Privacy Policy

2. How do we collect personal information?

When website visitors and users send us a message through the contact form, register with us, purchase a service, or subscribe to the newsletter (please refer to section 1 for details).

Your personal information will be used for the treatment of your requests, answering of questions, coaching services, and marketing purposes.

The information requested as part of the contact form, the registration process, the service purchase and execution, or the newsletter subscription, is mandatory for the good treatment of your requests. Default from answering the information may lead to an inability to contact you back and/or address your request.

By providing your information through the contact form, the registration process, the service purchase and execution, or the newsletter subscription, you give us the consent to treat and store your personal information.

3. Why do we collect personal information?

We collect non-personal and personal Information for the following purposes:

1. To provide and operate the services.
2. To provide Users with ongoing customer assistance and technical support.
3. To be able to contact Visitors and Users with general or personalized service-related notices, promotional and campaign messages.
4. To create aggregated statistical data and other aggregated and/or inferred non-personal information, which we or our sales and marketing business partners may use to provide and improve the respective services.
5. To comply with any applicable laws and regulations.

4. How do we store, use, share and disclose site visitors’ personal information?

International Data Transfer
By using our online coaching platform, you (Coaches, Clients, and corporate program users) agree that your personal data, as provided by you or collected by us through the use of our services, may be processed and transferred outside of Singapore for operational purposes. This includes, but is not limited to, matching clients with coaches; providing user support, IT, and operational services from jurisdictions where our coaches and support personnel are based; and processing of session data by the video-conferencing provider (Microsoft Teams, Zoom, or Google Meet) chosen for a session, in the jurisdictions where that provider operates and under its own data protection arrangements. Depending on the engagement, personal data may be transferred between Singapore and other jurisdictions. We ensure that any such transfer is carried out in compliance with applicable data protection laws — including but not limited to the Singapore Personal Data Protection Act (PDPA), the EU General Data Protection Regulation (GDPR), the Personal Data Protection Law of the Kingdom of Saudi Arabia (KSA PDPL), and UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL) — using recognized transfer mechanisms such as Standard Contractual Clauses or equivalent contractual safeguards. We take appropriate steps to safeguard your personal information and maintain its confidentiality.

Service providers
We use third parties to provide various services on our behalf such as for hosting purposes, email services, credit card and payment processing, coaching session booking services, publications, or third-party advertising and marketing.

Hosting
The Website is hosted on aws.amazon.com. Aws.amazon.com provides us with the online platform that allows us to offer services to you. Your data may be stored through aws.amazon.com’s data storage, databases and the general aws.amazon.com applications. They store your data on secure servers behind a firewall.

Emails
For booking and payment processing purposes, when you write us or sign up to receive our newsletter, we will share your email address with our email service provider.

Payments
When you subscribe to a paid plan or service on the Website, we use a credit card processor to store your credit card details in a secure location, and also to charge your credit card when payments are due for payments. We use Stripe.com as a payment gateway. Stripe is one of the leading payment providers in the world. Your payment information may be stored by Stripe and their business partners such as but not limited to Visa, Mastercard, or American Express. Additionally, Stripe collects identifying information about the devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection. You can learn more about Stripe and read its privacy policy.

Coaching Session Booking
Coaching sessions are hosted on a third-party video-conferencing platform — Microsoft Teams, Zoom, or Google Meet — selected for that session by the client or participant. The relevant video-conferencing provider acts under its own terms of service and privacy and data protection arrangements. This means that your connection to a session, and any session-related data handled by that platform, are subject to the selected provider’s own terms and data protection arrangements, and not solely to this Privacy Policy. CoachBase does not host or store recordings of coaching sessions and recommends that recording remain disabled by default. This information is also presented to participants at first-time login, when they accept the Platform’s terms.<br>Coaches are provided with the ability to voluntarily connect their video call solution providers (Microsoft Teams, Zoom, Google Meet) and calendar solution providers (e.g., Google, MS 365, iCloud, Exchange) to synchronize their availabilities and coach booking slots. We use API to connect each of these solutions through the Website.<br>The Platform also offers participants an optional "add to calendar" feature for their own personal calendar (for example, Apple iCloud, Google Calendar, Yahoo, Microsoft 365, or Microsoft Outlook). Where you choose to use this feature, only session scheduling information (date, time, and join link) is added to your own calendar, by your own action. The relevant calendar provider acts as your own service under its own terms and data protection arrangements and is not engaged by CoachBase as a subprocessor for this purpose.

Publications
Coaches are provided with the ability to voluntarily publish their own publications (e.g., articles, videos, events) on the Website and CoachBase’s social media pages (LinkedIn, Facebook, Twitter, Instagram, Telegram, YouTube) as well as their own social media pages through CoachBase (button that the Coach can unable/disable upon submitting the publications). The latter involves the display of CoachBase logo and related service information together with the publication, the name of the Coach who has submitted it and a link to his/her profile on the Platform. By submitting their publications, Coaches give their consent for CoachBase and their third-party digital marketing providers to publish their publications on their behalf, and make them visible to the public.

In order to enable us to manage volumes and storage, and ensure adequacy with the platform brand positioning, the publication and duration of the publication made visible to the public will be at the Platform’s discretion.

Submitted publications are stored by the Platform for an unlimited duration on a free and secured cloud database. If Coaches wish to withdraw, amend, or delete a publication stored by us, they can do so by contacting us at: info@coachbase.io.

Third Party Advertising
Ads appearing on the Website may be delivered to users by CoachBase or one of our Web advertising partners. Our Web advertising partners may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement. In this way, ad servers may compile information about where you, or others who are using your computer, saw their advertisements and determine which ads are clicked on. This information allows our advertising network to deliver targeted advertisements that they believe will be of most interest to you. This Data Privacy Policy covers the use of cookies by CoachBase only and does not cover the use of cookies by any advertisers. We have no access or control of these third-party cookies.

Our third-party advertising partners may employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers personally identifiable information.

Links to Other Sites
This Website contains links to other sites that are not owned or controlled by CoachBase. Please be aware that we, CoachBase, are not responsible for the data privacy practices of such other sites.

We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects personally identifiable information.

This data privacy statement applies only to information collected by CoachBase Website.

Co-Branding
Please note that when you use our Feedback Page and other Feedback features, you will be on a third-party site. The pages will be branded as ours but powered by the third party. Please note that the third parties’ privacy policy governs the collection and use of information provided on the site powered by them. Their privacy policy link is included on each of the co-branded pages.

CoachBase Social Media and Forums
If you comment on posts published on the CoachBase social media and forums, you should be aware that any personally identifiable information you submit can be read, collected, or used by other users of these forums and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums. To request removal of your personal information from our blog or community forum, contact us at info@coachbase.io. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Social Media Widgets
Our Website includes Social Media features, such as the Like button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

Third parties are prohibited from using your personally identifiable information for any other purpose including their own marketing. These companies are authorized to use your personal information only as necessary to provide these services to us.

Information stored by us is maintained and treated confidentially, whether in print or digital/electronic format. For public marketplace users, our default retention period is 24 months following a period of 24 months of inactivity, after which the information is discarded unless required to be maintained by law. For corporate client program users, retention is governed by the agreement with the relevant corporate client and the applicable Data Processing Agreement: on termination or expiry of that agreement, personal data processed on the corporate client’s behalf is deleted or returned (at the client’s choice) within ninety (90) days, unless a longer period is required by law or specifically agreed with the relevant corporate or end client. Encrypted system backups may persist for up to twelve (12) months where earlier deletion is not technically practicable, and are not actively accessed except for legal, audit, security, or disaster-recovery purposes.<br>For corporate client program users, the specific data points visible to your organization’s sponsors through the sponsor dashboard are configurable per organization and confirmed in the contract at onboarding, as described in Section 5 of this policy.

Lastly, if CoachBase is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Legal Disclaimer

We may be obligated to share information with legal enforcement agencies according to relevant local regulations upon their request. We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Website.

We will share your personal information with third parties only in ways that are described in this data privacy policy. We do not sell your personal information to third parties.

5. Corporate Client Program Users

Where your organization (a corporate client) engages CoachBase to provide coaching to you as an employee or authorized participant, the way we collect and handle your data differs in some respects from our public marketplace. This section explains those differences. In this context, your employer is generally the data controller and CoachBase acts as data processor, processing your data on your employer’s documented instructions and under a separate Data Processing Agreement.

What we collect from corporate program users.
We collect: your name, email, and login password; and, where provided by your organization at setup, your phone number, date of birth, gender, job title, department or unit, organization name, preferred coaching language(s), country, and time zone. Some of these fields are optional and are provided at your organization’s discretion during platform setup; where they are pre-set by your organization, they are not editable by you. We also collect coaching-related inputs, including your pre-coaching questionnaire responses (such as development goals, engagement, tenure, experience, and seniority), your coaching plan, your coaching goals and their current and target ratings, your goal-progress updates and free-text comments, 360-feedback inputs and outputs where the 360 module is activated for your organization, and your feedback on your coach and the platform.

Who can see your data.
Access is governed by role. You and your assigned coach can see your full coaching record. Your organization’s sponsors (HR, L&D, or program sponsors) can see, through a sponsor dashboard, the structure and progress of the engagement — including coaching plans, goals, goal-progress ratings, 360-feedback outputs, and session and engagement metrics. Sponsors cannot see your free-text coaching notes, your free-text progress comments, or the content of confidential conversations between you and your coach. The CoachBase administrative team can access profile and operational data only and cannot view the substantive free-text content of your coaching plan or notes. The exact data points exposed to the sponsor dashboard are configurable per organization and confirmed in the contract at onboarding. You are informed of sponsor-dashboard visibility at first login and through your organization’s program communications.

Consent.
For corporate program users, consent is obtained both via the contract with your organization and from you at first login, and is recorded with a timestamp for audit purposes. You may withdraw consent at any time by contacting our Data Protection Officer (details below).

Your rights.
You may exercise your data subject rights — access, correction, deletion, portability, objection, and restriction of processing — as described in this policy. Requests are processed within 30 days and can be sent to info@coachbase.io.

Retention.
During your engagement, your coaching and account data are retained as needed to deliver the services. On termination or expiry of your organization’s agreement, CoachBase deletes or returns the personal data processed on its behalf (at your organization’s choice) within ninety (90) days, unless a longer period is required by law or specifically agreed with the relevant corporate or end client.

Anonymized and aggregated data.
For corporate client program users, any use of anonymized or aggregated data derived from the program is governed by the agreement with the relevant corporate client and the applicable Data Processing Agreement. Where those documents restrict or condition such use, they prevail over the general descriptions of aggregated-data use elsewhere in this policy.

6. How do we communicate with site visitors?

We may contact you to notify you regarding the services we provide to you and manage related bookings, payments, and queries, to share marketing campaigns that we may find valuable to you, to poll your opinions through surveys or questionnaires, to send updates about the company, or as otherwise necessary to contact you to enforce our Terms of Use, applicable national laws, and any agreement we may have with you. For these purposes we may contact you via email, telephone, and text messages.

We may also send you our newsletter if you opt to receive this communication from CoachBase. If you wish to unsubscribe from promotional emails including newsletters, you may do so by following the unsubscribe instructions included in each promotional email.

Lastly, CoachBase may send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such emails which are not promotional in nature by editing your notifications settings, though CoachBase reserves the right to send you notices about your account even if you opt out of all voluntary e-mail notifications.

When you use CoachBase as a potential coaching client, you may request/purchase a consultation directly from one of the coaches listed in our directory as part of the booking process or participate in our Referral Program.

If you request a consultation as part of the booking process, we will ask for your name, phone, location/time-zone, email address and your comments if any via the Platform to process the booking and payment if any on your behalf. You and your Coach will receive emails with the booking and payment details.

If you participate in the CoachBase Client Referral Program (i.e., get a Coach recommended to you), we ask for your name, email address, phone number (optional), location, your goal for hiring a coach, and any additional details that pertain to your request for a coach. By default, we will publish your request (not including personally identifiable details) as a means for communicating to Coaches your request. After submitting your referral request, we contact you to collect more information about your coaching needs, send you up to five recommended coaches, and periodically follow-up with you to ensure that we have delivered a high-quality service. In all cases, CoachBase stores personal information to track the success of our services.

7. How do we use cookies and other tracking tools?

As is true of most websites, we gather certain information automatically and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.

The Website may track personal information using software, cookies and tracking tools (e.g., cookies, flash cookies, web beacons, tags, scripts etc.). This information is used by CoachBase and our analytics affiliate, or email partner.

These technologies are used in generating statistics, measuring and collecting session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page, analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies to remember users’ settings (e.g., language preference) and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

Please note that third-party services, such as Google Analytics or other applications offered through aws.amazon.com, placing cookies or utilizing other tracking technologies through aws.amazon.com's services, may have their own policies regarding how they collect and store information. As these are external services, such practices are not covered by aws.amazon.com's data privacy policy.

Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 to collect and store information.

Various browsers may offer their own management tools for removing HTML5 LSOs.

8.How can site visitors change or remove information?

Access and control over most personal information on CoachBase is readily available through the profile editing tools for the Coach. The Coach may modify or delete any of his/her profile information at any time by logging into your account and submitting the changes to us.

Individuals who wish to cancel their CoachBase account may do so from their profile page. Removed information may persist in backup copies for a reasonable period of time but will not be generally available.

We will retain your information for as long as your account is active or as needed to provide you services. For public marketplace users, our default retention period is 24 months following a period of 24 months of inactivity, after which the information is discarded unless required to be maintained by law. For corporate client program users, retention is governed by the agreement with the relevant corporate client and the applicable Data Processing Agreement, as described in Section 5 of this policy. In all cases, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

9.Security

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. CoachBase takes appropriate precautions to protect our users’ information. Your account information is located on a secured server behind a firewall. When we collect sensitive information such as your credit card, we use SSL encryption to protect this data. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.<br>In the event of a personal data breach affecting your personal information, we will notify affected users and the relevant authorities without undue delay, as required by applicable data protection laws, and will take reasonable steps to contain and remediate the incident.

Because email and instant messaging are not recognized as secure communications, we recommend you to be mindful of the private information you share with us by e-mail or instant messaging services.

10.Release of information

The Coach may engage in training and continuing education pursuing and/or maintaining Coaching credentials. That process may require the names and contact information of Clients for possible verification by the coaching organizations granting these credentials. By buying coaching services on the Platform, Clients agree to have only their name, contact information, and start and end dates of coaching shared with staff members of these coaching organizations and/or other parties involved in this process for the sole and necessary purpose of verifying the coaching relationship for professional accreditation purposes.

According to the ethics of the coaching profession, topics may be anonymously and hypothetically shared with other coaching professionals for training, supervision, mentoring, evaluation, and for coach professional development and/or consultation purposes.

11.Record retention policy

The Client acknowledges that the Coach has their own record retention policy with respect to documents, information and data acquired or shared during the term of the Coach-Client relationship. Such records need to be maintained by the Coach in a format of the Coach’s choice (e.g., print or digital/electronic) and secured/treated confidentially throughout the contract and for a period of not more than 24 months after contract termination. The Coach commits to send the notes to the Client on request, and to destroy them after 24 months.

12.Privacy policy updates

We reserve the right to modify this data privacy policy at any time, so please review it frequently. The date at the top of this page indicates when this policy was last revised. This policy applies to all information that we have about you, and to your account with us. Changes and clarifications will take effect immediately upon their posting on the website.

If we make changes to this policy, we will post those changes to this data privacy statement and other places we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

If we make material changes to this policy, we will notify you that it has been updated here, by email, or by means of a prominent notice when you log into the Website prior to the change becoming effective.

13.Ownership of intellectual property, copyrights, and logos

14.Limitation of liability

First, to the maximum extent permitted by applicable law, in no event shall CoachBase, be liable for any indirect, punitive, incidental, special, consequential or exemplary damages, including without limitation, damages for loss of profits, goodwill, use, data or other intangible losses, arising out of or relating to the use of, or inability to use, the service.

To the maximum extent permitted by applicable law, CoachBase assume no liability or responsibility for any:

• errors, mistakes, or inaccuracies of content;
• personal injury or property damage, of any nature whatsoever, resulting from your access to or use of the service and;
• any unauthorized access to or use of the secure servers and/or any and all personal information stored therein.

15.Preference of law and dispute resolution

This policy provided hereunder, and any and all claims and disputes related hereto and/or to the data, shall be governed by, construed under and enforced in all respects solely and exclusively in accordance with the internal substantive laws of Singapore, without respect to its conflict of laws principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being decided exclusively by a court of competent jurisdiction located in Singapore. The application of the United Nations Convention of Contracts for the International Sale of Goods is hereby expressly excluded.

16.Questions and contact information

If you would like to: oppose, access, correct, amend, or delete any personal information we have about you, or have any questions or concerns related to protection of personal data, these data privacy policies, or the security on our Website, you are invited to contact us at:

• Email: info@coachbase.io or Chief Data Protection Officer: yuansheng.wong@coachbase.io
• Address: CoachBase Pte Ltd, 7 Temasek Boulevard, #12-07 Suntec Tower One, Singapore (038987)
• Phone: +65 9857 7953