Bestselfy – Privacy Policy

 

Last updated: 1 April 2020

 

At Bestselfy, we take privacy seriously. So much so, below is our Privacy Policy which describes, in detail, how Bestselfy, Inc. (“Bestselfy”, “we,” “us” or “our”) collects, uses, and shares information about you and the choices you have regarding this information. This Privacy Policy applies to the information we collect when you access or use our products, services, and technology platforms (including the websites and mobile applications that help us provide the coaching services) (collectively, the “Services”). Please note that this Privacy Policy does not apply to your use of third party sites, services, or applications you may access through our Services. We encourage you to review the privacy policies of those third parties for more information regarding their privacy practices.

 

CHANGES TO THIS PRIVACY POLICY

 

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy. In some cases, such as a material change in our practices, we may provide you with additional notice, such as adding a statement to our homepage or sending you an email notification. We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy.

 

COLLECTION OF INFORMATION

 

If you visit our website or use our mobile applications, we will collect certain information about you. For all users and visitors see ‘Information We Collect Automatically’ below for details on what we collect via technology.

 

Information You Provide to Us

 

We collect information you provide directly to us when using the Services. 

 

If you are a prospective employee or Bestselfy coach we collect information if you apply for a job or apply to become a coach, request customer support, or otherwise communicate with us. For applicants residing in the European Union, please see this Notice regarding the collection of your personal information. 

 

Depending on how you registered for the Services (directly online or through your employer) we will need to collect certain personal information such as your name and email address. In some cases, we may also need your mailing and billing address, user ID, work experience and education, payment information, and any other information you choose to provide.

 

Platform Information of Subscribers

 

If you are a registrant on our website and use our coaching services via our website or one of our mobile applications (“Subscriber”), we will collect information as it relates to your use of the platform.  For example, we collect information when you download our mobile application(s), register for our Services, sign up for an account, or complete a quiz or questionnaire. 

 

You may also provide us information to facilitate your coaching experience. For example, to help you choose the right coach, you will respond to surveys to help us match you with a coach that aligns with your coaching goals. While these surveys will help us match you with the right coach, the surveys do not collect any personally identifying information (known as ‘PII’). We may collect information such as your coaching platform usage, development programs planned and attended, engagement status, session ratings, title, employment details, and any other information you choose to provide in conjunction with the Services.

 

Information We Collect Automatically When You Use the Services

 

When you access or use the Services, we automatically collect information about you, including the following:

 

Log Information: We log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to the Services.

 

Information Collected by Tracking Technologies: We use different technologies to collect information, including web beacons. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and to understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see “Information Collected By Cookies” below.

 

Browser local storage. We also store data locally on your device to enhance the user experience for our Services. For example, browser local storage allows us to save the state of your current page so that when you return at a later time or refresh the browser, the page will remain the same. We may also use browser local storage to: (i) save a list of items the user last used on the website or Services (such as events and properties the user selected) so we can display “recently viewed items”; or (ii) marking once a user has seen a tutorial, video, tooltip or onboarding flow so that the user only sees the content one time.

 

Mobile Services. We may also collect information from your mobile device, such as but not exclusively, the first time the mobile application is opened, mobile carrier, and the type of device that is being used,  if you have downloaded our applications. This information is generally used to help us deliver the most relevant information to you and improve our Services and coaching platform. Examples of information that may be collected and used include how you use the Services and information about the type of device you use. In addition, in the event our mobile applications crash on your mobile device, we will receive information about your mobile device model and OS version, which allows us to identify and fix bugs and otherwise improve the performance of our Services. We send you push notifications from time-to-time such as reminders for coaching sessions. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information. We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. 

 

Information Collected by Cookies

 

We use different technologies to collect information, including cookies. Cookies are small text files placed on an individual’s computer by websites that the individual has visited. They are used to make websites work more effectively and efficiently. No Personal Information is stored within them; however, details below describe some of the cookies Bestselfy uses, and to explain why they are used. 

 

We use the following cookies in conjunction with providing you the Services. To change your cookie settings/preferences at any time, please visit our cookie preference page.

 

Cookie Settings

 

Name

 

Purpose

 

Cookie Privacy Policy Link

 

Google Analytics

 

Analytics

Ad targeting, website personalization, and analytics

Lead capture and analytics

Website chat, account based marketing, and lead capture

To opt-out of all cookies on your browser, please visit the following links (note, this will opt you out of all cookies, not just bestselfy.com), please visit the following:

 

Chrome Opt Out

Safari Opt Out

Explorer Opt Out

 

Information We Collect From Other Sources

 

We may also obtain information from other sources, such as list providers and publicly available sources, and combine that with information we collect through the Services. We also may receive information about you from the coaches with whom you interact through the Services.

 

USE OF INFORMATION

 

We may use the information we collect to provide, maintain, and improve the Services, including to assess and improve the quality of the Services.

 

Subscribers

 

The information we collect from Subscribers may be used to:

 

Provide and deliver the products and services you request, process transactions, and send you related information;

 

Verify your identity and, if applicable, authorization for you to use the Services (such as from your employer);

 

Respond to your comments, questions, and requests;

 

Send you technical notices and other administrative messages;

 

Communicate with you about products, services, offers, promotions, rewards, and events offered by us or others, and provide news and information we think will be of interest to you;

 

Monitor and analyze trends, usage, and activities in connection with the Services;

Conduct research, analysis, and surveys;

 

Personalize and improve the Services and provide content or features that match user profiles or interests; and

 

Carry out any other purpose for which the information was collected.

 

Employees

 

The information we collect from employees may be used to: 

 

Determine your compensation and to compensate you;

 

Respond to your comments, questions, and requests;

 

Send you technical notices and other administrative messages;

 

Communicate with you about products, services, offers, promotions, rewards, and events offered by us or others, and provide news and information we think will be of interest to you;

 

Monitor and analyze trends, usage, and activities in connection with the Services; and/or

 

Conduct research, analysis, and surveys.

 

SHARING OF INFORMATION

 

If you are a Subscriber, when you use the Services, we may share information about you so that we can provide Services to you. We may also share information with the employer or other entity who has sponsored your use of the Services, such as the program you selected and how you used the Services (such as the number of sessions you attended, when the session was attended, or completion of an assessment). We may also provide aggregated and de-identified information. We may also share or transfer [SW2] information about you as follows or as otherwise described in this Privacy Policy:

 

With vendors, consultants, and other service providers who need access to such information to carry out work on our behalf;

 

In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;

 

If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property, and safety of you, us, or others;

 

In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company; and

 

With your consent or at your direction, including if we notify you through the Services that certain information you provide will be shared in a particular manner and you provide this information.

 

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

 

ANALYTICS AND ADVERTISING SERVICES

 

We may allow others to provide analytics services on our behalf in performance of the Services under a master agreement with a Bestselfy customer. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Services, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Bestselfy and its third party providers, to analyze and track data and better understand your online activity while using our Services. 

 

TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES

 

We are based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the United States and other countries, where you might not have the same rights and protections as you do under local law.

 

Please direct any inquiries or complaints regarding our compliance with the Terms & Conditions to the point of contact listed in the “Contact Us” section below. If we do not resolve your complaint, you may submit your complaint free of charge to https://www.jamsadr.com/eu-us-privacy-shield, our designated Privacy Shield dispute resolution provider. Under certain conditions specified by the Terms & Conditions, you may also be able to invoke binding arbitration to resolve your complaint. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. If we share EU Data with a third-party service provider that processes the data solely on our behalf, then we will be liable for that third party’s processing of EU Data in violation of the Terms & Conditions, unless we can prove that we are not responsible for the event giving rise to the damage.

 

DATA RETENTION

 

We store the information we collected about you for as long as is necessary for the purpose(s) for which we originally collected it, or in furtherance of other legitimate business purposes, including our responsibility to meet our legal, regulatory, or other compliance obligations.

 

YOUR CHOICES

 

Your Information

 

You may update, correct or delete information about you at any time by contacting us at compliance@bestselfy.com. Please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period.

 

Promotional Communications

 

If you are outside of the EU, you may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at hi@bestselfy.com. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.

 

YOUR CALIFORNIA PRIVACY RIGHTS

 

A business subject to California Civil Code section 1798.83, the California Consumer Privacy Act (“CCPA”) is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the type of personal information disclosed, for the third parties' direct marketing purposes. Please note that under the CCPA, businesses are only required to respond to a customer request once during any calendar year.

 

In addition, a business subject to CCPA must allow California residents under age 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. Your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

 

If you are a California resident and would like to make any such a request, contact us at either:

 

Bestselfy, Inc. 

11 Duck Marsh Lane

Orleans, MA 02653

Attn.: Data Protection Officer

e-mail: compliance@bestselfy.com

 

EUROPEAN ECONOMIC AREA

 

If you are in the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data. 

 

Legal Basis for Processing

 

If you are in the EEA, when we process your personal data we will only do so in the following situations:

 

We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the services you have requested).

 

We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our Services, and to provide, secure, and improve our Services.

 

You have provided consent for us to process your personal data.

 

Data Subject Requests

 

If you are in the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred.  You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can log into your account. Alternatively, you may contact us as indicated below.

 

Questions or Complaints

 

If you are in the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. 
For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. 

 

CONTACT INFORMATION

 

If you have questions or comments about our Privacy Policy, or you are a consumer with a request, please email our Privacy Team or Data Protection Officer at compliance@bestselfy.com. 

 

You can also reach us by via postal mail at:

 

Bestselfy, Inc. 

11 Duck Marsh Lane

Orleans, MA 02653

USA

 

Now, go be your Bestself(y)!

Contact

Need to get in touch with us? We're all ears.  

Enterprise solution:
enterprise@bestselfy.com

 

Need support?
hi@bestselfy.com

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