Platform Privacy Policy

For privacy information and to exercise your rights, please contact your employer, except:

• If you have signed in by providing your name and email address directly to CoachHub (typically via a page on coachhub.com), our privacy policy below will be applicable for you.
• If you have signed up to be part of our market research our privacy policy below will be applicable for you.
• If you reside in the United State of America, our privacy policy below will be applicable for you.
• If you are a Coachhubber, our privacy policy below will be applicable for you in connection with your use of the Platform.

To make the Platform work properly and enhance user experience, CoachHub uses necessary cookies. For more information please visit CoachHub Web Apps Cookie Policy.

Privacy Notice

The CoachHub platform (the “Platform”) is a digital coaching platform available through mobile (iOS and Android) and web-app (https://dashboard.coachhub.com), and used by businesses to support employee personal and professional development. The Platform allows companies to offer their employees (“Users”) personalized professional coaching by experienced coaches. CoachHub employees also have access to the Platform in the course of their duties (“Coachhubbers”).

CoachHub is committed to transparent data protection practices in accordance with the following principles and in compliance with applicable data protection laws, in particular the EU General Data Protection Regulation. We care deeply about protecting your privacy rights and keeping your data secure.

When you (User or Coachhubber) use the Platform, your data is processed by CoachHub as a data controller. This privacy notice (“Privacy Notice”) is intended to inform you about the information we collect, how we use it, whom we share it with, your privacy rights, and the controls we give you to access, update, and delete your information.

Please read this Privacy Notice carefully. If you are a resident of California, please see Section Your Rights of California Residents.

1. Identity and contact of the data controller

The data controller is:

CoachHub GmbH
Alexanderstraße 36
10179 Berlin, Germany
+49-30-23321151
datenschutz@coachhub.com
https://coachhub.com

2. Identity and contact details of the data protection officer

We have designated a data protection officer, who you can contact for all requests and questions concerning your personal data:

DataCo GmbH
Nymphenburger Str. 86
80636 Munich, Germany
datenschutz@dataguard.de
+49 89 7400 45840
www.dataguard.de

3. Data processing by the App Stores

When you download the CoachHub application via an app store (e.g., Google Play or Apple App Store), information about that operation is sent to the app store you selected (the “App Store”). Any further data processing is controlled by and should be explained by the App Store, as applicable. We have no influence on the data collection by the App Stores and are not responsible for it. Information on data protection at Google can be found here: https://policies.google.com/privacy. More information on data protection at Apple can be found here: https://support.apple.com/en-gb/102399.

4. Permissions

To be able to use all functions of the mobile version of the Platform, we need some system permissions. These permissions are requested once at the first start of the mobile app or during the first session when using the respective function.

Location data

We use the IP address of your device ID to determine the proximate location of your device. We use this information to identify the server geographically closest to the User for providing the best possible video and session quality.

Access to camera and microphone

To enable coaching sessions via video call, we need access to the camera and microphone of your end device.

Push notifications

Push notifications are sent to your mobile device to enable session and notification reminders. Push notifications are sent to your device through the operating system on your device (Apple or Google) and your data may be transferred to their servers in the U.S.

5. What personal data do we collect, how and why?

We process your personal data as described in this Privacy Notice for the following purpose:

• Data collected in connection with the provision of coaching services: We will use your personal data to register you on the Platform, verify your employer details and link your account to your employer’s account, evaluate your coaching needs, assign you a coach based on your coaching needs, provide you with services offered via the Platform and respond to your requests.
  • Categories of personal data processed: identification data, CoachHub platform data, coaching session data, connection data, psychometric assessment data (if your subscription includes psychometric assessments).
  • Source of data: data you and your employer (CoachHub, if you are a Coachhubber) provide; data automatically generated.
  • Legal basis: CoachHub’s legitimate interest in providing the coaching services ordered and paid for by its client, your employer.
  • Data retention period:
    • If you are a User: duration of CoachHub’s contractual relationship with your employer.
    • If you are a Coachhubber: duration of your employment contract with CoachHub. Your data is then stored in an intermediate archive for the duration of the applicable legal prescription.
• Data collected to ensure the operation of the Platform: We will collect data where necessary to ensure the proper operation and security of the Platform as well as to provide support:
  • Categories of personal data processed: identification data, connection data.
  • Source of data: data you and your employer provide (CoachHub, if you are a Coachhubber); data automatically generated.
  • Legal basis: CoachHub’s legitimate interest in ensuring the proper operation and security of the Platform.
  • Data retention period:
    • If you are a User: duration of CoachHub’s contractual relationship with your employer.
    • If you are a Coachhubber: duration of your employment contract with CoachHub. Your data is then stored in an intermediate archive for the duration of the applicable legal prescription.
• Data collected when you participate in our market researches: We may conduct market researches, and in this context, we may offer you to take part in an interview. Your data will be processed to manage your participation in this market research and to offer you a gift to thank you for your participation. In any case, we will always ask your employer’s permission to invite you to take part in a market research.
  • Categories of personal data processed: name, surname, email address, job title, video recordings taken during the interview, audio recordings captured during the interview, your opinion and feedback relating to the coaching program.
  • Source of data: data you provide to us.
  • Legal basis: your consent.
  • Data retention period: your personal data is kept for the time required to carry out the market research, before being deleted or anonymized.

Please note that your data may be kept for a longer period of time, for example in order to establish proof of a right or to comply with a legal obligation. In any case, your data is not kept beyond what is strictly necessary for the purposes for which it is processed. When your data is no longer required, we will ensure that it is deleted or anonymized.

6.Processing personal data of minors

Our services are not designed for or intended for minors. We do not knowingly solicit or collect personal data from minors. Persons under the age of 18 may not do business with CoachHub. If we discover that we have collected information about a minor, we will delete it. Please contact us using the contact information above if you believe you have provided us with information about a minor.

7. With whom do we share your personal data?

We share your personal data only with:

• our duly authorized personnel, who need to access to your data in the course of their duties in connection with the purposes described above;
• CoachHub’s legal entities, which need to access to your data in connection with the purposes described above and which are required to comply with this Privacy Notice (the updated list of these entities is available at: https://www.coachhub.com/imprint/);
• our service providers who act as data processors (the updated list of these entities is available at: https://coachhub.com/subprocessors;
• our external advisors (lawyers, auditors, etc.);
• public or judicial authorities, if we are legally required to do so or to protect our rights or the rights of third parties.

We may also share your personal data with third parties in connection with a potential or actual sale or restructuring of our company or certain of our assets, in which case your data may be one of the transferred assets.

8. Where is your personal data processed?

We store your personal data in the European Union.

However, your data may be transferred outside the European Union when it is transferred to processors located outside the European Union. Where applicable, we undertake in the absence of an adequacy decision by the European Commission under Article 45 of the GDPR, to frame such a transfer with appropriate transfer mechanisms under Article 46 et seq. of the GDPR (such as standard contractual clauses adopted by the European Commission). You will be able to obtain a copy of these (excluding confidential provisions) at any time by contacting us at the contact details set out at the beginning of this Privacy Notice.

9. Rights of EU Data Subjects

You benefit from certain rights under applicable data protection laws:

• you may withdraw your consent to any processing of your data based on your consent at any time.
• you may ask us to confirm whether we are processing your data and, if so, to inform you of the characteristics of the processing, to allow you to access it and obtain a copy.
• you may ask us to correct or complete your data if it is incorrect or incomplete.
• you may ask us to delete your data or to limit the processing of your data.
• you may ask us to provide your data in a structured, commonly used and machine-readable format, or you may request that it be transmitted directly to another data controller.
• if you reside in France, you have the right to set out (general or specific) instructions about what to do with your data after your death.
• you may object to any processing of your data that is based on our “legitimate interest”. If you exercise this right, we must cease processing your data unless we demonstrate imperative and legitimate grounds that override your fundamental rights and freedoms, or for the establishment, exercise or defence of legal claims.
• you may object at any time to the processing of your data for commercial prospecting purposes.

For more information about your rights, to exercise them or for any question or complaint about the protection of your personal data, you can contact us or our data protection officer at the contact details mentioned at the beginning of this Privacy Notice.

You also have the right to lodge a complaint with the competent supervisory authority regarding the processing of your data.

10. Rights of California Residents

Notice at collection

If you are a resident of the state of California, under the California Consumer Privacy Act and the California Privacy Rights Act (collectively, the “CCPA”) we are required to provide additional disclosures relating to the processing of your Personal Information.

When you use the Platform, CoachHub may collect the following categories of Personal Information (as defined under the CCPA). The table below and the information immediately following the table are a summary of the categories of Personal information we have collected over the last 12 months, the purposes of the collection and how long we retain such information. We do not knowingly collect information from individuals under the age of 18. We do not sell or share personal information for targeted advertising purposes.

Categories of Personal Information We Collect		Our Business or Commercial Purposes for Collection and Use of Your Personal Information
Personal Identifiers, including first and last name, email address, telephone/mobile phone number, login credentials, company code		We may use your Personal Identifiers to: Register you to use the Platform. Verifying your employer details. Link your account to your employer’s account. Assign one of our career coaches to you for a personalized coaching experience. Provide you with services offered via the Platform. Respond to your request. Provide you with customer services, including responding to your inquiries, service questions and feedback, fulfilling and verifying requests made pursuant to this Privacy Notice.
Demographic Information, including your gender and language preferences.		We may use your Demographic Information to: Register you to use the Platform. Provide the personalized coaching services in the Platform.
Commercial Information, including, (i) category of your request, topic of inquiry, information/ text of messages that you send us and the time of request, and the desired future date for us to contact you, when you fill out our electronic contact form; (ii) number of coaching sessions, date of the invitation, when you register and use the Platform; and (iii) the content of the chat with the coach, inputs to the micro-learning activities; recording from camera and microphones during the coaching session; start of the coaching period; duration of the coaching period and end of the coaching period.		We may use your Commercial Information to: Register you to use the Platform. Provide the personalized coaching services in the Platform. Provide you with customer services, including responding to your inquiries, service questions and feedback, fulfilling and verifying requests made pursuant to this Privacy Notice.
Device, and Internet and Network Activity Information (IP Address, Device IDs). This includes (i) usage information (e.g. date and time you access the Platform, and what information and files have been downloaded or presented thorough the Platform); and (ii) information about your visits to (e.g. acceptance of our General Terms and Conditions, notice of Privacy Notice, and date and time of registration), or use of, our Platform, and various attributes associated with your device (e.g., IP address, Device and operating system metadata, Device identification IMEI (International Mobile Equipment Identity), the unique number of the network subscriber IMSI (International Mobile Subscriber Identity), the mobile phone number (MSISDM), installed fonts, language and browser settings, time zone in order to create a device fingerprint or identifier so that we can recognise your device HTTP status code, and transferred amount of data)		We may use your Device, and Internet and Network Activity Information to: Register you to use the Platform. Provide the personalized coaching services in the Platform. Determine the general geographic region from which you are accessing the Services, using your IP address, which allows us to determine the server geographically closest to the user for providing the best possible video and session quality. Review statistical information about the use of the systems in order to improve their design and functionality, to understand how they are used, and to assist us with resolving questions. Recognise you, your device or your browser when you use our services so that we can facilitate navigation and display information more effectively.
Audio and Visual Information, including, your profile photo, and visual and audio information recording during your coaching session.		We may use your Audio, Visual Information to: Register you to use the Platform. Provide the personalized coaching services in the Platform. Provide you with services offered via the Platform.
General Location Information (e.g. zip code and IP Address.		We may use your General Location Information to: Provide the personalized coaching services in the Platform. Provide you with services offered via the Platform. Determine the general geographic region from which you are accessing the Services, using your IP address, which allows us to determine the server geographically closest to the user for providing the best possible video and session quality.

In addition to the purposes set forth above, we may use all of the categories of Personal Information noted above as we believe necessary to:

• to verify your identity or determine your eligibility to use the Platform;
• to enforce our rights in connection with our privacy practices, or to enforce agreements;
• to protect against unauthorized access to our systems or other inappropriate use of our Platform, including protecting the safety of our company, our Platform, customers, Users, and others;
• to comply with laws, regulations, court orders and subpoenas or similar requests for information by authorities;
• to perform audits;
• to contact you about the Platform or policy updates;
  for research and analytics, including to identify usage trends, and to improve and update our products and services;
• to assist us in fraud prevention or investigation, all on the basis of our legitimate interest in the continuation of our commercial activities and the protection of our rights; and
• for purposes otherwise permitted by law or as we may notify you and obtain your consent.

Aggregate or De-identified Information

We may collect, use and share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. We will maintain and use de-identified information in de-identified form and will not attempt to re-identify the information, except to make sure the information is truly de-identified.

Sources of Personal Information

We collect the categories of personal information specified above from the following sources:

• Directly from you: for example, when you register for the Platform, schedule sessions with our coaches or otherwise use the services offered via the Platform, submit a request via our contact form or otherwise email us regarding the services or use of the Platform.
• Automatically through tracking technologies: such as through the use of mobile software development kits (SDKs) and APIs, and we may use third party services to collect this Personal Information when you use our Services. For example, when you visit or navigate the Platform on any device; enable location-based features on the Platform, or elect to receive push notifications.
• From service providers and contractors: the updated list of these entities is available at: https://coachhub.com/subprocessors. For example, we work with service providers and contractors who collect information in order to:
  • Offering and improving products and services;
  • IT development and support;
  • Verifying your information; and
  • Enable certain functions in the Platform.

Section ‎3 (Data processing by the App Stores), Section ‎4 (Permissions), and Section ‎5 (What personal data do we collect, how and why?) provides additional information about the Information we collect, use, and retain your personal information.

Your Rights as California Residents

Under the CCPA, you have the:

• Right to Know

You have the right, up to two times every 12 months, to ask us to disclose the categories of Personal Information we have collected about you, the categories of sources from which we collected it, our business or commercial purpose for collecting, selling, or sharing Personal Information about you, the categories of Personal Information we sold or disclosed, the categories of third parties to whom we have shared Personal Information about you, and the specific pieces of Personal Information we collected about you.

• Right to Correct and Delete

You have the right to send us a request to correct or delete Personal Information we have about you, subject to certain exceptions allowed under applicable law.

• Right to Opt-Out of the Sale and Sharing of Your Personal Information (Opt-out of Targeted Advertising)

Under the CCPA, you may be able to request that we not sell, or share your Personal Information, for targeted behavioural advertising purposes. We do not currently share or use your Personal Information for Targeted Advertising purposes.

• Right over sensitive Personal Information

We do not collect, use or disclose Sensitive Personal Information of consumers for the purpose of inferring characteristics about consumers.

• Right not to be discriminated against

You have the right to not be discriminated against, when exercising your rights under the CCPA. For example, by receiving a different quality of services, if you exercise any of these rights.

• Right to appoint an authorized Agent.

You have the right to appoint an authorized agent to exercise these rights for you. Under the CCPA, an authorized agent is a natural person or a business entity that a person has authorized to act on their behalf subject to the requirements under the CCPA. If you would like to designate an authorized agent to submit a request to know, a request to delete, or a request to correct Personal Information on your behalf, please contact us as seen below under “How to submit a request”. When submitting the request, please ensure the authorized agent identifies himself/herself/themselves as an authorized agent. We will require written proof of the agent’s permission to do so and we will need to verify your identity directly. Once verified, your authorized agent may act on your behalf.

• How to Submit a Request

To exercise your rights above, please:

• Email us at privacy@coachhub.com; or
• Call us at +1-646-971-9522

In order to respond to your request, we may validate your email address if you have an account with us. If you use an authorized agent to exercise rights for you, we will confirm that the agent is authorized by you.

11. Privacy notice update

We may amend this Privacy Notice from time to time, including to comply with any legislative or regulatory, case law, editorial or technical advances. We will notify you of any material changes.