Privacy Policy

CoachSelect Privacy Policy

Effective Date:  April 25, 2024

Thank you for doing business with CoachSelect, Inc. (“CoachSelect,” 
“Company,” “we,” “our,” or “us”). We welcome you and hope you find our websites, web 
applications, and our other services and tools (collectively, the “Services”) helpful and useful. 
We have adopted this privacy policy (“Privacy Policy”) to help our website visitors, contractors, 
coaches, employees, current and potential customers, end users, and other business partners 
(“you” or “your,”) understand what Data we process, how and why we do so, and what your 
rights are regarding that Data.
 

We always seek to improve our Services to you, and that requires that we process information 
about you and your usage preferences. As we do so, we are absolutely committed to protecting 
your privacy and the security of your Personal Information.
 

In this Privacy Policy, we use certain defined terms to refer to the different types of information 
we process. “Data” is used to describe all the information we process that relates to you and your 
use of our Services, including all Personal Information. Our processing of “Data” is broken into 
different categories, which are detailed in the “Data We Process and How We Use It” section 
of this Privacy Policy. “Personal Information” is defined as any information relating to an 
identified or identifiable individual and is protected similarly as personal data or personally 
identifiable information under applicable data privacy and protection laws. Personal Information 
may include Sensitive Personal Information. “Sensitive Personal Information” is a class of 
Personal Information and generally includes: (a) social security number, passport number, 
driver’s license number, or similar identifier, (b) credit or debit card number (other than 
truncated digits), financial information, banking account numbers or passwords, (c) employment, 
financial, genetic, biometric or health information, (d) racial, ethnic, political or religious 
affiliation, trade union membership, or information about sexual life or sexual orientation, (e) 
account passwords, (f) criminal history, or (g) any other information or combinations of 
information that falls within the definition of “special categories of data” under applicable data 
privacy and protection laws.

We may refer to the different categories of Data separately, but when we use the word “Data,” 
we mean all the different categories described in this Privacy Policy. Because of the nature of 
our Services, the term “Data” also includes all information you gather, upload, or is otherwise 
processed when you use the Services. We do not process Personal Information without your 
consent. We rely on your compliance with any agreement(s) you may have with us to process 
your Data.

The term “Data” may not apply to information which does not relate to an identified or 
identifiable individual or to personal information or data rendered anonymous in such a manner 
that the individual is not or no longer identifiable (“Anonymized Data”). We hold all rights in 
and may use Anonymized Data for our own purposes in any legal manner and without attribution 
or compensation to any person.
 

This Privacy Policy applies to everybody who interacts with us online or otherwise. Because 
different portions of the Privacy Policy will apply differently to the various groups who interact 
with us, we have tried to clearly categorize the types of Data we process and how we do so. If 
you have any questions about this Privacy Policy or how we handle your Data, please email us at 
info@coachselect.com.
 

DESCRIPTION OF SERVICES
We provide a platform for individuals and companies to connect with our premium coaching 
network. In this Privacy Policy, all tools and services made available in connection with our 
platform, our operations, including our website, tools, and any other services that we provide 
directly to you, whether now known or developed later, are included in the term “Services.” 
 

LAWFUL BASIS FOR PROCESSING
Many jurisdictions require that we disclose to you the lawful basis for our processing of your 
Data. We do that in the “Data We Process and How We Use It” section and otherwise 
throughout this Privacy Policy. In general, our lawful basis for processing your Data is based on 
your specific consent or your contract with us.  
By accessing or using any of the Services or by otherwise interacting with us online or offline, 
you consent to our processing of your Data as described in this Privacy Policy. If our processing 
of your Data is based on your consent, you may withdraw your consent at any time, and we will 
cease processing your Data. However, in some cases, this may result in your inability to receive 
partial or full access to the Services, and your withdrawal of consent does not limit our ability to 
use Anonymized Data for use by us in connection with our legitimate business efforts in the 
future. In addition, your withdrawal of consent may not prevent us from processing Data if we 
have processed such Data pursuant to a different lawful basis or to preserve legal claims. For 
example, if you give your consent for us to process your Data, but we are also required by law to 
process your Data, that separate “lawful basis” will still apply, even if you withdraw your 
consent.

When you enter into an agreement with us, either by registering for and accessing the Services, 
by executing an agreement in hard copy, or by clicking “I Accept” or similar language online, we 
will process your Data for the purposes of fulfilling the terms of our contract with you. In that 
case, our processing of your Data is based on the contract, so your withdrawal of consent will 
only be effective after the purposes for processing that Data have been fulfilled and after we no 
longer have a legal obligation to process that Data.
In all cases, we will comply with applicable law and we will cease processing your Data after the 
legal right, obligation, or other lawful basis expires.   
 

INTENDED USERS 
Other than for Data processed for the specific purpose of providing the Services to users, we do 
not knowingly process Data from users who are under 18. If we become aware that we have 
processed Data from a person under 18, except to provide the Services to such person, and 
except to the extent allowed or required by law, then we will attempt to delete such Data as soon 
as possible, subject to our obligations under applicable law. If you are under the age of 18 in the 
jurisdiction in which you reside and want to make a request under applicable law, we may 
require you to make such request through a parent or guardian. If you believe that we have 
processed Data from a person under 18 in contravention of this policy, our provision of the 
Services, or applicable law, please contact us at info@coachselect.com.
 

DATA WE PROCESS AND HOW WE USE IT
Listed below are categories of Data we process when you use our Services. We never sell or 
share (as defined for restrictive purposes in the CPRA) your Data, and we always have a lawful 
basis for processing the Data, but that lawful basis might be different for different categories, and 
we describe those uses below. Regardless, we never process the Data for any purpose other than 
the purpose for which we processed the Data in the first place, unless we get your prior explicit 
consent.   
 

Please note that all coaches in our coaching network are independent contractors of CoachSelect. 
We do not control or take any responsibility for any information, including Personal Information 
and Sensitive Personal Information, you share or otherwise divulge to coaches. Coaches control 
and are responsible for securing any information shared by you with them while using the 
Services.
 

A.  Registration Data  
1.    Data Description: Registration Data may consist of the name, email address, street 
address, other contact information, and other information you provide us using the 
Services, both when you register for the Services and thereafter. Registration Data also 
includes your client type and other applicable registration information, if any and where 
applicable. 
2.    Lawful Basis for Processing: Our lawful basis for processing Registration Data is our 
contract with you and your consent. We can only provide certain of the Services to you if 
we have the Registration Data, so we need to process that Registration Data during the 
term of our contract. Even when the Registration Data is not critically necessary to the 
provision of the Services, we may still process that Registration Data to facilitate our 
contractual interactions with you.  
3.    How We Use It and Who We Share It With: Registration Data is accessible generally 
only to us and to you. In limited circumstances, we may share your Registration Data 
with our service providers, which help us provide the Services and are under obligations 
to protect the confidentiality of your Registration Data. Further, we provide coaches with 
your Registration Information, where applicable. We use Registration Data to provide the 
Services to you. At times, we will share the Registration Data with other third parties at 
your request. We may also use your Registration Data to offer our own goods or services 
to you, either directly through emails or through third-party platforms, but you may opt 
out of those communications at any time. 
 

B.  Engagement Data
1.    Data Description: Engagement Data consists of all the information you input, record, or 
otherwise divulge when using the Services, except as otherwise stated in this Privacy 
Policy. It also includes all information that is proprietary to you regarding your use of the 
Services (other than the data that qualifies as “Usage Data” below) that is processed by 
the Services. Engagement Data specifically includes the content of any text, personal 
preferences, and other information you divulge and include in the Services, such as 
surveys, forms, feedback, comments, questions, dialogue, video, audio, pictures, etc. 
Engagement Data may also include Sensitive Personal Information; however, you control 
what Sensitive Personal Information you divulge using the Services. Further, any 
information, including Personal Information and Sensitive Personal Information you 
divulge to coaches is not governed by this Privacy Policy.
Further, either we or a coach may share Engagement Data with your employer, if your 
employer paid for the Services or if disclosure of such information to your employer is 
part of the Services.
2.    Lawful Basis for Processing: Our lawful basis for processing Engagement Data is (1) our 
contract with you, (2) our obligation to provide you with the Services, and (3) our 
legitimate interest in improving our Services based on the Engagement Data we process.  
3.    How We Use It and Who We Share It With: Your Engagement Data is accessible to us, 
to you, to our employees or designated agents (if applicable), and to limited third parties 
that we use to provide and improve the Services, including coaches. If we share your 
Engagement Data with a third party, that party will be obligated to protect the 
confidentiality of your Engagement Data. Your disclosure of Engagement Data is 
voluntary and you assume all risk associated with our processing of your Engagement 
Data. We rely on your compliance with our agreement(s) with you that you have all 
necessary rights to all Engagement Data you processed by the Services. Both during the 
term of our agreement with you and thereafter, we may also convert Engagement Data to 
Anonymized Data, and that Anonymized Data belongs solely to us to use in our sole 
discretion (including to sell or share Anonymized Data, which is not Data). To the extent 
we are required to delete any Engagement Data about you, we may still retain 
Anonymized Data that may have originated as your Engagement Data.

C.  Usage Data
1.    Data Description: Usage Data consists of the following and similar information:
*    Information about your interactions with the Services, most commonly our website or 
mobile application, which includes the date and time of any requests you make. This 
also may include details of your use of any advertising you receive via the Services.
*    Adjustments you make to the default state of the Services, such as custom categories 
or settings.
*    The timing of the information you post to the Services including your interactions 
with us, but not including the content of those interactions, which would be included 
as Engagement Data. 
*    Technical data which may include URL information, cookie data, your IP address, the 
types of devices you are using to access or connect to the Services, unique device 
IDs, device attributes, network connection type (e.g. WiFi, 5G, LTE, Bluetooth) and 
provider, network and device performance, browser type, language, information 
enabling digital, mouse movements (including scrolling data), Please note, however, 
that if you disable certain functions, your use of the Services may be limited.
*    Rights management, operating system, and application version.
*    Motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or 
gyroscope), if any, required for the purposes of providing specific features of the 
Services to you.
2.    Lawful Basis for Processing: Our lawful basis for processing Usage Data is (1) our 
contract with you, (2) our obligation to provide you with the Services, and (3) our 
legitimate interest in improving our Services based on the Usage Data we process.  
3.    How We Use It and Who We Share It With: Usage Data is accessible to us, to you, to 
your employer, if your employer paid for the Services or if disclosure of such information 
to your employer is part of the Services, and to limited third parties that we use to provide 
and improve the Services. If we share your Usage Data with a third Party, that party will 
be obligated to protect the confidentiality of your Usage Data. We may also share Usage 
Data with other third parties at your specific request. We may use Usage Data to make 
improvements to the Services. Both during the term of our agreement with you and 
thereafter, we may also convert Usage Data to Anonymized Data, and that Anonymized 
Data belongs solely to us to use in our sole discretion (including to sell Anonymized 
Data, which is not Data). To the extent we are required to delete any Usage Data about 
you, we may still retain Anonymized Data that may have originated as your Usage Data. 

D.  Payment Data
1.    Data Description: Payment Data is only processed when your use of the Services is 
subject to the payment of a fee or other charge. However, we do not directly process your 
Payment Data because we use a third-party service provider that is PCI compliant to 
process payments. Payment Data will vary depending on the payment method you use but 
will likely include information such as: 
*    Name; 
*    Date of birth;
*    Certain credit card information used to reference a credit card; 
*    Address and postal code; and
*    Mobile phone number
2.    Lawful Basis for Processing: Our lawful basis for processing Payment Data is (1) our 
contract with you and (2) our legitimate interest in improving our Services based on the 
Payment Data we receive from you.  
3.    How We Use It and Who We Share It With: We only use Payment Data to facilitate 
payment. We do not communicate Payment Data to third parties because we do not 
directly process your Payment Data.

 

SHARING YOUR INFORMATION
We do not sell or share (as defined for restrictive purposes in the CPRA) your Data with third 
parties. Except where a specific limitation is noted above, we may share (other than as defined 
for restrictive purposes in the CPRA) your Data as follows:
1.    At Your Instruction. If you request us to make your Data available to a third party, and 
such request furthers the purposes of our Services, we will do so.
2.    Sharing with Vendors. In certain cases, we use the services of third-party vendors, to 
assist us in providing the Services. We may share your Data with such vendors solely for 
that purpose, and we will require those parties to abide by our privacy policies or privacy 
policies substantially in consonance with ours.
3.    Service Providers. We may use a third party to provide specific Services on our behalf, 
including sending emails to you, conducting surveys, processing transactions, or 
performing statistical analysis of our Services. In these cases, we may provide certain 
personal information, such as your name and email address and other information 
necessary for the service to be provided. However, these third parties are required to 
maintain the confidentiality of this information and are prohibited from retaining, 
sharing, storing, or using this information for any other purposes.
4.    Coaches/Employers. We share certain Personal Information with the coach(es) with 
which you connect via the Services. Further, either we or a coach may share information 
with your employer, if your employer paid for the Services or if disclosure of such 
information to your employer is part of the Services.
5.    Business Transitions. In the event that we go through a business transition, such as a 
merger, acquisition, liquidation, or sale of all or a portion of our assets, the information 
we have about you will, in most instances, be part of the assets transferred. We reserve 
the right to transfer that information in connection with such transactions without notice 
to you. We will not be required to obtain your consent for such a transfer.
6.    Legal Disclosure. We may disclose your Data if required to do so by law or in the good 
faith belief that such action is necessary to conform to applicable law, comply with a 
judicial proceeding, court order, or legal process served on us, protect and defend our 
rights or property, or investigate, prevent or take action regarding illegal activities, 
suspected fraud, situations involving potential threats to the physical safety of any person, 
or violations of our Terms and Conditions.
If we ever plan to process any Data in the future for any other purposes not identified 
above and we do not have a separate lawful basis for that new purpose for processing, we 
will only do so after obtaining your specific consent. 
Further, we do not sell or share (as defined for restrictive purposes in the CPRA) your 
Data for any purpose.

TECHNOLOGIES WE USE
The technologies we use for automatic Data processing may include the following:
*    Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your 
computer. You may refuse to accept browser cookies by activating the appropriate setting 
on your browser. However, if you select this setting you may be unable to access certain 
parts of our Services. Unless you have adjusted your browser setting so that it will refuse 
cookies, our system will issue cookies when you direct your browser to our Services.
*    Web Beacons. Pages of the Services and our emails may contain small electronic files 
known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that 
permit the us, for example, to count users who have visited those pages or opened an 
email and for other related website statistics (for example, recording the popularity of 
certain website content and verifying system and server integrity).
*    Other Technologies. We may also use device identifiers, local storage, html modifiers, 
and different types of caching to help us understand the devices and users who access the 
Services. Those methods include device identifiers that are either hardware-based or 
software-based, persistent, or non-persistent, and which may identify either a device or a 
software module within a device (such as a web browser).   
“Do Not Track” Options
Your web browser(s) may offer a “Do Not Track” option, which allows the individual to signal 
to operators of websites and web applications and services (including behavioral advertising 
services) that he or she does not wish such operators to track certain of his or her online activities 
over time and across different websites. We do our best to support Do Not Track requests but 
cannot guarantee full support based on the variety of internet browsers and technologies which 
means that we may process information about your online activity both while you are using the 
Services and after your use of the Services.

YOUR RIGHTS REGARDING YOUR DATA
Under applicable data protection, privacy, and other laws, you may have certain rights related to 
your access and control of your Data. Such rights may include the following:
1.    The right to access, correct, update, or request deletion of your Data. 
2.    The right to object to processing or restrict the processing of your Data (Please note that 
if you exercise this right, it may limit or eliminate our ability to provide you the 
Services).
3.    The right to request portability of your Data.
4.    The right to opt-out of marketing communications we send you. You can exercise this 
right by clicking the "Unsubscribe" or "Opt-Out" link found in these communications.
5.    The right to not be subject to a decision based solely on automated processing, including 
profiling, known as Automatic Decision Making. 
6.    The right to submit a complaint to any applicable regulatory authority about our 
processing activities.
7.    The right to opt-out of us sharing (as defined in the CPRA) your Data, including for 
direct marketing purposes, subject to certain legal exceptions.
8.    The right to limit use, disclosure, and restrict sensitive personal information (as defined 
in the CPRA).
We may use additional processes to verify your identity before we reveal or delete any of your 
Data, including two-factor or two-step authentication measures to ensure we can identify you.
This list may not include all of your rights under applicable laws. If you believe you have 
additional rights, please contact us using the methods in this Privacy Policy.
Further, although we currently do not process Data without consent, if we at any time in the 
future process Data without your express consent, you may opt-out or withdraw consent at any 
time.
Please note that exercising any of the above rights may limit or eliminate our ability to provide 
you the Services. If so, we may terminate the Services due to such requests.
We will try to comply with your request(s) as soon as reasonably practicable and at the very least 
as required under applicable law. Upon receipt of your written request, we will provide you with 
a copy of your information, although in certain limited circumstances we may not be able to 
make all relevant information available to you, such as where that information also pertains to 
another user. In such circumstances we will provide reasons for the denial to you upon request.
Please also note that if you do opt-out of receiving marketing-related emails from us, we may 
still send you messages for administrative or other purposes directly relating to your use of the 
Services, and you cannot opt-out from receiving those messages while continuing to use the 
Services.
Further, you may opt-out or disable certain functions on your particular device, preventing us 
from processing Data. For example, you may refuse to accept browser cookies. If you disable 
such features, your ability to use and access the Services may be limited.
To exercise any of these rights, or if you have any questions about our processing of your Data, 
please contact us at info@coachselect.com.

A.  Privacy for EU/UK Residents
The Regulation (EU) 2016/679 (General Data Protection Regulation) made effective in Europe 
on May 25, 2018 (“GDPR”) requires that we clearly describe to data subjects the data we 
process and how we use that data. This Privacy Policy does that and if you have any questions 
for us regarding our data processing, please contact us at info@coachselect.com. We comply 
with the GDPR requirements to the extent they apply to us.
 

We are based in the United States. By accessing or using the Services or otherwise providing 
information to us, you understand that your information will be subject to processing in and to 
the United States and in our other locations.
 

Due to the nature of our Services, we typically act as a “Controller” as defined under the GDPR 
depending on your engagement with us. If you believe that this role should be defined 
differently, please contact us at info@coachselect.com.
 

Pursuant to the GDPR, residents of the EU (and the EEA, as applicable) have the right to 
obtain our confirmation of whether we maintain personal information relating to them in 
the United States. If you are a resident of Europe, upon request from you, we will provide 
you with access to the Data that we process about you. Please contact us if you have any 
questions.
Further, if you are a resident of the United Kingdom (“UK”), to the extent the GDPR as 
incorporated into UK law pursuant to s.3 of the European Union (Withdrawal Act) 2018 
(as amended, the “UK GDPR”) applies to us, we will follow all supplemental requirements 
under the UK GDPR and you have all rights as a UK citizen under the UK GDPR.

B. Privacy for California Residents
California adopted the California Consumer Privacy Act (“CCPA”), which took effect at the 
beginning of 2020 and has now adopted the California Privacy Rights Act ("CPRA"), which 
fully took effect January 1, 2023. We comply with the requirements of the CCPA and CPRA to 
the extent they apply to us.  
If you are a California resident, you may request to exercise your rights for any Data we have 
processed in the 12 months prior to your request. Such request covers any categories, sources, 
purposes, and, if applicable, third parties to whom we share the Data. Further, you can exercise 
any of your rights free of discrimination, for example, we cannot increase the price of the 
Services or decrease the quality of the Services because you exercise your rights.
Due to the nature of our Services, we typically act as a “business” as defined under the CCPA 
and CPRA. If you believe that this role should be defined differently, please contact us at 
info@coachselect.com.
For more information, please direct your questions to us at info@coachselect.com.

C. Privacy for Singapore Residents
Data privacy and protection is governed in Singapore by the Personal Data Protection Act 2012, 
as amended from time to time (“PDPA”). We comply with the PDPA as an organisation (as 
defined in the PDPA) to the extent it applies to us. If you have any questions about your rights 
under the PDPA, please contact us info@coachselect.com.  

​

D. Other Data Privacy and Protection Laws
We strive to comply with all data protection and privacy laws in applicable jurisdictions, to the 
extent such laws apply to us and our Services. We strive to be transparent about our data 
processing activities and have disclosed our practices throughout this Privacy Policy. If you have 
any questions about your rights under any applicable data protection and privacy laws, please 
contact us at info@coachselect.com.

SECURITY
The security of your Data is important to us. We use commercially reasonable efforts to process 
your Data in a secure environment. We take technical, contractual, administrative, and physical 
security steps designed to protect Data that you provide to us. We have implemented procedures 
designed to limit the dissemination of your Data to only such designated staff as are reasonably 
necessary to carry out the stated purposes we have communicated to you. 

THIRD-PARTY POLICIES
You may be able to access third-party websites and other tools and services or products via a link 
on our website, mobile application, or via our other tools. The privacy policies of these third 
parties are not under our control and may differ from ours. The use of any Data that you may 
provide to any third parties will be governed by the privacy policy of such third party or by your 
independent agreement with such third party, as the case may be. If you have any doubts about 
the privacy of the information you are providing to a third party, we recommend that you contact 
that third party directly for more information or to review its privacy policy.
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or 
other practices of any third parties, including any third party operating any offering, site, or other 
products and Services used in connection with the Services. The inclusion of a link does not 
imply endorsement of the linked site or service by us or by our affiliates. 

DATA RETENTION
We will process your Data for as long as it remains necessary for the identified purpose or as 
required by law, which may extend beyond the termination of our relationship with you. We may 
process certain Data as necessary to prevent fraud or future abuse, or for legitimate business 
purposes, such as analysis of Anonymized Data, account recovery, or if required by law. All 
retained information will remain subject to the terms of this Privacy Policy. 
AMENDMENT OF THIS PRIVACY POLICY
We reserve the right to change this Privacy Policy at any time. If we decide to change this 
Privacy Policy in the future, we will post or provide appropriate notice. Unless stated otherwise, 
our current Privacy Policy applies to all Data that we have about you and your account. The date 
on which the latest update was made is indicated at the top of this document. We recommend 
that you print a copy of this Privacy Policy for your reference and revisit this policy from time to 
time to ensure you are aware of any changes. Your continued use of the Services signifies your 
acceptance of any changes.

CONTACT US
You can help by keeping us informed of any changes such as a change of your personal contact 
information. If you would like to access your information, if you have any questions, comments, 
or suggestions of if you find any errors in our information about you, please contact us at 
info@coachselect.com. If you have a complaint concerning our compliance with applicable 
privacy laws, we will investigate your complaint and if it is justified, we will take appropriate 
measures.