Business Solutions for Growth, LLC dba Cohen Coaching
Effective Date: May 25th, 2018
This Policy is subject to change by Business Solutions for Growth, LLC (referred to throughout this Policy as “we”, “our” and “us”) at any time and at our discretion without notice by updating this posting. By using this website, you accept the terms and privacy practices contained in this Policy.
We understand the importance that Internet users place on privacy, and this Policy describes how we use personal information that is collected at our website.
Please read this Policy before using this website or submitting any personal information. California residents, please also see the “Note to California Residents” Section for additional rights that apply to you.
We take children’s privacy very seriously. This website should only be accessed by persons eighteen (18) years or older. Due to the age restrictions of this website, none of the information obtained by this website falls within the Child Online Privacy Act (COPA). However, if your minor child has provided us with personally identifiable information, you may contact us if you want this information deleted from our records. We will then remove your child’s information from the database that stores the information.
With the exception of your account information and other information we collect in connection with your registration or authentication into our Services, this Policy does not apply to our security and privacy practices in connection with your access to and use of the Services. These security and privacy practices, including how we protect, collect, and use electronic data, text, messages, communications or other materials that you submit to us and that are stored within the Services, are detailed in and governed by other applicable agreements relating to your access to and use of such Services.
Subscribers to our Services (“Subscribers”) are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals with whom our Subscribers interact. We collect information under the direction of our Subscribers and have no direct relationship with individuals whose personal information we process in connection with our Subscriber’s use of our Services. If you are an individual who interacts with one of our Subscribers, please contact our Subscriber directly for assistance with any requests or questions relating to your personal information.
We may transfer personal information to companies that help us provide our Services.
THE TYPE OF INFORMATION WE COLLECT FROM YOU
Like most places on the Internet, simply by visiting our website you automatically tell us certain information. This includes basic information such as your IP address, when you visited, the website from where you came prior to visiting us, the website where you go when you leave our website, your computer’s operating system, and the type of web browser that you are using. Our website automatically records this basic information about you and stores it in log files.
We combine this automatically collected log information with other information we collect about you. We do this to offer special discounts and to improve marketing, analytics, and website functionality.
Technologies such as: cookies, beacons, tags, and scripts are used by us and our marketing, advertising and support partners. These technologies are used in analyzing trends, administering the website, tracking users’ movements around the website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
We may also collect any data that you provide us when you post it at our website (through our Contact Us page) or by email (such as your name and email address). You can always choose not to provide us with information. However, if you do choose not to provide certain information, we may deny you access to some or all of our website’s services and features.
Any information you provide on our website order forms is collected by our payment processing service providers on their servers. That information is then shared with us. This information includes ordering information such as shipping and billing names and addresses, phone numbers, email address, and credit card information (See “Orders and Use of Personal Information” below). We use this information primarily to fulfill customer orders and requests. We do not share this information with any third parties. However, we may disclose personal information collected if we have received your permission beforehand or in very special circumstances, such as when we believe that such disclosure is required by law or other special cases described below.
Emails or newsletters that we send electronically may use techniques such as web beacons or pixel tags to gather email metrics and information to improve the reader’s experience, such as the number of emails that are opened, whether they were forwarded or printed, the type of device from which they were opened, and the location (e.g. city and state) associated with the applicable IP address.
ORDERS AND USE OF PERSONAL INFORMATION
If you purchase a product or service from us, we request certain personal information from you on our order form. You must provide contact information (such as name, email, and shipping address) and financial information (such as credit card information and expiration date). We use this information for billing purposes and to fill your orders. If we have trouble processing an order, we will use this information to contact you.
By submitting your email address on this website, you agree to receive email from us. You can cancel your participation in any of these email lists at any time by clicking the opt-out link or other unsubscribe option that is included in the respective email. We only send emails to people who have authorized us to contact them, either directly, or through a third party. We do not send unsolicited commercial emails, because we hate spam as much as you do.
By submitting your email address, you also agree to allow us to use your email address for custom audience targeting on sites like Facebook, where we display custom advertising to specific people who have opted-in to receive communications from us.
In addition, you agree that by submitting your telephone contact information on this website and/or registering to receive the products and/or services offered herein, such act constitutes a purchase, an inquiry, and/or an application for the purposes of the Amended Telemarketing Sales Rule (ATSR), 16 CFR Part 310 et seq. and any applicable state and local “do not call” regulations. We retain the right to contact you via telemarketing in accordance with the ATSR and the applicable state regulations.
We ask for and may collect personal information such as your name, address, phone number and email address when you register for or attend a sponsored event or other events at which we participate.
WHAT WE DO WITH YOUR INFORMATION
We may use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to (a) provide, operate, maintain, improve, and promote the Services; (b) enable you to access and use the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners. You can opt-out of receiving marketing communications from us by contacting us at info@CohenCoaching.com or following the unsubscribe instructions included in our marketing communications; (f) monitor and analyze trends, usage, and activities in connection with the website and Services and for marketing or advertising purposes; (g) investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities; (h) personalize the website and Services, including by providing features or advertisements that match your interests and preferences; and (i) for other purposes for which we obtain your consent.
As a general rule, we will not share, sell, rent or trade your data with third parties without your permission. However, there are some important exceptions to this rule that are described in the following paragraphs.
We may, in our sole discretion, provide information about you as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or other legal process for purposes of fraud investigations, alleged intellectual property infringement, or any other suspected illegal activity or matters that may expose us to legal liability.
Although we do not disclose individually identifiable information, we may disclose aggregate data about our website’s visitors to advertisers or other third parties for marketing and promotional purposes.
We share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of our website, application development, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.
If we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, your personal information will likely be among the assets transferred. You will be notified via email and/or prominent notice on our website for 30 days of any such change in ownership or control of your personal information.
BEHAVIORAL TARGETING / RE-TARGETING
HOW LONG WE RETAIN YOUR PERSONAL INFORMATION:
ACCESS TO PERSONAL INFORMATION
Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at info@CohenCoaching.com. Subscribers to our Services may update or change their account information by editing their profile or organization record or by contacting info@CohenCoaching.com for more detailed instructions. To make a request to have personal information maintained by us returned to you or removed, please email info@CohenCoaching.com. Requests to access, change, or remove your information will be handled within thirty (30) days.
An individual who seeks access to personal information, or who seeks to amend or delete personal information stored or processed by us on behalf of one of our Subscribers, should direct his/her query to the Subscriber. Upon receipt of a request from one of our Subscribers for us to remove or amend the data, we will respond to their request within thirty (30) days. We will retain personal information that we store and process on behalf of our Subscribers for as long as needed to provide the Services to our Subscribers. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you are a Subscriber or otherwise provide us with personal information in connection with your use of our website or Services, we will delete this information upon your request, provided that, notwithstanding such request, this information may be retained for as long as you maintain an account for our Services, or as needed to provide you with our Services, comply with our legal obligations, resolve disputes and enforce our agreements.
We provide you the opportunity to opt-out from any promotional, marketing, or informational emails that we may send you. You may do so by following the instructions included in each communication or by emailing us at info@CohenCoaching.com.
The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
When you enter sensitive information (such as a credit card number) on order forms that are hosted by our PCI compliant third-party service providers, the transmission of that information is encrypted using secure socket layer technology (SSL).
If you have any questions about the security of your personal information, you can contact us at info@CohenCoaching.com.
We use Google Analytics Advertiser Features to optimize our business. Advertiser features include:
- Remarketing with Google Analytics
- Google Display Network Impression Reporting
- DoubleClick Platform Integrations
- Google Analytics Demographics and Interest Reporting
By enabling these Google Analytics Display features, we are required to notify our website visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to gather data about your activities on our website. Among other uses, this allows us to contact you if you begin to fill out our check-out form but abandon it before completion, with an email reminding you to complete your order. The “Remarketing” feature allows us to reach people who previously visited our website and match the right audience with the right advertising message.
As advertisers on Facebook and through our Facebook page, we (not Facebook) may collect content or information from a Facebook user and such information may be used in the same manner specified in this Policy. You consent to our collection of such information.
We abide by Facebook’s Data Use Restrictions.
- Any ad data collected, received or derived from our Facebook ads (“Facebook advertising data”) is only shared with someone acting on our behalf, such as our service provider. We are responsible for ensuring that our service providers protect any Facebook advertising data or any other information obtained from us, limit our use of all of that information, and keep it confidential and secure.
- We do not use Facebook advertising data for any purpose (including retargeting, commingling data across multiple advertisers’ campaigns, or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis (unless authorized by Facebook) and only to assess the performance and effectiveness of our Facebook advertising campaigns.
- We do not use Facebook advertising data, including the targeting criteria for a Facebook ad, to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer or device.
- We do not transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad network, ad exchange, data broker or other advertising or monetization related service.
LINKS TO OTHER SITES
Our website contains links to other sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites.
We encourage you to be aware when you leave our website and to read the privacy policies of each and every website that collects personal information.
This Policy applies only to information collected by our website.
We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at info@CohenCoaching.com.
CHILDREN’S PRIVACY STATEMENT
This children’s privacy statement explains our practices with respect to the online collection and use of personal information from children under the age of thirteen and provides important information regarding their rights under federal law with respect to such information.
- This website is not directed to children under the age of thirteen and we do NOT knowingly collect personally identifiable information from children under the age of thirteen as part of the website. We screen users who wish to provide personal information in order to prevent users under the age of thirteen from providing such information. If we become aware that we have inadvertently received personally identifiable information from a user under the age of thirteen as part of the website, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of thirteen as part of the website.
- Because we do not collect any personally identifiable information from children under the age of thirteen as part of the website, we also do NOT knowingly distribute such information to third parties.
- We do NOT knowingly allow children under the age of thirteen to publicly post or otherwise distribute personally identifiable contact information through the website.
- Because we do not collect any personally identifiable information from children under the age of thirteen as part of the website, we do NOT condition the participation of a child under thirteen in the website’s online activities on providing personally identifiable information.
FAIR INFORMATION PRACTICES
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
To comply with the Fair Information Practices Principles we will take the following responsive action, should a data breach occur:
We will notify you via email within 30 business days.
We also agree with the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- Send information and respond to inquiries
- Process orders and to send information and updates pertaining to orders.
- Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To comply with CAN-SPAM, we agree to the following:
- Not use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or website headquarters.
- Monitor third-party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email and we will promptly remove you from Select or ALL correspondence.
Additional Rights for EEA and Certain Other Territories:
If you are from certain territories (such as the EEA), you may have the right to exercise additional rights available to you under applicable laws, including:
- Right of erasure: In certain circumstances, you may have a broader right to erasure of personal information that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
- Right to object to processing: You may have the right to request that we stop processing your personal information and/or to stop sending you marketing communications.
- Right to restrict processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is inaccurate or unlawfully held).
- Right to data portability: In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance.
If you would like to exercise such rights, please contact us at info@CohenCoaching.com. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. A list of contact details for the EU data protection authorities is available here.
LEGAL BASIS FOR PROCESSING (EEA ONLY):
If you are an individual from the European Economic Area (EEA), our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: (a) we have your consent to do so, (b) where we need the personal information to perform a contract with you (e.g. to deliver the Services you have requested), or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on your consent before its withdrawal.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our (or a third party’s) legitimate interests which are not already described in this notice, we will make clear to you at the relevant time what those legitimate interests are.
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.
INTERNATIONAL TRANSFER OF INFORMATION COLLECTED
Business Solutions for Growth, LLC is a U.S.-based company. We primarily store personal information about our website visitors and Subscribers within the United States. To facilitate our global operations, we transfer and access such personal information from around the world, including from other countries in which Business Solutions for Growth has operations, for the purposes described in this Policy. We may also transfer your personal information to our third party subprocessors, who may be located in a different country than you. Such countries may have laws that are different, and potentially not as protective, as the laws of your own country.
Whenever Business Solutions for Growth transfers personal information originating in the European Economic Area (EEA) it will do so on the basis of the EU standard contractual clauses.
If you are visiting our website from the EEA or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which we operate. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.
NOTE TO CALIFORNIA RESIDENTS
If you live in the State of California, under the California Civil Code you have the right to request that companies who conduct business in California provide you with a list of all third parties to which the company has disclosed Personal Information during the preceding year for direct marketing purposes.
If you are a California resident and want to request information about how to exercise your third-party disclosure choices, you must send a request with a preference on how our response to your request should be sent (email or postal mail).
All requests sent via regular mail must be labeled “Your California Privacy Rights” on the envelope or post card and clearly stated on the actual request. For all requests, please include your name, street address, city, state, and zip code. Please include your zip code for our own record keeping.
We do not accept requests via telephone or by facsimile. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
We may update this Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Any questions or concerns about this policy should be brought to our attention by contacting us at the following email, telephone number or mailing address, and providing us with information relating to your concern.
Telephone Number: +1 (602) 399-7430
Business Solutions for Growth, LLC
3928 E. Beverly Road
Phoenix, AZ 85042