Privacy policy

1. What is this Privacy Policy?

This Data Collection and Processing Policy (“Privacy Policy”) aims to provide a clear and understandable explanation of the data collection and processing practices of MeetCoach (“Company,” “we,” “us,” or “our”). By accessing and using our mobile application or website (“Platform”), you accept and agree to be bound by this Policy, in addition to the General Terms and Conditions .

In this Policy, “data” refers to any information that can be linked to an individual or household, including but not limited to, name, email address, phone numbers, device ID, third-party identifiers, contact information, communications with coaches, and IP address. Some jurisdictions may classify this as “personal data,” “personally identifiable information,” or “sensitive personal data” in certain circumstances.

We collect data to provide and improve our services, communicate with you, and comply with legal obligations. By using our Platform, you agree to the collection and processing of your data as described in this Policy.

We may share your data with our service providers to provide and improve our services. However, we will never sell your data to third parties without your consent.

We take appropriate technical and organizational measures to protect your data from unauthorized access, disclosure, or alteration. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

If you have any questions or suggestions regarding this Policy, please contact us at contact@meetcoach.com.

This Policy constitutes a legally binding agreement between you and MeetCoach. If any provision of this Policy is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.

2. Who does this apply to?

This policy governs the collection and use of information for any visitor accessing the public portions of our websites and apps, any user accessing the paid portions of our Platform, and any independent contractor coach using the Platform to deliver sessions.

However, this policy shall not apply to the collection and use of information for employees or independent contractors (excluding coaches) of MeetCoach.com or its parent company. If you are a current or former job applicant, employee, owner, director, officer, or independent contractor (excluding coaches) of MeetCoach.com, please contact us at contact@meetcoach.com to obtain the appropriate notice that governs those portions of the Platform.

3. When you use the term “Service Provider” in this Policy, what do you mean?

A Service Provider is defined as an individual or entity with whom we have a legal agreement to process data either collected by us or on our behalf. When data is processed on our behalf, it can only be done so under our direction; no other entity has the authority to authorize it. Our Service Providers are prohibited from disclosing any individually identifiable data to any person or company other than ourselves or their own subcontractors (provided that their subcontractors are bound by data Processing terms that are no less restrictive than those that bind the Service Provider).

The data obtained by our Service Providers must be used solely for the purpose of performing the services specified in our agreement with them or as reasonably necessary to accomplish one or more of the following:

• Conformity with applicable law, regulation, or legal process
• Detection, prevention, or mitigation of fraud or security vulnerabilities
• Debugging to identify and repair errors impairing existing intended functionality
• Internal research for technological development and demonstration of our products or services, provided that such use is reasonably necessary and proportionate to accomplish the purpose for which the data was shared.

4. When you use the term “Third Party” what do you mean?

As per this policy, a Third Party is defined as an entity other than a Service Provider stated in item number 3, and excludes coaches or any other parties explicitly referred to in this Policy.

5. Do you collect, store, or Process my data?

In this policy, the term “Processing” refers to various activities carried out with data, such as collecting, storing, and utilizing it. The categories of data that we Process are outlined below. We Process this data to facilitate the operation of the Platform and ensure that you can use our services effectively. We may also Process data to send you periodic emails or text messages, but you may opt-out of receiving such communications at any time.

Furthermore, if you agree to opt-in, we may Process and share some of your data with Third Parties for advertising purposes. More information about this can be found in the relevant sections of this policy.

By using the Platform, you acknowledge and agree to the terms of this data Processing clause. If you do not agree with these terms, you should refrain from using the Platform.

6. What specific data are you Processing?

The type of data we Process is determined by the manner in which you use our website, app, or Platform. The specific data we Process is described below, while the reasons for Processing such data are elaborated on in the subsequent section.

Name of category of data Information that is collected
“Visitor data” Upon visiting the website, app, or Platform, we collect various information, including the pages you accessed, your interactions with features, the duration of your visit, any site or app errors encountered, details regarding your device and browser, as well as your IP address. If available, we may also Process your Third-Party identifier or advertising ID and share it if you consent to opt-in.
“Onboarding data” Upon registration with the Platform, users are required to complete a questionnaire, and the information provided is subject to Processing. This may include details such as email address, phone number, chosen name (first name or pseudo), and physical address, among other identifiers.
“Account Registration Data” Upon registration with the Platform, we collect and Process various data points, including the account name chosen by the user, their email address, age, phone number, and email verification status.

Each user, including coaches, who creates an account on the Platform is assigned a unique account ID, generated sequentially.
“Transaction Data” We collect and Process information relating to payment transactions on the Platform, such as whether a user has successfully completed payment for our services, subscribed to services using a trial offer, canceled or ended a trial, received discounts or financial aid, or requested extensions or refunds.
“Member Engagement Data” We collect and Process data related to logging in to the Platform, as well as the user’s activities during that session, such as login timing, message count, and duration of messages sent or received via the Platform. Additionally, we record the timing, count, and length of sessions held. Please note that this category excludes Session Communications Data, such as the content of any messages, sessions, or chat messages.
“Checkout Flow Data” We collect and Process data related to user registration on the Platform and payment made to access our Platform’s services.
“Coach Data” To follow up with you regarding your application status, as well as to identify, match, credential, re-credential, run checks, and process payments to coaches, we collect and Process a range of coach information, including their name, bank account details, gender, date of birth, professional identification numbers, email address, phone number, physical address, license information, areas of interest/expertise, education, and job history.
“Session Quality Data” We collect and Process client feedback about their coaches, including their ratings and reviews. Additionally, we track any actions related to switching coaches or discontinuing sessions, along with the reasons provided by the client. We also collect and Process data on coach session availability and any session cancellations.
“Coach Engagement Data” We collect and Process data related to coach activity on the Platform, including their login history, the number of sessions they conduct, and the number of messages and words exchanged by the coach.
“Session Communications Data” To facilitate sessions, we collect and Process all communications and related information that users share with their coaches, including chat and private messages.
“Customer Support Communications Data” We collect and Process all communications that users have with our customer support team.

7. Why do you collect and Process my data?

We have several reasons for Processing your data, and while we have provided examples that we believe may be of interest to you, please don’t hesitate to contact us at contact@meetcoach.com if you have any other questions or concerns.

We process some data to connect you with sessions: To connect you with sessions on our Platform, we need to Process certain data that will allow us to facilitate information sharing between you and your coach. This may include details such as your coach’s specialties, your state (if applicable), and your country, which will help us determine the best coach to assist you based on any applicable licensing requirements.

We Process some data to communicate with you, verify your identity and secure your account: To communicate with you, verify your identity, and secure your account, we Process certain data. This includes ensuring that we can respond to your inquiries or concerns about the Platform and provide appropriate assistance.

We Process some data to monitor and improve session quality: To ensure the quality of sessions on our Platform, we Process certain data for monitoring and improvement purposes. This may include tracking whether a session session was completed or interrupted, or if a coach ended the session intentionally. Additionally, we collect and analyze client feedback such as ratings, reviews, and complaints to maintain the quality of coaches on our Platform.

We Process some data to monitor Platform usage for product improvements: Some data is processed to monitor Platform usage for product improvements. For instance, tracking regular usage of certain pages, buttons, or features on the Platform is important to allocate our improvement resources appropriately. We may also process data to track site visits across the Platform if you opt-in to “performance cookies.”

We Process some data to personalize your web or app experience: We process certain data to customize your web or app experience. For instance, if you indicate that you prefer a coach who incorporates religious practices, we use that information to match you with a suitable coach who can fulfill your requirements. Similarly, if you express a desire for assistance with anxiety, we may suggest relevant features and content, such as sessions focused on anxiety-related topics.

We Process data to offer you new features and make the services more convenient for you: For instance, we may analyze your data to determine which products and features to introduce to you. Moreover, we may keep track of when you have already seen a pop-up on the Platform and avoid showing it to you again. Additionally, we may use your IP address to help auto-fill your state and country details or facilitate entering your contact information.

We Process certain data to comply with legal requirements: For instance, we may be required to share certain information requested in a court-issued subpoena. This is not exclusive to our online platform and also applies to in-person sessions. It’s worth noting that, as a general practice, we rely on your selected coach to determine whether to produce any session notes or messages you have shared with them. Several jurisdictions have strict rules regarding the confidentiality and disclosure obligations associated with coach-client relationships. We suggest discussing your concerns regarding disclosure with your coach early on.

We collect and process certain data to ensure the safety of our users and others. For instance, if we have reason to believe that you or anyone else may be in imminent danger or that your privacy has been violated, we may use the information to investigate or contact you or the relevant authorities, if legally permissible, to take appropriate action.

We Process certain data to monitor and safeguard the security of the Platform: For instance, data may be processed when issuing security patches and bug fixes to address security risks. Additionally, data may be processed to track potential abuse on the platform, prevent and detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

We collect and Process some data to help us understand how you use our service and enhance it: For instance, we may evaluate the usage of different features and allocate more resources to the ones that are popular, or remove features that aren’t benefiting our users. Additionally, we may request your feedback on ways to improve our platform or your experience with your coach.

If you are a coach on our Platform, in addition to the previously mentioned purposes, we may also process your data to:

• Assist in the coach recruitment process and onboard you to the Platform.
• Operate the Platform, match clients to you based on your specialties, and facilitate the communication between you and your clients.
• Verify your identity and secure your account.
• Run background checks and other screening required for credentialing and re-credentialing purposes.
• To pay you and comply with all relevant tax laws.
• Provide you quality statistics, feedback from our MeetCoach.com operations, and feedback from clients.
• Offer you information about new features, opportunities, perks and other incentives.
• Promote your profile on MeetCoach.com and with Third-Party websites and directories to get you more clients.
• Send you email, calls or chat reminders, notifications & updates about your profile or account.

We use your data to communicate with you about opportunities, promotions, news, updates, and reminders related to our services and your account. For instance, we may send you emails to offer you discounts or special promotions, or to inform you about session-related news or content that may interest you. You have the option to unsubscribe from these emails or marketing communications at any time.

If you opt in to targeting cookies and web beacons, we Process some data for advertising purposes: To learn more, see section, “Are you using my data for advertising?” .

8. Who can see the interactions I have with my therapist?

Messages sent between you and your coach are visible to both of you.

With your consent, MeetCoach.com may review your messages with your coach for quality assurance purposes. This includes situations where you express concerns about your coach, or if there are concerns about a specific coach’s session. If we need to access and retrieve your messages for any legal reasons, you will be notified.

Additionally, our internal Legal or Trust and Safety teams may review correspondence for specific accounts if there are suspected security, legal, fraud or abuse issues.

Your messages with your coach are not shared with any Third Party, and your sessions are not recorded . We also do not disclose when you send a message or have a session with your coach to any Third Party.

9. What are the purposes for sharing my data?

Here’s some further information regarding the purposes for which we may share your data:

• Your data may be shared to comply with applicable laws. For example, a court might subpoena information from us where we would be required to share certain information requested in the subpoena. This is not unique to MeetCoach.com and is applicable to in-person session as well. Keep in mind that, as a general rule, we defer to your chosen coach to decide to produce (or not produce) any session notes or messages you have had with them. Many jurisdictions have strict rules governing coach/client relationships and the confidentiality requirements associated with that. We encourage you to discuss with your coach early on if you have concerns about their disclosure obligations.

• Occasionally, your data may be handled by a select number of employees who are part of our parent company for support services. These employees are under strict duties of confidentiality. For example, a paralegal at our parent company may receive subpoenas or legal correspondence on behalf of members or former members (sometimes others too) and make sure they are provided to MeetCoach.com’s Legal team to address.

• To help us operate the Platform, we may share certain data with Service Providers that provide limited services. Some examples of these Service Providers include:
•Data hosting and storage providers, such as Amazon Web Services.
•Technology Service Providers that offer tools to enhance our Platform’s functionality, like technology for hosting group meetings.
•Customer Service Providers, who help us manage requests and questions from our members, visitors, and coaches in a secure way.
•Email management and communication Service Providers that make it easier for us to reach out to you and vice versa.
•Billing and payment processing Service Providers, such as Stripe, which help us process payments securely and issue tax documents to coaches. In order to do this, we may share some data with these Service Providers, like a coach’s email address, name, and tax ID.
• Reporting and analytics Service Providers that help us keep track of which pages and features are most used on our site.
•Advisors and lawyers who assist us with business matters.

• We may share your data with these Service Providers on a need-to-know basis and ensure that they are bound by confidentiality obligations. Please note that these Service Providers do not have any independent right to share your data and are only permitted to use it as directed by us.

• In the event of an asset sale, merger, or bankruptcy, we may share certain aspects of your data.

• We utilize several APIs and SDKs to enhance your user experience. When these tools are active, any location data you provide may be read, accessed, and gathered by the associated website in accordance with its Privacy Policy. As an illustration, we use the Google Maps API to prepopulate your address for ease of use while completing forms. The Google Maps features and content are subject to the most recent versions of their terms and conditions:
•Google Maps/Google Earth Additional Terms of Service at https://maps.google.com/help/terms_maps.html
•Google Privacy Policy at https://www.google.com/policies/privacy/

Note that if you make any information publicly available on the Platform, such as with a public post, will be regarded as available for use and reference and anyone may see and use such information.

If you opt-in to “performance cookies” , we may use Third-Party analytics cookies from trusted partners to Process data for activities including but not limited to analyzing traffic sources, visits, and site interactions. This analysis helps us to improve our products and services.

If you opt-in to “targeting cookies” and web beacons, information regarding your activity on our websites, excluding activity when you’re logged in and have started therapy, may be shared for advertising purposes. To learn more, see section: “Are you using my data for advertising?”

10. Do you Process location data?

When you start session on our Platform, we will ask for your address information as part of your contact details. We need this information to comply with session regulations and ethical code. In case your coach believes that you are in immediate danger, your contact information may be used to reach out to you.

In addition, we process IP addresses which provide a general location that can be used to auto-fill some of the address fields mentioned above for your convenience. To accomplish this, we use the Google Maps API on our app and website. Please note that the location you share while these tools are running may be accessed and collected by Google in accordance with their Privacy Policy. It is important to be aware that Google Maps features and content are subject to the then-current versions of their terms and policies.:
• Google Maps/Google Earth Additional Terms of Service at https://maps.google.com/help/terms_maps.html
• Google Privacy Policy at https://www.google.com/policies/privacy/

IP address is also Processed by the Captcha security API tool we use. We use Captcha to identify potentially malicious actors trying to access our site. Here is the Captcha Privacy Policy and terms of service.

To learn about the additional purposes for which we Process IP addresses, please see the following Sections:
• Why do you collect and Process my data?
• Are you using my data for advertising?
• Additional privacy notice for California residents

11. Can my date be used for advertising?

We advertise our mental health support services on Third-Party websites and apps to connect with people who may need our help. To make the advertising process cost-effective and ensure that the ads are relevant and interesting, we use targeting cookies and web beacons.

If you opt-in to these tools, we may share some of your non-sensitive Visitor Data , such as your IP address, Third-Party identifier (if applicable), and Checkout Flow Data (if applicable), to show you personalized ads for our services on some Third-Party websites. Please note that we do not share any of the private information you share with your coach, such as your session notes, session data, or contact details, with Third-Party advertisers.

It is important to emphasize that even if you opt-in to targeting cookies and web beacons, we still do not share any private information with Third-Party advertisers, such as your name, email address, or phone number. Your privacy and confidentiality are our top priorities, and we respect the trust you have placed in us.

12. What is a cookie and a web beacon?

A “cookie” is a small data file that is accessible within a folder on a computer and it is used for record-keeping purposes. Cookies are used to enhance performance of the Platform and for Third-Party tracking (as described above). For example, cookies may be used to help you quickly log into certain platforms and websites without having to enter your credentials every time.

A “web beacon” or “pixel” is a tiny and sometimes invisible image or embedded code, placed on a web page or email that can report your visit or use to a Third Party (again, as described above). In general, these tools can be used to monitor the activity of users for the purpose of web analytics, advertising optimization, or page tagging.

13. What are you using cookies and web beacons for?

We use our own and Third-Party cookies and web beacons to deliver a faster and safer experience, to monitor and analyze usage, to comply with laws, and for advertising purposes. To read more about the kinds of cookies we use and their purposes, or update your settings or opt out, go to “Cookie Settings” .

14. How do I opt out of cookies and web beacons?

Please send a request via email to contact@meetcoach.com to opt-out of tracking via cookies or web beacons, or for instructions on how to remove previously set cookies.

15. How do you keep my data secure?

We apply industry standards and strive to apply best practices to prevent any unauthorized access and disclosure. Internet-based services carry inherent security risks, but our systems infrastructure, encryption technology, operation and processes are all designed, built, and maintained with your security and privacy in mind. Our Platform is certified by HiTrust (HITRUST Risk-based, 2-year (r2) Certified), one of the most recognized data security certification programs in the health industry.

MeetCoach.com has a team of professionals whose job it is to make sure we use secure technology to protect your data. We have security staff who test internal security at MeetCoach.com to try and anticipate threat actors and security staff that act defensively and build processes and infrastructure to prevent incidents and attacks. We have numerous robust security practices such as:

• All the messages between a member and their therapist are secure and encrypted by 256-bit encryption.
• Our servers are distributed across multiple Tier 3 – AWS Data Centers for optimal security and protection.
• Our browsing encryption system (SSL) follows modern best practices.
• Our databases are encrypted and scrambled rendering them useless in the unlikely event that they are stolen or inappropriately retrieved.
• We have robust monitoring and alerting systems and procedures in place that include both automated systems and humans (for example, there is always at least one security personnel active in our 365/24/7 on-call rotation).

For your own security, keep the following in mind:

• Phishing: This is a type of online identity theft or account hacking. We will never request your login information or credit card information in any non-secure or unsolicited communication. You should always be diligent when you are asked to provide your account information and make sure it is in our secure system.

• Third-Party links: Our Platform may contain links to a Third-Party website or service. We do not control Third-Party websites, and do not have control over their privacy policies and terms of use. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that Third Party or of their privacy and security policies or practices.

16. Do you sell my data?

We aren’t paid by anyone for any data. However, in California, the laws define “sale” broadly to include the sharing of personal information in exchange for anything of value. If you opt into our use of targeting cookies and web beacons, this use may be considered a “sale” of personal information under that specific California law. For specific information on your data rights as a resident of California, see the additional notice for California residents .

17. Can I sign up for MeetCoach.com and remain anonymous?

When you sign up for an account on MeetCoach.com, we do not ask you for your full name. You may pick any name or “Pseudo” which will identify you in the system. You will need to provide an email address so that we can verify you, keep your account secure and so we can communicate with you. You can choose an email that does not include your name, but you should be aware that in some jurisdictions emails may be “personal data,” “personally identifiable information” or “sensitive personal data” in certain circumstances. When you decide to start the session process, we’ll ask you for your contact information for emergency situations. Your coach may request additional specific information about you as required by their licensing board guidelines.

Even though we try to limit the kinds of information you must provide to us as discussed above, it is very difficult to be truly “anonymous” when you use any app or the internet. Read more about what data we Process and why here:

• What specific data are you Processing?
• Do you collect or Process location data?
• Why do you collect and Process my data?
• What are you using cookies and web beacons for?

If you’re interested in further limiting what data is Processed, send a request email to contact@meetcoach.com to opt-out of tracking via cookies or web beacons, or for instructions on how to remove previously set cookies.

18. How do I request my data or delete it?

To receive a summary copy of your data, please log in to your account and go to Menu > My Profile, which you may be able to request a copy of your data. The data you will receive as part of this request includes the contact information that you input on the site, questionnaire answers, contact information, messages you sent to your coach, and other personal data.

Additional data which we maintain includes email interactions with our help desk, which is stored on your email system. You may also request this information by writing to contact@meetcoach.com.

Please send a request email to contact@meetcoach.com to delete the above data or opt out of MeetCoach.com services. Some data will be maintained as allowed by law or required by our retention policy.

You may reach out to us at contact@meetcoach.com if you need additional help. We will only comply with a request for deletion of your data if we can verify your identity. There is usually no charge. In exceptional circumstances, we may charge a reasonable fee after discussing the fee with you.

Please note that if you’ve started session, we may retain some of your data for an extended period based on applicable data retention laws.

Requirements:

• Only you or your authorized representative may make a request on your behalf. You may also make a request on behalf of your minor child depending on the applicable laws.
• We reserve the right to deny information requests that are unduly burdensome as allowed by law.
• You must provide sufficient information that allows us to reasonably verify your identity or status as an authorized representative.
• You must provide details that allow us to understand, evaluate, and respond to your request.

If you have any questions about your rights, want to exercise them, or want to appeal our response to your request, please contact us in any of the following ways:

MeetCoach.com
OCEANYA LTD
15A Main Street, Blackrock
POD 2, The Old Station House
A94 T8P8 Dublin, Ireland
contact@meetcoach.com

We will not discriminate against you for exercising any of your privacy rights. We will not deny you services, charge you different prices or rates, impose penalties, or provide a different quality of service.

19. How can I stop receiving direct marketing emails from you?

You can always opt out of receiving marketing emails. In order to opt out, you can select the unsubscribe link located at the bottom of the relevant email communication.

20. How do you treat data from children?

We don’t knowingly collect or solicit any data or information from anyone under the age of 15 or knowingly allow such persons to become our users. The Platform is not directed at and not intended to be used by children under the age of 15. If you’re aware that we have collected personal information from a child under age 15 please let us know by contacting us through contact@meetcoach.com, and we’ll delete that information.

21. How do you use my data to comply with the law?

We comply with government agencies when required by law, just as we would for in-person session. For instance, we may be required to share certain information requested in a subpoena. However, it is important to note that, as a general rule, we defer to your chosen coach to decide whether or not to produce session notes or messages you have had with them. The confidentiality requirements associated with therapist/client relationships are strictly governed by many jurisdictions, and we encourage you to discuss any concerns you may have about disclosure obligations with your coach at the outset.

Moreover, coaches may be obligated to disclose information to authorities to meet professional and legal responsibilities. Mental health professionals may be required to disclose information or take action related to reported or suspected abuse, serious suicidal potential, threatened harm, and court-ordered treatment, among other things. If you have any concerns about this, please discuss them with your coach.

22. Will you change this Privacy Policy?

This Privacy Policy is subject to updates, and we will inform you of any significant changes either on our website or app when you log in to your account. We recommend that you check this page regularly for the latest information.

23. Additional privacy notice for California residents

This Privacy Notice for California Residents supplements the MeetCoach.com Privacy Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act (“CPRA”) of 2023.

The CCPA and the CPRA are California laws that provide its residents with certain rights over information about them, including notice about the categories of personal information we have collected from them in the preceding 12 months and the purposes for which the information is used or disclosed, and correction of personal information.

The following Sections outline the data that is Processed by us, as well as the purpose for collection, and the categories of sources of such information:

• What specific data are you Processing?
• Do you collect or Process location data?
• Why do you collect and Process my data?
• What are you using cookies and web beacons for?

The data referenced at those links may fall in certain defined categories under the
CCPA and CPRA. Accordingly, we may have collected:

• Identifiers
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Protected classification characteristics under California or federal law
• Commercial information
• Biometric information
• Internet or other similar network activity
• Geolocation data
• Sensory data
• Sensitive Personal Information
• Professional or employment-related information
• Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

The information that we have disclosed in the past 12 months and the recipients of the information are described above, in the Section titled “What are the purposes for sharing my data?” The information that we may have shared in the past 12 months falls into the following personal information categories under the CCPA and CPRA:

• Identifiers
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Protected classification characteristics under California or federal law
• Commercial information
• Internet or other similar network activity
• Geolocation data
• Sensory data
• Sensitive Personal Information
• Professional or employment-related information
• Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

As noted in the Section titled “Do you sell my data?” , our “sale” of information (including sale of information about consumers under the age of 16) consists of the disclosure of your information for targeted advertising purposes, and we aren’t paid by any Third Party for any data. The information that we may have “sold” (for purposes of the CCPA and CPRA) in the past 12 months falls into the following personal information categories under the CCPA and CPRA:

• Identifiers
• Commercial information
• Internet or other similar network activity

Do I have the right to know what information you have about me?

Yes, as a California resident you can request certain information about what we have Processed over the past 12 months. Once we receive and verify your consumer request, we can provide:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of Third Parties with whom we shared that personal information.
• The specific pieces of personal information we collected about you.
• Whether we disclosed your personal information for a business purpose and the personal information categories that each category of recipient obtained.

To ensure your identity, we will cross-check the information you provide with the data we have on file. You have the option to request a correction to any of your personal details that are incorrect, either by logging in to the platform with your correct credentials or by contacting us at contact@meetcoach.com.

Can I “opt out” or request that you delete my information?

Yes, you can request that we delete your data as described in the section of this policy called: “How do I request my data or delete it?” Once your request is received and verified (by matching the information you provide with information that we maintain about you), we’ll move forward with the Process of deleting your information in line with our legal requirements and retention policy. We cannot fulfill a deletion request and need to retain your information if the data is necessary to:

• Provide you services, take actions reasonably anticipated within the context of our ongoing business relationship, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with applicable laws, including but not limited to, the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.) and information covered by the California Confidentiality of Medical Information Act.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

As noted above, you may opt out of the “sale” of personal information about you by withdrawing your consent to accept cookies used for advertising here. Our websites are also designed to implement a do-not-sell privacy preference requested via a global privacy control.

Other California privacy rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to Third Parties for direct marketing purposes. To make such a request, please send an email to contact@meetcoach.com.

24. General Data Protection Regulation (GDPR) and UK General Data Protection Regulation Notice

This section provides additional information about our Policy relevant to you if you are from the European Economic Area (the EEA), United Kingdom, and Switzerland (together “European Area Countries”). It supplements and should be read in conjunction with the rest of the Policy.

Under the European Area Countries’ privacy laws, we are the Controller with respect to your data.

When is my data used?

• We may process your personal information when it is in our or a third party’s legitimate interests. “Legitimate interest” is a term that the General Data Protection Regulation (GDPR) and UK General Data Protection Regulation Notice define. Our legitimate interests include managing MeetCoach.com’s business and the platform, ensuring the safety and security of the infrastructure, preventing fraud, conducting research and development, and managing contracts and legal claims.
• Your data is used when it is necessary for the provision of the Platform, which includes product development, internal analytics, and improving the safety, security, and performance of the Platform. We will only use our or a Third Party’s legitimate interests to process your data if these interests do not override your rights and interests.
• When it is necessary to do so to comply with any legal obligations imposed upon us, for example under our contractual obligation or applicable law.
• In rare instances, when it is a medical emergency, we may use your data to protect your or another’s vital interests if consent is not a reasonable option.
• When you have consented to the use of your data, for example for marketing purposes or through the use of cookies and web beacons. Where consent is the legal basis, you have the right to withdraw your consent at any time.

What Lawful Basis for Sensitive Data is Used in the UK and EEA?

About sensitive personal information:

MeetCoach.com may collect and process certain types of personal information, including sensitive personal information that falls under UK and EEA regulations. The legal bases for this processing include health and social care, legal obligation, public interest, and consent, with the right to withdraw consent at any time. Examples of sensitive personal information include racial or ethnic origin, religious or philosophical beliefs, and health or sexual orientation data.

As part of the registration process for our sessions, we require you to complete a questionnaire to personalize the service and connect you with the right coach. Your answers may include sensitive personal information, as defined above, and you may continue to provide such data during sessions. This data is necessary to provide you with personalized and effective healthcare services, including the selection of a coach that meets your unique needs. The coach will review this data and may decline to work with you if they feel it is not a good fit.

We may also use this information to improve our service and understand how you interact with the services.

How we obtain your personal information

MeetCoach.com obtains the categories of personal information listed above from the following sources:

• Directly from you, such as information when you apply to be a coach or that you submit during the Process of using and paying for our Sessions.
• Indirectly from you, such as through your actions on our website.
• From Third-Party business partners, such as social media sites, ad networks, and analytics providers.

What are my rights and choices under European Area Countries laws?

European Area Country residents have specific rights regarding their data. This section describes your rights if you are resident in the European Area Countries and explains how to exercise those rights.

• You have the right to make a subject access request. This means that you can ask us for a copy of any data we hold about you. We will typically provide you with the copy within one month of your request. However, in some cases, we may need to extend the period by two months to account for the complexity of your request or difficulty in accessing the data you asked for. We usually do not charge for this service, but we may discuss a reasonable fee with you in exceptional cases.

• If the data we have about you is incorrect, you have the right to request rectification. We will review the data and make any necessary corrections.

• In certain circumstances, you have the right to ask us to erase your data.

• If you wish to transfer the electronic data we hold about you to another organization, you have the right to data portability in certain cases.

• You have the right to object to the use of your data for direct marketing purposes. If we process your data based on your consent and you no longer want us to continue processing it, you can object to it. You can also object to our processing your data if we rely on legitimate interests as our basis for doing so. If you provide us with specific reasons for your objection, we will consider them. However, if we have compelling legitimate grounds for continuing to process your data, we may still do so, and we will let you know the reasons for our decision. Keep in mind that objecting to certain processing may affect our ability to provide you with services.

• We use limited data to operate our Platform and conduct certain profiling activities to support and grow our business. We rely on our legitimate interests as the lawful basis for processing your data in this way. However, if you don’t want us to process your data in this way, you can exercise the rights mentioned above.
To exercise the rights in relation to your data set out in this section, please contact us at contact@meetcoach.com.

Is my data transferred internationally?

We may transfer your data to organizations in countries that do not have an adequacy decision under the General Data Protection Regulation, as part of our standard business practices. However, we will ensure that specific safeguards or derogations are in place to protect your data when it is transferred to such countries.

These safeguards may include transferring the data to fulfill a contract between you and us, obtaining your explicit consent after making you aware of the risks involved, or implementing contracts with third-party organizations to ensure that the recipient organization has an adequate standard of data protection in place.

If you have any questions about this policy or your data, please contact us at contact@meetcoach.com. While we are committed to addressing any concerns you may have about the use of your data, you have the right to lodge a complaint with the supervisory authority in your country of residence under GDPR.

Last Updated: April 12, 2023