Effective date: July 16, 2020
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
|CATEGORY OF PERSONAL DATA||EXAMPLES OF PERSONAL DATA WE COLLECT||CATEGORIES OF THIRD PARTIES WITH WHOM WE SHARE THIS PERSONAL DATA|
|Profile or Contact Data||First and last name. Email. Phone number. Unique identifiers such as hashed passwords. Profile picture. Location.||Service Providers. Advertising Partners. Business Partners. Parties You Authorize, Access or Authenticate.|
|Payment Data||Payment card type. Last 4 digits of payment card. Billing address, phone number, and email.||Service Providers (e.g., our payment processing partner, currently Stripe, Inc.)|
|Commercial Data||Purchase History. Consumer Profiles.||Service Providers. Advertising Partners. Business Partners. Parties You Authorize, Access or Authenticate.|
|Device/IP Data||IP address. Device ID. Domain server. Type of device/operating system/browser used to access the Services.||Service Providers. Advertising Partners. Business Partners. Parties You Authorize, Access or Authenticate.|
|Web Analytics||Web page interactions. Referring webpage/source through which you accessed the Services. Non-identifiable request IDs. Statistics associated with the interaction between device or browser and the Services.|
|Social Network Data||Email. Phone number. User name/handles. IP address. Device ID. Profile Picture.|
|Geolocation Data||IP-address-based location information.|
|Inferences Drawn From Other Personal Data Collected||Profiles reflecting user attributes. Profiles reflecting user behavior.|
|Other Identifying. Information that You Voluntarily Choose to Provide.||Identifying information submitted by you to the Services, or in emails or messages you send us. Survey responses. Content you upload to the Services.||Business Partners. Parties You Authorize, Access or Authenticate.|
We collect Personal Data about you from the following categories of sources:
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and
improve our Services. Cookies are small pieces of data –usually text files– placed on your computer, tablet, phone or similar device when you use that
device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third
requests sent from a browser at this time.
We use the following types of Cookies:
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will
prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new
Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences
every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve
advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors
(“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users
on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including
when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you
through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable
ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser,
just as if you had requested a web page from their site.
We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices. Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website http://www.youronlinechoices.eu/.
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures
based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or
other sign-on mechanisms; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect
the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services, and for an additional two years or until we receive a request to delete it. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
As noted in the Terms of Service, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at [email protected]
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise
these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we
are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect
to such data.
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. We do not currently sell any Personal Data, and we have not done so over the past 12 months.
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information (like your account credentials)
to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and
respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use
Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request by reaching out through our contact page.
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct
marketing purposes; in order to submit such a request, please contact us at [email protected]
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”)
with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. MandyCoach will be the controller of your Personal Data processed in connection with the Services.
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at [email protected] Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
The Services are hosted and operated in the United States (“U.S.”) through MandyCoach and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where
you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to MandyCoach in the U.S.
and will be hosted on U.S. servers, and you authorize MandyCoach to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of
your data to the U.S. pursuant to EU-U.S. Privacy Shield Framework, the details of which are further set forth below.
In compliance with the Privacy Shield Principles, MandyCoach commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact MandyCoach at [email protected]
In compliance with the Privacy Shield Principles, Mandycoach commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Mandycoach at [email protected]
With respect to Personal Data received or transferred pursuant to the Privacy Shield Frameworks, Mandycoach, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
MandyCoach, Inc. is responsible for the processing of Personal Data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. MandyCoach, Inc. complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, including the onward transfer liability provisions.
Dispute Resolution: MandyCoach will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data in accordance with the principles contained in this Policy. MandyCoach has chosen the EU Data Protection Authorities (EU DPAs) to serve as an independent recourse mechanism (IRM) for dispute resolution arising from collection, use, and retention of Personal Data transferred from EU member countries to companies in the United States and has remitted the following fee to USCIB, acting as a trusted third party on behalf of the European Union (EU) Data Protection Authorities.