Data Privacy Policy

Last updated: 2020-04-13

Introduction

This privacy policy applies to all information collected through our websites (such as thecomingoutcoaches.com, the-gay-side-of-life.com and any related services, sales, marketing or online and live events (we refer to them collectively in this privacy policy as the “Sites“).  

Who we are

  • Our website address is: https://thecomingoutcoaches.com. We are two individuals, Lucie and Vanessa, that want to change the world. We founded together the Coming Out Coaches. We are located in the canton Lucerne, Switzerland: Postfach, ….
  • When we say ‘we’, ‘us’, ‘GSL’ or ‘COC’, it’s because that’s who we are and we own and run the Sites.
  • If we say ‘policy’ we’re talking about this privacy policy. We are  following the policy to make sure that your data is protected.
  • We want to create a safe space, and this is a responsibility that we share all together. That’s why we also have our ‘Terms of Services’ (TOS), that provides the rules how we provide our services and how, you and us, together we take care of each other on this platform.

Our Values

To protect your data and provide a safe space for you is part of our mission. We are looking on sustainable solutions. That’s why we have chosen Infomaniak as our web hosting provider: 

  • Your data is stored exclusively in Switzerland in a TIER III+-type data center (TIER III means that it is already the second highest security level) in the area of Geneva – the place to be chosen by organisations such as the World Health Organisation and the World Trade Organisation and many more.
  • Our platform is hosted in the greenest data center in Switzerland. It is designed to live without active cooling and uses only energy from regenerative sources such as water. 
  • You can find more information about our amazing hosting partner and their data center here.

What personal data we collect and why we collect it

Personal Data

We may collect personally identifiable information, such as your name, shipping address, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily give to us when you register with the Site or when you choose to participate in various activities related to the Site, such as online chat, message boards, comments and contact forms. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site.

Derivative Data

Our servers automatically collect information when you access the Site, such as your anonymized IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site.

Payment Data

We may collect financial information, such as data related to your payment method (e.g. valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information about our services from the Site. We store only very limited, if any, financial information that we collect, in our bookkeeping tool bexio. Otherwise, all financial information is stored by our payment processor, (PaypalStripe) and you are encouraged to review their privacy policy and contact them directly for responses to your questions.

Mobile Device Data

Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.

Cookies and Web Beacons

If you leave a comment on our site you may opt-in to saving 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 visit our login page, 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.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site and improve your experience. When you access the Site, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Site. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

Web Analytics

We may also partner with selected third-party vendors, such as Google Analytics, to allow tracking technologies and remarketing services on the Site through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor or the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

Embedded content from other websites

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.

How we Use the collected data

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience.  We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.  
We use the information we collect or receive:  
  • To facilitate account creation and logon process [with your Consent]. If you choose to link your account with us to a third party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed “Social Logins” for further information.
  • To send you marketing and promotional communications [for Business Purposes and/or with your Consent]. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “Your Privacy Rights” below).
  • To send administrative information to you [for Business Purposes, Legal Reasons and/or possibly Contractual]. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
  • Fulfill and manage your orders [for Contractual reasons]. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Sites.
  • To post testimonials [with your Consent]. We post testimonials on our Sites that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at Contact Us and be sure to include your name, testimonial location, and contact information.
  • To protect our Sites [for Business Purposes and/or Legal Reasons]. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).
  • To respond to legal requests and prevent harm [for Legal Reasons]. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • To enforce our terms, conditions and policies [for Business Purposes, Legal Reasons and/or possibly Contractual].
  • To enable user-to-user communications [with your consent]. We may use your information in order to enable user-to-user communications with each user’s consent.
  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.

Who we share your data with

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We only share and disclose your information in the following situations:

We may share information we have collected about you in certain situations. Your information may be disclosed as follows: 

Compliance with Laws

We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests and Legal Rights

We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

Vendors, Consultants and Other Third-Party Service Providers

We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

Business Partners

We may share your information with our business partners to offer you certain products, services or promotions, in which case we will require those affiliates to honor this privacy policy.

With your Consent

We may disclose your personal information for any other purpose with your consent.

Other Users

When you share personal information (for example, by posting comments, contributions or other content to the Sites) or otherwise interact with public areas of the Sites, such personal information may be viewed by all users and may be publicly distributed outside the Site in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Sites, and view your profile.

How long we retain your data

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). 

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

What rights you have over your data

If you have an account on one of our Sites, 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.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm]

Where we send your data

Your information, including personal data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside of Switzerland and choose to provide information to us, please note that we transfer the data, including personal data, to Switzerland and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Your contact information

If you have questions or comments about this policy, email us at Contact Us or by post to

The Coming Out Coaches, Postfach….

Additional information

How we protect your data

We use administrative, technical, and physical security measures to help protect your personal information, such as  security plugins and choosing a TIER III+-type data center Swiss hosting provider Infomaniak. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.  Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

What data breach procedures we have in place

 In the event of a data breach, we will inform the regulatory authorities within 72 hours since becoming aware of the data breach. We will take actions to
  • prevent the further spread/loss of data and recover the data that has been lost
  • identity risks arising from the breach
  • contact appropriate parties besides the regulator
  • and, prevent future breaches.

What third parties we receive data from

We don’t receive additional data from other third parties than mentioned above.

What automated decision making and/or profiling we do with user data

None.

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Testimonial of Diana

When I decided to start my sessions with The Coming Out Coaches, I was stuck in a constant loop of negative self-talking, while being so exhausted by hating my body.
After my sessions with them, there has been an amazing transformation: it is the first time in my life that at last I look at me with compassion and offer myself genuine acts of self-care!
With the mind coaching, Lucie helped me form new thought patterns to protect me from and finally get rid of my negative inner dialogues and look at myself as the universe’s first priority. She also taught me the ultimate and most long-term skill of self-care: cooking delicious and healthy meals to nurture my body and mind!
With the body and nutrition coaching, Vanessa helped me understand the basics of nutrition, and how this can complement my goals on improving my self-image. Topping it with a set of exercises to strengthen my body and help me improve my everyday movements, I feel stronger and more confident than ever!
Diana, 37, Switzerland
Manager

Testimonial of Aya & Pascale

The time with Lucie and Vanessa was very educational and inspiring.
We started to pay attention to things that changed our everyday life in a positive way.
We would recommend the coaching sessions with Lucie to anyone. With her positive, motivating, and intelligent way she always manages to make people laugh and think. Lucie responded very well to our needs and always took us one step further from coaching to coaching.
The body sessions with Vanessa were also characterized by positive events. As an enthusiastic athlete, she is very authentic and can respond extremely well to people and their goals. Thanks to Vanessa, we acquired knowledge that is still part of our everyday life today.
We thank them both from our hearts!
Aya (25) & Pascale (22), Canton of Aargau, CH
Multimedia production student & Car body work and paint

Testimonial of Brigitte

Originally, I wanted to get coached because of my diet cola addiction. I used to drink between 1.5 - 2 liters of cola every day. Several times I wanted to drink less, and I had never managed to do it. Lucie and I each had the coaching session via Skype. Already at the first meeting, I felt that Lucie could definitely help me. She was very sympathetic and sensitive to me. She recognized where my problems were, and she was able to ask the right questions at the first meeting. Many thoughts went through my head after the conversation. At the second meeting, we came a little closer to my problem. I realized that my unlimited cola consumption and my recurring eating attacks belonged together. Cola and food are comforts for me during a bad day, or out of boredom and loneliness.
Lucie has a great talent to recognize problems and to help. She inspired me to focus on good thoughts. With her help, I arranged my life differently. I had good conversations with my husband after a long time. I told him about my coaching and discussed with him how we could better arrange our life together. Since my coaching, we have been trying to have dinner together and share our news of the day. I have now filled my fridge with vegetables, salad, and healthy food. I treat myself to diet cola on special occasions, and then I enjoy it even more. Regarding the topic of sports, I regularly go for weight training and have started jogging again. I can't turn my plan into reality every day because I don't always feel well. But thanks to Lucie, I have learned to accept that there are also bad days. To be grateful for my good life and to enjoy it. Lucie could help me a lot, and I am so grateful to her.
I recommend Lucie very much. She asks the right questions. She recognizes the problems, supports you, and is a warm person.
Brigitte, 55, Ebikon, CH
Secretary