Last Updated June 17, 2021
iPEC Perfect Creation, LLC d/b/a iPEC Coaching and its authorized licensees (“iPEC,” “we,” “us,” or “our”) offer certifications, training programs, retreats, and community events (together, “Programs”) that permit applicants to obtain a certification to become certified professional coaches or to simply further their personal development. We have also developed proprietary online assessments (including the Energy Leadership™ Index or ELI and the SCOPE assessment), which measure how an individual perceives and approaches work and life (together, “Assessments”). The ELI is available through an iPEC Certified Professional Coach and the SCOPE assessment is available on our mobile application (“App”) available for free download on mobile and/or tablet devices. The App processes the information you give us in much the same way as the Assessment available on our Site does.
1. INFORMATION WE COLLECT
In relation to your use of our Programs or the Assessments, or when you interact with us through our site, telephone, or otherwise, we collect information that alone or in combination with other information could be used to identify you (“Personal Data”) as follows:
Personal Data You Provide Us:
Request Information or Content. We collect Personal Data you voluntarily provide us when you request information, ask to download content (such as guides), call or email us directly, register for a webcast or other event. The data we collect typically includes your first and last name, email, phone number, country of location, and areas of interest.
Apply for Programs or Make Purchases. When you apply to our Programs or make purchases from us (this could be books, workbooks, client materials, etc.) we collect financial information including but not limited to credit card information that you provide to us.
Coach Community Forum; Other Public Areas of the Site. We may collect Personal Data disclosed by you on our coach community forum (including your username and password used to access the forum), blogs, and our other areas of the Site to which you can post information and materials. You should be aware that any information that you post in the coach community forum or other public area of the Site might be read, collected, and used by others who access it.
Information We Receive Automatically: When you visit, use, and interact with the Site or install, use, or interact with the App, we may receive and use certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit our Site or use the App, peak hours of visits, which page(s) are visited on our Site or the App, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access and visit our Site (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, Site navigation pattern. In particular, the following information is created and automatically logged in our systems:
- Log data: Information (“log data”) that your browser automatically sends whenever you visit the Site. Log data includes your Internet Protocol (“IP”) address (so we understand which country you are connecting from when you visit the Site), browser type and settings, the date and time of your request, and how you interacted with the Site.
- Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
- Usage Information: We collect information about how you use our Site or the App, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
Information We Collect Through Our Social Media Pages: We have pages on social media sites like Facebook, Twitter, and LinkedIn (“Social Media Sites”). When you interact with our pages on the Social Media Sites, we will collect Personal Data that you elect to provide to us through your settings on the Social Media Site, such as your contact details. In addition, the Social Media Sites providers may give us aggregate information and analytics data about the use of our social media pages. We are not responsible for the privacy practices of these Social Media Sites and any information you share with them is subject to their privacy policies and terms of service.
Information We Receive From an Assessment: In delivering an Assessment which is administered by one of our coaches, we may process certain personal data about users/coaches’ clients on behalf of coaches. For European Users, when we collect information on behalf of coaches we are doing so as a data processor (except when we engage directly with students to review the results of an Assessment or to provide training). We process this information pursuant to coaches’ instructions and subject to our agreements with them. If you are an individual who took an Assessment and have questions about how your Personal Data is processed by your coach, please contact that coach directly.
2. HOW WE USE INFORMATION
We use your Personal Data as necessary (i) to provide the services you have asked us to provide; (ii) for certain legitimate interests; (iii) as necessary to comply with applicable law; or (iv) with your consent, if required, as further described below.
We use the Personal Data that you provide when you inquire or apply to our Programs or other materials including the Assessment as necessary to enter into, or perform, a contract with you, including sending you materials, certifications, or other documents relevant to your purchase, or use of our Assessments, and communicating with you in connection with the foregoing, including by email, by phone, or by texting you.
We use Personal Data that you submit when you request information on the Site to respond to your request and as necessary for our legitimate interests in providing you the feedback that you are requesting.
We also use Personal Data as necessary for other legitimate business interests:
- To send administrative information to you, for example, information regarding our services, program offerings, changes to our terms, conditions, and policies, program evaluation and survey requests, including communicating with you in connection with the foregoing, including by email, by phone, or by texting you;
- For internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to prevent fraud, criminal activity, or misuses of our Site or the App and ensure the security of our IT systems, architecture and networks;
- In connection with recording your call with us (as described under the “Personal Data You Provide Us” section above), for training and quality control purposes, and to improve our services.
- To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or other third parties.
For information about what we mean by legitimate interests and the rights of individuals in the European Union (“EU”) and the United Kingdom ("UK"), please see the “European Users” section below.
Marketing. We may contact you to tell you about information we believe will be of interest to you, such as announcements, information about products and services, features, surveys, newsletters, promotions, contests, and upcoming events. If we do, where required by law, for example if you are in the EU or the UK, we will only send you marketing information if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving emails by following the instructions contained in each promotional email we send you or by contacting us as explained at the bottom of this Policy. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding our Site, the App and services and to respond to your requests.
3. SHARING AND DISCLOSURE OF INFORMATION
In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:
- Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with providers of hosting and other information technology services; customer and faculty support; developers and consultants; email communication software providers and email marketing, automation, and newsletter providers; electronic signature service providers; payment processors; web analytics and digital advertising services (for more details on the third parties that place cookies through the Site, please see the “Cookies” section below); database and sales/customer relationship management services; content delivery networks; customer support services. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us.
- Business Partners. Information collected is shared with our business partners (such as universities and other educational institutions) on an as needed basis. For example, if you elect to enroll in our Program at an educational institution, we may share your name with that institution for security purposes.
- Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
- Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or comply with legal process, including to meet national security or law enforcement requirements, (ii) protect and defend the rights or property of iPEC and its affiliates and subsidiaries, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Site, iPEC’s its affiliates and subsidiaries or the public, or (v) protect against legal liability.
4. DATA RETENTION
If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.
To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
5. UPDATE YOUR INFORMATION
If you need to change or correct your Personal Data, or wish to have it deleted from our systems, you may contact us at email@example.com. We will address your request as required by applicable law
6. CALIFORNIA PRIVACY RIGHTS DISCLOSURES
Third Party Marketing: California Civil Code Section § 1798.83 permits users of our Site or the App that are California residents to request the categories of Personal Data we disclosed to third parties for their direct marketing purposes in the year preceding the request, the names and addresses of such third parties, and, in certain circumstances, examples of the products or services marketed by such third parties. These requests may be made once per year. To make such a request, please email us at firstname.lastname@example.org or write us at:
iPEC Perfect Creation, LLC d/b/a iPEC Coaching
149 Avenue at the Common, Suite 202,
Shrewsbury, NJ 07702
Phone: +1 866.722.6224
Our Site is not directed to children who are under the age of 13. iPEC does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to iPEC through the Site please contact us at email@example.com and we will endeavor to delete that information from our databases.
9. EUROPEAN USERS
Scope. This section applies to individuals in the EU and in the United Kingdom (UK) (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, to the extent applicable, Switzerland).
We act as a data processor on behalf of our coaches for the processing of Personal Data provided by coaches’ clients when taking an Assessment. If you are a client of one of our coaches, please contact that coach to exercise the rights described below.
Your Rights. Pursuant to the European Union General Data Protection Regulation (or GDPR), you have the following rights in relation to your Personal Data, under certain circumstances:
- Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
- Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
- Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to data portability:You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that is processed by automated means. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
- Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
- If we are relying on a legitimate interest to process your Personal Data, unless we demonstrate compelling legitimate grounds for the processing or your data is needed to establish, exercise or defend legal claims;
- If we are processing your Personal Data for direct marketing. We may keep minimum information about you in a suppression list in order to ensure your choices are respected in the future and to comply with data protection laws (such processing is necessary for our and your legitimate interest in pursuing the purposes described above);
- Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your data before we received notice that you wished to withdraw consent.
- Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
Please see the “Contact Us” section below for information on how to exercise your rights.
Before July 16, 2020, we relied on our EU-U.S. Privacy Shield certification to transfer Personal Data that we receive from the EU and the UK to iPEC in the U.S. On July 16, 2020, the European Court of Justice ruled that the EU-U.S. Privacy Shield is no longer available for these data transfers. In light of this, iPEC no longer participates in the Privacy Shield. For data transfers from July 16, 2020 onwards we instead we rely on Standard Contractual Clauses approved by the European Commission to transfer Personal Data we receive from our EU-based authorized licensees. Transfers of your Personal Data to iPEC to the United States are also necessary to perform the agreement we have entered into, or are about to enter into, with you or otherwise in your interests. However, we will continue to protect all data transferred to us under the Privacy Shield before July 16, 2020 in accordance with the principles of the Privacy Shield.
10. LINKS TO OTHER SITES
Our Site, systems, apps, and services use physical, electronic, and managerial procedures to protect information collected online including firewalls to protect the loss, misuse, and alteration of information under our control. However, no method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee its absolute security.
13. SITE CONTENT
You may access, download, and print materials on this Site for your personal and non-commercial use. You may not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, create derivative works from, transfer, or sell any information, software, products or services obtained from our Site and systems without first obtaining written consent from iPEC. Furthermore, you may not use the materials found on the Site on any other websites or in a networked environment without first obtaining written consent from iPEC.
All materials on this site (as well as the organization and layout of the site) are owned and copyrighted by iPEC Coaching. © 2019 iPEC Coaching. All rights reserved. No reproduction, distribution, or transmission of the copyrighted materials at this site is permitted without the written permission of iPEC.
14. CONTACT US
149 Avenue at the Common, Suite 202,
Shrewsbury, NJ 07702
Phone: +1 866.722.6224
If you are an individual in the EEA or the UK, you can also contact DataRep, who has been appointed as iPEC Coaching’s representative in the EEA and the UK pursuant to Article 27 of the European Union General Data Protection Regulation on matters related to the processing of personal data that take place in the EEA and the UK. Please contact DataRep as follows:
Austria: DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria
Belgium: DataRep, Place de L'Université 16, Louvain-La-Neuve, Waals Brabant, 1348, Belgium
Bulgaria: DataRep, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria
Croatia: DataRep, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia
Cyprus: DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus
Czech Republic: DataRep, IQ Ostrava Ground floor, 28. rijna 3346/91, Ostrava-mesto, Moravska, Ostrava, Czech Republic
Denmark: DataRep, Lautruphøj 1-3, Ballerup, 2750, Denmark
Estonia: DataRep, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia
Finland: DataRep, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland
France: DataRep, 72 rue de Lessard, Rouen, 76100, France
Germany: DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany
Greece: DataRep, 24 Lagoumitzi str, Athens, 17671, Greece
Hungary: DataRep, President Centre, Kálmán Imre utca 1, Budapest, 1054, Hungary
Iceland: DataRep, Kalkofnsvegur 2, 101 Reykjavík, Iceland
Ireland: DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland
Italy: DataRep, Viale Giorgio Ribotta 11, Piano 1, Rome, Lazio, 00144, Italy
Latvia: DataRep, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia
Liechtenstein: DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria
Lithuania: DataRep, 44A Gedimino Avenue, 01110 Vilnius, Lithuania
Luxembourg: DataRep, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg
Malta: DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta
Netherlands: DataRep, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands
Norway: DataRep, C.J. Hambros Plass 2c, Oslo, 0164, Norway
Poland: DataRep, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland
Portugal: DataRep, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal
Romania: DataRep, 15 Piaţa Charles de Gaulle, nr. 1-T, Bucureşti, Sectorul 1, 011857, Romania
Slovakia: DataRep, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia
Slovenia: DataRep, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia
Spain: DataRep, Calle de Manzanares 4, Madrid, 28005, Spain
Sweden: DataRep, S:t Johannesgatan 2, 4th floor, Malmo, SE - 211 46, Sweden
United Kingdom: DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom