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Sounding Board Privacy Policy

Table Of Content

Last Updated January 31, 2022

This policy describes how Sounding Board Labs, Inc. (“Sounding Board” or the “Company”) collects, aggregates, stores, safeguards and uses the data and information (including non-public personal information, or “NPI”) provided by users through our website, www.soundingboardinc.com (the “Site”), as well as information collected by us through other means, including by email, over the phone, or in offline communications. This Site is operated by the Company and has been created to provide information about our company and our coaching services and related services (together, the “Services”).

We take your privacy and the security of your information seriously.

This policy explains:

  • What information we collect, and how we use it
  • Choices you can make about the way your information is collected and used
  • How we protect personal information electronically and physically

This policy is incorporated into and a material term of your registration and/or use of Sounding Board’s products and services, including our website, www.soundingboardinc.com. By using the Site or Services, you consent to the practices set forth in this Privacy Policy.

General Statements

1.1 This is the Privacy Policy for SoundingBoard Inc, but we’ll refer to ourselves as “SoundingBoard,” or “the Company,” or use “we/us/our” pronouns.

1.2 We have a Privacy Policy for a few reasons. First: it’s required by law. Second, and more important, we want you to understand how we use data so you can make an informed decision about how you share with us, what you share with us, and how we use your information. Finally, our privacy policy sets internal rules for how we use data and holds us accountable: if we don’t tell you what we’re doing here, in the Privacy Policy, we won’t do it at all unless we specifically obtain your permission.

1.3 We want this Privacy Policy to be understandable on its own, but there are concepts, terms, and phrases that have specialized meaning because they come directly from privacy laws. You can look at the “Further Reading” section to get a clearer idea of what these terms mean.

1.4 We operate in more than one country and specific laws in many places require those specific things are included within a privacy policy. We believe that including all these requirements throughout a privacy policy makes it harder for the policy to be understood. As such, we have taken the decision to write this Privacy Policy in the clearest way that we can and include the specific international legal requirements in the “International Rights” section at the end of this Policy.

1.5 In some Sections below we refer to “GDPR art.” and then mention some numbers and letters. Where we do this, we are referencing a specific article within the European Union’s General Data Protection Regulation (or GDPR) that permits us to collect and use your data in a specific way. We do this for two reasons: (1) in some instances, we are required to under GDPR; and (2) because GDPR is considered to be the highest standard of privacy law in the world and we want you to know that, irrespective of where you live, we are applying the highest standards when it comes to your personal data. GDPR doesn’t apply to everyone, only those who are geographically located in the EU. That said, we still want to outline our GDPR obligations so you can understand what we are doing.

2. Information About SoundingBoard and this Privacy Policy

2.1 This Privacy Policy outlines how SoundingBoard collects and processes your personal data through your use of SoundingBoard’s websites, app, or any other services sponsored or controlled by SoundingBoard (a conference or an in-person survey, for instance). In other words, if we’re collecting personal data in any form, this Privacy Policy applies.

2.2 Along those lines, SoundingBoard is the “Controller” of the personal data it collects, which means we are the entity that decides how to collect, process, and use personal data.

2.3 We’ll provide links to this Privacy Policy wherever we can – on our websites, at conferences, on another website before you take a survey, etc. You should read this Privacy Policy, think about it, ask questions, and decide if you’re comfortable with it. Also read our Terms and Conditions, which control how we provide our services, and any other notices or policies we post so that you can make an informed decision about interacting with us.

2.4 When we make a change to this Privacy Policy, we’ll post a notice for you to review. This Privacy Policy was last changed on January 31, 2022.

2.5 We are not responsible, though, for links to third-party sites that we present to you, either on this website or elsewhere online. Once you access sites or apps via those links, our Privacy Policy no longer applies, and so you’ll need to read their privacy policies as well.

3. What data are we collecting about you?

3.1 Not all data is “personal data” under the law, but a lot of it is, and more than you might think. Because we operate in more than one country, we’ve taken the approach that the broadest definition of personal data is best, because it allows us to explain what we collect more simply. And so, for SoundingBoard’s purposes, personal data is:

Any information that can, either alone or with other information, be used to identify an actual human person or their household. ​

 

3.2 These are the categories of personal data that we collect:

  • “Basic Data” means your name and your email address. Basic Data is collected only if you elect to provide it to SoundingBoard in the course of using the SoundingBoard Application or our marketing website.
  • “Purchase Data” is all Basic Data plus any other information related to the purchase of a subscription of a product or service from us by your employer or any other entity.
  • “Technical Data” means any information we collect as we operate our websites and apps, like your IP address when you connect to our websites, your mobile device identifier, what browser you used to access our site and what operating system you’re using, the movement of your mouse on the screen (mouse hovers and clicks, for example) the length of time you spend on our website, any extensions or apps you use along with ours.
  • “Coaching Session Data” means any data about your attendance at, participation in, or activity during a coaching session or other event hosted by SoundingBoard. This can include data such as your responses during a session, any material you submit, documents you review or download, etc.
  • “Profile Data” means the more detailed SoundingBoard profile information that you’ve set up and shared with us. Your profile data includes your account id, your password, your activity while logged in (including outcomes, written work product, reviews, ratings, submissions, comments, and feedback) and history, and sessions you’ve attended or registered to attend.
  • “Feedback and Marketing Data” means information that we collect to suggest new products or services that you might find interesting. This includes any surveys or questionnaires we conduct (whether they’re in an email, on our website, or at a physical location). Feedback and marketing data also means all other forms of Personal Data, your preferences when it comes to how, when, and why we communicate with you about our products and services, and any interactions you have with our marketing materials (for instance, whether you opened a survey or responded to an in-store questionnaire). Feedback and Marketing Data is collected whenever you provide the types of feedback described in this section or interact with our marketing materials. We talk a lot more about marketing in the section below called “Marketing our Products.”
  • “Third Party Data” means any personal data about you that we obtain – whether by purchasing it or simply receiving it – from anywhere outside of SoundingBoard. We don’t control how those third parties get their data about you, but we won’t take any personal data about you from a third party unless they can prove to us that they had your data lawfully and properly in the first place and are permitted to share it with us. Often times, this data is publicly available information like an address, business title, or social media profile, but it could be just about anything.

 

3.3 As explained below, we may combine different kinds of personal data in the performance of our services. We’ll also sometimes combine the personal data you’ve given us with non-personal data. For example, we might combine data about the time and location of your coaching session with data about your review of the session or the coach to improve our offerings and make changes to our sessions. If the combined data can identify you, we’ll treat it like personal information, even though some parts of the combined data (like the weather) can’t identify you.

3.4 We do not collect any “Special Categories” of Personal Data about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, or information about criminal convictions or offenses.

4. Cookies

We use Cookies and other tracking technology to make our websites operate properly and to provide you with a better experience. You can control how non-technical cookies operate on our sites by clicking on the cookie banner that appears when you visit one of our sites.

5. How we collect personal data:

We collect personal data in a variety of ways, depending on how you interact with us, including:

5.1 Direct interactions. You may give us your Basic, Purchase, Technical, Coaching Session, Profile, or Feedback and Marketing Data, by interacting with us, as when you:
sign up for or take part in sessions;

  • create an account or profile;
  • sign up, attend, speak at, or otherwise participate in one of our sessions or at an event;
  • sign up to receive information, including marketing information, from us;
  • make a claim based on subscription or communicate with us about your enrollment;
  • contact customer support or request technical assistance;
  • access SoundingBoard via social media accounts or SoundingBoard’s website(s);
  • enter a promotion or survey; or
  • give us feedback or reviews.

 

5.2 Through automated technologies or interactions. As you interact with our website, we automatically collect Product Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Product Data about you if you visit other websites employing our cookies.

5.3 From third parties or publicly available sources.  We may receive personal data about you from various third parties and public sources.  We also store or process personal data through our third-party vendors, including

  • completing sales;
  • hosting and managing sessions
  • identifying potential new customers or conducting market research
  • monitoring activity on our website, including user interaction and fraud prevention, and;
  • managing email and marketing campaigns

6. Why (and how) we use personal data:

6.1 We only use personal data when we have a lawful basis for doing so. Sometimes we rely on your consent to use personal data. When we do, we will always give you the option to withdraw your consent at any time.

6.2 The following list sets out how we use personal data, and the lawful basis for doing so:

  • Completing a transaction. We need Basic Data and Purchase Data in order to complete payment for and enrollment in one of our sessions or events. We need this information in order to be able to fulfil our part of our contract with the entity purchasing the coaching session on your behalf, and so collecting this data is necessary to the performance of our contract with you (GDPR art. 6(1)(b)).
  • Providing customer service. Depending upon what you contact us for and request, we will use any and all categories of Personal Data we have in order to provide you with customer service. For instance, if you call us to discuss a problem with your session, we’ll use Basic Data, Purchase Data, and likely also Profile Data to be able to respond to your query. We need this information in order to be able to fulfill our part of our contract with you (GDPR art. 6(1)(b)), and because we have a legitimate interest in being able to respond to your questions (GDPR art. 6(1)(f)).
  • Marketing to you and others. See section 7 below, “Marketing our Products.”
  • Managing our website and services. We’ll use Basic Data, Technical Data, Purchase Data, and Profile Data to keep our website and other online services operating properly (fraud detection and prevention, site maintenance and updates, app maintenance and updates, IP logs). We use this data because we have a legitimate interest in administering/improving our site and apps, running IT services, ensuring network security, preventing fraud (GDPR art. 6(1)(f)), and because we need to demonstrate our compliance with data security obligations both as a legal matter and if we are involved in a business reorganization (a merger or acquisition) (GDPR art. 6(1)(c), GDPR art. 6(1)(f)).
  • Creating insights and analysis. We’ll use Basic Data, Event Data, Profile Data, and Feedback and Marketing Data to analyze what customers are reading, how they use their subscriptions, how they use other products and services related to ours, how we might be able to build better products (better layouts for a publication, for instance) and to understand general trends in the market. We may share or sell those analyses to third parties, and we may also sell or share data about you to providers who would like to market to you. As we explain below, you can decide how much information we share with third parties.
  • Rating, grading, and evaluating performance in sessions. We will store and share with the user’s employer information around engagement with the application. This will include: coach name, manager name, sessions scheduled/completed/missed, goals and insights, and survey information. This information will not be shared with any other individual or entity. We need this information in order to be able to fulfil our part of our contract with you, and so collecting this data is necessary to the performance of our contract with you (GDPR art. 6(1)(6)). [
  • Creating and managing your profile. When you create a profile, you agree to share Basic Data, Coaching Session Data, Usage Data and Profile Data with us so that we can provide you with a tailored, custom experience (use metrics, recommendations, trends, etc). We need this information in order to be able to fulfil our part of our contract with you, and so collecting this data is necessary to the performance of our contract with you (GDPR art. 6(1)(b)).
  • We also use this information to create our own internal user profile for you, which we use to market products to you, deliver content that we think is relevant to you, to advertise to you, to learn about you in particular and our customers more generally, and to create an analysis of our business, our customers, and our market. We have a legitimate interest in doing these things in order to grow our business and learn about our industry (GDPR art. 6(1)(f)), but we will only process this information in this way if you have agreed (consented) to us doing so, and you can withdraw your consent at any time (GDPR art. 6(1)(a)).

 

6.3 We will only keep your Personal Data for as long as necessary under the circumstances in which we collected it, including our obligation to hold onto it for legal, regulatory, or accounting purposes. If we are able to make data completely anonymous (that is, it can’t be used to identify you), we may keep that data indefinitely for statistical or analytic purposes.

7. Marketing our products

A general note on marketing data: We advertise because we want people to participate in to, and get value from, our sessions, and because we want our business to succeed. That means we place ads, send emails, run promotions, send out questionnaires, take surveys, conduct interviews, and do everything else that a marketing department does to try to create a brand. We’re telling you this bluntly so that you have an easier time understanding what we mean when we talk about marketing: it’s our effort to help our business grow. Part of that growth is understanding what our existing coachees like, what they don’t like, and what they might like in the future. We want to know, for instance, why our coachees took part in a particular session. We think that knowing what our customers like will help us improve our existing services and design and deliver new, better ones in the future. The most important part in all of this: you have control over how, and if, we market to you. The basis upon which we use this information is your consent (GDPR art. 6(1)(a)) and you can withdraw that consent at any time. You can always decide how much information you share and how we contact you when it comes to marketing. 7.1 Promotional offers We use your Basic, Coaching Session, Usage, Profile, and Feedback and Marketing Data to create a marketing profile for you so that we can send you information about what sessions, products, or services you may find interesting. If you’ve opted-in to receive communications, we’ll send you emails, texts, or other communications in the format you’ve chosen. We may ask you to opt-in to marketing communications via email, on our website, in the app, or in a physical location like a store or a conference. 7.2 Third-party marketing As explained above, we do share Marketing and Profile data about you with commercial partners and third parties who may want to directly market to you. We will get your express opt-in consent before we share your personal data with any other company for their own marketing purposes. 7.3 Opting out You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience, or other transactions. 7.4 Cookies Cookies are small files that track your activity online. Some of them are purely functional (they allow websites to load faster) and some of them are for marketing (tracking how you interact with websites). We use cookies for both purposes, but you can read more about cookies (and how to block them) in our cookie policy. 7.5 Change of purpose We only use your Personal Data in the ways we’ve outlined in this Privacy Policy, unless we think there is a reason that we can use it for another purpose that 1) is fair, and 2) is compatible with the original reason we collected it. We’ll tell you if we need to use your Personal Data for a purpose other than the original purpose for which we collected it 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. 7.6 Data retention We delete or anonymize your Personal Data as soon as it is no longer required for the purposes we have collected unless we are legally required to continue processing your Personal Data. The one primary exception here is that, if you ask us to delete your data and “forget” you, or ask us not to contact you, we’ll keep your email address on our master do-not-contact list as proof that we followed your request and so that we can avoid contacting you in the future. 7.7 Automated Decisions We don’t use an automated decision-making system (an algorithm or machine learning tool) to make decisions about you. We’ll use a system that makes recommendations for what we think you’ll like, but acting on those recommendations is always in your hands, not ours.

8. Disclosure of your personal data

8.1 Sometimes, we will share your Personal Data with:

  • Outside third parties. As explained above, we use outside vendors and service providers to enable our company to function. The kinds of third parties we share your data with are:
    • Service providers acting as processors based outside of the EEA who provide IT and system administration services including cookies/user experience/analytics.
    • Professional advisers acting as processors including lawyers, bankers, auditors and insurers based outside the EEA who provide consultancy, banking, legal, insurance and accounting services.
  • We’ll also share Personal Data if we buy, sell, transfer, or merge parts of our business with another company.
  • Regulators. If we are subject to an audit, review, or other inquiry by a properly constituted regulatory agency (like the Federal Trade Commission, for instance), they may require us to share the data we have, including Personal Data.
  • Subpoenas and legal demands. We have to comply with lawful subpoenas or investigative demands from courts and law enforcement agencies.

 

8.2 We share your Personal Data outside third parties only to enable us to fulfil our part of our contract with you (GDPR art. 6(1)(b)), because you have consented to it (GDPR art. 6(1)(a)), or because it’s necessary for a legal or regulatory requirement (GDPR art. 6(1)(c)). None of these third parties are allowed to use your Personal Data in any way that is different from the reasons we outline here.

9. International transfers

9.1 We are based in the United States and will transfer data from other parts of the world as outlined in this Privacy Policy.

9.2 For those present in the EU, we won’t transfer your Personal Data outside of the European Economic Area unless the place we are transferring it has a similar degree of protection for personal data as the EEA or we have another lawful basis for transferring the data.

9.3 In order for us to transfer personal data out of the European Union, we’ll need your consent to do so, and we’ll always ask for it before transferring data. We also use the Standard Contractual Clauses in agreements to ensure an adequate degree of security and privacy for personal data.

9.4 If you have questions about transferring data out of the EEA, please contact us and we’ll provide you with more information.

10. Data security

10.1 We work hard to keep your data (and ours) safe.  We use a variety of tools – technological, administrative, and physical – to keep data secure.  These safeguards are designed to ensure that whatever Personal Data we keep is protected against unlawful access or use. Despite our best efforts, however, no security measures are completely impenetrable.

10.2 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 where we are legally required to do so.

11. Your legal rights

11.1 When you provide us with personal data, you have rights about how we use it, and why. In some circumstances, those rights are set out in specific legislation like the European Union’s GDPR, Canada’s PIPEDA, or California’s Consumer Privacy Act. In general, you have the right 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.

 

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

11.2 No fee usually required
In some rare circumstances, you may have to pay a fee regarding a request, but in general you don’t have to pay anything to exercise these data rights.

11.3 What we may need from you
In order to make sure that you’re the person entitled to exercise the rights listed above, we’ll sometimes request information to verify your identity. We will not ask for more data than is necessary to confirm your identity.

11.4 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.

12. Third Party Services

As explained above, we may provide links to websites or services operated by third parties. This Privacy Policy does not apply to these third-party websites or services. If you follow a link to any of these websites or services, please note that these websites or services have their own privacy policies and terms & conditions, and that we do not accept any responsibility or liability for their policies.

13. Contact Us

If you have any questions about this Privacy Policy, please contact us:
By email: [email protected]
By mail:
SoundingBoard
[email protected]
27068 La Paz Rd #318, Aliso Viejo, CA 92656

14. Further Reading

Privacy rights are very complicated.  We want you to be able to make informed choices about how and why you share your data with us.  Here are some links to important guidance and documents from governments and policy groups that talk about key issues.  We’ve outlined key rights under the GDPR and CCPA below, but here are some other helpful links:

Key Terms

The European Commission provides a good explanation of what “personal data” is, and you can read the entire GDPR here

Your EU Rights

If you’re present in the European Union, the Information Commissioner’s Office in the UK provides a succinct explanation the rights you have when it comes to data.

FTC Principles

The Federal Trade Commission is the main agency that handles privacy issues. They have a series of posts about consumer privacy rights that you can read here.

PIPEDA

Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) covers privacy rights as well, and the Office of the Privacy Commissioner offers its explanation of rights here.

15. International Rights

YOUR RIGHTS
Rights for EU Residents
If you are present in the EU, you have the right to:

Request access to your personal data (commonly known as a “data subject access request”) (GDPR art.15). 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 (GDPR art.16). 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 (GDPR art.17). 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. We’ll also maintain a record of your email address in a master list of deletion requests to demonstrate that we have complied with your request and will not contact you in the future.

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 (GDPR art.21). You also have the right to object where 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.

Request restriction of processing of your personal data (GDPR art.18). 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 (GDPR art.20). 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 have the right to object to the processing of your Personal Data under certain circumstances in particular if we process your Personal Data on the basis on legitimate interest (GDPR Art. 6 (1)(b)) or if we use your personal data for marketing purposes.

You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your residence, place of work or place of the alleged infringement if you consider that our processing of your Personal Data infringes the applicable data protection laws. Please contact us at “Contact Us” and we will provide you with detailed information as regards the contact details of the appropriate supervisory authority.

Your California Privacy Rights
If you are a California customer, you have the right to receive, once per year, free of charge, 1) the identity of any third-party company to which we have disclosed your personal information as defined by California’s “Shine the Light” law for that company’s own direct marketing purpose; and 2) a description of the categories of personal information disclosed. To request this information, please contact us at [email protected] or the mail address set forth in the section entitled “Contact Us” below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided email or mail address.

For California residents, you can make a CCPA “Do Not Sell” request to us by either emailing us at [email protected], or contacting us here.

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