Effective Date: May 11, 2020

This Privacy Policy applies to Systems Business Coach Inc. (“SBC”, “we” or “our”) services, including but not limited to the SBC websites systemsbusinesscoach.com, organizedandprofitable.com, smallbusinesscoachtraining.com and members.smallbusinesscoachtraining.com (the “Website”), SBC applications and SBC products (the “Service”), and details how we collect, use, and disclose data, including personal data, about you (“you” or “your”) and all of our users (“Users” and each, a “User”).

By clicking “I AGREE” or similar CONFIRMATION or by using the Service you are agreeing to the terms of this Privacy Policy.

 

1. DESCRIPTION OF THE SERVICE

SBC is a coaching platform that assists coaches (each, a “Coach”) and their clients (each, a “Client”) achieve their business goals.  In order to help each Coach and Client achieve their goals, the Service may collect certain important information when you use the Service.  As the information we collect may include sensitive data, we aim to be transparent and clear about how we collect, use and share data about each Coach and Client, including you.

2. How we obtain PERSONAL data

The Service collects and processes personal data, which is information about you or that identifies you.  Subject to legal, contractual and technical requirements, you may choose not to provide SBC with certain data or request the deletion of certain data, which may impact the Service features available to you or essential operation of the Service.

3. Personal data we Collect

We collect certain personal and anonymous data when you use the Service including when you initially sign up on the Website (“Sign-up”) and during your continued use of the Service.  The following is a description of the personal data that we may collect, use and process in connection with the Service:

• your contact information including your full name, email address, phone number (“Contact Info”);
• if you are a Coach, information about your coaching business, which may include a list of Clients you coach and details about their businesses and your business (“Business Information”); and
• any information you provide to us in any business questionnaires or surveys that contains personal data according to applicable law (“Form Details”).

If you are a Coach, by agreeing to the terms of this Privacy Policy, SBC’s terms of use (“TOU”) and using the Service, you confirm you are in full compliance with privacy laws, including any and all requirements to obtain the consent of each Client that works for you prior to providing any personal data regarding such Clients to SBC.

 

4. Processing of Your Personal and ANONYMOUS data

We process your personal data for our legitimate business purposes.  These uses include but are not limited to:

• providing the Service to you, including providing useful feedback on the Business Information that you provide;
• understanding your needs and improving the quality of the Service, including providing support and feedback to both Coaches and Clients, analyzing functionality and technical issues, tracking use of the Service and generating internal reports and data models that we use to improve the service;
• supporting the security and integrity of the Service, including verifying your identity, controlling access to the Service and protecting SBC and third parties against privacy breaches, errors, fraud, theft, suspicious activity, violations of the TOU and other illegal activity;
• contacting you for various reasons including feedback requests or marketing purposes, if you previously consented to such contact; and
• for contractual, legal, regulatory or audit obligations, including responding to requests from law enforcement or a government agency asserting lawful authority to obtain the data or where SBC has reasonable grounds to believe the data could be useful in the investigation of unlawful activity, complying with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of data, complying with court rules regarding the production of records and data, defending SBC in a legal, regulatory or administrative proceeding or in a contractual dispute or providing information to our legal counsel.

We may disclose your personal data to our parent companies, affiliates, subsidiaries, employees and contractors for the same purposes described above.  We may also disclose your personal data to third parties, who may be located in a foreign jurisdiction and subject to foreign laws.

 

5. THIRD-PARTY SERVICES

This Privacy Policy only applies to personal data that SBC collects, processes and discloses and does not apply to the collection, processing and disclosure of data by third parties through third-party services, which may be broader than set forth in this Privacy Policy, and that may be embedded into the Service.  In many cases, third-parties may collect personal data about your online activities over time and across different websites and services.  We strongly recommend that you read each third-party privacy policy carefully before using the Service.  A full list of third-parties that we share your personal data with can be found here.  Please contact us directly using the information found below if you would like to learn more about third-party data practices.

 

6. Cookies and Tracking Technologies

The Service uses tracking technologies, such as cookies, web beacons, JavaScript tags and clear GIFs to collect data about you, such as your IP address and device information.  Based on this data, third-parties may be able to resolve your identity across multiple devices.  This data is collected, used and disclosed in accordance with the terms of this Privacy Policy and the applicable third-party privacy policies.  Certain Service features may rely on tracking technologies and by declining to accept cookies, disabling JavaScript or by changing certain settings on your device, you may not have access to these features.  Further details regarding the Service’s use of cookies can be found here.

 

7. Obtaining, rectifying and controlling your personal data

You may contact SBC to obtain a copy of any personal data we collect about you, the production of which may be subject to a fee as permitted by applicable law.  In addition, you may contact SBC to correct inaccurate personal data or to complete incomplete personal data.

You may be able to opt-out of some or all of the ways in which your personal data is processed, or request the deletion of certain personal data, except where the personal data is necessary or vital for:

• the performance of contractual obligations, such as the TOU or certain legal obligations;
• protecting your interests or those of another person; and
• our legitimate interests or the legitimate interests of a third-party,

and may do so by requesting deletion by contacting us using the contact information found below.

 

8. Data Storage and Retention 

While SBC is a Canadian company, the data you provide through the Service may be stored and processed by third parties in countries around the world.  You authorize SBC and third parties acting on our behalf to process your data in any country of their choosing, which may cause your data, including personal and anonymous data, to be subject to privacy protections and legal rights that may not be equivalent to those in your country.

For residents in the European Economic Area (the “EEA”), SBC complies with Articles 44-49 of the European Union’s General Data Protection Regulation (the “GDPR”).  Currently, all transfers of personal data to Canada from residents of the EEA are covered by an adequacy decision as described in Article 45 of the GDPR.

Your personal data is retained until you request its deletion or until SBC no longer requires such data for the purpose for which it was collected or until deletion is required by law, whichever is earlier in time.

 

9. DO NOT TRACK DISCLOSURE

Do Not Track (“DNT”) is a web or device setting that allows you to request that receivers of personal data stop their tracking activities.  When you choose to turn on the DNT setting in your browser or device or use alternative consumer choice mechanisms, your browser or device sends a special signal to websites, analytics companies, advertising networks, plug-in providers and other web services you encounter to stop tracking your activity.  Currently, there are no DNT technology standards and, as a result, we do not respond to DNT requests.

 

10. CALIFORNIA “SHINE THE LIGHT” RIGHT

If you are a California resident, California Civil Code 1798.83 grants you the right to request disclosure of the categories of personal information we provided to third parties, and the names and addresses of these third parties, for direct marketing purposes during the preceding calendar year.  If you are a California resident and would like to make this request, please contact us using the contact information set forth below.

Please note that you may only make this request once per year.

 

11. Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.120 permits you to opt-out of the sale of your personal information to third parties.  Currently, SBC does not sell your personal information to third parties and as such no opt-out of the sale of such personal information is necessary.  Although SBC does not sell your personal information to third-parties, SBC does provide a general opt-out right to all of our users as described in our Privacy Policy.  Furthermore, as SBC already complies with other US, Canadian and EEA privacy laws, the rights provided by law to Californian residents are already provided for in our Privacy Policy.  If you have any other questions about our privacy practices, please email us at admin@systemsbusinesscoach.com.

 

12. EUROPEAN USERS AND RIGHTS OF EUROPEAN ECONOMIC AREA RESIDENTS

The processing of your Contact Info, Business Information and Form Details is necessary for our provision of the Services to you, as described in Article 6(1)(b) of the GDPR.  In other cases, such as when you provide consent to contact you using additional Contact Info that you provide to us, SBC may collect such personal data pursuant to Article 6(1)(a) of the GDPR.

If you are a resident of the EEA, you have certain rights in regards to your personal data.  These rights include:

• A Right of Access. You have the right to access your personal data that we hold about you free of charge in most circumstances.
• A Right to Rectification. If your personal data is inaccurate or incomplete, you can change the information you provided by contacting SBC using the e-mail listed below.
• A Right to Erasure. You have the right to obtain deletion of your personal data under most circumstances.  In most cases, you may simply request the deletion by using the contact information found below.  Please be careful as deletion of data in this manner is permanent and the data cannot be recovered.
• A Right to Object. If the processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR or if your personal data was collected based on your consent according to Article 6(1)(a) of the GDPR, you have the right to object to this processing.  If you object, we will no longer process your personal data unless there are compelling and prevailing legitimate grounds for the processing as described in Article 21 of the GDPR; in particular, if the personal data is necessary for the establishment, exercise or defense of legal claims or if personal data is required for the provision of the Service and you still wish to use the Service.
• A Right to file a Complaint. You have the right to file a complaint with the appropriate supervisory authority in your jurisdiction.
• A Right to Restriction of Processing of your Personal Data. You have the right to obtain restrictions on the processing of your personal data as described in Article 18 of the GDPR.
• A Right to Personal Data Portability. You have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller under the conditions described in Article 20 of the GDPR.
• A Right to Post-Mortem Control of Your Personal Data. Certain jurisdictions grant post-mortem controls of your personal data and if such rights are applicable in your jurisdiction, you may have the right to establish guidelines for the preservation, the deletion and the transmission of your personal data after your death through a will or through your estate.
• A Right to Opt-out of Marketing Communications. You have the right to opt-out of marketing communications we send you at any time.  If you receive any marketing e-mails from us, you can exercise your right to stop such communications by clicking on the “unsubscribe” or “opt-out” link on any marketing e-mails SBC sends you.  To opt-out of other forms of marketing, please contact us using the contact details provided below.

 

13. Change of Ownership or Business Transition

In the event of, or in preparation for, a change of ownership or control of SBC or a business transition such as the sale of some or all SBC’s assets, we may disclose and/or transfer your personal and anonymous data to third-parties who will have the right to continue to collect and use such data in the manner set forth in this Privacy Policy.

 

14. Security

We are committed to ensuring that your data is secure.  To prevent unauthorized access, disclosure, or breach, we have put in place suitable physical, electronic, and administrative procedures to safeguard and secure the data we collect and process, including appropriate protections for any sensitive personal data we collect.

 

15. Contact Preferences

 We communicate with you primarily through the Service itself, but we may sometimes collect your email address, phone number or other Contact Info in order to respond to support requests or comments.  If you have provided us with your email address and would like to change the email preferences we associate with you (for example, unsubscribing from receiving certain types of email) you may do so by clicking a link within certain types of emails that we send to you or, if no link is available, by replying with “unsubscribe” in the email title or body.  On rare occasions, some types of email are necessary for the Service and cannot be unsubscribed from if you continue to use the Service.

 

16. Updates

 SBC reserves the right, in its sole discretion, to modify this Privacy Policy at any time (each an “Update”) and shall make each Update available on the Website.  You are deemed to accept an Update by continuing to use the Service.  Unless SBC states otherwise, an Update is automatically effective 30 days after posting on the Website, except in such case where an Update is immaterial to any of your legal rights or legal obligations of SBC and such Update is made only to correct a typographical, formatting or grammar inaccuracy, and in such case, an Update is effective immediately after posting on the Website.

 

17. Contact Us

If you have requests, questions or comments about the Privacy Policy or our data collection in general, please contact our Privacy Team at admin@systemsbusinesscoach.com.

 

Privacy Support Team

Systems Business Coach Inc. – 3963 205B Street, Langley, BC V3A 2B2
Owner contact email: admin@systemsbusinesscoach.com.