COGNACTION PRIVACY POLICY

The act of coaching is deeply personal. It often involves sharing intimate details of what clients are dealing with, what their goals are, what obtacles arise, and much more.

We know full well that the expectation of confidentiality and privacy are essential to coaching success. The foundation of trust between coach and client is critical for the coaching relationship to lead to transformational results of the client.

As such, at cognaction, we have the utmost respect for privacy of clients, and treat all data with care according to rigorous standards of confidentiality and security.

This Privacy Policy outlines what information we collect, how we use it, your rights, and our practices around that information.

1. THE INFORMATION WE COLLECT, AND HOW WE USE IT

All of the information we collect in Cognaction is in one of three varieties.

1.1 USER ACCOUNT INFORMATION

This information is focused on users of our site: coaches who sign up, clients who sign up for our newsletters, or to take part in our group or individual coaching services.

The information collected is, at minimum, name, username, email address, and a password. In terms of passwords, we only store a garbled up version of passwords through one-way hashing, which does not enable us to view real passwords.

Additional user account information that CAN be optionally entered and store includes:
Address
Telephone number(s)
Time zone
Avatar image
Gender

1.2 HOW WE USE ACCOUNT INFORMATION

All user information is used exclusively for delivery the cognaction coaching services. Specifically, this includes:
Proper identification and authentication to access the system based on login credentials (username and password).
In-app display of user activity (e.g. a name & head shot of who posted a comment).
Sending emails (including system-generated notifications, messages to and from system users, and messages from CA staff to system users).
Conversion of times (e.g. “Sent on:” dates) to a user’s time zone.
Generation of gender specific language (e.g. using “his” or “her” rather than “their”).
Management and processing of subscription payments for cognaction services.

1.3 USAGE DATA

This is automatically collected log information, including AND limited to:
Records of log in activity (who logged in, when, which browser, and from what IP address)
Records of in-app activity (who issued what request to the server in the course of using the application, when, and the CPU run time of processing the request)
Records of visits to the public facing marketing website and blog.

1.4 HOW WE USE USAGE DATA

This information is used exclusively by Cognaction staff and exclusively for the purposes of aiding in support, troubleshooting, debugging, and performance tuning.

1.5 COACHING DATA

We use Coachable to manage our coaching relationships. See more information about CoachAccountable Privacy Policies HERE.

2. YOUR RIGHTS

You have the right to have all your information deleted from our site. Upon request Cognaction will be happy to delete coach accounts, provided the request comes from a suitably authorized party and the request doesn’t interfere with the rights of others.

You have the right of portability of your data stored by Cognaction. HTML Client Export Files, downloadable reports, and a collective of all account data in JSON each allow you to download all your data from the cognaction site. These rights are mandated by the GDPR for citizens of the European Union, but Cognaction is proud to extend these rights to everyone. We have done so in full effect since day one of our business.

3. DATA STORAGE AND SECURITY

Cognaction owns the code, databases, and all rights to the cognaction website. You retain all rights to your data. We use third party vendors to provide hosting, necessary hardware, software, financial processing, networking, storage, and related technology.

To protect the security of personal information submitted to us, Cognaction follows generally accepted industry standards both during transmission and after the information is received. All information you provide to us is stored on secure servers. All exchanges between you and the website via the internet are encrypted using TLS encryption.

Where you have chosen a password that enables you to access your account within the website you are responsible for keeping this password confidential. If you choose to share your password, i.e. with a virtual assistant, you do so at your own risk. You may change your password at any time by going to the login page and use the “Forgot password” function.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. We strive to use rigorously secure means to protect your personal information. However, we cannot guarantee its absolute security. CoachAccountable has no liability for disclosure of your information, whether due to errors, unauthorized and improper acts, or otherwise.

If a security breach causes an unauthorized intrusion into our system that materially affects you or your clients, then we will notify you as soon as possible and later report the action we took in response.

4. DATA SHARING WITH SERVICE PROVIDERS

While we are the primary custodian and caretaker for your data as entered in to Cognaction, there are a few companies who will be handling certain parts of your data as a matter of course for us to provide the service. These companies are authorized to use your personal information only as necessary to provide these services to us, to which these services may include:
Providing our hosting server infrastructure
Payment processing
Providing customer service
Providing website visitor analytics
Sending email communications
These third party companies are subject to strict data processing terms and are prohibited from using you data for any purpose other than as they have been specifically contracted for.

5. THINGS WE DON’T DO

We are proud of the coaching and training services we provide. As such, you (and your data) are NOT the product. As such:
We don’t sell your data
We don’t sell/rent/give your email to other parties for any purpose
We don’t use your data to serve you ads

6. DISCLOSURE UNDER LEGAL NECESSITY

The information we collect is not shared with, rented or sold to others except under the following circumstances:
In order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Cognaction’s Terms of Service, or as otherwise required by law.
To comply with a governmental entity request or with any legal proceeding or process, or if we believe in good faith that such release is necessary in order to protect the rights, property or safety of Cognaction, our users or other third parties.
If Cognaction is acquired by or merged with another company. In this event, Cognaction will notify you via email, in-system alerts and/or with prominent notices on the Cognaction website before information about you is transferred and becomes subject to a different privacy policy.

7. CHILDREN

The Site and the Services are not directed to children under the age of 14, and Cognaction does not knowingly collect or use any information from children under the age of 14.

If you know of or have reason to believe anyone under the age of 14 has provided us with any personal data, please contact us. If we learn that Cognaction has collected information from a child under the age of 14 we will delete that information as quickly as possible.

8. ADDRESSING CONCERNS AND COMPLAINTS

Cognaction commits to resolve complaints about our collection or use of your personal information. If you have inquiries or complaints regarding our handling of your data in general, please first contact us directly:

Mrim Boutla, Founder and CEO, [email protected].

We’ll proudly do what we can to get the matter sorted promptly.

9. CHANGES TO THIS POLICY

Cognaction reserves the right to modify or update this Policy at any time. If we make significant changes to this Policy, we will notify you via email, at least 30 days prior to the implementation of the changes.

10. CONTACT US

If you have any questions, concerns or complaints about our Privacy Policy, please email our Founder at [email protected].