360 LEADERSHIP COACHING

PRIVACY POLICY

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR, You can be referred to as the Data Subject or the User.
Company ("the Company", "We", "Us", "Our") refers to 360 Leadership Coaching, trading as Stephanie Paillé. For the purpose of the GDPR, the Company is the Data Controller.
Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for election of directors or other managing authority.
Account means a unique account created for You to access our Service or parts of our Service.
Website refers to 360leadershipcoach.com, accessible from https://www.360leadershipcoaching.com
Service refers to the Website.
Country refers to: Canada.
Service Provider means any natural or legal person who processes data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, provide the Service on behalf of the Company, perform services related to the Service, or assist the Company in analysing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
Third-party Social Media Service refers to any website or social network through which a User can log in or create an account to use the Service.
Personal Data is any information that relates to an identified or identifiable individual. For GDPR purposes, this includes a name, identification number, location data, online identifier, or factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity. For CCPA purposes, Personal Data means any information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with You.
Cookies are small files placed on Your computer, mobile device, or any other device by a website, containing details of Your browsing history on that website among its many uses.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Data Controller for GDPR purposes, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Do Not Track (DNT) is a concept promoted by US regulatory authorities, particularly the FTC, for the internet industry to develop a mechanism allowing users to control tracking of their online activities across websites.
Business for CCPA purposes, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of processing it, and that does business in the State of California.
Consumer for CCPA purposes, means a natural person who is a California resident, as defined under California law.
Sale for CCPA purposes, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a Consumer's Personal Information to another business or third party for monetary or other valuable consideration.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. This may include, but is not limited to:

• Email address

• First name and last name

• Phone number

• Address, State, Province, ZIP/Postal code, City

• Usage Data

Sensitive Personal Data

GDPR specifies a set of personal data categories considered "sensitive," requiring special consideration by Data Controllers. With regard to any sensitive personal data We collect from You, upon submission of such data through the Website, You hereby expressly consent to Our processing of it for the purpose of providing and maintaining Our Service.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your device's Internet Protocol address (IP address), browser type and version, the pages of Our Service that You visit, the time and date of Your visit, time spent on those pages, unique device identifiers, and other diagnostic data.

When You access the Service by or through a mobile device, We may automatically collect information including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, IP address, mobile operating system, the type of mobile internet browser You use, unique device identifiers, and other diagnostic data.

We may also collect information that Your browser sends whenever You visit Our Service or access it through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track activity on Our Service and store certain information. Tracking technologies used include beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of Our Service.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. We use both for the purposes set out below:

Necessary / Essential Cookies
- Type: Session
- Administered by: Us
- Purpose: Essential to provide services available through the Website and to enable core features. Help authenticate users and prevent fraudulent use of accounts.
Cookies Policy / Notice Acceptance Cookies
- Type: Persistent
- Administered by: Us
- Purpose: Identify whether users have accepted the use of cookies on the Website.
Functionality Cookies
- Type: Persistent
- Administered by: Us
- Purpose: Allow Us to remember choices You make when using the Website, such as login details or language preference, for a more personal experience.
Tracking and Performance Cookies
- Type: Persistent
- Administered by: Third Parties
- Purpose: Track information about traffic to the Website and how users use it, and may be used to test new advertisements, pages, or features.

Use of Your Personal Data

360 Leadership Coaching may use Personal Data for the following purposes:

To provide and maintain Our Service, including to monitor the usage of Our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service available to You as a registered user.
For the performance of a contract: the development, compliance, and undertaking of the purchase contract for products, items, or services You have purchased, or of any other contract with Us through the Service.
To contact You: by email, telephone, SMS, or other equivalent forms of electronic communication, such as push notifications, regarding updates or informative communications related to functionalities, products, or contracted services, including security updates when necessary.
To provide You with news, special offers, and general information about other goods, services, and events which We offer that are similar to those You have already purchased or enquired about, unless You have opted not to receive such information.

We may share Your personal information in the following situations:

With Service Providers: to monitor and analyze the use of Our Service, show advertisements to You to help support and maintain Our Service, contact You, advertise on third-party websites to You after You visited Our Service, or for payment processing.
For Business transfers: in connection with, or during negotiations of, any merger, sale of Proprietor assets, financing, or acquisition of all or a portion of Our business to another company or proprietor.
With Affiliates: in which case We will require those affiliates to honour this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners, or companies We control or that are under common control with Us.
With Business partners: to offer You certain products, services, or promotions.
With other users: when You share personal information or otherwise interact in public areas with other users, that information may be viewed and publicly distributed by those users. If You register through a Third-Party Social Media Service, Your contacts there may see Your name, profile, pictures, and activity description.

Retention of Your Personal Data

The Proprietor will retain Your Personal Data only for as long as necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with legal obligations, resolve disputes, and enforce Our legal agreements and policies.

Personal Data We don't need to retain for legal compliance is normally deleted automatically after two years of inactivity. You are considered an active client when logging into Your account or when We receive a payment from You. You may update Your privacy settings to have Your Personal Data deleted at a time frame that suits You, or email [email protected] at any time.

The Proprietor will also retain Usage Data for internal analysis purposes, generally for a shorter period, except when used to strengthen security or improve functionality, or where legally required for longer retention.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Proprietor's operating offices and in any other places where the parties involved in processing are located. This means Your information may be transferred to, and maintained on, computers located outside Your state, province, country, or other governmental jurisdiction where data protection laws may differ from those of Your jurisdiction.

Your consent to this Privacy Policy, followed by Your submission of such information, represents Your agreement to that transfer.

The Proprietor will take all steps reasonably necessary to ensure Your data is treated securely and in accordance with this Privacy Policy, and no transfer of Your Personal Data will take place to an organization or country unless adequate controls are in place, including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Proprietor is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Proprietor may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

Other Legal Requirements

The Proprietor may disclose Your Personal Data in the good-faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Proprietor
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the internet, or method of electronic storage, is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party service providers to monitor and analyse the use of Our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of Our Service; this data is shared with other Google services and may be used to contextualise and personalise ads within Google's advertising network. You can opt out by installing the Google Analytics opt-out browser add-on. For more on Google's privacy practices, visit Google's Privacy & Terms page.

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials, and other information that may be of interest to You. You may opt out of receiving any or all of these communications by following the unsubscribe link or instructions provided in any email We send, or by contacting Us. We may use email marketing service providers to manage and send emails to You.

Behavioural Remarketing

The Proprietor uses remarketing services to advertise on third-party websites to You after You visit Our Service. We and Our third-party vendors use cookies to inform, optimize, and serve ads based on Your past visits to Our Service.

Facebook

Facebook remarketing service is provided by Facebook, Inc. Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can opt out of interest-based ads directly through Facebook, or through the Digital Advertising Alliance (US), the Digital Advertising Alliance of Canada, the European Interactive Digital Advertising Alliance, or Your mobile device settings. See Facebook's Data Policy for details.

Payments

We may provide paid products and/or services within the Service. In that case, We may use third-party services for payment processing. We will not store or collect Your payment card details — that information is provided directly to Our third-party payment processors, whose use of Your personal information is governed by their own privacy policy. These payment processors adhere to PCI-DSS standards, managed by the PCI Security Standards Council.

Stripe

Their Privacy Policy can be viewed at stripe.com/us/privacy.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Proprietor is subject.
Vital interests: Processing Personal Data is necessary to protect Your vital interests or those of another natural person.
Public interests: Processing Personal Data relates to a task carried out in the public interest or in the exercise of official authority vested in the Proprietor.
Legitimate interests: Processing Personal Data is necessary for the purposes of legitimate interests pursued by the Proprietor.

In any case, the Proprietor will gladly help clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Proprietor undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. You have the right, by law if You are within the EU, to:

Request access to Your Personal Data. You can access, update, or request deletion of Your Personal Data by emailing [email protected] or via Your membership suite profile area at any time, and to receive a copy of the Personal Data We hold about You.
Request correction of any incomplete or inaccurate Personal Data We hold about You.
Object to processing of Your Personal Data where We rely on legitimate interest as the legal basis, or where We process Your Personal Data for direct marketing purposes.
Request erasure of Your Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data to You or to a third party You have chosen, in a structured, commonly used, machine-readable format (applies only to automated information You provided consent for, or that We used to perform a contract with You).
Withdraw Your consent on the use of Your Personal Data at any time. Note that this may limit Your access to certain functionalities of the Service.

Exercising Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. We may ask You to verify Your identity before responding to such requests, and will try our best to respond as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. If You are in the European Economic Area (EEA), please contact Your local data protection authority.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan Page, on the basis of the GDPR, to obtain anonymized statistical data about Our users. Facebook places a Cookie on the device of a user visiting Our Facebook Fan Page; each Cookie contains a unique identifier code and remains active for up to two years, unless deleted earlier. Facebook receives, records, and processes the information stored in the Cookie. For more information, see Facebook's Data Use Policy.

CCPA Privacy

Your Rights under the CCPA

If You are a California resident, You have the following rights:

The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which they are used.
The right to access / the right to request. You may request and obtain information regarding the disclosure of Your Personal Data collected in the past 12 months to a third party for the third party's direct marketing purposes.
The right to say no to the sale of Personal Data. You may ask the Proprietor not to sell Your Personal Data to third parties via Our "Do Not Sell My Personal Information" page.
The right to know about Your Personal Data, including the categories collected, the sources, the business or commercial purpose, the categories of third parties We share it with, and the specific pieces of Personal Data collected about You.
The right to delete Personal Data collected in the past 12 months.
The right not to be discriminated against for exercising any of Your Consumer rights, including denial of goods or services, different prices or quality, or suggestions of different pricing or quality.

Exercising Your CCPA Data Protection Rights

To exercise any of Your rights under the CCPA as a California resident, You can email or call Us, or visit Our "Do Not Sell My Personal Information" page. The Proprietor will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request, extendable once by an additional 45 days when reasonably necessary, with prior notice.

Do Not Sell My Personal Information

We do not sell personal information. However, the Service Providers We partner with (for example, Our advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA.

If You wish to opt out of the use of Your personal information for interest-based advertising and these potential sales as defined under the CCPA, You may do so by following the instructions below. Any opt-out is specific to the browser You use — You may need to opt out on every browser You use.

Website

You can opt out of personalized ads served by Our Service Providers via:

• Our "Cookie Consent" notice banner

• Our "CCPA Opt-out" notice banner

• Our "Do Not Sell My Personal Information" notice banner

• Our "Do Not Sell My Personal Information" link

The opt-out will place a cookie on Your computer unique to the browser You use. If You change browsers or delete Your saved cookies, You will need to opt out again.

Mobile Devices

Your mobile device may allow You to opt out of interest-based ads and location tracking:

• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices

• "Limit Ad Tracking" on iOS devices

• Stop collection of location information by changing Your device preferences

"Do Not Track" Policy (CalOPPA)

Our Service does not respond to Do Not Track signals. However, some third-party websites do keep track of Your browsing activities. You can set Your browser preferences to inform websites that You do not want to be tracked by enabling or disabling DNT in Your browser's settings.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under 13. If You are a parent or guardian and are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under 13 without verification of parental consent, We take steps to remove that information from Our servers.

We may also limit how We collect, use, and store information from Users between 13 and 18 years old; in some cases, this means We will be unable to provide certain functionality of the Service to these users. Where consent is required from a parent under Your country's laws, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites not operated by Us. If You click a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services.

Changes to This Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective, and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically. Changes are effective when posted on this page.