At CoachLab Limited (“CoachLab”, “we”, “us”,“our”), we are committed to protecting your Personal Information and ensuring compliance with the New Zealand Privacy Act 2020 (Privacy Act) (if you are in New Zealand) and the European Union’s General Data Protection Regulation (GDPR) (if you are in a Member State of the European Union).
What is Personal Information
Personal Information means any information relating to an identified or identifiable natural person.
Your informed consent
If you wish to ‘opt-out’ of receiving certain communications from us or your Personal Information being provided to third parties for direct marketing purposes, then you should notify us or unsubscribe from our mailing list by clicking ‘unsubscribe’ at the bottom of our communications to you. If you decide to do so, then we will only communicate with you to the extent necessary to perform our obligations to you, such as to complete our transaction with you or where we are required to do so by law.
You can otherwise contact us at any time by clicking “Contact Us” on our Website.
For the purpose of:
- The GDPR, the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
- The Privacy Act, your Personal Information will only be used for the purpose for which it was collected in accordance with this Privacy Statement and the law. If that purpose no longer exists or your Personal Information is no longer needed for the purpose in which it was collected, then we will no longer use your Personal Information.
The “data controller” (for the purpose of the GDPR) and the “agency” (for the purpose of the Privacy Act 2020) that is responsible for your information is CoahLab Limited (NZCN 8235015), based in New Zealand.
Information that is collected and processed
The table below outlines the 4 general categories of information that we collect for processing and the legal basis on which that information is processed:
|Category||Types of Personal Information collected||Legal Basis for Processing|
|Information you provide us
You may choose to provide us with Personal Information when you communicate with us or create an account on the Platform.
|Example: when you make enquiries, when you opt-in to receive our marketing & promotional materials or when you create an account on the Platform.||
||We collect and process this information based on our legitimate interest to respond to your requests or queries, to provide you with a high level services on the Site, to market and promote the Site to you, and to fulfil our contractual obligations to you.|
|Information that is necessary for your use of the Site
We ask for and collect Personal Information when you use our Site.
|Example: when you sign up or register as a user of the Platform and use our Site.||
||We collect and process this information based on our legitimate interest to respond to your requests or queries, for assessment and acceptance purposes, for example, to confirm and verify your identity, administrative purposes such as due diligence and screening against publicly available government and/or law enforcement agency sanctions lists, to provide you with a high level of customer service, and to fulfil our contractual obligations to you. Without the information, we may not be able to provide you with our services.|
We collect and process this information based on our legitimate interest to conduct system administration and report aggregate information to our affiliates, business partners and/or other parties to conduct Site analysis and Website performance review
to ensure a positive user experience, performance of our contractual obligations to you, to provide and improve the functionalities of our Site and improve our services.
Enhancing the user experience and improving the quality of our services, processes and technology.
|Information we collect from third parties We may collect information that others provide about you or obtain information from other sources (including our third party service providers) and combine that information we collect through our Site.||Example: when you link, connect or login to our Site from a third party service (eg Google, Facebook etc), and when other parties provide us with information, including data to help improve user experience and to detect fraud and Site security issues.||
||We collect and process this information based on legitimate interest in ensuring a positive user experience, ensuring the security of our Site and the safety of our customers and, where necessary, to communicate with you.|
In addition to those that are outlined in the table, we will also collect and process information where you give us your informed consent.
How the information is used and disclosed
With your consent, we will collect, use and disclose your Personal Information for the following purposes:
to provide you with our services, including to:
- identify and verify your identity;
- communicate with you, such as sending you promotional emails about new products and services, special offers, promotions
- update, secure, and troubleshoot our Site as well as providing support;
- share information, when it is required to provide our products and service;
- improve and develop our products and services;
- personalise the services and make recommendations to you;
- respond to your queries regarding the Site, or our products and services;
- provide you with a positive user experience when you visit our Site, or use our services;
- to collect Fee that you owe, including authorising and processing credit card transactions or undertaking credit checks (if necessary);
- develop new services, features and/or content; and
- keep you updated on things that are happening at CoachLab;
- to run and maintain our Site such as ensuring our Site and network system are secure;
- for our internal record keeping purposes;
- to allow for the operation of our legitimate business activities and functions;
- the sale of all or substantially all of our business (whether by assets or shares);
- to comply with our legal obligations; and
- for any other purposes you consent to.
From time-to-time CoachLab may remove personal identifiers from your Personal Information and maintain it in an aggregate form. We may combine this information with other information that we hold to produce anonymous, aggregated statistical information to form part of our services or our marketing. Aggregate information may be shared with third parties and used in connection with our business function. Once your Personal Information is anonymised, it may no longer be capable of identifying, or being re-linked, to you.
Cookies help us provide you with a better Site and user experience by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the information you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.
If you decline cookies, this may prevent you from taking full advantage of functionality and services available on our Site.
Transfer of information to other countries
In order for you to use our Site and to provide you with our products and services, we may need to disclose and transfer your Personal Information to third parties located outside New Zealand. We will take reasonable steps to ensure that the overseas recipient is required to protect your Personal Information in a way that, overall, provides comparable safeguards to those under New Zealand privacy laws. Examples of such steps include a written agreement between us and the recipient, or making reasonable enquiries regarding the data protection standards of the country in which the recipient is domiciled in.
If you are in a Member State of the European Union, your Personal Information may be transferred to or stored in a geographic region that imposes different privacy obligations than the country you are currently in. We will only transfer your Personal Information to a “secure third country”, such as New Zealand, or to a third country or international organisation where appropriate safeguards are provided in accordance with the GDPR.
Controlling your Personal Information
You can choose to restrict the collection or use of your Personal Information in the following ways:
- Indicate to us in writing that you do not wish to be contacted for direct marketing purposes. If you have told us, then you have opted-out of receiving electronic marketing communications from us.
- If you have previously agreed to us using your Personal Information for direct marketing purposes, you can change your mind at any time by letting us know you no longer wish for your Personal Information to be used for direct marketing purposes by contacting us using the contact details listed above or unsubscribing from our mailing list by clicking ‘unsubscribe’ at the bottom of our electronic communications.
We will not sell, distribute or lease your Personal Information to third parties unless we have your consent, or we are required by law to do so.
Links to other websitess
How you can request access or correction of your information
If you wish to request correction of your Personal Information that we hold, please login to your account on our Site to make changes. If you do not have an account with us, then contact us using the contact details listed above.
We will correct your Personal Information if it is necessary to ensure that your Personal Information is accurate, up to date, complete and not misleading. If we decide that it is unnecessary to correct your Personal Information, we will let you know the legal reasons for our decision. If you are not happy with those reasons, then you have the right to complain to the New Zealand Privacy Commissioner: www.privacy.org.nz/your-rights/how-to-complain/.
If you wish to request access to your Personal Information that we hold, contact us using the contact details listed above. You have the right to request access to Personal Information that we hold about you. If we do not give you access to the Personal Information that you have requested, then we will let you know the legal reasons for not disclosing your Personal Information. If you are not happy with the legal reasons provided, then you have the right to complain to the New Zealand Privacy Commissioner: www.privacy.org.nz/your-rights/how-to-complain/.
If you are in New Zealand and you think that your privacy rights have been interfered with, you can make a written complaint to our Privacy Officer by email to Support@coachlab.live or otherwise contact the NZ Privacy Commissioner at https://www.privacy.org.nz/your-rights/making-a-complaint/complaint-form/.
If you are in a Member State of the European Union, you have the following rights with respect to your Personal Information:
- Lodging complaints: You have the right to lodge a complaint with a ‘supervisory authority’ established by a Member State under Article 51 of the GDPR.
- Right of rectification: You have the right to obtain from us without undue delay the rectification of inaccurate Personal Information. We may seek to verify the accuracy of the Personal Information before correcting it.
Right to restrict processing: You have the right to limit the ways in which we use your Personal Information, in particular where:
- you contest the accuracy of your Personal Information;
- the processing is unlawful and you oppose the erasure of your Personal Information;
- we no longer need your Personal Information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or
- you have objected to the processing of your Personal Information pending the verification by a supervisory authority of whether our legitimate grounds to process override your own.
- Right of access and portability: You have the right to request certain copies of your Personal Information held by us. You may also be entitled to request copies of Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider nominated by you (where technically feasible).
Right to be forgotten: You have the right to request the erasure of your Personal Information without undue delay where one of the grounds set out in Article 17(1) of the GDPR apply. Please note that:
- we may retain some of your Personal Information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety;
- we may retain and use your Personal Information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting, auditing and regulatory compliance obligations; and
- because we maintain our Site to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may not be able to be removed from our backup systems.
Your California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at the physical address or email address included below.