Last updated: January 2023
COACHINHO respects your privacy and is committed to protecting the personal information of its users - subscribers, coaches, employees and other visitors to the Website ("Users"), as well as partners, influencers and other collaborators working with COACHINHO. We believe that you have a right to know our practices with respect to those information we collect when you visit and/or use the Website. This policy explains our privacy practices for the Site and the services COACHINHO offers, as well as the privacy practices that apply to affiliates, influencers and other collaborators who are natural persons. By accessing and/or using the Site and related sites, applications, services or goods and/or registering for a COACHINHO account and/or using it as an employee and/or registering as a user, partner, coach or association, you agree to the terms of this Policy, including the collection, use, disclosure, processing and retention of personal data. This policy also tells you how to restrict the sharing of information.
What kind of information we collect
When you register with or use the Site, fill out contact forms, or use the Site as an employee, we ask you to provide certain personal information, including a valid email address, account credentials, and username. We may also ask you to provide or otherwise collect additional information that you provide to us, such as your profile information, physical or billing address, telephone number or other contact information, financial information (such as payment method and credit card number), and additional authentication information.
We also collect information as you access, browse, view or otherwise use the Site. When you access the Site, we are aware of your use of the Site and collect, collate and record information relating to that use, including geo-location information, IP address, device and connection information, browser information and web log information, and any communications recorded by users through the Site. We use this information to improve the user experience, personalise your browsing experience and monitor the website to prevent fraud and inappropriate content or behaviour. We combine your personal information with information we collect automatically or receive from other companies and use it to improve and personalise our services, content and advertising and/or to prevent fraud.
How we collect information
Information provided by you: You provide most of the information we collect directly to us. You do this by completing the registration details on the site and connecting to your COACHINHO account. This may include information about coaches and their offerings, education and profession, sharing portfolios, reviews and feedback from buyers, and anything you add to your user profile.
How we use the information we collect
Where relevant under applicable law, any processing of your personal data will be justified by a "legitimate reason" for the processing. In most cases, processing will be justified on the basis that:
you have given us your consent to use your personal data for a specific purpose;
our use of your personal data is necessary to perform a contract with you or to take steps to enter into a contract with you (for example, to provide you with a subscription);
the processing is necessary to comply with a relevant legal or regulatory obligation we have (e.g. anti-fraud); or
the processing is necessary to further our legitimate interests as a business (e.g. to improve our services to you), subject to your interests and fundamental rights and provided that at all times it is done in a way that is proportionate.
We will use your personal data for the following purposes:
To provide you with a quality service and security, to operate the Website, to fulfil our obligations to you and to develop and improve our service. For example, we use the information we collect from you to verify your identity. We also use this information to set up your account, verify or re-assign a password, log your activity, enable your communication with other members, provide customer support and contact you from time to time. The information helps us to develop and improve our services to you, to understand and analyse your preferences and performance, and to customise and personalise your experience (including through course suggestions, search result ranking, etc.).
To contact you as requested by you or as otherwise authorised by you or permitted under this Policy.
To promote and advertise the Website. For example, we use the information we collect from you to send direct marketing messages (as described below), to show you information that may be of interest to you, to organise and facilitate referral programmes, competitions or other promotional activities or events.
To maintain appropriate business records, to comply with lawful requests from public authorities and to comply with applicable laws and regulations or as otherwise required by law.
We will ask for your consent before using any information for a purpose other than that stated in this policy.
We use your personal data to send you direct marketing communications about our COACHINHO products, services or promotions that may be of interest to you or our related services. This may be by email or targeted online advertising.
Our processing of your personal data for marketing purposes is based on our legitimate interest or your consent or as otherwise permitted by applicable law. You have the right to opt out of direct marketing in any form at any time - you can exercise this by following the opt-out link included with each communication or by sending an unsubscribe email.
We take steps to limit direct marketing to a reasonable and appropriate level and to send you communications that we believe may be of interest or relevance to you based on the information we have about you.
How long do we keep personal information?
As a general rule, we only keep personal information for as long as is necessary to fulfil the purpose for which it was collected. However, in certain circumstances we may keep your personal information for longer periods.
We will retain personal data for the following purposes:
for as long as it is necessary and relevant to our business, for example, so that we have an accurate record of your dealings with us in the event of a complaint or challenge; and
in relation to personal data from closed accounts, to comply with applicable laws, prevent fraud, collect fees owed, resolve disputes, troubleshoot problems, assist in investigations, enforce our website terms and conditions and take other actions as permitted by law.
Children under 13
Our Site is intended for use by children under the age of 13 provided that it is used under the supervision of at least one parent or guardian. Persons under the age of 13 should not provide any personal information to or on the Site. We do not knowingly collect personal information from children under 13. Parents and guardians should supervise their children's activities at all times. If we learn that we have collected or received Personal Information from a child under 13 without the consent of at least one parent or guardian, we will delete that Personal Information. If you believe that we may have information from or about a child under 13, please contact us at firstname.lastname@example.org.
Disclosure of personal information to third parties
We do not sell your personal information to third parties for their marketing purposes without your explicit consent.
We share your personal information with third parties as described below:
We share personal information with service providers who provide us with services to operate the website, open and operate your account, and provide ancillary services and solutions. These include, but are not limited to, hosting services, billing and payment service providers, CRM systems, forum hosting, community management services, data and cybersecurity services, web analytics and performance tools, translation tools, IT SaaS services, session recording, communication systems, mailing systems, data optimisation and marketing services, data enrichment services, legal and financial advisors or technical consultants. In accordance with applicable law, we take commercially reasonable steps to require third parties to adequately protect your personal data and only process it in accordance with our instructions;
We disclose personal data to law enforcement, government agencies or other parties in response to a subpoena or court order, legal process or to regulators if we believe we are required to do so by law or that it is reasonably necessary to comply with legal process; If we believe it is necessary or appropriate to disclose personal data to law enforcement, for example. For example, to investigate actual or suspected fraud or violations of law, breaches of security, or violations of this Policy; to respond to claims against us; and to protect the rights, property, or personal safety of COACHINHO, our users, or the public;
We share personal information with payment processors, fraud detection agencies and similar third parties to facilitate payments made through the Site and to secure and protect the Site from fraud, unauthorised transactions (such as money laundering), claims or other liabilities;
We also share limited personal information with such social media platforms and marketing partners, such as Meta, Google and TikTok, to promote COACHINHO. Such third-party features and services collect certain information about you and may set a cookie to enable their functionality. The features of such third party providers are subject to their policies.
We disclose Personal Information to COACHINHO's affiliates, which are linked by common control, to operate the Site, to provide our services to you, and for other purposes set forth herein; and
Personal Information will also be disclosed if we undergo a business transition, such as a merger, sale, transfer of all or a portion of COACHINHO's assets, acquisition, bankruptcy or similar event. In the event that we sell a business or assets, we will share your information with the potential buyer. If we or substantially all of our assets are acquired by a third party, the information we hold about our users will be one of the transferred assets.
Please note that your profile information and additional information about your activities (including courses, ratings, comments on the website as well as on social media channels will be made public and visible to all users of the website. If you publish your information and/or share your information with other COACHINHO users, you do so at your own risk.
Use of WhatsApp Newsletter
Insofar as you have consented, COACHINHO processes your personal data provided or available (e.g. name, telephone number, e-mail address, messenger ID, profile picture, messages) for communication regarding the preparation and execution of any orders as well as for sending promotional information (e.g. offers, newsletters) using the instant messaging service "WhatsApp" of WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
An existing messaging account is required to use this service.
In addition to the recipients already specifically named above, we use the help of further service providers (order processors) to fulfil our obligations.
We would like to point out that you can revoke your consent for the future at any time without giving reasons by informing us of your revocation via Whatsapp with a message with the note STOP/INFOSTOP or by e-mail to the e-mail address email@example.com or our imprint of the corresponding processing of your personal data.
The above-mentioned data will be deleted by us in accordance with the legal requirements as soon as the consent permitted for processing is revoked or if the purpose of processing this data no longer applies or it is not required for the purpose.
If the data is not deleted because it is required for other and legally permissible purposes, its processing is limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
Where we store your personal information
Some of the personal information you provide to us is stored or processed on our behalf by third party vendors and data processing companies and may be located in other jurisdictions, such as the United States and Germany, whose laws may differ from the jurisdiction in which you live. Whether the data is transferred to third parties or internally, all transfers of personal data from the European Economic Area ("EEA") to countries that do not provide an adequate level of data protection are subject to the European Union (EU) standard contractual clauses and/or equivalent data transfer rules to protect the security and confidentiality of personal data. We will take all reasonable steps to ensure that your personal data is treated securely and in accordance with this policy.
Responsible provider of the Facebook Messenger service:
Responsible provider of the WhatsApp Messenger service:
Responsible provider of the Instagram Direct Messages service:
Responsible provider of the Google Messages service:
Responsible provider of the ChatWerk platform/service:
We take great care to ensure the security of the website and your data and to prevent unauthorised access, loss, misuse, alteration, destruction or damage through industry standard technology and internal procedures. Among other things, we regularly maintain Payment Card Industry Data Security Standards (PCI DSS) certification (in relation to credit card payments). In addition, we contractually ensure that third parties who process your personal data also ensure the confidentiality and integrity of your data in a secure manner. However, the transmission of data over the Internet is not completely secure and although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.
Users who have registered on the Site agree to keep their password strictly confidential and not to disclose it to any third party.
We can provide more information about our data security practices upon request.
Rights of EU users
Under the applicable EU Regulation, you have the following rights in relation to your personal data:
To obtain a copy of your personal data, together with information on how and on what basis that personal data is processed;
To rectify inaccurate personal data;
Erase your personal data in certain circumstances if (a) you consider that it is no longer necessary for us to hold your personal data; (b) we process your personal data on the basis of legitimate interests and you object to this processing and we cannot demonstrate an overriding legitimate reason for the processing; (c) if you have provided us with your personal data with your consent and you wish to withdraw your consent and there is no other ground on which we can process your personal data; and (d) if you believe that the personal data we hold about you is being processed by us unlawfully;
to restrict the processing of your personal data if: (a) the accuracy of the personal data is contested; (b) the processing is unlawful but you object to the erasure of the personal data; (c) we no longer need the personal data for the purposes for which it was collected but it is necessary for the establishment, exercise or defence of a legal claim; or (d) you have objected to the processing of your personal data on the basis of our legitimate interests and we are considering your objection;
to object to decisions based solely on automated processing;
if you have provided us with your personal data with your consent, to ask us for a copy of that data in a structured, machine-readable format and to ask us to transfer (port) that data to another data controller; or
obtain a copy of, or access to, the security arrangements under which your personal data is transferred outside the EEA.
You also have the right to lodge a complaint with a data protection supervisory authority.
We will ask you for additional data to confirm your identity and for security purposes before we share the data we have requested from you. We reserve the right to charge a fee where permitted by law. We will refuse to process requests that jeopardise the privacy of others, are extremely impractical or would cause us to take action that is not permitted by applicable law. In addition, to the extent permitted by applicable law, we will retain certain personal information for a limited period of time for record keeping, accounting and fraud prevention purposes.
Updating personal information
We take steps to ensure that the personal information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your account profile settings. If you believe that your information is incorrect or inaccurate in any way, please let us know immediately. We will ensure that we investigate the matter and correct any inaccuracies as soon as possible or give you the opportunity to update or delete it quickly - unless we need to retain that information for legitimate business or legal purposes. When we update your personal information, we will ask you to verify your identity before we can process your request. If for any reason you have a problem deleting your personal information, please contact COACHINHO Customer Support and we will make reasonable efforts to delete that information in accordance with applicable data protection laws.
You can review and change your personal information by logging into the Site and visiting your account profile page.
To exercise any of your rights in connection with your personal information, please send us your request at firstname.lastname@example.org. We will process all requests in accordance with all local laws and our policies and procedures. Even if you do not have an active COACHINHO account, please contact us at email@example.com.