A. GDPR Compliance Statement
1. Introduction
At Coaching Scribe, operated by Sports Toolkit Ltd., we are committed to protecting the privacy and security of our users. This GDPR Compliance Statement outlines the types of personal information we collect, how we use it, how we protect it, and the rights of our users regarding their personal information.
2. Data Collection
We collect personal information when you register for an account, subscribe to our services, or interact with our features. This information may include your name, email address, contact details, professional details, and any other information you choose to provide related to your coaching activities.
3. Use of Data
We use the personal information collected to:
Provide, operate, and maintain our services
Improve, personalise, and expand our services
Understand and analyse how you use our services
Develop new products, services, features, and functionality
Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes
Send you emails
Find and prevent fraud
4. Data Protection
Coaching Scribe implements security measures to protect your personal information from unauthorised access, alteration, disclosure, or destruction. We apply industry-standard practices and take all reasonable steps to ensure the confidentiality and integrity of your data.
5. Your Rights
Under GDPR, you have the following rights:
The right to access – You can request copies of your personal data.
The right to rectification – You can request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
The right to erasure – You can request that we erase your personal data, under certain conditions.
The right to restrict processing – You can request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing – You can object to our processing of your personal data, under certain conditions.
The right to data portability – You can request that we transfer the data we have collected to another organisation, or directly to you, under certain conditions.
To exercise any of these rights, please contact us.
6. Data Sharing
We do not share or sell your personal data with third parties for marketing purposes. Personal data may be shared with trusted partners who assist in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential.
B. Data Processing Addendum ("DPA")
This Data Processing Addendum ("DPA") forms part of the Terms & Conditions ("Principal Agreement") between Sports Toolkit Ltd, trading as Coaching Scribe ("Data Controller"), and third-party service providers such as Squarespace and Stripe ("Data Processors"). This DPA details the obligations and conditions under which personal data is processed and is integral to the agreement between the Parties.
1. Definitions
"Personal Data" means any information relating to an identified or identifiable natural person that is processed under the Principal Agreement.
"Data Protection Laws" refers to the General Data Protection Regulation (GDPR), the United Kingdom General Data Protection Regulation (UK GDPR), and all other applicable laws relating to the processing of Personal Data.
2. Processing of Personal Data
The Data Processors shall process Personal Data solely on the documented instructions of the Data Controller. These instructions include all matters regarding the collection, processing, storage, and transfer of Personal Data.
The Data Processors will not transfer Personal Data to a third country or international organisation without the compliance measures required by the GDPR, except where EU or member state law requires such a transfer. If such a requirement exists, the Data Processor shall inform the Data Controller of this legal obligation before processing unless prohibited by law.
3. Rights of Data Subjects
The Data Processors shall, where possible, notify the Data Controller within 24 hours if they receive a request from a Data Subject to exercise rights under the GDPR, such as access, correction, deletion, or portability of their Personal Data. The Data Processors shall not respond to any such Data Subject request without the prior written consent of the Data Controller.
4. Personnel
The Data Processors shall ensure that all personnel engaged in the processing of Personal Data are informed of its confidential nature, have received training on their privacy and data protection responsibilities, and are bound by confidentiality obligations.
5. Security
The Data Processors must implement technical and organizational measures to ensure an appropriate level of security for Personal Data, including measures for pseudonymization, encryption, and ensuring ongoing confidentiality, integrity, availability, and resilience of processing systems.
6. Subprocessing
The Data Processors may not engage any subprocessor without the Data Controller's prior specific or general written authorisation. If general authorisation is provided, the Data Processor must inform the Data Controller in advance of any changes to subprocessors, affording the Data Controller the opportunity to object.
7. Data Transfers
Any transfer of Personal Data outside the EU/EEA shall be conducted in compliance with GDPR provisions, including adherence to Standard Contractual Clauses or other EU-approved mechanisms.
8. Audit and Compliance
The Data Processors shall provide all necessary information to demonstrate compliance with this DPA and permit audits, including inspections by the Data Controller or an auditor appointed by the Data Controller. Such audits will be conducted with reasonable notice, during regular business hours, and in a manner that does not disrupt the Data Processors' operations.
9. Termination
Upon termination of the data processing services under the Principal Agreement, the Data Processors shall, at the choice of the Data Controller, delete or return all Personal Data to the Data Controller and delete existing copies unless EU or member state law requires storage of that Personal Data.
10. Third-Party Data Processors
Squarespace DPA: Available at www.squarespace.com/dpa.
Stripe DPA: Available at www.stripe.com/gb/legal/dpa.
These documents reflect the data processing agreements with our third-party providers and are integral to ensuring compliance with Data Protection Laws.
C. CCPA Compliance Statement
1. Introduction
Coaching Scribe, operated by Sports Toolkit Ltd., values the privacy of its users and recognises the importance of your personal information. We are committed to respecting your privacy rights under the California Consumer Privacy Act (CCPA). This statement provides necessary information about your rights under the CCPA and our practices regarding the collection, use, and sharing of personal information.
2. Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, Coaching Scribe has collected the following categories of personal information from consumers within the last twelve (12) months:
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Internet or other similar network activity including, but not limited to, browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
3. Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with your registration, the information will be used to process your registration.
To provide, support, personalise, and develop our website, products, and services.
To create, maintain, customise, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To help maintain the safety, security, and integrity of our website, products and services, databases, and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
4. Sharing Personal Information
Coaching Scribe may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
5. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. You have the following rights:
Right to Know and Data Portability: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you the categories of personal information we collected about you, the categories of sources for the personal information, our business or commercial purpose for collecting or selling that personal information, the categories of third parties with whom we share that personal information, and the specific pieces of personal information we collected about you.
Right to Delete: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.
6. Exercising Your Rights
To exercise the rights described above, please submit a verifiable consumer request by contacting us.
Only you, or someone legally authorised to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
7. Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice's effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
8. Contact Information
Reach out to Coaching Scribe here.