Coaching Interactive (“CI”) considers Client Information privacy as one its highest company value; we understand that people put private personal information in CI's hands and we undertake to do our best to protect that privacy. The following document is intended to describe CI's policy regarding the protection of client and coach data and it addresses the following list of issues and potential client concerns. By accepting the Coaching Interactive General Terms of Use of the web site you indicate that you understand and accept this CI Privacy Policy as updated periodically. This document specifies the following topics | 1. | - Brief summary and concept
- Definitions
- What personally identifiable information is collected from you through the web site
- What the information intended for and how it is used
- Who provides the coaching service? (TM>CM>CO) & 3rd party
- Who has access to the coaching information and under what conditions?
- Use of Information available through CI site
- Limitations on use of information
- With whom may the information be shares
- How can inaccuracies in the information be corrected.
- CI obligation to do the best effort it reasonably can to protect privacy.
- Security procedures practiced to protect loss, misuse or alteration of info by CI
- Strict enforcement and improvement of the security policy and procedures
- The limitations and risks associated with use of digital data, computers and internet.
- Commitment not to actively path information to other parties without permission.
- Potential access to data for technical reasons (part of terms, may duplicated here)
- The potential operation of a (qualified and certified) supervisor for QA purposes.
- Storage, Deletion and access to user data
- Information which is private or proprietary to CI and CI's partners
- What happens if a coach terminates his use of the CI system.
- CI Owns the log files and statistical data on the technical use of the site,
- Registration info collected by CI (CC, contact info, addresses etc.)
- Client-Coach Communication Using the CI Service
- Education, Minors and Parents responsibility
- CI delivered information
- Contacting us
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The Coaching Interactive system provides an enabling platform for coaching; Coaching is done independently by clients using Self coaching programs or interactively with a personal coach. Statement of Policy The private information stored in the system relates to clients and coaches and is relevant to the coaching process performed on the system. This information belongs first and foremost to the client and the coach and will not be used for any other purpose. 1. Brief summary and concept Coaching Interactive (“CI”) provides an Interactive Coaching Platform, Self Coaching tools, Best Sellers Coaching (“BSC”) content and Personal Coaches to clients around the world, making coaching available to everyone. Using the platform, clients record sensitive private information for their personal use and for confidential sharing with their personal coaches. As such, maintaining data privacy is a fundamental cornerstone of the services provided by CI. To assure the privacy of the client and coach data, CI has established and is implementing unique and rigorous privacy policies, practices and procedures which are described in brief in this document and which attempt to relate to all aspects of securing the data ranging from the technical to the practical, procedures and enforcement mechanism applied. The document describes who has access to what information and under what conditions; what personally identifiable information is and how it is collected from clients who use the web site; what is the intended use of the information and who is providing the coaching services to the client and as such has access to the coaching information, describes the uses and limitations on use of such information and with whom and under what circumstances it may be shared or corrected. The document outlines CI's obligation and methods of protecting the private information and the security procedures practiced for that purpose to prevent loss, misuse or alteration and how they are being enforced. On the other hand it also lists the inherent privacy risks associated with the use of digital data, computers and internet. The document also lists access provided to the data for distinct well defined purposes such as quality assurance supervision and technical support when and if requested by clients and coaches. It then continues to describe how data is storage, deleted or accessed by present and past clients. A special chapter handles privacy with relations to third party providers with whom CI collaborates to offer a more complete and comprehensive coaching offering (with client's awareness and approval). What happens to the data if a client's personal coach terminates his use of the CI system? Some information relating to the use of the site is logged and a paragraph addresses the ownership and potential use of such logged data, including the registration details collected by CI, The nature of use of the platform for coach – client communication is briefly outlined and attention is given to the special responsibility of parents with young children who may have access and may use the site. CI does not share information with others for promotion; however we may share necessary information with third party providers the services of which a client elects to use. CI will also encourage clients and coaches to share their experiences; all these are done on a pre approved consent basis which is described in detailed below. Our use of registration and log data is very careful and anonymous as described in more detail. 2. Terms definitions Caching Interactive (CI) System, Platform A Web based system used for the purpose of coaching which served to deliver to clients coaching content and personal coach guidance and communication. Coaches means personal coaches who provide a coaching service to a client and are in turn part of a hierarchical set up including Coach Managers (CM) and Coaching Territory Managers ™ who act to support and manage the use of the CI Platform. Client Private Data, Personal details is information entered by a client voluntarily into the system for the purpose of facilitating the provision or the conduct of a coaching service and as such may be private to the client and must therefore be properly protected, Coaching Sessions, Program – a structured set of modular content units used to enable interactive coaching over the web. It may include text, images & questionnaires. A program is made of Sessions; a super program is a combined set of programs. One or a few sessions nominally emulate a face to face coaching engagement between a client and a coach. Self coaching where by a client works with the system without the involvement of a coach. Interactive coaching is a web based coaching where a live Personal Coach interacts with the client (a-synchronously, namely the coach and the client do not work together at the same time but rather interact at different times), similar to the way e mail is exchanged, Accredited Coach is a coach which was accredited by CI or a Territory Manager to provide interactive coaching on the CI platform. Supervisor coach is a highly experienced and qualified coach who supervises and guides coaching in providing interactive service over the CI platform. 3. What personally identifiable information is collected from you through the web site? User registration details, use of the site log, and mostly – private information entered by the user during the self or interactive coaching sessions. During Interactive Coaching the coach is privy to data entered by the client during all his coaching sessions in the coaches site, (including data entered in Self coaching, but excluding data entered during self or interactive coaching in other coaches site) 4. What is the information intended for and how is it used. The prime purpose of the information is for the client's own use in working through the coaching programs. It is meant to help the client retrospectively examine such things as his/her Goals, his/her current Reality, Optional avenues he/she Will take, (hence the G.R.O.W model). Progress is made by client's commitment to Tasks with specified dates which are placed in the client Calendar. This information entered by the client and responses offered by the coach are also recorded in the system communication channel between the client – The e trail, (An e mail communication and Journal). This recorded information is meant to allow the client to review and reflect on the process, in order to support his growth, and for the coach to follow up on the client progress and be able to offer coaching questions, guidance and coach the client along the way, which is done and stored on the system as well. The information may also be viewed by a CI certified supervision coach to assure proper quality of service, and by CI qualified technical personal if called in by the client for technical assistance. 5. Who provides the coaching service? (CO<CMLTM) & 3rd party The coaching service is provided to the client by the coach who is in full charge of the operation of the system and the provision of service to the client. Coaching Interactive maintains sites for coaches using the system. All sites are maintained on CI servers, the responsibility for the content placed on those sites lies strictly with the coaches The coach in turn is supported by a Coach Manager who in turn is supported by the CI Territory manager, who in turn is supported and reports directly to CI. These CI system management organizations are strictly supportive of the coach who is the service provider to the client. For Self programs which are used without a coach, the only party that is privy to the information is the client. When the service is provided in collaboration with a third party content, methodology or process provider, such as with Best Seller Coaching, the client can consult on maters relating to the coaching methodology directly with a support agent established by the third party. Such third party support team will however NOT has direct or independent access to the private data entered by the client?. In the future, CI plans to have a service whereby certain qualified Interactive Coaches may offer such third party Self programs as an integral part of their Interactive Coaching Programs. In such instances, the third party coaching session summaries may be transferred into the CI platform and made available as e trail journal reports for regular interactive use by client and coach. 6. Who has access to the coaching information and under what conditions? 6.1. Only the client has access to the information is the self only coaching application. 6.2. Client and coach on coaches sessions performed in a personal coach's site, 6.3. A Certified QA Coaching Supervisor when operating on the site, 6.4. A qualified technical team, with special training, when and if called in by a client and a coach for technical support on a specific client request. 6.5. Private registration information (User contact, payment records etc) is accessible to CI administration and management, billing and tech support team. 6.6. 7. Use of Information Available through CI site To assure Clients and Coaches with the best service possible and to facilitate communication among Clients and Coaches, CI provides an internal communication resembling e mail to paying Clients and Coaches under specific circumstances. The service is primarily aimed to provide communication of the client with the system and provide the coaching session's record for himself ("Self mode") and communication with a coach ("Interactive mode"). By review and acceptance of the CI's Terms of Service, users agree to use the service as provided and described above. 8. Limitations on use of information Registered users may not use information gathered through the CI site transaction to defame, abuse, harass, stalk, threaten or otherwise violate the legal and civil rights of any other registered user. Registered users may not use information gathered through the CI site and any activity related to it or facilitated by it, to sell any goods or services for any commercial purpose outside the scope of the CI service. Email addresses and personal information may not be used to forward surveys contests, pyramid schemes or chain letters, or to post the same message repeatedly (a practice referred to as "spamming"). CI may terminate the ability of any Client or Coach or Coach manager or territory manager, to use the CI service if any of terms of the privacy policy is not strictly adhered to by them. 9. With whom may the information be shared Coaches are strictly bounded by the coaching agreement with the client (as well as with CI) to protect client private data, such data may not be used without prior client consent, with anyone for any purpose, Data may be partially shared with third party providers if and when a client expresses a desire to benefit from such third party providers, typical example may be Web based Self Assessment providers. Only information required to facilitate such use of third party services will be provided. CI will encourage client and coaches sharing of information with other coaches and clients. Sharing experiences in this manner is known to improve user experience and effectiveness of the coaching processes both for the contributors and users of such content. Such shared information may include testimonials and case studies, papers, and other forms of best coaching practices and wisdom, However – sharing of used contributed content of this nature will be strictly on a voluntary basis. Sharing will be facilitated by the CI system with proper administration aimed to assure user awareness of the shared nature of the contribution. CI currently does not share aggregated demographic information with partners or advertisers, but CI reserves the right to do so in the future. However this will not be linked to any personal information that can identify any individual person. We use a credit card processing company to bill users for use of the service. These companies do not retain share, store or use personally identifiable information for any secondary purposes. We reserve the right to partner with third parties to provide specific services. When the user signs up for these services, we will share names, or other contact information that is necessary for the third party to provide such services. These parties will not be allowed to use personally identifiable information except for the purpose of providing these services.
Tell-A-Friend If a user elects to use our referral service for informing a friend about our site, we ask them for the friend's name and email address and automatically send the friend a one-time email inviting them to visit the CI site and store this information for the sole purpose of sending the one-time email. The friend may than contact CI at a prescribed e mail address 10. How can inaccuracies in the information be corrected. Users who have access to the CI system and services can always modify and alter data (Other than User Name used to log into the system) via My Office > My details function. Modifiable data include and is not limited to Personal details (Given and family name, etc) Contact information and payment means (Credit cards, PayPal, etc.). Some data entered during the coaching sessions may be modified such as questionnaires or My Life or GROW sessions, some pieces of information provide for updated versions ("New", questionnaires etc.). Data stored in coaching sessions report in the form of E mail hold record of past interactions and as such cannot be altered or modified. Correction of data can be effected by the coaches, or the CM, TM or CI Customer Support at support@coachinginteractive.com 11. CI obligation to do the best it reasonably can to protect privacy. CI regards client and coach privacy as the highest company value. Coaching Interactive is committed to make its best possible effort to take all measures and protect the private information of clients and coaches. 12. Security procedures practiced to protect loss, misuse or alteration of info by CI In order to assure consistent high quality and constantly improving security measures to protect client private data, a detailed effective procedure is put in place, enforced and monitored. It relates to such issues as who has access to what information, how passwords are kept and refreshed, what training CI personnel have to undergo to be qualified to service clients and coaches at the various administrative levels, it spells out specific processes for the tracking of security challenges, experience and lessons learned ( A Learning Organization structure) 12.1.Data Communication Security We Provide. This website takes every precaution to protect our users' information. When, in the registration form, users are asked to enter sensitive information (such as a credit card number), the information is encrypted. CI uses the industry standard Secure Socket Layer (SSL) encryption and firewalls to protect against loss, misuse, and alteration of any personal data under our control. While on a secure page such as our registration form, there is a "locked" icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer. If you have any questions about the security at our website, you can send an email to security@coachinginteractive.com
12.2.Cookies A cookie is a piece of data stored on the user's hard drive containing information about the user. Usage of a cookie is in no way linked to any personally identifiable information while on our site. Once the user closes their browser, the cookie simply terminates. For instance, by setting a cookie on our site, the user would not have to sign in his or her email and password more than once, thereby saving time while on our site. If a user rejects the cookie, he or she may still use our site. The only drawback to this is that the user will have to sign in each time he or she visits the site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. 13. Strict enforcement and improvement of the security policy and security procedure The above procedure and the overall security status on the company and its service are periodically reviewed. Records are taken. Recorded instances of security events are analyzed, with conclusions and recommendations effectively deduced and implemented. As a result the security procedure itself is constantly updated, when changes and updates relates to the users or coaches, the territories are alerted to inform the hierarchical Coach management, coaches and clients trees. 14. The limitations and risks associated with use of digital data, computers and internet. Notwithstanding the measures which CI takes as mentioned above, to assure best available security to its clients and coaches, the vary fact that data is handled in a digital manner which is easily transferable over the internet or other digital storage and communication media and is ubiquitous form, presents a security hazard users should be aware of. To improve protection, a forum is established within CI to constantly examine potential security concerns, with the sole purpose of alerting the system in case of such security hazards in order to address such weak points as best we can. However one has to bear in mind that such potential security breaches may come abut and protect accordingly. While CI does make best effort to protect client data it can not assure a 100% unbreakable solution, and potential such breaches may come about unintentionally or even due to hackers’ directed attack. 15. Commitment not to actively transfer information to other parties without permission. CI does not share user data for promotion and marketing purposes. If in the future such use of the data may become useful for CI's users, as envisioned by CI, it will be provided only with user consent provided via the CI system. Such use of data will not be user specific, with user details properly concealed. 16. Potential access to data for technical reasons Technical assistance and support is provided to users by their coaches. Coaches in turn are supported by the coaching and technical teams of the CM and TM organizations, who are trained and supported by the CI team. The provided escalated support may need to relate to relate to client specific issues or technical difficulties, and thus, may need to be exposed to client private information. Such exposure will take place only when a client and coach request. CI may alert the client and coach to the potential required approval for access to private data, but by Appling for assistance from a CM, TM or CI, both users and coaches acknowledge their awareness of the potential need for such exposure. 17. The potential operation of a (qualified and certified) supervisor for QA purposes. To assure quality of coaching service, including enforcement of the privacy policy, CI may at times make coaching supervisors available and authorized to examine the functionality of and the CI platform offering and the manner in which it is used by coaches to provide quality service to the clients. For that purpose, qualified supervisors may have access to private information. Supervisors will communicate strictly with the supervised coaches and report to the CI hierarchy (CM, TM, CI) on any potential deviations. Such supervision is provided only for the purpose of assurance of high quality coaching service through the CI platform, worldwide. 18. Storage, Deletion and access to user data CI is obliged to maintain client and coach data and make them available on the CI internet system as long as clients and coaches have an active service package (license for use) for the use of the system. However, CI also stores information of past users and makes them available for follow on use. This data is stored for a minimum of one year after service termination by CI on a voluntary basis and may be terminated at any time. CI may offer in the future for a free a record transfer service whereby past e trail journal record may be transferred to clients or coaches in PDF form. CI may also elect to provide past users with continues access to such stored data, but such access may be terminated at any time and is done strictly as a voluntary service to its clients and coaches. Upon a user specific request CI may provide a paid-for service of deletion of all user data from the system. As deletion of data from data bases requires action, CI may elect to effect such deletion by altering key access parameters to the data, such as user names and pass words and key data base records to the point where they are not recognized, and are re written over rather than by actual removal of stored data from the records, which may be effectively costly or impossible to do. Such data removal, when and if requested and performed will render the data un-usable and non-recoverable, and clients must be made aware by their coaches of the implication of such record removal request. 19. Information which is private or proprietary to CI and CI's partners The CI system contains a very significant amount of information, technical concepts, coaching methods and processes, programs and other tools. Such information is proprietary to CI or its partners. As such it cannot be used, copied distributed etc, in any way other than intended to by the terms of use of the site. Clients and coaches should review the terms of use carefully before accepting and agreeing to them. Information protection and compliment use is a fundamental corner stone in the service provided by CI, and the above mentioned terms will be strictly enforced. 20. What happens if a coach terminates his use of the CI system. A client may have access to his coaching sessions in a personal coach site on the CI system. If a coach elects to terminate his relations with CI and not use the CI system, he may recommend to his client to purchase a record of client data. If a client elects to also keep the data stored on the system, CI via the CM or TM may approach such client and offer to provide a replacement or alternative coach. If client elects to use the services of such alternative coach, the client will have available to him an in system tool allowing a selected forwarding of any or all the past stored data on the e trail, form once coach to another. 21. CI Owns the log files and statistical data on the technical use of the site, CI may use IP addresses to direct the user to the proper territory and tuned coaching services and better administer the site, and gather broad demographic information for aggregate use. IP addresses are also linked to personally identifiable information in order to improve the user's experience when using the site. CI may but is not obliged to retain emails, letters, or other correspondence with its users to ensure quality control and the best possible service. Log logins and use of the system are logged as well and provide CI and the coaches using the system, an indication as to the usability and actual use of the site by clients and coaches. The accumulated statistical data is owned by CI. 22. Registration Information In order to use this website, Clients and Coaches complete a registration form with contact and financial information, such as name and email address. The information is used to provide purchased services on and for user sign in. This business information is owned by CI, and will not be used or shared with any party without prior consent. Only CI stores personally identifiable information collected at the sites. Any questions arising from collection of information through the CI service at our partner sites should be directed to security@coachinginteractive.com 23. Client-Coach Communication Using the CI Service
The communication between the client and the coach is done in a manner resembling e mail communication. But as opposed to regular e mail, the client coach communication is restricted to the CI servers and is not actually transferred over the internet as e mail. The secured environment is aimed primarily to protect client data and while making it available for clients and users from anywhere anytime. It avoids multiple records on various client and coach computers. Access to the information is protected by User name and Password, which are recoverable from the CI site if lots, 24. Education, Minors and Parents responsibility Some consider Coaching to be the next trend in modern education; however, parents should always supervise their children's use of the Internet in general and of the CI site and services in particular, as it involves processes that may be of strong influence on their children. CI makes the best possible effort to assure that only highly qualified content and personnel use the site for coaching and education, nevertheless it is the parent's responsibility to assure that the proper coach and coaching process is offered to their children in addition to the fact that there are commercial and financial aspects to the use of the site which must be approved. Some products are available commercially for that purpose and for filtering material that may be consider harmful to minors, an example is available at http://worldvillage.com/wv/school/html/control.htm.
To avoid any doubt, the information obtained by or available on the Platform does not fall within the child online privacy act (COPA) and is not monitored as doing so. 25. CI delivered information CI creates and distributes such information to its coaches and clients as the well known CoachLetter which is distributed in a number of languages worldwide. CI may provide users with an option to unsubscribe to allow removal from newsletters, promotions, etc., by following the appropriate mechanism in the registration form or the My Office>My details 26. Contacting Us If you have any questions about this privacy statement, the practices of this site, or your dealings with Coaching Interactive, please contact us (http://www.coachinginteractive.com) by clicking the ‘Contact us’ link on the button or writing to security@coachinginteractive.com |