Effective Date: May 25, 2018
This policy describes how BetterManager, Inc. (“BetterManager” or the “Company”) manages personally identifiable information, or “PII”) provided by users through our Website, www.bettermanager.us (the “Website”), our Coaching Platform, as well as information collected by us through other means, including during the rendering of our service, by email, over the phone, or in offline communications.
- Information collected by us;
- How we may use your information;
- How we share your information;
- Whether we collect information from minors;
- The types of cookies we use and how you can reject these cookies;
- California does not track Disclosure;
- Where we store your information;
- How we keep your information secure;
- Your rights in relation to your information;
- How to contact us;
- Changes to our policy.
1. Information collected by us:
- Information you provide to us: BetterManager collects information from you when you choose to provide it to us through the WebWebsite, Coaching Platform or through any other means. This may include when you request coaching services, request information from us, sign up for newsletters or our email lists, use our Website, or otherwise contact us. The information we collect may include your name, address, email address, telephone or mobile phone number, information relating to your employment or professional activities and financial account information.
2. How we may use your information:
3. How we share your information:
- BetterManager is not in the business of selling your information. There are, however, certain circumstances in which we may share your personal data with certain third parties without further notice to you, as set forth below: Agents, Consultants and Third Party Service Providers: BetterManager, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
- Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets.
- Legal Requirements: BetterManager may disclose your personal data 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, (ii) protect and defend the rights or property of BetterManager, (iii) act in urgent circumstances to protect the personal safety of users of the Website, the Services or the public, or (iv) protect against legal liability.
- Links to other Websites: The Website may have links to third-party Websites, which may have privacy policies that differ from our own. We are not responsible for the practices of such Websites, nor does any such link imply that BetterManager endorses or has reviewed the third party Website subject to such link. We suggest contacting those Websites directly for information on their privacy policies.
4. Whether we collect information from minors:
5. The types of cookies we use and how you can reject these cookies:
- We have outlined below the individual cookies we use and why we use them:
6. California does not track disclosure:
- Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed above (e.g., by disabling cookies). For more information about tracking, please click here.
7. Where we store your information:
- The data that we collect from you is processed outside the European Economic Area (EEA), and we have ensured that there is an adequate level of protection for such data.
8. How we keep your information secure:
- All information you provide is stored on servers managed by SpeedyRails, Inc, Amazon Web Services and Zoom, Inc. The Server Infrastructure is provided by Rackspace Inc (for SpeedyRails, Inc), Amazon Web Services, and Zoom, Inc. More information on these providers is available at speedyrails.com, rackspace.com, aws.amazon.com/s3 and zoom.com.
9. Your rights in relation to your information
- To keep your personal data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.
- Individuals located in the European Economic Area (EEA) have certain rights in respect of their PII, including the right of access, rectification, restriction, opposition, erasure, and data portability. Where possible, we rely on user consent as a lawful basis for processing personal data and obtain such consent in compliance with applicable laws. In some cases, BetterManager may process PII pursuant to a legal obligation or to protect your vital interests or those of another person.
- How may I exercise my individual rights? BetterManager users may access and update their PII through their account settings in the BetterManager Coaching Platform. Users located within the EEA may contact us with questions or requests regarding their PII using the contact information below. Please note that BetterManager may request additional information from you to verify your identity before we disclose any personal or account information. We only send marketing communications to users we believe to be located in the EEA with their prior consent, and they may opt out of such communications at any time by clicking the “unsubscribe” link found within BetterManager email updates and changing their contact preferences. Please note, you will continue to receive essential account-related information, even if you unsubscribe from promotional emails.
- Who Can I Contact BetterManager Regarding Data Protection Issues? BetterManager has designated a Data Protection Officer to assist with data privacy and data protection issues. You may contact him by emailing email@example.com and addressing your questions or concerns to the Data Protection Officer.
10. Contacting us is easy
11. Changes to our policy: