InsideTrack’s Privacy Policy

InsideTrack is operated by INSIDETRACK , INC. (hereinafter, “we”, “our” or “us”). We are a wholly owned subsidiary of Strada Education Network. We respect your privacy and are committed to protecting your information. The privacy policy below discloses our practices regarding information collection and usage solely for the InsideTrack app that can be downloaded from app stores called “uCoach” and the coaching platform used by InsideTrack’s coaches called the “uCoach Platform” (collectively, the "uCoach"). This privacy policy does not apply to any other websites, apps or services provided by us, our affiliates or clients, unless it appears on such website, app or service.

This privacy policy aims to give you information on how we collect and processed your information through your use of uCoach, including any data you may provide through uCoach when you use our Service or contact us using the contact information below.

It is important that you read this privacy privacy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing information about you so that you are fully aware of how and why we are using your data.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

Information Collection
Information Use and Sharing
Third-party Links and Social Networking Services
Data Security
Data Retention
Additional EU Disclosures
Opt Out
Data Relating to Children
Cross Border Transfers
California Privacy
Updates to this Privacy Policy

INFORMATION COLLECTION

Your provision of your personal information to us is completely voluntary. “Personal information” is information that can specifically identify you. We do not collect personal information unless you submit that information to us, or a customer institution has provided information to us that it warrants has been received by them from you via your consent.

Categories of personal information we may collect include:

Identity Data, which includes name or other similar identifiers.

Contact Data, which includes address, email address and telephone numbers.

Additionally, we may also collect certain others types of information that, along with Identity Data and Contact Data, may be considered and specifically named “personal data” in certain jurisdictions, including the European Union (“EU”), such as:

Technical Data, which includes internet protocol (IP) address, location data, your login data, and device and browser information.

Profile Data, which includes your username and password.

Usage Data, which includes information about how you use uCoach.

IF YOU ARE SITUATED IN THE EU, PLEASE SEE THE SECTION “ADDITIONAL EU DISCLOSURES” THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

We use different methods to collect data from and about you including through:

Direct interactions: You may give us your information by downloading the uCoach mobile app or by submitting a request for information from a school or institution that is a customer of InsideTrack.

This includes information you provide when you:
download uCoach from the app store
create an account by registering on the uCoach mobile app;
request information to be sent to you; or
give us feedback.

Automated technologies or interactions: As you interact with uCoach, we may automatically collect Technical Data and Usage Data about your. Some of the ways in which we or our website may collect are further described below:

Location Data: The uCoach mobile app, when given permission, will collect the latitude and longitude coordinates of your device when you are using certain functionality. We use this information to help us provide you with helpful information about the school you are interested in, and is only collected while the app is running. We also use geo-IP data to identify the city a user is visiting on the mobile app in order to provide you a more customized experience. If you would like to opt-out of location, tracking, please see the Opt-out section below.

INFORMATION USE AND SHARING

Subject to the section titled “Additional EU Disclosures”, we use information held about you to perform our services and for other purposes outlined below. Specifically, we use your information for a variety of purposes:

Where we need to perform the contract that we have entered in with an institution to which you have submitted a request for inquiry form.

To perform specific services that you have requested via a coaching relationship that you have established with an InsideTrack coach.

To respond to your direct inquiries.

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.

Subject to the section titled “Additional EU Disclosures”, we may share the information we collect about you with certain third parties in the following ways:

We will share your information with schools to which we have a contract with to provide coaching services and to which you have either submitted a request for information form or to which you have enrolled as a student.

Third parties to whom we need to share your information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the policies for the website.

THIRD-PARTY LINKS AND SOCIAL NETWORKING SERVICES

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. 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 policy of every website you visit.

The Website may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Website, we are doing so merely as an accommodation and, like you, are relying upon those third party services to operate properly and fairly.

You should be aware that information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control such uses of your information, and by using such services you assume the risk that the information provided by you may be viewed and used by third parties.

DATA SECURITY

We have put in place appropriate security measures to prevent information about you from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed; however, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. We have put in place procedures to deal with any suspected data breach that will affect you and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

We will only retain your information 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. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

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

ADDITIONAL EU DISCLOSURES

Our role as data controller and data processor

InsideTrack, Inc. generally acts as the data controller of your information submitted through uCoach; however, under certain circumstances, the schools and institutions we are contracted with may engage us to provide them with certain processing services related to information owned or controlled by the school and institution. We are not responsible for any school’s or institution’s use of information for which it is an owner or controller. As processor for a school or institution, we only act under their instruction with respect to the processing of your information. To learn more about how a school or institution may use such information, you should review its privacy policy.

If you are situated in the EU and have any complaints regarding our privacy practices as a data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance. Please see our contact details below in the section titled “Contact Us”. If you are situated in the EU and have a complaint, please contact our privacy counsel, Lara Corey, at privacy@insidetrack.com.

Provision of personal data and failure 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 our services). In this case, we will not be able to provide services to you.

Legal basis for our processing of your personal data

Below are the types of lawful basis that we will rely on to process your personal data:

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 where 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 at privacy@insidetrack.com.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at privacy@insidetrack.com. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Collection of personal data from third party sources

We do not collect personal data about you from any third parties and public sources.

Withdrawing your consent

If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at privacy@insidetrack.com.

Use of your personal data for marketing purposes

We do not use your personal data for marketing and advertising. We may process data you have provided us to the school or institution for which you have requested more information and which which we have a contract to provide you with coaching services. The school or institution may then contact you using the personal data that we have provided to the school or institution.

Rights of EU Data Subjects

Under certain circumstances, you have rights under data protection laws in relation to your personal data. you have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This 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.

Request erasure of your personal data. This 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.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

Request restriction of processing of your personal data. This 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. 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.

Withdraw 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.

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.

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.

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.

To exercise your rights, please contact us at privacy@insidetrack.com.

Additionally, in the situation where a school or institution is the data controller and you would like the school or institution to delete information they have collect about you, we encourage you to contact the school or institution directly. If you are unsuccessful in reaching the appropriate contact at the school or institution, please contact us at privacy@insidetrack.com and we will do our best to connect you with the right person who can help you.

OPT OUT

Opting out of messages from us

To opt-out of any future messages from us, you should send an unsubscribe request to us at privacy@insidetrack.com. You can also unsubscribe from further communications from a coach by informing them that you no longer wish to receive messages via uCoach. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of uCoach may no longer be available to you.

Opting out of cookies

If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of uCoach or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your device without your knowledge. For more information about cookies, please visit our Cookie Policy

Opting out of location tracking

You may also adjust the settings on your mobile device to allow or restrict the sharing of location information. For example, the "location" permissions on your mobile device may allow you to elect whether to never share location information with us, to share location information only while you are using the uCoach mobile app, or always share location information even if you are not using the uCoach mobile app. If you elect to not share your location information, you may be unable to access some features of our Services that are designed for mobile devices. Also, in the event that you prevent the sharing of location information, we may still estimate your general location based on the IP address you use to access our Services.

DATA RELATING TO CHILDREN

Our Website is designed for those 16 years of age and older. We do not knowingly collect information from anyone under the age of 13 (or such other age as may be restricted under local law). If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.

CROSS BORDER TRANSFERS

Our website is maintained in the United States. If you are visiting from the regions with laws governing data collection and use that may differ from those in the United States, please note that you may be transferring your information to the United States and in other countries around the world. You freely and specifically give us your consent to export and use your information within the United States and in other countries as specified in this Privacy Policy. You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States. If you are situated in the EU, whenever we transfer your personal data to processors outside of the EU, we ensure appropriate and suitable safeguards are used in such transfer. We may use specific contracts approved by the European Commission which give personal data the same protection it has in the EU For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

CALIFORNIA PRIVACY

If you are a California resident this section applies to you. Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of personally identifiable information, such as name, email address and mailing address and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please contact us at privacy@insidetrack.com.

UPDATES TO THIS PRIVACY POLICY

We reserve the right, at our discretion, to change, modify, add, or remove portions from this privacy policy at any time. However, if at any time in the future we plan to use your information in a way that materially differs from this privacy policy, we will post such changes here or email you. We encourage you to periodically review the website for the latest information on our privacy practices. You are bound by any changes to the privacy policy when you use uCoach after such changes have been first posted.

CONTACT US
InsideTrack Inc.
121 SW Salmon Street
Portland OR 97204
(415) 243-4440
privacy@insidetrack.com