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Extended Policy Information for EU Residents

The European Union’s General Data Protection Regulation (GDPR), in effect on 25 May 2018, provides additional governance for EU residents and are stated below.

International transfers

We may transfer your Personal Data outside the European Economic Area (EEA) but only to a country or territory that ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data including to:

  • Request access to your Personal Data.
  • Request correction of your Personal Data.
  • Request erasure of your Personal Data.
  • Object to processing of your Personal Data.
  • Request restriction of processing your Personal Data.
  • Request transfer of your Personal Data.
  • Right to withdraw consent.

A little more detail on each:

  • Requesting access to your Personal Data (commonly known as a “data subject access request”) enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Requesting correction of the Personal Data that we hold about you enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Requesting erasure of your Personal Data enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Objecting to processing of your Personal Data - You may object If processing your data impacts on your fundamental rights and freedoms. You also have the right to object when we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities when our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Requesting a restriction of processing of your Personal Data enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
    • (a) if you want us to establish the data’s accuracy;
    • (b) where our use of the data is unlawful but you do not want us to erase it;
    • (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;
    • (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Requesting the transfer of your Personal Data to you or to a third party means we will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • You can withdraw your consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please Contact us.

Contact details

Our full details are:

  • Full name of legal entity: Kimsey-House Enterprises, Inc. dba The Coaches Training Institute (CTI)
  • Name or title of Data Protection Specialist: Global Head of Technology
  • Email address: dataprotection@coactive.com
  • Postal address:
    • U.K. - 39-41 North Road, London, N7 9DP, United Kingdom
    • Spain - Entença 94 Despacho 2, 08015 Barcelona, Spain
    • U.S. - 2370 Kerner Blvd, Suite 370, San Rafael, CA 94901, U.S.A.
  • Telephone Number: U.K. +44 (0)203 763 9445 ; Spain +34 932 80 86 87 ; U.S. +1 415-451-6000

You have the right to make a complaint at any time to your member state and to the EDPS (European Data Protection Supervisor. The EDPS is the EU’s independent data protection authority -

We would, however, appreciate the chance to deal with your concerns before you approach any authority so please contact us in the first instance.

If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

No fee usually required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Third parties  - External Third Parties

Service providers acting as processors based in the United States who provide IT, cloud-based software and system administration services.