TopLine Communication LLC

Privacy Shield – Privacy Policy

 
 

TopLine Communication LLC (“Company,” “we,” “us”) wants to safeguard your personal information. This policy describes our privacy practices regarding the collection, use, storage, and transfer of information from individuals residing in European Union (“EU”) member countries and Switzerland, in connection with our Company and its online coaching programs, such as Coaching Right Now.

TopLine Communication LLC complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce (“DOC”) regarding the collection, use, and retention of personal information from EU member countries and Switzerland. TopLine Communication LLC has certified to the DOC that it adheres to the Privacy Shield Principles of notice; choice; accountability for onward transfer; security; data integrity and purpose limitation; access; and recourse, enforcement and liability. If there is any conflict between Privacy Shield Principles and this privacy policy, the Privacy Shield Principles shall govern.

The EU-U.S. and Swiss-U.S. Privacy Shield Frameworks were designed by the DOC and the European Commission and Swiss Administration to provide companies with a mechanism to comply with data protection requirements when transferring personal data from the EU and Switzerland to the United States in support of transatlantic commerce. To learn more about the Privacy Shield program, and to view our certification page, please visit: https://www.privacyshield.gov/.

Notice of Information Collected and Maintained on the Company Site

Coaching Right Now is an online management coaching platform that TopLine Communication LLC delivers to and hosts for corporations and their managers and employees. The information we obtain is used for the purpose of personal coaching, assessment, training, advice, and other related purposes. This includes both the information provided directly by your employer on your behalf and the information you submit to us, via phone, website, email, or other means.

We collect personal information from our clients, such as name, address, email addresses, phone numbers, and resume information (e.g., company name, employment history, education, experience, job qualifications, professional credentials, skills, language skills, memberships in professional organizations, etc.). Personal information is defined within the context of Privacy Shield provisions as information that: (1) is transferred from citizens of the EU and/or Switzerland to the United States, (2) is recorded in any form, (3) is about or pertains to a specific individual, and (4) can be linked to that individual. This information is collected both online and offline and is maintained on the Company site that is hosted by TopLine Communication LLC in the United States.

Use, Purpose and Disclosure Policies of Information Maintained on the Company Site

Access to the information collected and maintained on the Company site is limited to your employer and to our selected Company employees who are responsible for maintaining and updating your data profile. Selected online coaches may also work directly with you and/or your employer to assess, evaluate, coach, consult, instruct, and/or interpret the information in your data profile. Additionally, information may be provided to third parties, such as business partners, 360 degree report vendors, etc., who are relevant to or consistent with the purposes of coaching and/or evaluation processes. We may also be required to disclose certain personal information in response to lawful requests made by public authorities necessary for national security and/or law enforcement requirements.

Data Integrity and Purpose Limitation

We process personal information in a way that is compatible with and relevant for the purposes for which it was originally collected from or subsequently authorized by the individual. To the extent necessary for these purposes, the Company shall take reasonable measures to ensure that personal information collected is accurate, complete, current, and reliable for its intended use.

Security

The security of your personal information is our high priority. We protect this information by maintaining physical, technical, and procedural safeguards to protect your personal information from loss, misuse, error, unauthorized access or disclosure, alteration, and destruction. We use a self-assessment approach to periodically review our privacy policies to ensure they are accurate, properly displayed, consistent with privacy principles and are appropriate for the purposes for which the information was intended to be collected and used. Access to the information collected and maintained by the Company is limited to you and your employer and to selected Company employees who are responsible for using, maintaining and updating your data profile. Selected coaches may also work directly with you and your employer to assess, evaluate, coach, consult, instruct, and/or interpret the information in your data profile.

Onward Transfers and Disclosures to Service Providers

If we need to transfer information to a third party service provider who is acting on our behalf and under our direction we will seek to ascertain that the service provider also subscribes to the relevant EU-U.S. and Swiss-U.S. Privacy Shield provisions. TopLine Communications LLC may be liable for the appropriate onward transfer of personal information to third parties.

Customer Choice and Access

We recognize the individual’s right to access their personal information. As a valued customer, you have the opportunity to review your personal data and make choices about how it can be used and shared. In the event your personal information is intended to be used for purposes that are incompatible with the purposes for which it was originally collected or subsequently authorized by you, or disclosed to an unrelated third party, we will inform you and offer you the ability to opt out of such uses and/or disclosures. If we need to disclose sensitive personal information to an unrelated third party or use it for a purpose that is incompatible with the purpose for which it was originally collected or subsequently authorized by you, we will obtain your express consent. We may also be required to disclose personal information in response to lawful requests made by public authorities necessary for national security and/or law enforcement requirements.

We will allow you to have access to your own personal information and allow you to correct, amend, or delete any inaccurate information, except where the burden or expense of providing such access would be disproportionate to the risks to the individual’s privacy regarding the case in question, or where the rights of persons, other than the individual, would be violated. To access your personal information you may contact us at the following address:

TopLine Communication LLC
Attn: Ms. Kelly Ellis, Privacy Shield Program Coordinator
4707 West Farwell Avenue
Lincolnwood, IL 60712
Email: kelly@coachingrightnow.com

Resolution and Enforcement Provisions

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, TopLine Communication LLC commits to resolve complaints about your privacy and/or our collection or use of your personal information. Citizens of EU member countries and Switzerland who have inquiries or complaints regarding this privacy policy should first contact TopLine Communication LLC at the following address to communicate their concerns:

TopLine Communication LLC
Attn: Ms. Kelly Ellis, Privacy Shield Program Coordinator
4707 West Farwell Avenue
Lincolnwood, IL 60712
Email: kelly@coachingrightnow.com

We will investigate and attempt to satisfactorily resolve any complaints or disputes regarding the use or disclosure of the personal information of EU or Swiss citizens in accordance with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as outlined in this privacy policy.

If a complaint or dispute cannot be resolved through our internal processes, TopLine Communication LLC has further committed to refer unresolved privacy complaints under the EU-U.S. or Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacyshield/for-eu-consumers for more information and/or to file a complaint. It may also be possible under certain limited conditions for individuals to invoke binding arbitration before the Privacy Shield Panel, to be created by the U.S. Department of Commerce and the European Commission. TopLine Communication LLC is subject to the investigation and enforcement authority of the U.S. Federal Trade Commission (FTC).

Contact Information

TopLine Communication LLC’s privacy policy is available by request and is posted on our Privacy Shield Certification page on the U.S. Department of Commerce website at: https://www.privacyshield.gov.

Any questions, comments, or concerns regarding our EU-U.S. and Swiss-U.S. Privacy Shield Privacy Policy or data collection and processing practices can be mailed or emailed to:

TopLine Communication LLC
Attn: Ms. Kelly Ellis, Privacy Shield Program Coordinator
4707 West Farwell Avenue
Lincolnwood, IL 60712
Email: kelly@coachingrightnow.com

This privacy policy may be amended from time to time as required in a manner that is consistent with Privacy Shield provisions. We will make any revised privacy policies available upon request and post them on our Privacy Shield Certification page on the U.S. Department of Commerce website at: https://www.privacyshield.gov.

Effective Date: 6/12/2017