Privacy Policy

1. Introduction

This privacy policy (“Privacy Policy”) will give you information about how we collect, store and process your information when you visit the website, www.thegrowthally.com (“Website”) or its derivatives; and/ or use individual and executive coaching services (“Services”). By using the Websites and/ or Services, you agree to the collection, storage and use of information/ data in accordance with this Privacy Policy. We recommend that you read this Privacy Policy carefully when using the Website or Services By using the Website or Services, you are accepting the practices described in this Privacy Policy. If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

2. Information Collection

(a) Information Collected From You

We collect several types of personal and non-personal information when you visit the Website or use the Services. We collect personal information such as your full name, email address, phone number when you contact us through our Website’s contact page, email us, or otherwise communicate with us. When you engage the Services, we may collect additional personal information about you such as your home and work address, age, occupation, job title, credit card information and other information you choose to provide. If you are an employee of a company or organization, such company or organization may provide us with your personal information for the purposes of providing you with executive and/or leadership coaching. We do not sell your information to third parties, but only use it internally and share it with our partners (including payment partners) as mentioned this Privacy Policy for the purposes of providing the Services.

The following are additional situations in which you may provide your information to us:

● When you sign up for any newsletters or other materials;

● When you provide information to us through a third-party application or website;

● When you communicate with us or request information about us or the Services, whether via email or other means;

● When you provide any online testimonials (blogs, videos);

● When you participate in any of our marketing initiatives, including any events, webinars;

● When you register and/or participate in online forums, reviews or provide any content or submissions.

As you navigate through and use our Website, we automatically collect non-personal information from your browser, computer, or mobile devise when you access the Website through the use of various technologies, including cookies and pixel tags. 

(b) Data Collection From Our Channel Partners

We may receive your information from third parties when you visit our web page on social media sites (e.g., Facebook, Google, LinkedIn). When you visit any of these online sites, our partners may collect:

● Information about your visit, clicks, page information, your activity on our webpage on our online channels or third-party channels (such as social networks).

● Location information or your IP Address that we use to give you relevant online content.

● Information you’ve shared publicly on online forums.

(c) Device Information

When you access our Websites by or through a mobile device or any desktop or handheld device, we may collect certain information automatically, including, but not limited to, the type of device you use, your device unique ID, the IP address of your device, your operating system, the type of internet browser you use and other statistics.

(d) Usage, Behavior and Preference Information

We collect information about how you and Website visitors interact with our Website, pages visited and viewed and links clicked. In some cases, we do this through use of cookies, pixel tags and similar technologies that create and maintain unique identifiers. A cookie is a small file placed on your device. It may be possible to refuse to accept cookies by activating the appropriate setting on your device. However, if you select this setting you may be unable to access certain parts of the Website. We cannot control the use of cookies by third parties (or the resulting information) and use of third party cookies is not covered by this Privacy Policy. This information is used by us in order to enable us to better understand how our Websites are being used by visitors and allows us to administer and customize the Website to improve your overall experience. We may aggregate information from the visitor of the Website, such as demographic statistics of our users (e.g. geographical allocation of our visitors), number of visitors and average time spent on the Website which will also be considered as non-personal information.

3. Why we need to collect and process information

We need to collect and process information, so that:

● To present our Websites and its contents to you.

● You can contact us to use the Services;

● We can provide you with information, or services that you request from us;

● We can notify you about changes to our Website and/or Services or any services we offer or provide through it;

● We can process payments received from you for the Services;

● We can send you any information you asked us for or answer your questions;

● We can ask users to give us feedback/testimonials on the Services;

● We can provide you with relevant marketing information about the Services;

We can carry out our obligations and enforce our rights arising from any contracts entered into between you and us.

4. Disclosure of Information

We may disclose the information we collect from you as described in this Privacy Policy or as described at the time of collection or sharing, including as follows:

(i) with the general public if you submit content in a public forum (such as social media website such as Google, Facebook, Twitter, Instagram), for reviews, comments, social media posts, or about the Services;

(ii) To any person who, in our reasonable judgment, is authorized to receive your information as your agent, including as a result of your business dealings with that person (for example, your attorney);

(iii) To our third-party partners and service providers so that they may provide support for our business, including handling of data storage, surveys, research, internal marketing, delivery of promotional, marketing and transaction materials, and maintenance and security. These entities are authorized to use your information only as necessary to provide these services to us and are contractually obligated to keep your information confidential;

(iv) We may access, read, preserve and disclose any information that we reasonably believe is necessary to comply with or as required by law or ordered by a court, regulatory, or administrative agency;

(v) As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule or regulation, or are otherwise interfering with another's rights or property, including, without limitation, our rights or property;

(vi) If requested by authorities in the event of any act of terrorism or instance of local, regional or national emergency;

(vii) To enforce our Terms of Use, this Privacy Policy, and any other applicable agreements and policies; 

(viii) With your consent; and

(ix) To enforce or protect our rights.

5. Your Rights in Relation to the Personal Information we Collect

You have the right to access, correct, delete, restrict processing, and object to processing of your personal information. If you wish to (i) update, alter, delete or obtain a copy of your personal information that we hold; (ii) restrict or stop us from using any of the personal information which we hold on you, including by withdrawing any consent you have previously given to the processing of such information; or (iii) where any personal information has been processed on the basis of your consent or as necessary to perform a contract to which you are a party, request a copy of such personal information in a suitable format, you can request this by emailing us at the address set out at the end of this Privacy Policy. We endeavor to respond to such requests within (forty-five) 45 days, although we reserve the right to extend this period for complex requests and due to other circumstances.

We reserve the right to deny you access to our Website for any reason permitted under applicable laws. Such exemptions may include national security, corporate finance, and confidential references. If we deny access or correction, we will provide you with written reasons for such denial unless it is unreasonable to do so and, where required by local data protection laws, will note your request and the denial of same in our records.

6. California Privacy Rights

Please review these additional privacy disclosures as required under the California Consumer Privacy Act (“CCPA”), which provide a summary of how we collect, use and disclose personal information about you and explain your rights under California law.

We collect Personal Information as per Section 2 of this Privacy Policy. The business or commercial purpose for collecting Personal Information is described in Section 3 of this Privacy Policy. We disclose these categories of Personal Information for the business purposes described in Section 4 of this Privacy Policy.

Under the CCPA, California residents have the right to request access to or delete their Personal Information, to request additional details about our information practices, to opt out of the ‘sale’ of Personal Information (if applicable), and not to be discriminated against. Below we explain how you may exercise these rights.

· Right to Know: You may request access to the specific pieces of Personal Information we have about you. You may also request additional details about our information practices, including the categories of Personal Information we collect, the sources of information, the types of third parties we share information with, the types of Personal Information we share for business purposes, and details about the information we have sold, if any. 

· Right to Modify and Delete: You may review, modify and request deletion of your Personal Information. Note that even if we honor your request to delete your information, we may retain certain information as required or permitted by or required by law.

· Right to Non-Discrimination: We will not discriminate against you for exercising any of the above rights. We will not deny you the Services, charge you different prices or rates, or lower the quality of the Services offered to you if you exercise your rights under the CCPA.

You may exercise your rights by emailing us at the address set out at the end of this Privacy Policy.

Under the CCPA, you may exercise these rights yourself or designate and agent (by way of a written and duly signed authorization, including electronically signed authorization) to make these requests on your behalf. To exercise your rights, you must submit a written request which describes in detail your request in order for us to understand, evaluate and respond to it. Upon receipt of your request to exercise your rights to access and edit or delete your Personal Information, we will verify your identity in a manner we determine most appropriate to protect your security and privacy. We will work to respond to your request within (forty-five) 45 days of receipt. There is no fee charged by us for processing such requests.

7. Links to Third-Party Websites

Our Website, as well as the email messages sent with respect to the Services, may contain links or access to websites operated by third parties that are beyond our control such www.Gallup.com, www.wiley-epic.com(third party online tools that allow the clients to access their personality assessments) or social media websites such as Facebook, Twitter, Linkedin, Instagram. Links or access to third party websites from the Services are not an endorsement by us of such third parties, or their websites, applications, products, services, or practices. We are not responsible for the privacy policy, terms and conditions, practices or the content of such third parties. These third parties may send their own cookies to you and independently collect data. If you visit or access a third-party website, application or other property that is linked or accessed from the Services, we encourage you to read any privacy policies and terms and conditions of that third party before providing any personally identifiable information. If you have a question about the terms and conditions, privacy policy, practices or contents of a third party, please contact the third party directly.

8. How Long We Retain Your Information

We generally retain your information as long as reasonably necessary to provide you the Services and/or to comply with applicable law. We can retain copies of information about you or Services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with the Services, to assist with investigations, or to take any other actions consistent with applicable law.

9. Our Cookie Policy

Cookies are small data files that your browser places on your computer or device. A cookie itself does not contain or collect information. However, when it is read by a server via a web browser it can help a website deliver a more user-friendly service – for example, remembering previously entered details. Like most websites, our Website collects some information (e.g., information on IP addresses, browsers, internet service providers, referring pages, exit pages, operating systems, date stamps, time stamps and clickstream data). We and our Website user tracking utility partners use browser storage, app storage, cookies, pixels, beacons, scripts and tags to analyze trends, administer the site, track user movement through the site and collect demographic information about our overall user base. We may receive reports on these from our Website tracking utility partners on an individual and aggregate basis. 

10. Data security and integrity

The security, integrity and confidentiality of your information is extremely important to us. We, strive to implement and maintain reasonable, industry-standard secure storage technologies and commercially acceptable security procedures and practices appropriate to the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure. Your information will be stored on a computer with multi-factor authentication security. However, we cannot ensure or warrant 100% security of any information you provide to us or guarantee that information may not be accessed, disclosed, altered, or destroyed by unauthorized persons or hardware or software failure. Further, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the information we have collected from you. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

11. Do not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals transmitted by web browsers.

12. Children’s Privacy

The Website and Services are not targeted towards children. We do not knowingly collect, maintain, or use personal information from children under 13 (and in certain jurisdiction under the age of 16) years of age, and no part of our Website is directed to children under the age of 13 (and in certain jurisdiction under the age of 16). If you learn that your child has provided us with personal information without your consent, you may alert us at angie@thegrowthally.com.

13. Notice to California Residents

If you’re a California resident, you’re permitted by “Shine the Light” law (California Civil Code Section 1798.83) to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes. With respect to these entities, this privacy policy applies only to their activities within the State of California. To make such a request, please send an email to angie@thegrowthally.com.

14. Notice to Nevada residents

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to angie@thegrowthally.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.

15. Changes to this Privacy Policy

This Privacy Policy will remain in effect, except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page. We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Services after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If we make any material changes to this Privacy Policy, we will place a prominent notice on our Website. This Privacy Policy shall be governed by the laws of the State of California and submitted to the exclusive jurisdiction of the courts in Northern District of California.

16. How to contact us

If you have any questions about this Privacy Policy, please contact us at angie@thegrowthally.com. Please include your name and pertinent info in your inquiry.