Privacy Policy

CTI may collect, use, store and transfer different kinds of Personal Data about you.  

These are the types of Personal Data we may collect: 

• Identity Data includes first & last name, company, job title. 
• Contact Data includes billing address, delivery address, email address and telephone numbers. 
• Financial Data payment card details if you make purchases from us or if you otherwise subscribe to our chargeable services. 
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. 
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. 
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 
• Usage Data includes information about how you use our website, products and services. 
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 
• Voice Recordings associated with calls made to our Customer Experience team, information about the call, and information you share during the call.  
  
• Information shared with CTI during communications and interactions with us, including content of email messages, chatbot sessions, and phone calls.  

We also collect and use Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your Personal Data. If we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy notice. 

We do not collect any Special Categories of Personal Data about you while you visit the Site.  

Articles on this Site may include embedded content (e.g., videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. 

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website. 

When visitors leave comments on the Site (e.g., on our blog) we collect the data shown in the comments form, and the visitor’s IP address and browser user agent string to help spam detection. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/.

After approval of your comment, your profile picture is visible to the public in the context of your comment. 

Cookies are a standard technology used by commercial web services to store small pieces of information on your hard drive by sending a small string of text to your browser. Cookies make your use of our Site more pleasing and efficient by, for example, ‘personalizing’ your user interface or identifying which parts of the site you have previously visited. Most web browsers automatically accept cookies unless you have configured yours not to accept them. For us to provide you with services, your browser must accept cookies, as they are essential for Site administration and security.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.  

If you leave a comment on our Site, you may opt-in to save your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year. 

If you have an account and you log in to this Site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser. 

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed. 

When a visitor uses the chatbot on our website, they will be asked to consent to sharing personal data (name and email address) in order for CTI to process their data and provide the content that is requested. You will be prompted to consent to drop a cookie in your browser before the start of the chat session or if you attempt to leave the page during a chat conversation. This cookie is used to interact with you as a website visitor and to provide your chat history. Consent for the cookie placement is not required in order to use the chatbot, but navigating away from the page, your current chatbot conversation will be lost.  

Information attained by the Chatbot is used only for the intended purposes stated when it is collected. CTI makes every effort to avoid the collection of excessive or irrelevant information.  

CTI strongly encourages visitors to not provide sensitive personal information through Chatbot. This includes race or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health, sexual orientation, or criminal record. If sensitive information is provided through the Chatbot, CTI will delete this information and not use it for processing.  

Information provided through the Chatbot will be processed via HubSpot, CTI’s Content Relationship Management system. The logic and content that make up the Chatbot is built on the HubSpot platform. 

We use different methods to collect data from and about you through various interactions. You may give us your Identity, Contact and Financial Data through: 

• Direct interactions: by filling in forms or by corresponding with us by post, phone, email or otherwise. 
• Purchasing our products or services. 
• Applying for a job or volunteer position. 
• Applying for Coach Certification. 
• Creating an account on the Site. 
• Subscribing to our service or publications. 
• Request marketing to be sent to you. 
• Enter a competition, promotion or survey. 
• Contact us for support or to give feedback. 
• Using the Chatbot on the website.
• Automated technologies or interactions: as you interact with the Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies. 

We will only use your Personal Data when the law allows us to. We must use your data only on a lawful basis including, but not limited to using such data to fulfil a contract we have with you; to comply with legal obligations; to lawfully gain information to help us develop our services; to monitor how our website is being used and any issues with the Site; for marketing and communications purposes (as set forth below)  to keep you informed of developments and new products; etc. By providing us with your Personal Data, you indicate that you consent to allow us to process and maintain your Personal Data.

Most commonly, we will use your Personal Data in the following circumstances: 

• CTI may collect information in conjunction with registration for programs and related services and to perform follow-up with its program registrants, as part of the registration process for CTI programs. 
• Where we need to fulfil the contract to provide you with CTI services.We may use your IP Address to maintain and administer CTI’s Site. 
• Your IP Address may also be used to help identify you and to gather broad demographic information, some of which we may aggregate and then share with our partners. 
• We may also use your IP address to track information you have seen on our Site. 
• We may use your name, email address and mailing address to assist us in communicating with you. 
• Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests. 
• Where we need to comply with a legal or regulatory obligation. 
• Visitor comments may be checked through an automated spam detection service. 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.  You will receive marketing communications from us if you have requested information from us, have purchased goods or services from us, or if you provided us with your details when you registered for a promotion.  We will not supply your details to any company outside CTI for marketing purposes.   

Opting out of marketing messages 

You can opt out of marketing messages at any time by doing one of the following: 

• Use the opt-out link at the bottom of any marketing message you receive 
• Email the marketing department and request to opt-out of receiving messages 

CTI reviews and classifies all data (electronic and printed) that is in our possession as per our Secure Data Classification Policy, applying the appropriate levels of protection as required by state, federal, and international law, as well as proprietary, ethical, operational, and privacy considerations. Security standards, which define these security controls and requirements, may include document marking/labeling, release procedures, privacy, transmission requirements, printing protection, computer display protections, storage requirements, destruction methods, physical security requirements, access controls, backup requirements, transport procedures, encryption requirements, and incident reporting procedures.  

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will actively review the information we hold and when there is no longer a customer, legal or business need for us to hold it, we will delete it securely. To determine the appropriate retention period for Personal Data, we 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 process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

For users that register on our website, we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information. 

Although we use third parties to store and process data, we will not sell, share or rent personal information to others except in accordance with this Policy. We will disclose to third parties only the information necessary for the third party to provide contracted services. 

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions. 

We may obtain information about you provided to us by third parties such as credit reporting agencies or strategic alliance partners to offer you their services and products, to improve our services, or to evaluate your eligibility for our services. 

Disclaimer of Responsibility for Privacy Policy And Content at Linked Sites

CTI’s Site may provide you with links to other websites. We are not responsible for those sites and cannot control the use of information that you submit once you reach those sites, nor can we control the content of what is offered on those sites or on links from those sites. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. 

CTI takes great precautions to protect our users’ personal information. 

When users submit sensitive information via the Site, the information  is encrypted and protected with a widely accepted industry standard encryption protocol – SSL.  The servers that we store user information on are also housed in a secure environment. The security of your personal information is important to CTI and we follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. 

Access to all our users’ information is restricted. Only employees who need the information to perform a specific job are granted access to personally identifiable information. Furthermore, all employees are kept up to date on our security and privacy practices. Any time new policies are added, our employees are notified and/or reminded about the importance we place on privacy and what they can do to ensure that our users’ information is protected. Employees receive annual Security and Privacy Awareness training.  

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach when we are legally required to do so. 

If you have an account on this Site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes. 

Please submit requests by fax or postal service: 

FAX

Co-Active Training Institute
FAX: 415.472.1204
ATTN: Legal Department 

POSTAL SERVICE

Co-Active Training Institute
ATTN: Legal Department
899 Northgate Drive, Suite 304
San Rafael, CA 94903