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Privacy Policy

Puregain Privacy Policy.

The act of business coaching can be deeply personal.  It commonly involves sharing intimate details of what people are dealing with, what their ambitions are, details about business and personal financial situations, what problems arise in business, and much more.

We know full well that the expectation of privacy in a coaching relationship is essential.  It is vital to the foundation of trust between coach and client that is so often necessary to do meaningful work in a business coaching relationship.

 As such we recognize that, for Puregain the documentation of the coaching process, we need to have the utmost respect for privacy, 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.

The Information We Collect, and How We Use It

User Account Information

This is the stuff of "who's who" in our system.

The information collected is, at minimum, name, username, email address, business address, telephone number including mobile and office numbers, and a for the Puregain Accountability Centre a profile password.

How We Use Account Information

All user information is used exclusively for delivery of Puregain Business Coaching and documentation on the Puregain Accountability Centre.  Specifically, this includes:

  1. Proper identification and authentication to access the PAC system based on login credentials (username and password).
  2. PAC profile display of user activity (e.g. a name & head shot of who posted a comment).
  3. Sending emails (including system-generated notifications, messages to and from system users, and messages).
  4. Generation of gender specific language (e.g. using "his" or "her" rather than "their").
  5. Management and processing of coaching payments for Puregain coaching services.

All data is used solely for internal communications between Puregain Business Coaching the PAC and its clients. And that's it.  We do not and never have shared your data outside to a third party, with the EXCEPTION of your name, telephone number and business address to register you as a guest at any hotel used for the Puregain Business Retreat after you have confirmed your attendance.

Usage Data when in the PAC

This is automatically collected log information, including AND limited to:

  1. Records of log in activity (who logged in, when, which browser, and from what IP address)
  2. 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)

How We Use Usage Data

The information gathered during all communications with, and visits to Puregain website and the PAC portal is used exclusively by Puregain for the purposes of business coaching, aiding in support, troubleshooting, advising and business performance improvement. 

Coaching Data

This is the details of your relationship with Puregain. "Coaching Data" encompasses anything that Puregain can set up during the course of coaching and also using the PAC to support, document, or communicate our coaching relationship, including but not limited to: Action items, Metrics and data, Worksheets, Session Notes, Journal Entries, File uploads, links and embedded media, email, Whats app, Whiteboards, Appointments and calendar data feeds, Templates, Courses, Other PAC and website settings.

How We Use Coaching Data

We capture and store coaching data via the PAC and direct email, for the purpose of making it accessible to authorized users, including but not limited to:

Data that can be accessed in the PAC portal by the user who entered it.

Data that can be accessed other users who should see it (e.g. Action items set up by coach for a client, or Session Notes for a client that were not marked private).

Data delivered by email as initiated by user action (e.g. a progress report set to send weekly to a designated email recipient).

Appointment data privately made available for calendar system interchange.

Your Rights

You have the right to be forgotten by Puregain and deleted from Puregain records and the Puregain Accountable Centre.  We are able to delete any and all client data within our system at any time.  Upon request we will be happy to delete client accounts, provided the request comes from a suitably authorized person.

You have the right to correct your data stored with Puregain and the PAC. 

The only exception is retroactive modification of the record of appointments.  This is for the sake of having a largely immutable record, to benefit both parties with regard to common coaching engagement terms.

You have the right to know what data is processed about you by Puregain an d all this data is available in your PAC profile.  Reading this very privacy policy grants you this right.

You have the right of portability of your data stored by The Puregain Accountability Centre.  If you want to get your data out of the PAC. These rights are mandated by the GDPR for citizens of the European Union,

Data Storage and Security

The Puregain Accountability Centre owns the code, databases, and all rights to the portal. You retain all rights to your data. The PAC use third party vendors to provide hosting, necessary hardware, software, networking, storage, and related technology.

To protect the security of personal information submitted to us, the Pac portal 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 PAC via the internet are encrypted using TLS encryption.

Where you have chosen a password that enables you to access your profile, 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 your My Account page.

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 and 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.

Office based storage of Name Telephone, email, address for the issuing invoices and accounting and coaching communications.

Data Sharing

While we are the primary custodian and caretaker for your data as entered in to Puregain and Puregain Accountability Centre, 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 which these services may include:

Providing our hosting server infrastructure, providing website visitor analytics, sending email & SMS communications. These third-party companies are subject to strict data processing terms and are prohibited from using your data for any purpose other than as they have been specifically contracted for.

Things We DON'T Do

We are proud to charge for our service actual real money by which we can run our business.  You (and your data) are NOT the product.

As such, to put your mind to rest, here are some things we DON'T do:

We don't sell your data, We don't sell/rent/give your email to other parties for the purpose of marketing to you (or for anything else), We don't use your data for research, machine learning, underhanded social engineering experiments.

 

Disclosure Under Legal Necessity

The information we collect is not shared with, rented or sold to others except under the following circumstances: 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 Puregain.

If Puregain is acquired by or merged with another company. In this event, we will notify you via email, in-system alerts and/or with prominent notices on the PAC before information about you is transferred and becomes subject to a different privacy policy.

Children

The Site and the Services are not directed to children nor persons under the age of 18, and Puregain does not knowingly collect or use any information from children nor persons under the age of 18.

Puregain Accountabilty Centre Privacy Shield

The PAC servers are located in the United States, so your usage of The PAC profile means your information will be transferred to and stored there and participates in and has certified its compliance with both the EU-U.S. and Swiss-U.S. Privacy Shield Framework.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks and is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. We are responsible for the processing of Personal Information we receive under each Privacy Shield Framework and subsequent transfers to service provider third parties. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

Addressing Concerns and Complaints

In compliance we commit to resolve complaints about our collection or use of your personal information. If you have inquiries or complaints regarding our Privacy policy or handling of your data in general, please first contact us directly:

Courtney Wilding. Owner and Founder cwilding@puregain.co.uk.

Data Protection Authority

If you are a citizen of the European Union and believe we maintain your personal data subject to the General Data Protection Regulation (GDPR), you may direct questions or complaints to the UK's Information Commissioner's Office:

https://ico.org.uk/about-the-ico/

Changes to this Policy

Puregain 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 and PAC notifications at least 30 days prior to the implementation of the changes.

Contact Us

If you have any questions, concerns or complaints about our Privacy Policy please email us at swilding@puregain.co.uk.