*** Last updated: June 2, 2020 ***
Thank you for visiting our website (the “Site”). Rose Viggiano is committed to treating your personal information with respect and sensitivity.
Please read this policy to learn how we collect, use, share, and otherwise process information relating to individuals, such as contact information (“Personal Data”), and to learn about your rights and choices regarding your Personal Data.
- Visit our Site;
- Visit our social media pages;
- Receive communications from us or send information to us, including emails, phone calls, texts or fax; or
- Register for, attend or take part in our events or webinars.
Our Site may contain links to other websites, applications, and services which are maintained by third parties and are governed by their own privacy policies. Review those policies to better understand their privacy practices.
Why we collect and process your personal data
We collect Personal Data for a variety of purposes, including:
- Some device and usage data from your computer, phone, or other devices to (1) develop, improve and manage our Site and services, and (2) ensure the security and proper functioning of our Site and related services. For example, we may use device or usage to investigate suspicious activity on our Site and to enforce our terms and policies, to the extent it is necessary for our legitimate interest in promoting the safety and security of the Site and services, and in protecting our rights and the rights of others.
- Your billing information when you purchase our services. If you have provided financial information to us, we process your Personal Data to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you;
- Your name and contact information, or device or usage data to send you marketing communications about us and our services through email, text messaging or telemarketing. These communications may include information about our services, products, or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent.
- As otherwise needed to comply with our legal obligations under applicable laws and cooperate with public and government authorities, courts or regulators to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our Site, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, respond to lawful requests, or for auditing purposes.
We only collect and process your Personal Data to the extent it is necessary for fulfilling these purposes and where we can rely on a legal basis for such processing. Where required, we will ask you for your prior consent to processing.
International transfer of your personal data
When you give your Personal Data to us, that information will be collected, transferred to, and stored by us in the United States to provide services to you and to enable you to interact with our Site. If you live in the European Economic Area (EEA) or another country outside the U.S., your data will be processed outside your local jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislature or regulator, and that may not provide for the same level of data protection as your jurisdiction, such as the EEA. Where required by applicable law, we will only share, transfer, or store your Personal Data outside of your jurisdiction with your prior consent.\
Data we collect
Personal Data we collect directly from you
The Personal Data we collect directly from you includes identifiers, professional or employment-related information, financial account information, commercial information, visual information, and internet activity information. We collect such information in the following situations:
- If you request information about our services; sign up for an event or webinar; or download certain content, we may require that you provide your contact information, such as your name, address, phone number, or email address;
- If you make purchases via our Site or register for an event or webinar, we may require that you provide to us your financial and billing information, such as billing name and address, credit card number or bank account information;
- If you interact with our Site or emails, we automatically collect information about your device and your usage of our Site or emails (such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Data using cookies, web beacons, or similar technologies;
- If you use and interact with our Site, we automatically collect information about your device and your usage of our services through log files and other technologies, some of which may qualify as Personal Data;
- If you voluntarily submit certain information to us, such as filling out a survey or contact form, we collect the information you have provided as part of that request; and
- If you engage us for services, we collect the Personal Data that you voluntarily provide to us, which may include information about your background, family, education, professional experience, and other details relevant to the coaching relationship.
Personal Data we collect from other sources
We may collect information about you from other sources including from publicly available information. We may combine this information with Personal Data provided by you. The Personal Data we collect from other sources may include identifiers, professional or employment-related information, education information, or information about Internet activities. In particular, we may collect Personal Data from the following sources:
- Publicly available information, such as job titles, email addresses, phone numbers, intent data, IP addresses, or social media profiles.
- Another individual at your organization or a family member who may provide us with information for the purposes of obtaining services.
How we use device and usage data
Similar to other websites, when individual users visit our Site, we may use common tools and technologies for collecting usage data, such as cookies, web beacons, and pixels, to automatically collect information that may contain Personal Data as you navigate our Site, our services, or interact with emails we have sent to you. We use these tools to gather information about the use of our Site, your preferences, and how people interact with our emails. When you visit our Site, we, or an authorized third party, may place a cookie on your device that collects information about your online activities over time and across different sites.
This information may include identifiers and internet activity information such as IP address, location, browser type, Internet service provider and/or mobile carrier, the pages viewed, date and time stamps associated with your usage, and frequency of visits to the Site. This information is used to help us provide and improve our Site, offer a tailored experience for website users, and secure and maintain our Site.
Tracking technologies in email communications
We may also use web beacons and pixels in emails we send to you. For example, we may place a pixel in marketing emails that notify us when you click on a link in the email. We use these technologies to operate and improve our marketing emails.
We use data available from Google (such as age, gender and interests) with Google Analytics. You can opt out of Google Analytics using the Ad Settings provided by Google can also opt out of the Google browser add-on to prevent use of your data by Google Analytics.
The following describes how we use different categories of cookies and similar technologies and your options for managing the data collection settings of these technologies.
- Analytics cookies help us calculate the number of people visiting our site and what parts of the Site are most popular.
- Targeting cookies record your visit to the Site, the pages you visited, and the links you followed.
Opt-out from the setting of cookies on your individual browser
You can opt-out from the collection of non-essential device and usage data on your web browser by managing your cookies at the browser or device level.
When we use social media features
Our Site may use social media features, such as the Facebook “like” button or the “Tweet” button (“Social Media Features”) that allow you to post information about your activities on our Site to outside platforms and social networks. Social Media Features may also allow you to like or highlight information we have posted on our Site or our branded social media pages. Social Media Features are either hosted by each respective platform or hosted directly on our Site. To the extent the Social Media Features are hosted by the platforms themselves, and you click through to these from our Site, the platform may receive information showing that you have visited our Site. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our Site with your social media profile.
Your interactions with Social Media Features are governed by the privacy policies of the companies providing them.
Who we share Personal Data with
- Business Partners: We may co-sponsor webinars with other businesses or service providers and share your contact information with them.
- Service Providers: With our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, marketing, for the purposes and pursuant to the legal bases described above.
- Professional Advisers: In some instances, we may share your Personal Data with professional advisers, including lawyers, bankers, auditors, and insurers, to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data.
Where required, we will obtain your consent prior to sharing your Personal Data.
For more information on the recipients of your Personal Data, please contact us by using the information in the How to contact us section, below.
How long we keep your Personal Data
We may retain your Personal Data for a period of time consistent with the original purpose of collection (see the “Purposes for which we process Personal Data and the legal bases on which we rely” section, above) or as long as required to fulfill our legal obligations. We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Data, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation). After expiry of the applicable retention periods, your Personal Data will be deleted.
For more information on data retention periods, please contact us by using the information in the How to contact us section, below.
Your rights relating to your Personal Data
You may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:
- To access your Personal Data held by us (right to access);
- To correct inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete (right to rectification);
- To erase/delete your Personal Data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);
- To restrict our processing of your Personal Data to the extent permitted by law (right to restriction of processing);
- To transfer your Personal Data to another controller, to the extent possible (right to data portability);
- To object to any processing of your Personal Data carried out on the basis of our legitimate interests (right to object). If we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
- To the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.
How to exercise your rights
To exercise your rights, please contact us by using the information in the How to contact us section, below. We try to respond to all legitimate requests within one month and will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than a month, depending on the complexity and number of requests we receive.
We may need to verify your identity and place of residence before completing your rights request.
Your preferences for email and SMS marketing communications
If we send you marketing communications, you may manage your receipt of marketing and other non-transactional communications by clicking on the “unsubscribe” link located on the bottom of the marketing emails, or by replying or texting ‘STOP’ if you receive an SMS communication.
Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your event registrations or security information.
How we secure your Personal Data
We take appropriate precautions including organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data we process or use. While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your passwords and limiting access to your devices. If you have any questions about the security of our Site, please contact us by using the information in the How to contact us section, below.
Our Site is not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us by using the information in the How to contact us section below and we will take steps to delete their Personal Data from our systems.
How to contact us
To exercise your rights relating to your Personal Data, or if you have questions regarding our privacy practices, please send an email to firstname.lastname@example.org or write to us at:
Rose Viggiano Coaching
PO Box 2601
Novato, CA 94948
If you believe that we could not assist with your complaint or concern, and you are located in the EEA, you have the right to lodge a complaint with the supervisory authority in your country.