Privacy Policy
Last updated May 26, 2023
At Lyndsay Bray Coaching Group, ("Company," "we," "us," or "our'') value and respect your privacy and are committed to protecting your personal data. This privacy notice describes how and why we might collect, store, use, and/or disclose ("process") your information or personal data when you use our coaching/consulting services and website ("Services" or "platform"), such as when you:
Visit our website Lyndsay Bray Coaching Group, or any website or platform of ours that links to this privacy notice
Engage with us in other related ways, including any sales, marketing, or events
We value transparency and strive to provide a safe and respectful coaching environment for our clients. We collect, use and share data from coaches providing services on our platform, users of our platform, entities that contract on behalf of users of our platform, and visitors to our website.
Definitions
This Privacy Policy is relevant to the Site, Services, and platform and explains how our practices affect applicants, site visitors, coaches, users, and user organizations. The following terms are defined:
Lyndsay Bray Coaching Group is a coaching, consulting, and leadership development group for coaches and consultants to provide services and business development for individuals and organization groups including but not limited to individual and group coaching/consulting, custom training programs, design and development of leadership & management programs through a variety of techniques and methods on our mobile application and online platform (the “platform”).
Users refer to people who receive our services directly through the platform.
User Organizations are entities that contract with us to provide services to their employees or others on the platform.
Coaches are business coaches who typically contract with us to provide services to Users via the platform.
Visitors are individuals who access our website www.lyndsaybray.com (the “Site”).
Applicants are individuals who apply for a job with Lyndsay Bray Coaching Group.
Personal Data refers to data associated with an identified or identifiable natural person and is protected as personal information (or substantially equivalent terms) under applicable data protection laws.
Data From Our Website
As a visitor to our public website, we collect certain information. We use cookies and similar technologies (e.g., web beacons, pixels, and ad tags) to collect data (e.g., device IDs) from our public Site to recognize you and your device(s) on, off, and across different services and devices where you have engaged with our Site. We also allow third parties to use cookies as described in our Cookie Policy. We may also collect (or rely on others who collect) data about your device where you have not engaged with our Site (e.g., ad ID, IP address, operating system and browser data) so we can provide our Visitors with a better user experience. You can opt-out of our use of data from cookies and similar technologies that track your behavior on the sites of others for ad targeting and other ad-related purposes. Please review the Cookie Policy for all relevant details.
Data From Applicants
If you apply for a job (“Applicant”) with Lyndsay Bray Coaching Group, we collect certain personal information from you to process your application, such as your name, email address, phone number, location, and work history. This information is used to evaluate your experience and communicate with you. We work with third-party vendors to assist in the application process, and where those systems have access to your personal information, we will provide the appropriate disclosures. If any of these systems require highly sensitive personal information or request session recordings, you will be notified at that time. If you are an EU Applicant, please review the Notice for EU Candidates which includes information about what personal information we collect, how we collect, use and disclose that information and the legal grounds for us doing this, and your rights in respect of your personal information.
Data Collected from Coaches:
As a Coach for the Lyndsay Bray Coaching Group, we may collect data when you reach out to us to provide coaching services, use the platform, request technical support, or initiate communication with us. We never require sensitive personal data such as financial information, but we may ask for demographic or personal data for testing new tools or features, staffing specific programs, or conducting research studies. This data may include gender, race, ethnicity, specialized skills such as ASL, or for federal programs, your citizenship. Providing this personal information is optional, and we will ask for your consent to record your coaching session for training, research, or other purposes. We may capture data such as your image, voice, or transcript of the recording to conduct analysis for the betterment of our members and your future coaching sessions. We understand that video recordings may contain sensitive personal information, and we will take precautions to minimize the amount of personal data accessed by analyzing the recordings after de-identification or analyzing the transcript rather than the full video. We may also ask you to provide data to improve your experience on the platform, such as reviewing your coaching and platform experience or personal preferences within your coach profile, including preferred pronouns and language. Your decision to provide personal data has no impact on your role as a coach, and you may withdraw your consent at any time by emailing support@lyndsaybray.com.
Data Collected from Users:
As a User on the Lyndsay Bray Coaching Group platform, we collect data when you register and access our services. We require certain personal data to create your account, such as your name, email address, phone number, role or title, country, and state. We need this data to create your account, match you with a coach in the appropriate time zone, and ensure we have minimum location data to respect your specific privacy rights. We may also ask you to provide data to improve your experience on the platform, such as completing surveys or assessments to match you with a coach that aligns with your coaching goals, reviewing your coaching and platform experience, or personal preferences within your user or coach profile. To facilitate a meaningful coaching experience, you and your coach will have access to your matching survey and assessment responses, while reviews or opinions will only be shared with a coach on an aggregated or de-identified basis. We also collect usage data from users accessing the platform, such as which programs you attend, your session ratings, employment details, and any other usage data you share with us. We may provide individually identifiable data regarding your registration date, number of coaching sessions completed, and dates of completed assessments to your sponsoring organization, but we will never provide details about specific coaching sessions or individual topics discussed. We may also provide aggregated and de-identified insights on topics and themes discussed by all users associated with your sponsoring organization. If you register through a license purchased by a user organization, the organization may provide us with certain demographic data about you or share employment data via HRIS integration or third-party systems. If you have concerns about this data collection, please speak with your program manager or contact at your user organization. We may also collect aggregated and de-identified data related to your use of the platform to analyze your usage and improve our services.
Audio & Video Data
We may record coaching sessions on the platform with the express consent of both Coach and User (each a “Recording”). If you have consented to a Recording, it will be used to inform analyses on the quality and effectiveness of your coaching session.
The session recording may be used in the following ways:
• Analysis of aggregate call statistics such as number of speakers turns
• Text analysis including full transcript, key words, themes, and sentiment of words
• Audio analysis
• Video analysis including facial expressions and body language
We have developed software to view and analyze these sessions and derive insights from them in a deidentified manner to improve your experience and our platform and Services. When Lyndsay Bray Coaching Group uses the term “de-identified,” we understand this is useful as a data minimization technique and included within this term is a commitment not to re-identify the data unless necessary to provide Service to You.
Lyndsay Bray Coaching Group is constantly looking for ways to improve our services and occasionally in our pursuit of the best tools to provide the analysis we need to serve our Users, we may use third-party vendors to assist with analyzing this data. When working with third-party vendors, Lyndsay Bray Coaching Group will only provide data in a deidentified manner and will ensure that your data remains confidential to your experience with Lyndsay Bray Coaching Group.
Lyndsay Bray Coaching Group requires all third-party vendors to certify in contract that they will never sell data and will maintain strict privacy and security controls for all data they may have access to as a result of working with Lyndsay Bray Coaching Group.
The session recordings will be securely stored in our data center in the United States, and our employees can access them on a need-to-know basis only. Session recordings will never be shared with your User Organization. Your sponsoring User Organization will never receive access to your individual recording, although they may see aggregate and de-identified analysis of all Users connected to your sponsoring Organization so long as our data scientists can confirm a minimum threshold of Users from your organization to maintain anonymity.
Personal Health Information
Lyndsay Bray Coaching Group's Services do not collect any Personal Health Information as defined under the Health Insurance Portability and Accountability Act (“HIPAA”), and the use of our Services does not require HIPAA compliance. Additionally, Lyndsay Bray Coaching Group is not considered a Covered Entity under HIPAA. Lyndsay Bray Coaching Group acknowledges and understands the definition of health information is more expansive under GDPR and other privacy regulations, to include general well-being and any data relating to a person’s physical or mental health; therefore, handles all health information as sensitive and has implemented additional security and confidentiality protocols for all health-related information.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@lyndsaybray.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Lyndsay Bray Coaching Group and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process under the Personal Information Provided by You section.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when with whom we share your personal information below.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what Lyndsay Bray Coaching Group does with any information we collect? Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
names
phone numbers
email addresses
mailing addresses
job titles
usernames
passwords
contact preferences
contact or authentication data
billing addresses
debit/credit card numbers
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
health data
financial data
Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Stripe via the CA platform. You may find their privacy notice link(s) here: https://www.coachaccountable.com/privacy.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
INFORMATION AUTOMATICALLY COLLECTED
In Short: Some information - such as your Internet Protocol (IP) address and/or browser and device characteristics - is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons and communicating with next of kin
If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
If the collection is solely for journalistic, artistic, or literary purposes
If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:
Website Hosting Service Providers
User Account Registration & Authentication Services
Performance Monitoring Tools
Finance & Accounting Tools
Data Storage Service Providers
Data Analytics Services
Communication & Collaboration Tools
Affiliate Marketing Programs
We also may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.
We want to make it clear that Lyndsay Bray Coaching Group does not use cookies within our Platform. However, cookies and similar technologies are used on our public website, lyndsaybray.com, and are disclosed within our Cookie Policy.
In order to provide specific functionality within our Platform, there is a limited use of tracking technology as disclosed within our Cookie Policy. Lyndsay Bray Coaching Group will not request specific geo-location data from our Users. Users can manage their Cookie preferences within their User Profile on the Platform.
Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than twelve (12) months past the termination of the user's account.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@lyndsaybray.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
ACCOUNT INFORMATION
If you would at any time like to review or change the information in your account or terminate your account, you can:
Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services. For further information, please see our Cookie Policy.
If you have questions or comments about your privacy rights, you may email us at support@lyndsaybray.com.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA PRIVACY NOTICE
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We will/have collected the following categories of personal information in the past twelve (12) months:
Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
Collected: YESPersonal information categories listed in the California Records statute
Name, contact information, education, employment, employment history, and financial information
Collected: YESProtected classification under California or federal law
Gender and date of birth
Collected: NOCommercial information
Transaction information, purchase history, financial details, and payment information
Collected: YESBiometric information
Fingerprints and voiceprints
Collected: NOInternet or other similar network activity
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements
Collected: NOGeolocation data
Device location
Collected: YESAudio, electronic, visual, thermal, olfactory, or similar information
Images and audio, video or call recordings created in connection with our business activities
Collected: NOProfessional or employment-related information
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us
Collected: YESEducation Information
Student records and directory information
Collected: NOInferences drawn from other personal information
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics
Collected: NOSensitive Personal Information
Account login information, contents of email or text messages, debit or credit card numbers and health data
Collected: YES
We will use and retain the collected personal information as needed to provide the Services or for:
Category A - As long as the user has an account with us
Category B - As long as the user has an account with us
Category D - As long as the user has an account with us
Category G - As long as the user has an account with us
Category I - As long as the user has an account with us
Category L - As long as the user has an account with us
Category G - we collect data from Site Visitors such as data about your device and location via IP address, the type of browser you use, amount of time you spend on the Site, pages viewed, forms submitted, and the digital channel that brought you to the Site. If you access the Site via a mobile device or have downloaded our mobile application, we may collect data such as the first time the mobile application is opened, mobile carrier, and the type of device being used.
Category L - information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
Lyndsay Bray Coaching Group collects and shares your personal information through:
Targeting cookies/Marketing cookies
More information about our data collection and sharing practices can be found in this privacy notice and our Cookie Policy.
You may contact us by email at support@lyndsaybray.com, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" your personal information.
Lyndsay Bray Coaching Group has not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Lyndsay Bray Coaching Group has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?".
Your rights with respect to your personal data
Right to request deletion of the data - Request to delete personal data
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed - Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell or share personal information to third parties;
the categories of personal information that we sold, shared, or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
the business or commercial purpose for collecting, selling, or sharing personal information; and
the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
If the business collects any of the following:
social security information, drivers' licenses, state ID cards, passport numbers
account login information
credit card numbers, financial account information, or credentials allowing access to such accounts
precise geolocation
racial or ethnic origin, religious or philosophical beliefs, union membership
the contents of email and text, unless the business is the intended recipient of the communication
genetic data, biometric data, and health data
data concerning sexual orientation and sex life
you have the right to direct that business to limit its use of your sensitive personal information to that use which is necessary to perform the Services.
Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other purpose unless you provide consent for the use or disclosure of sensitive personal information for additional purposes.
Please note that sensitive personal information that is collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as the publicly available information.
To exercise your right to limit use and disclosure of sensitive personal information, please email support@lyndsaybray.com or submit a data subject access request.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us by email at support@lyndsaybray.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.
VIRGINIA CDPA PRIVACY NOTICE
Under the Virginia Consumer Data Protection Act (CDPA):
"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.
"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.
"Sale of personal data" means the exchange of personal data for monetary consideration.
If this definition "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.
The information we collect, use, and disclose about you will vary depending on how you interact with Lyndsay Bray Coaching Group and our Services. To find out more, please visit the sections above:
Personal data we collect
How we use your personal data
When and with whom we share your personal data
Your rights with respect to your personal data
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
Lyndsay Bray Coaching Group has not sold any personal data to third parties for business or commercial purposes. Lyndsay Bray Coaching Group will not sell personal data in the future belonging to website visitors, users, and other consumers.
Exercise your rights provided under the Virginia CDPA
More information about our data collection and sharing practices can be found in this privacy notice and our Cookie Policy.
You may contact us by email at support@lyndsaybray.com, by submitting a data subject access request, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at support@lyndsaybray.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible.
If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at support@lyndsaybray.com or contact us by post at:
Lyndsay Bray Coaching Group
6515 Minola Street
Houston, TX 77007
United States
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please send an email or post with the subject ‘Data Subject Access Request’.
EFFECTIVE DATE AND UPDATES
This Privacy Policy is effective as of May 25, 2023 and supersedes all prior versions. We may update this Privacy Policy from time to time by posting a new version on our website. Your continued use of our coaching services and website after any such update constitutes your acceptance of the updated Privacy Policy.