Introduction: Our commitment to your privacy
What information do we collect?
CTI may collect, use, store and transfer different kinds of Personal Data about you. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
These are the types of Personal Data we may collect:
- Identity Data includes first & last name, Company, job title.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details if you make purchases from us or if you otherwise subscribe to our chargeable services.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you while you visit the Site (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
What do we use this information for?
We will only use your Personal Data when the law allows us to. We must use your data only on a lawful basis including, but not limited to using such data to fulfil a contract we have with you; to comply with legal obligations; to lawfully gain information to help us develop our services; to monitor how our website is being used; for marketing and communications purposes (as set forth below) to keep you informed of developments and new products; to identify issues with our website etc. that we need to fix. By providing us your Personal Data you indicate that you consent to allow us to process and maintain your Personal Data.
Most commonly, we will use your Personal Data in the following circumstances:
- CTI may collect information in conjunction with registration for programs and related services and to perform follow-up with its program registrants, as part of the registration process for CTI programs.
- Where we need to perform the contract we are about to enter into or have entered into with you to provide you with CTI services available to you.
- We may use your IP Address to help diagnose problems with our server, and to administer CTI's Site.
- Your IP Address may also be used to help identify you and to gather broad demographic information, some of which we may aggregate and then share with our partners.
- We may also use your IP address to track information you have seen on our Site.
- We may use your name, email address and mailing address to assist us in communicating with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- For Marketing as follows:
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will not supply your details to any company outside CTI for marketing purposes. Currently only we will contact you for marketing purposes. If in the future we ask a third party approved by us to contact you in order to fulfil the services we provide to you we will ensure that we have a GDPR agreement with that third party regarding the use of any data we supply them about you for the purposes of their contacting you.
If we mistakenly email an individual, the individual should use the opt out/ unsubscribe link at the bottom of every email, and inform us of our error at Marketing@coactive.com
Opting out of marketing messages
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at Marketing@coactive.com. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product/service purchase, registration, product/service experience or other transactions.
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
We will actively review the information we hold and when there is no longer a customer, legal or business need for us to hold it, we will either delete it securely or in some cases anonymise it.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
With whom do we share your information?
Although we use third parties to store and process data, we will not sell, share or rent personal information to others except in accordance with this Policy. We will share aggregated demographic information with our partners and advertisers. Such information is not linked to information that could identify any individual. We partner with third parties to provide specific services. When you sign up for services provided by a third party, we will disclose to the third party only the information that is necessary for the third party to provide these services.
We may also use outside shipping companies to ship orders and use a credit card processing company to bill users for goods and services. We will disclose to such third parties only the information that is necessary for the third party to provide these services.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
CTI takes great precautions to protect our users’ personal information. When users submit sensitive information via the Site, the information is protected both online and off-line through information that is encrypted and protected with a widely accepted industry standard encryption protocol - SSL.
In addition to using SSL encryption to protect sensitive information online, we protect users' information off-line. Access to all of our users' information, not just the sensitive information mentioned above, is restricted. Only employees who need the information to perform a specific job (for example, our billing clerk or a customer service representative) are granted access to personally identifiable information that others do not have access to. Furthermore, all employees are kept up-to-date on our security and privacy practices. Any time new policies are added, our employees are notified and/or reminded about the importance we place on privacy and what they can do to ensure that our users' information is protected.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach when we are legally required to do so.
How is your Personal Data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
- apply for our products or services;
- create an account on the Site;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
Automated technologies or interactions. As you interact with the Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies.
Our Use of Information from Third Parties
We may obtain information about you provided to us by third parties such as credit reporting agencies or strategic alliance partners in order to offer you their services and products, to improve our services, or to evaluate your eligibility for our services. However, we will not release personal information about you to them other than in aggregated, derivative form.
CTI's Site may provide you with links to other websites. We are not responsible for those sites and cannot control the use of information that you submit once you reach those sites, nor can we control the content of what is offered on those sites or on links from those sites.
We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
We may transfer your Personal Data outside the European Economic Area (EEA) but only to a country or territory that ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
Your legal rightsUnder certain circumstances, you have rights under data protection laws in relation to your Personal Data including to:
- Request access to your Personal Data.
- Request correction of your Personal Data.
- Request erasure of your Personal Data.
- Object to processing of your Personal Data.
- Request restriction of processing your Personal Data.
- Request transfer of your Personal Data.
- Right to withdraw consent.
- Requesting access to your Personal Data (commonly known as a “data subject access request”) enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Requesting correction of the Personal Data that we hold about you enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Requesting erasure of your Personal Data enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Objecting to processing of your Personal Data - You may object If processing your data impacts on your fundamental rights and freedoms. You also have the right to object when we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities when our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Requesting a restriction of processing of your Personal Data enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Requesting the transfer of your Personal Data to you or to a third party means we will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- You can withdraw your consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
Contact detailsOur full details are:
- Full name of legal entity: Kimsey-House Enterprises, Inc. dba The Coaches Training Institute (CTI)
- Name or title of Data Protection Specialist: Global Head of Technology
- Email address:
- Postal address:
- U.K. - 39-41 North Road, London, N7 9DP, United Kingdom
- Spain - Entença 94 Despacho 2, 08015 Barcelona, Spain
- U.S. - 2370 Kerner Blvd, Suite 370, San Rafael, CA 94901, U.S.A.
- Telephone Number: U.K. +44 (0)203 763 9445 ; Spain +34 932 80 86 87 ; U.S. +1 415-451-6000
You have the right to make a complaint at any time to your member state and to the the EDPS (European Data Protection Supervisor. The EDPS is the EU’s independent data protection authority - https://edps.europa.eu/data-protection/our-role-supervisor/complaints_en.
We would, however, appreciate the chance to deal with your concerns before you approach any authority so please contact us in the first instance.
If you fail to provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
No fee usually required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Third parties - External Third Parties
Service providers acting as processors based in the United States who provide IT, cloud-based software and system administration services.