you can do by emailing support@theagilecoach.com.
Users in Australia
If you are an Australian resident and you have a complaint, you may refer it to the office of the Australian Information Commissioner (“OAIC”). You can contact OAIC by visiting www.oaic.gov.au; forwarding an email to enquiries@oaic.gov.au; telephoning 1300 363 992; or writing to OAIC at GPO Box 5218, Sydney NSW 2001.
Users Outside of the U.S.
In order to provide the Services to you, we must transfer your data to the United States and process it there. By visiting or using our Services, you consent to the storage of your data on servers located in the United States. If you are using the Services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries. Specifically, personal data collected in the United Kingdom (“UK”), Switzerland, and the European Economic Area (“EEA”) is transferred and stored outside those areas. Additionally, if you are located in the EEA, UK, or Switzerland, you also have the right to lodge a complaint with your data supervisory authority.
Personal data is also processed outside of the UK, Switzerland, and the EEA by our The Agile Coach group companies, or our service providers, including to process transactions, facilitate payments and provide support services. We use Standard Contractual Clauses adopted by the European Commission to facilitate transfers of personal data from the EEA to third countries and have entered into data processing agreements with our service providers and The Agile Coach group companies to restrict and regulate their processing of your data. By submitting your data or using our Services, you consent to this transfer, storage, and processing by The Agile Coach and its processors.
Your Rights Under the General Data Protection Regulation (GDPR)
How to File a GDPR Complaint
We hope that we can resolve any query or concern you raise about our use of your information. The GDPR also gives you the right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
15. Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After the expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
16. Provision of personal data as a statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact our Data Protection Officer. Our Data Protection Officer clarifies to the data subject whether the provision of the personal data is required by law, contract, or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of non-provision of the personal data.
17. Contact Us
If you have any queries on any aspect of our Privacy Policy, please contact us at:
E-MAIL: support@theagilecoach.com