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CoachHub Privacy Notice Last update: 19 June 2024
CoachHub is committed to transparent data protection practices in accordance with the following principles and in compliance with applicable data protection laws, in particular the EU General Data Protection Regulation.
This Privacy Policy applies to your use of the CoachHub website (“Site”) and social media. It applies to you when you visit our Site, when you sign up to receive our newsletter, when you apply for one of our job offers, if you (or your employer) are likely to be interested in our services and generally when you interact with us.
Please note that this Privacy Policy does not apply to our digital coaching platform and services. Please contact us for details.
The controller of your personal data within the meaning of the General Data Protection Regulation (GDPR) and other data protection regulations is:
CoachHub GmbH Alexanderstraße 36, 10179 Berlin Germany +49 30 23321151 privacy@coachhub.com
We have designated a data protection officer, who you can contact for all requests and questions concerning your personal data:
DataCo GmbH Nymphenburger Str. 86 80636 Munich Germany datenschutz@dataguard.de
+49 89 7400 45840 www.dataguard.de
As a matter of principle, we only process personal data of our users insofar as this is necessary for the provision of a functional website as well as our contents and services.
We process your personal data for the following purposes:
• Provision of Site and creation of log files: each time our Site is accessed, our system automatically collects data and relevant information from the computer system of the calling device.
○ Categories of personal data processed: your navigation data. This data includes:
◘ Information about the browser type and the version used ◘ Operating system ◘ Internet service provider ◘ IP address ◘ Date and time of access ◘ Websites from which your system accesses the Site ◘ Websites that your system accesses via our Site
○ Source of data: data we automatically collect. ○ Purpose: The temporary storage of the IP address by the system is necessary to enable delivery of the website to your computer. For this purpose, your IP address must remain stored for the duration of the session. The storage in log files is done to ensure the functionality of the Site. An evaluation of the data for marketing purposes does not take place in this context. ○ Legal basis: our legitimate interest in making our Site and its functionalities accessible. ○ Data retention period: The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the Site, this is the case when the respective session has ended. In the event that the data is stored in log files, this shall be the case after seven days at the latest. Storage beyond this, e.g. for fraud prevention, is possible. In this case, the IP addresses of the users are deleted or alienated so that an assignment of the calling client is no longer possible.
• Sending you our newsletter: we may offer you (e.g., upon downloading an ebook or other resources from our website) to subscribe to our newsletter free of charge. If you choose to register for the newsletter, the data from the input mask is transmitted to us.
○ Categories of personal data processed:
◘ Email address ◘ Name ◘ First name ◘ IP address of the accessing computer ◘ Date and time of registration
○ Source of data: data you provide us with. ○ Purpose: The collection of your email address serves to deliver the newsletter. The collection of other personal data during the registration process serves to prevent misuse of the services or the email address used. ○ Legal basis: your consent. If you provide us with your email address, we will first send you a confirmation email. Please activate the link in the email in order to be included in the newsletter distribution list. ○ Data retention period: We will send you our newsletter until you unsubscribe through your account (if any) or through the unsubscribe link provided in each newsletter, or if no account is associated with the email address used for newsletter subscription, 3 years after your last interaction (click) with a newsletter The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. The user’s email address is therefore stored as long as the subscription to the newsletter is active. The other personal data collected during the registration process is usually deleted after a period of seven days.
• Newsletter performance: if you choose to register for our newsletter, we will analyze our newsletter performance by collecting usage data.
◘ Clicks/open rate ◘ Name ◘ First name ◘ Email address ◘ Device used ◘ “Unsubscribe” requests
○ Source of data: data provided automatically when you interact with our newsletter. ○ Purpose: analyzing the performance of our newsletter. ○ Legal basis: our legitimate interest in analyzing the performance of our newsletter in order to improve it. ○ Data retention period: 6 months
• Processing your requests: you can contact us, including to book a demo, by phone, email or by using the contact form available on our Site.
○ Categories of personal data processed: contact information and content of the request. If you use the contact form on the Site, we collect the following data:
◘ Email address ◘ Name ◘ First name ◘ Telephone / mobile phone number ◘ IP address of the calling computer ◘ Date and time of contact ◘ Company name
○ Source of data: data you provide us with. ○ Purpose: The processing of the personal data from the input mask or email serves us solely to process the contact. The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems. ○ Legal basis: our legitimate interest in responding to your queries. If your request aims at the conclusion of a contract, this will be the legal basis for the processing of your personal data. ○ Data retention period: the data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input mask of the contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation is ended when the circumstances indicate that the matter in question has been conclusively clarified. The additional personal data collected during the sending process is deleted after a period of seven days at the latest.
• Conversion tracking: In order to better align our Google Ads ad impressions of potential customers and actual conversions of prospects to customers on our websites, we use Google Enhanced Conversions for the Web and offline conversion imports using Google Click ID (GCLID) from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).
○ Google Enhanced Conversions for the Web: This is done with the help of so-called conversion tracking tags via Google Tag Manager. Tags are “measurement codes and associated code fragments” that can communicate with the Tag Manager servers and can be configured via a web-based user interface, the Google Tag Manager. A cookie is not set for this purpose.
If you, as a customer, go from one of our advertisements to our websites and order a product there, we receive your data directly, including your email address.
Your email address is used by us as a so-called identifier and is recorded in the conversion tracking tags, hashed and transmitted to Google in this hashed form (called SHA256). Google uses this data to associate your actions and purchases on our website with your Google account, provided that you have registered an account with Google and logged into it when you clicked on an ad. We have no influence on the further use of the data and the scope of the data that Google collects.
You can give your consent to Google Enhanced Conversions in our Cookies Settings. You can revoke this consent at any time with effect for the future by deactivating Google Enhanced Conversions in our cookie banner.
More information about Google Enhanced Conversions for the Web can be found at the following link : https://support.google.com/google-ads/answer/9888656?hl=en
○ Offline conversion imports using Google Click ID (GCLID): This is done to see what happens in the offline world after signing up using a form from Hubspot using the GCLID (Google Click Identifier). This lets us capture the GCLID (Google Click Identifier) parameter that’s appended to the URL that you click through from one of our ads or forms.
After CoachHub creates a conversion event in HubSpot, lifecycle stage data from you engaging with our ads and forms will be synced with our Google Ads account. You must have a value populated for the Google ad click id contact property, which represents your Google Click Identifier (GCLID). Conversions uploaded more than 90 days after the associated last click won’t be imported by Google Ads and will therefore not show up in our conversion statistics.
You can give your consent to Google offline conversion imports using Google Click ID (GCLID) by accepting this CoachHub Privacy Notice.
More information about Google offline conversion imports using Google Click ID (GCLID) can be found at the following link: https://support.google.com/google-ads/answer/7012522?hl=en&sjid=8803374091021053466-EU
We use this information to improve our measurement of the conversion of prospects to customers on our websites. This is done by tracking actions that take place on our websites, as well as Google’s attribution of the submitted data.
The processing of your personal data is based on consent pursuant Art. 6 para. 1 s. 1, lit. a GDPR.
General information on data protection at Google can be found at the following link: https://policies.google.com/privacy.
• Commercial prospection and networking: we may collect and use data about you identified as professional, from your profiles (a) public from a professional social network you use and (b) private if we are linked on these networks. This data may also be publicly accessible and/or communicated by partners, third parties or service providers in the context of business relationships or data supply.
○ Categories of personal data processed: identification data (title, last name, first name), contact details (email address, profile), data on professional life (job title, name of the employer). ○ Source of data: data we collect indirectly as described above. ○ Purpose: marketing purposes. ○ Legal basis: our legitimate interest in promoting and developing our business. ○ Data retention period: we retain your data until during 3 years from the end of the commercial relationship, if you are a customer, or from the collection of your data or the last contact from you, if you are a prospect.
• Social media management: our company presence in social networks is used for communication and information exchange with (potential) customers. In particular, we use the company presence to present CoachHub and its services. The publications on such social networks may contain the following content: information about services, customer contact, company news. Each user is free to publish personal data through activities on the relevant social network. The data generated by the company website is not stored in our own systems. If you carry out an action on one of our social media (e.g. comments, posts, likes, etc.), you may make personal data (e.g. real name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by the relevant social network, the company jointly responsible for the CoachHub GmbH corporate presence, we cannot provide any binding information on the purpose and scope of the processing of your data. Please refer to the social network’s own privacy policy for additional information on the processing of your personal data in this respect:
◘ Instagram: https://help.instagram.com/519522125107875 Join Controllership Agreement: https://www.facebook.com/legal/controller_addendum ◘ Facebook: https://www.facebook.com/CoachHubIO ◘ Linkedin: https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv Join Controllership Addendum https://legal.linkedin.com/pages-joint-controller-addendum Independent Controller ◘ X: https://twitter.com/de/privacy
• Processing your applications: you can apply for our job offers by sending us an email or by using the dedicated form available on our Site. After sending your application, you will receive confirmation of receipt of your application documents from us by email.
○ Categories of personal data processed: if you use the application form on the Site, we will collect the following data:
◘ Title ◘ First name ◘ Surname ◘ Telephone / mobile number ◘ Email address ◘ Salary expectation ◘ Curriculum vitae ◘ Availability as of, location
Alternatively, you can also send us your application by email. In this case, we will collect your email address and the data you provide in the email.
After sending your application, we will send you an email confirming receipt of your application documents. ○ Source of data: data you provide us with. ○ Purpose: The processing of personal data from the application form is solely for the purpose of processing your application. The other personal data processed during the submission process serve to prevent misuse of the application form and to ensure the security of our information technology systems. ○ Legal basis:
◘ The processing of your application is necessary to take steps at your request prior to entering into a contract. ◘ Where we are required by law to verify the existence of a work permit for a foreign applicant, we base the processing on a legal obligation. ◘ To keep the CV of an unsuccessful candidate in our CV library, we rely on the candidate’s consent.
○ Data retention period: after completion of the application procedure, the data will be stored for up to six months. Your data will be deleted after six months at the latest. In the event of a legal obligation, the data will be stored within the framework of the applicable provisions.
Please note that your data may be kept for a longer period of time, for example in order to establish proof of a right or to comply with a legal obligation. In any case, your data is not kept beyond what is strictly necessary for the purposes for which it is processed. When your data is no longer required, we will ensure that it is deleted or anonymized.
Our services are not designed for or intended for minors. We do not knowingly solicit or collect personal data from minors. Persons under the age of 18 may not do business with CoachHub. If we discover that we have collected information about a minor, we will delete it. Please contact us using the contact information above if you believe you have provided us with information about a minor.
We share your personal data only with:
• our duly authorized personnel, who need to access to your data in the course of their duties in connection with the purposes described above; • our service providers who act as data processors, essentially:
○ For applicants’ personal data: Workday; ○ For personal data collected via emails sign ups from demo requests, event sign ups, ebook downloads, newsletter: Hubspot and Salesforce; ○ For webinar registrations: Hubspot, Salesforce and Goldcast; ○ For commercial prospection and networking: Hubspot, Salesforce and Outreach; ○ Hosting provider: Amazon Web Services. our external advisors (lawyers, auditors, etc.); public or judicial authorities, if we are legally required to do so or to protect our rights or the rights of third parties.
We may also share your personal data with third parties in connection with a potential or actual sale or restructuring of our company or certain of our assets, in which case your data may be one of the transferred assets.
We store your personal data in the European Union. Our website is hosted on AWS EU datacenters.
However, your data may be transferred outside the European Union when it is transferred to processors located outside the European Union. Where applicable, we undertake in the absence of an adequacy decision by the European Commission under Article 45 of the GDPR, to frame such a transfer with appropriate transfer mechanisms under Article 46 et seq. of the GDPR (such as standard contractual clauses adopted by the European Commission). You will be able to obtain a copy of these (excluding confidential provisions) at any time by contacting us at the contact details set out at the beginning of this Privacy Policy.
You benefit from certain rights under applicable data protection laws:
• You may withdraw your consent to any processing of your data based on your consent at any time. • You may ask us to confirm whether we are processing your data and, if so, to inform you of the characteristics of the processing, to allow you to access it and obtain a copy. • You may ask us to correct or complete your data if it is incorrect or incomplete. • You may ask us to delete your data or to limit the processing of your data. • You may ask us to provide your data in a structured, commonly used and machine-readable format, or you may request that it be transmitted directly to another data controller. • If you reside in France, you have the right to set out (general or specific) instructions about what to do with your data after your death. • You may object to any processing of your data that is based on our “legitimate interest”. If you exercise this right, we must cease processing your data unless we demonstrate imperative and legitimate grounds that override your fundamental rights and freedoms, or for the establishment, exercise or defense of legal claims. • You may object at any time to the processing of your data for commercial prospecting purposes.
For more information about your rights, to exercise them or for any question or complaint about the protection of your personal data, you can contact us or our data protection officer at the contact details mentioned at the beginning of this Privacy Policy.
You also have the right to lodge a complaint with the competent supervisory authority regarding the processing of your data.
We may amend this Privacy Policy from time to time, including to comply with any legislative or regulatory, case law, editorial or technical advances. We will notify you of any material changes.