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SOCCER COACHING SOLUTIONS

Express Coaching Limited (trading as CoachFX)
Privacy Policy January 2020

This policy explains how we process personal data within our global businesses delivering software, content and consulting services, including how it affects our websites: www.coachfx.com, www.coachfxlive.com and our iOS app CoachFXGO.

1.0 Who We Are

We are Express Coaching Limited. We represent the global online coaching business trading under the name CoachFX, CoachFXLive and CoachFXGO. Express Coaching Limited is committed to keeping your information secure and managing it in accordance with our legal responsibilities, under the privacy and data protection laws applicable wherever we operate in the world, as well as the General Data Protection Regulation (Regulation (EC) 2016/679 (“GDPR”) in the European Union (“EU”). We keep this Privacy Policy under regular review and update it from time to time. This policy was last updated in January 2019. Please review this policy periodically for any changes.

2.0 Who This Policy Applies To

We provide software and online coaching services to a range of clients throughout the world. Details of our services can be found elsewhere on this website or those listed above. This policy applies to you whether you are a user of our software, subscriber to our coaching content or a coach belonging to an organization that has signed you up to our services. Additionally, this policy will apply to you if you attend one of our events or have subscribed to receive information about our services or any of our marketing materials.

3.0 Gathering Information

Our users and clients expect us to provide the best service possible therefore we collect personal data in the following ways:

3.1 Directly - If you subscribe to any of our CoachFX products and services directly, or contact our sales or customer support we need to collect your name, billing address and email address to validate your subscription(s) or enquiry. This information has never been and never will be disclosed to third parties without your explicit consent.

3.2 Indirectly – If you are a member of an organization which has subscribed their members with any of our CoachFX products or services we need to collect your name and email address to validate your subscription(s). We will never contact you directly until you activate your subscription. This information has never been and never will be disclosed to third parties without your explicit consent.

3.3 Automatically – To optimize our online services we collect and store functional data and usage data such as the type of content you view to ensure that content presented to you is tailored to your viewing preferences.

4.0 Data Exchange

We want to outline here the various scenarios where there is an exchange of data between you and CoachFX’s products and services:

4.1 First Contact - If you want to get information about CoachFX, you either visit one of our websites, see us on social media, are introduced via an organization you are a member of or you meet us at an event for example. You may voluntarily provide us with personally identifiable information. These include, for example, your first and last name or your e-mail address. In addition, we may also collect information for statistical purposes through cookies or similar technologies. Data collected – First name, last name, club name, e-mail address as well as anonymous information passed on via cookies or similar technologies. Reason for collecting data - We use the data collected in order to be able to present you product news from CoachFX as quickly as possible and to inform you about upcoming events or other innovations at CoachFX. We use the additional, anonymous information that we have received through cookies or similar technologies in order to optimize our websites for all visitors. It is therefore in our legitimate interest to use your personal data for these purposes.

4.2 Purchasing Products or Services - Once you have decided to purchase a chargeable CoachFX product, resource or service, you can successfully complete your purchase either through the CoachFX website. For this we need data from you to complete your purchase. Data collected – first name, last name, country, street, house number, postal code, city, country, telephone, e-mail address, and payment information. Reason for collecting data - We use this data to complete your order, to check if there are any questions, to ask if you were satisfied with your purchase or to resolve any other issues related to your purchased CoachFX product. The processing of the collected data is necessary at this point in order to fulfill the agreement you have entered into.

4.3 Subscribed by Member Organization - You may have been given access to CoachFX products and services by an organization you are a member of for example a club, member association, league, national governing body etc. In order to validate your benefit provided by this member organization we need to collect your name and email address from the member organization to establish your account on the CoachFX website. This ensures that when you enter your email address and password you have been provided with, your account has access to the content the member organization has requested for you. Data collected – first name, last name, club or organization you are a member of and email address. Reason for collecting data – to validate your account and ensure you get access to the content your member organization has provided for you.

4.4 Registration - To use the CoachFX products or services you need to either register or validate your registration. Upon registration, you will need to enter your e-mail address and your first and last name and password of your choice. The password is used in this context only for authentication and for clear access to your CoachFX account. Upon registration, we assign your account a unique numerical identification number to identify your CoachFX account without direct reference to your person. This unique number is linked to the email address you provided when registering. Data collected – first name, last name, email address and password. This password cannot be recovered by anyone within Express Coaching Limited. Reason for collecting data – this data is collected to ensure you have access to the functionality and content you should do and prevents any unauthorized access. Additionally, we may have to communicate directly with you to provide you with updates on our products and services. It is therefore in our legitimate interest to use your personal data for these purposes.

4.5 Using Products and Services - Once you have registered and have access to the CoachFX product or service we want to ensure you have an optimal experience therefore we collect functional data to ensure you have the best experience. Data collected – registration data is collected (as above) to validate your account, functional data such as the category of content you access and the type of device you are using eg iOS, device type etc.). Reason for collecting data - this data is collected to optimize your experience of our CoachFX products or services. This is necessary to fulfill the contract you have entered into. In addition, we collect this data to perform product improvements, which is our legitimate interest.

4.6 Support - At any point in the process whether it be prior to registering or whilst you are registered for any CoachFX product or service you may contact us with a question either technical or sales related about one of our CoachFX products or services. Data collected – This includes, but is not limited to your e-mail address, name, telephone number, content of your request, and any documents submitted about your problem. In part, it helps our team to access diagnostic data. You can optionally submit these together with your request to us. This includes information such as your browser, your operating system, your app version, and your installed third-party apps. Reason for collecting data - we only collect this data in order to offer you the best possible support. For technical problems or general customer inquiries we use your contact details in order to get in touch with you about your question. In the case of technical problems, we need your additional information about the system in order to be able to help you immediately and effectively. The use of this data is necessary to fulfill the contract you have entered into.

4.7 Additional Note on Payment Information - Please note that we do not store any payment or credit card information from you. We do not even use the payment information you have entered. This information is only used by our payment service provider for the purchase of CoachFX product or service.

5.0 Sharing of Your Data

5.1 Third party - At times we use third parties to provide certain services on our behalf such as website management, hosting payment processing and email marketing services. We will only share information with these third parties to ensure you are provided with the best possible service that has been agreed to by you. These are the only examples of when we would disclose your personal information to third parties or their agents but this is only done under our direction, in compliance with data protection laws and in line with this privacy policy. The use of this data is necessary to fulfill the contract you have entered into.

5.2 Possible forced disclosure - We must disclose your personal information if we are required to do so by law or if it is absolutely necessary to carry out our service. We also need to disclose your personal information if it is absolutely necessary to protect our rights or our users. In this case, your data may be disclosed to law enforcement agencies, law enforcement agencies or legal proceedings.

5.3 Sale or merger of CoachFX - In the event of a merger, sale or acquisition (all or part of our assets), we will disclose your personal information. Of course, we will inform you about your rights in such a case in good time via our website.

6.0 Personal Data Use, Security, Storage and Rights

6.1 Data use - In the majority of cases, the use of your personal data is necessary in order to fulfill the contract you have entered into or your member organization has entered into. For example, to complete your registration, manage your CoachFX account, assist with any queries, or complete the purchase of a CoachFX product. We also need to be able to perform basic functions safely to fulfill your contract. You have explicitly consented to the additional use of your personal information. In part, we also use your personal information when we pursue our legitimate interests. We refer to our legitimate interest when analyzing and optimizing our CoachFX products and services, our content on our websites and apps. We also refer to our legitimate interest to send you information on updates or information on CoachFX products and services. We also refer to our legitimate interest to use your data for fraud detection or for administrative or legal concerns.

6.2 Data security - Our goal is to make the protection of your personal data as safe as possible. We use SSL technology for the transmission of personal data. This means that all personal data from our server will be encrypted and transmitted to you. It is basically impossible for other people to read your data during the transmission. We point out, however, that data transmission over the internet can have security gaps. Complete protection of data against access by third parties can never be 100% guaranteed. Your password is always stored as a one-way hash function, so it cannot be viewed or recovered by anyone, not even an Express Coaching Limited employee (it can only be reset by an employee in exceptional cases).
In order to gain access to your CoachFX account and our services, you must log in to your CoachFX account with your username and password. You are required to ensure the confidentiality of your information, to keep your password secret and never to disclose it to third parties. Please inform us immediately if you think your password has been misused. Please also make sure that you always log out to complete your session completely. Please never give your password to third parties. We will never ask for your password.
If you have any questions about the security of your personal data, please contact us by e-mail at support@coachfx.com.

6.3 Storage - We use many technical and organizational measures to protect your personal information. For example, we store the personal information collected on restricted access systems located on controlled servers. Of course, we ensure that the third-party vendors we engage in their data centers implement appropriate security measures to maximize the protection of your information. Your data will be stored at our partner, the Paragon Internet Group (trading as Tsohost), United Kingdom and are therefore subject to the highest European standards. When storing your personal data, we are bound by certain guidelines. As long as you use our products and services, we must keep your personal information. Likewise, we are bound by applicable laws, especially regarding the storage of documents / invoices. We also retain your personal information in order to resolve disputes with other parties and for any other purpose that allows us to conduct our business. Of course, all personal information we hold is subject to this Privacy Policy. If you would like to know specifically how long we would keep certain personal information of you, please send us an e-mail to support@coachfx.com.

6.4 Your data rights - You can obtain information about your stored data at any time free of charge and without disclosing the reason. If you have an active account with CoachFX you can access your personal information directly by logging on to your account. If you do not have an active account you can email us at support@coachfx.com and we will provide you with this information. You may inform us at any time if your personal information has changed at any time. You may also request the deletion of your personal information in certain situations. Please email us at support@coachfx.com for any of these requests. In certain circumstances we have been provided with your personal data by an organization you are a member of. You can also at any time revoke the consent given to us for use of your data without giving reasons. You also have the right to refuse the use of your personal information at any time if the use is based on a legitimate interest. Because we rely on the accuracy and timeliness of your personal information, please contact us directly if your personal information changes. Just let us know your changes via email to the following address: support@coachfx.com. We will endeavor to answer your request as soon as possible however the latest will be 30 days. We are committed to finding a solution to your request or complaint however if we cannot help you with your complaint, you can also file your complaint or problem with the data protection authority of your country or your supervisory authority. However, we will do everything we can to avoid this in advance.

6.5 Email marketing - Of course, you may object to receiving direct mail from CoachFX. For this you can simply click on the “Unsubscribe” link at the end of the e-mail.

7.0 Use of Cookies and Similar Technology

7.1 Cookies - A cookie is a small file that is loaded onto your device and that enables CoachFX features. For example, we may use cookies to identify your device, keep you safe when you access CoachFX and our other websites, and to detect when someone tries to access your account from another device. In addition, cookies allow us to share content with you on CoachFX and present relevant ads to you. We use the following cookies: 7.1.1 Required cookies: These types of cookies are essential for the proper use of our products and features. Without these cookies, for example, you will not be able to log in to our website or apps. Information Cookies: These cookies collect information about your user behavior. We use these cookies to optimize our website for you and to optimize your user experience as much as possible. 7.1.2 Functional cookies: These cookies help us to remember your choices, such as: your geographic location to view our website for your region. Third party cookies: These cookies are provided by websites that are not affiliated with CoachFX and are therefore subject to the privacy policy applicable to these external service providers. 7.1.3 Analytical cookies: Our websites use analytical cookies such as Google Analytics. This website uses Google Analytics and Google Remarketing. These are services of Google Inc. (“Google”). Google uses so-called “cookies”, text files that are stored on your computer and that allows an analysis of the use of the website by you. The information generated by the cookie about your use of this website (including your IP address) is transmitted to and stored by Google on servers in the United States. The IP address is then shortened by Google for the last three digits, a clear assignment of the IP address is therefore no longer possible. Google complies with the US Safe Harbor Privacy Policy and is registered with the US Department of Commerce Safe Harbor Program. Google will use this information to evaluate your use of the website, to compile reports on website activity for website operators and to provide other services related to website activity and internet usage. Google may also transfer this information to third parties if required by law or as far as third parties process this data on behalf of Google. Third parties, including Google, place ads on websites on the Internet. Third parties, including Google, use stored cookies to serve ads based on previous visits by a user to this site. Google will never associate your IP address with other Google data. The data collection and storage can be contradicted at any time with effect for the future. You can disable the use of cookies by Google by visiting the page to disable Google advertising. Alternatively, users can disable the use of third-party cookies by visiting the opt-out page of the Network Advertising Initiative. We point out, however, that you may not be able to use all the features of this website in this case. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. The data collection and storage can be contradicted at any time with effect for the future. For more information about Google’s terms, please visit Google’s private policy page. 7.2 Privacy Policy for the use of Google AdSense This website uses Google AdSense, a service for integrating advertisements of Google Inc. (“Google”). Google AdSense uses so-called “cookies”, text files that are stored on your computer and that allow an analysis of the use of the website. Google AdSense also uses so-called web beacons (invisible graphics). These web beacons can be used to evaluate information such as visitor traffic on these pages. The information generated by cookies and web beacons on the use of this website (including your IP address) and delivery of advertising formats are transmitted to and stored by Google on servers in the USA. Google may disclose this information to contractors of Google. However, Google will not merge your IP address with other data you have stored. You can prevent the installation of cookies by setting your browser software accordingly; however, please note that in this case you may not be able to use all features of this website to the fullest extent. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

8.0 Complaints

If you have a complaint about how we have handled your personal data, contact us using the details below, and we will investigate your complaint. Please use the same contact details to instruct us to cease processing your personal data.

9.0 Contact Us

If you have any questions about this Privacy Policy, or would like to exercise your rights with respect to your personal data, please contact us at support@coachfx.com, or write to: Support Team Express Coaching Limited 3 Grosvenor Crescent Glasgow G12 9AE Scotland