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    Privacy Policy

     Our Privacy Commitment

    TopLine Communication LLC (“company,” “we,” “us”) and its online coaching programs, such as Coaching Right Now, are committed to protecting and safeguarding your personal information.

    We are an approved “Active Participant” (participant in good standing) in the U.S. Department of Commerce (“USDOC”) Privacy Shield Program. In this capacity, we comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield framework as set forth by the USDOC regarding the collection, use, and retention of personal information transferred from the European Union (“EU”), the United Kingdom (“UK”), and Switzerland to the U.S. in reliance on Privacy Shield Principles.

    We also comply with the General Data Protection Regulation (“GDPR”) as adopted and subsequently amended by law, as it applies to the personal data privacy rights of individuals residing in the EU and the United Kingdom.

    Information explaining our privacy policy, including specific Privacy Shield and GDPR provisions, is described below.

    Privacy Summary

    This privacy policy includes a discussion of the following privacy-related areas:

    • Our company’s name, contact information, and designated privacy representative
    • Our adherence to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield framework as it pertains to residents of the EU, the United Kingdom, and Switzerland
    • Our adherence to the General Data Protection Regulation (“GDPR”) as it pertains to residents of the EU and the United Kingdom
    • The types of personal information we collect, and the various ways that personal information is collected
    • The purposes for which our company collects, processes, uses, transfers, and retains personal information
    • Our commitment not to sell, rent, or trade your personal information to unrelated third parties
    • Our commitment not to use your personal information for any purposes other than the business purposes for which it was originally collected without your explicit and advanced consent
    • The types of people who have access to your personal information and the business reasons for their access
    • Our relationships with companies, business partners, and third-party service providers who are working with us and/or acting on our behalf in order to provide our business services to you
    • Our website privacy practices
    • A description of aggregated data and the types of aggregated data we collect
    • Our website cookie policies, including an explanation of cookies, types of cookies, the purposes of cookies, how we use cookies, the “cookie consent” feature, and how to manage your cookies
    • Our marketing communications with you and your right to opt-out at any time
    • Our policies regarding any applicable statutory or contractual requirements or obligations
    • Our policies regarding data storage and retention
    • Our customer choice policies that allow individuals to withdraw consent (“opt out”) where relevant
    • Our policies regarding the sharing of personal information
    • Our policies regarding data transfers and required data disclosures
    • Our policies regarding data security and your access to personal information
    • How to contact us with questions, issues, complaints, or concerns regarding your personal data
    • Our policies regarding dispute resolution and enforcement within the Privacy Shield Framework and how to lodge complaints with relevant contacts and supervisory authorities
    • Our policies regarding dispute resolution and enforcement within the General Data Protection Regulation (“GDPR”) and how to lodge complaints with relevant contacts and supervisory authorities

     

    Privacy Shield – Framework and Principals

    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 transferred from the European Union (EU), the United Kingdom (UK), and Switzerland to the United States in reliance on Privacy Shield.

    TopLine Communication LLC has certified to the U.S. Department of Commerce 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 with respect to such data. If there is any conflict between this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern.

    GDPR – Framework and Principals

    TopLine Communication LLC adheres to the General Data Protection Regulation (“GDPR”), which can be viewed in its entirety at: https://gdpr.eu.

    Our company adheres to the GDPR’s six core principles for processing personal data, which are:

    • Personal data must be processed lawfully, fairly, and transparently
    • Personal data must be collected and processed only for specific and legitimate purposes
    • Data collection should be minimized (collect only what is necessary for business purposes)
    • Accuracy of personal data should be monitored, and timely efforts should be made to rectify incorrect data and comply with reasonable and legitimate data management requests
    • Data should only be stored as long as necessary to fulfill its business purpose
    • Implement appropriate security measures to protect the processing of data

    Types of Personal Information We Collect

    TopLine Communication LLC, through its online management coaching program, Coaching Right Now, hosts, manages, and provides an online coaching platform and related coaching services for businesses, managers, and employees.

    The information we obtain is used for the purposes of business, professional, and personal coaching; training; advice; assessment; evaluation; consultation; feedback; instruction; development; and other related business, professional, and personal development purposes.

    Personal information is collected in a variety of ways including but not limited to website visits, online registrations, contact forms, information requests, surveys, online forums, phone calls, conference calls, video conferences, meetings, emails, individual feedback, coaching sessions, written documents and reports, evaluations, questionnaires, assessments, analytical tools, and coaching and training platforms.

    This personal information is provided by you through your website visits and the information that you provide to us through a variety of means and methods. It is also provided on your behalf by related parties, such as employers, managers, business partners, coaches, etc.

    We collect a variety of personal information that includes, but is not limited to, name, address, email addresses, phone numbers, company information (company name, title, position responsibilities, etc.), resume information (employment history, education, work experience, qualifications, honors, awards, professional credentials, professional skills, language skills, memberships in professional organizations, interests, goals, prior training, etc.), and other related information.

    We do not sell, rent, or trade this information to third parties or use the information for anything other than the business purposes for which it was originally collected.

    Website Privacy Standards

    We appreciate the opportunity to connect with you on our website and are committed to protecting and safeguarding your privacy. In this section, we explain the types of information we collect when you visit our website, how we use that information, any information disclosed to third parties, and the choices you have regarding the use of your personally identifiable information, including your right to view, correct and/or delete that information.

    Visitors can browse most portions of our website without revealing personally identifiable information such as your name, email address, phone number, etc. However, if you choose to voluntarily submit the “Contact Us” form on our website or sign up for any optional services (such as blogs, newsletters, etc.), you are giving your consent for us to use, store, and transfer all the personally identifiable information that you voluntarily provide to us.

    The information we collect is used for the purpose of offering you services and responding to your requests. In such instances, we may also choose to maintain a record of the personally identifiable information you provided in order to respond to your requests and/or offer better service to you in the event you contact us again.

    We collect data from our website which includes, but is not limited to, the Uniform Resource Locator (“URL”) of the website that referred you to us, your Internet Protocol (“IP”) address, cookies, your operating system and browser type, search terms you enter during your visit, etc. This data is primarily collected in an aggregated form in order to provide essential website functions and website analytics.

    By using our website, you acknowledge your acceptance of the Privacy Policy posted and in effect at the time of use.

    Aggregated Data

    Aggregated Data is information that does not, by itself, identify you as a specific individual. Such information includes, but is not limited to, the Uniform Resource Locator (“URL”) of the website that referred you to us, your Internet Protocol (“IP”) address (an automatically generated number assigned to your computer or mobile device when you browse the web), your operating system and browser type, any search terms you enter, etc. This aggregated information is used to monitor the level of internet activity, evaluate our internet effectiveness, and other related activities in order to improve our website and help make your website visit a user-friendly and enjoyable experience.

    We may collect, compile, store, transfer, publish, report, or otherwise use and/or disclose any Aggregated Data, provided that such information does not personally identify you. We do not correlate personally identifiable information with the Aggregated Data we collect.

    If in the future, any Aggregated Data were to be correlated with personally identifiable information, this correlated Aggregated Data would be treated with the same Privacy Protections with which we treat your personally identifiable information.

    Website Cookie Polices

    A “cookie” is a small data file transferred to your computer’s hard drive that allows a website to respond to you in a more user-friendly and responsive way, by gathering and storing information about your user preferences in order to provide you with a customized user experience. The use of cookies is a standard and acceptable website practice

    Cookies also offer users the added convenience of not having to repeatedly re-enter information they have previously provided. In addition, certain personalized features (such as preferences or browsing functions) require cookies to be sent to the user’s computer and/or the use of cookie-based authentication in order to verify the user.

    Most internet browsers (such as Microsoft Internet Explorer, Google Chrome, Firefox, etc.) are automatically set to accept cookies. However, you have the option to adjust these cookie settings, if you wish to do so, by following the instructions on your own computer or mobile devices.

    The cookie settings we use are designed to provide you with the best possible user experience on our website. We offer an opt-in, explicit “cookie consent” option to our website users which give you the right to choose the types of cookies you do or do not wish to use.

    Cookie management options include, but are not limited to, choosing the types of cookies you wish to accept or turning off the cookie function completely. However, please be aware that some websites features may not be available or may not display correctly, if cookies are turned off completely.

    Our website uses the following types of cookies:

    • Essential / Strictly Necessary Cookies: Cookies that are required for basic website functionality. An essential cookie remembers users while they are browsing websites but does not store permanent information. Therefore, this type of cookie is often called session cookie). Essential cookies keep track of what page a user is on, or from what account a user is accessing your site. Under the Cookie Law and the GDPR, essential cookies do not require user consent.
    • Functional / Performance Cookies: Cookies that are used to supplement a website’s functionality and performance but are not strictly necessary. Functional cookies are added to provide users with smooth and positive website user experience. Although functional cookies are not strictly necessary, disabling them may decrease website performance by causing certain website features to be unavailable or not to display correctly. Functional cookies also play an important role in user authentication. Functional cookies primarily use first-party cookies with some third-party cookies for plug-ins, etc. Our company uses Functional cookies optimize website performance and remember your previously selected preferences.
    • Analytics Cookies: Cookies that enable companies to monitor website activity and analytics. This cookie is used to gather analytical data on website usage trends through platforms such as Google Analytics. Much of the data gathered is aggregated and anonymized. Our company uses Analytics cookies to help us improve our products and services being offered to you.
    • Advertising Cookies: Cookies that allow companies to display ads on a website. Our company has many stringent restrictions on advertising and advertising cookies and greatly limits their use.

    TopLine Communication LLC and our online coaching platforms, such as Coaching Right Now, respect your internet privacy. Therefore, our company does not use “surveillance” cookies which are designed to track users’ internet activity even when they are browsing elsewhere on the web. The cookies we use are not designed to give us access to your computer or mobile device.

    Use of Third-Party Media

    Our website occasionally runs limited third-party ads and/or host links (such as on our website, in blogs, in newsletters, in social media, etc.) for companies with whom we have some business relationship. Links to third-party ads are provided for the information, benefit, and convenience of our customers.

    Third parties have their own privacy policies and we recommend that you independently review the privacy policies of every advertiser and website you visit online. Ads and/or links placed on our website do not constitute an endorsement of those companies.

    Marketing Communications

    If you have previously opted to provide us with your contact information and email address, we may offer you select e-communications that we feel correspond with your user preferences, such as newsletters, emails, account service information, blogs, or other similar materials. You have the right to opt out of any or all of these e-communications at any time through the “opt out” feature, which is typically located at the bottom of emails you receive from us.

    You are also invited to voluntarily participate in programs (such as user polls, surveys, questionnaires, etc.) which we use to obtain feedback from our valued customers in order to improve the products and services we offer to you.

    The Sharing of Personal Information

    In accordance with the GDPR and Privacy Shield Principles, we are legally permitted to share your personal information within our company in its various locations and on all of its various coaching platforms, and with all relevant employees, coaches, contractors, business partners, companies, third-party data processors, website service providers, and anyone we believe is necessary to help us complete the purposes for which the personal information was obtained (collectively: “our employees and partners”).

    Our employees and partners, with whom personal information is shared, are expected to abide by the applicable requirements of the GDPR and Privacy Shield framework. Mechanisms such as contracts and/or signed agreements will be used as needed to facilitate compliance.

     

    Data Storage and Retention

    Data is stored and maintained on a secure and limited access company site hosted by TopLine Communication LLC that is located in the United States. Access to stored data is limited to the specific company employees and coaches who require access to that data in order to perform the purposes for which the data was collected. A limited amount of data may also be stored offline in secure and access-controlled locations.

    Data is retained as long as needed to perform the purposes for which it was collected. This time period includes all follow-up and analysis work that our company needs to complete after the close of active engagements. In situations where we expect to have ongoing business or professional relationships with companies or their employees, we may choose to maintain all relevant current and prior data in a secure and access-controlled location for as long as the business or professional relationships with companies or their employees are expected to continue.

    Individuals may request to have their data deleted by sending a written request to the following contact.  If you request us to delete your data, we will respond to you within a reasonable timeframe, regarding the expected timing and the degree to which we expect to be able to complete your request.

    TopLine Communication LLC
    Attn: Ms. Kelly Ellis, Privacy Coordinator
    3 Golf Center #371
    Hoffman Estates, Illinois, 60169
    Email: kelly@coachingrightnow.com

    Customer Choice

    In accordance with the GDPR and Privacy Shield Principles, we offer individuals to ability to withdraw consent (“opt-out”), where relevant, before their personal information is disclosed to an unrelated third party or used for a purpose that is materially different from the purposes for which it was originally collected or subsequently authorized by the individual.

    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 explicit (“opt in”) consent.

    Opt-out requests to limit the use and disclosure of your personal information, must be submitted in writing to the following:

    TopLine Communication LLC
    Attn: Ms. Kelly Ellis, Privacy Coordinator
    3 Golf Center #371
    Hoffman Estates, Illinois, 60169
    Email: kelly@coachingrightnow.com

      

    Privacy Shield – Data Transfers from the EU, UK, and Switzerland

    TopLine Communications LLC expects our third-party service providers and companies with whom we have contractual agreements to adhere to the GDPR and Privacy Shield Principles. When personal data is transferred to third-party service providers acting on our behalf and under our direction, we require those service providers to commit to following the GDPR and Privacy Shield Principles.

    TopLine Communications LLC’s accountability for the personal data it receives and subsequently transfers to a third party is described in the GDPR and Privacy Shield Principles. The company remains responsible and potentially liable as stipulated in the GDPR and Privacy Shield Principles, if third-party service providers who process personal data on our behalf do so in a manner that is inconsistent with the GDPR and Privacy Shield Principles, unless TopLine Communications LLC is able to reasonably demonstrate it should not be held responsible for the event giving rise to the damage.

    In order to fulfill the purposes for which your personal information was obtained, some or all of your information may need to be involved in data transfers to various non-EU countries around the world, including but not limited to, the United States. By providing your personal information to us as part of your program participation, website visits, emails, phone calls, or through any other means, you are authorizing your consent for data transfers and data processing to occur to and within non-EU countries, including but not limited to the United States and in various countries around the world in which we have any kind of business-related or coaching presence.

    GDPR – Data Transfers from the EU and the UK

    On July 16, 2020, the Court of Justice of the European Union issued a judgment declaring the European Commission’s Decision (EU) 2016/1250 on July 12, 2016 as to the adequacy of data protection provided by the EU-U.S. Privacy Shield with regard to GDPR data transfer requirements was “invalid.” As a result of that decision, the EU-U.S. Privacy Shield Framework is no longer a valid data transfer mechanism to comply with EU GDPR data protection requirements when transferring personal data from the European Union to the United States.

    The full judgement of the Court of Justice of the European Union released on July 16, 2020 (also known as the Schrems II decision”) can be read at the following link:

    http://curia.europa.eu/juris/document/document.jsf?text=&docid=228677&pageIndex=0&doclang=en&mode=lst&dir=&occ=first&part=1&cid=9791227

    The Court of Justice of the European Union released a very complex and multi-layered judgement that affects how every U.S. company that does business with residents of the EU and the United Kingdom will be required to change how they handle international data flows and standard contractual clauses.

    Since the July 16, 2020 decision, TopLine Communications LLC has been examining a variety of alternative options and “supplementary measures” (paragraph 133 of the Schrems II decision) with the goal of achieving the standard of “Essential Equivalence” regarding data transfers from the EU and the United Kingdom. We are also actively researching and evaluating how other U.S. companies are responding to this challenge. Additional information will be forthcoming in our next privacy policy update.

     

    Law Enforcement and other Legal Disclosures

    In certain situations, TopLine Communications LLC may be required to disclose personal data in response to lawful requests by public authorities, including as required to meet national security or law enforcement requirements.

    For example, we may be required to provide personally identifiable information in response to court orders, subpoenas, government investigations, or other matters of legal, investigative, and/or national importance. We also reserve the right to report to law enforcement agencies any activities that we in good faith suspect to be in violation of the law. We may also release personally identifiable information when such release is reasonably necessary to protect the rights, property, safety, or lives of others and ourselves.

    Should TopLine Communications LLC or any of its current or future related entities merge with or be acquired by another business entity, or its respective assets be acquired, we may need to share your personally identifiable information with companies involved in these actions, especially those companies who may be assuming the role of serving you in the future.

    Security

    The security of your personal information is a high priority. We protect this information by taking reasonable steps in 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 and business partners (as defined above) 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.

    Because your username and password are specific to you, you acknowledge sole responsibility for any and all use of our website and/or any applications or platforms conducted with your username and password. It is your responsibility to safeguard the username and password you use to access our website and/or any applications or platforms, and to promptly advise us if you suspect your username and password have been compromised.

    Business-Related Access to Your Personal Information

    Access to the personal information collected by our company is limited to you, your employer, your managers, your coaches, and to company employees who are involved in maintaining, managing, updating, reviewing, and storing your personal information.

    A select number of coaches will also work directly with you and your employer/managers, to coach, train, assess, evaluate, consult, instruct, review, and interpret your personal information as it relates to offering coaching services.

    Additionally, information may be provided to related third parties, such as business partners, 360-degree report vendors, online training services, eLearning platforms, etc., who are relevant to or consistent with the core purposes of coaching, assessing, advising, evaluating, consulting, training, etc.

     

     

    Your Access to Your Personal Information

    We recognize your right to have access to your personal information and will allow you to correct, amend, or delete 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, could be violated.

    Residents of the EU, the United Kingdom, and Switzerland have the right to access their personal data in order to review, amend, edit, change, or delete it, by sending a written request to the following contact.  If you request us to delete your data, we will respond to you within a reasonable timeframe, regarding the expected timing and the degree to which we expect to be able to complete your request.

    Residents of EU member countries, the United Kingdom, and Switzerland also have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Individuals seeking access to their data should direct their inquiry to the following:

    TopLine Communication LLC
    Attn: Ms. Kelly Ellis, Privacy Coordinator
    3 Golf Center #371
    Hoffman Estates, Illinois, 60169
    Email: kelly@coachingrightnow.com

    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.

    Statutory or Contractual Requirements or Obligations

    We will inform you whether the provision of your personal data is part of a statutory or contractual requirement or obligation and the possible consequences of failing to provide your personal data under those circumstances. However, given the nature of our business, it is unlikely this situation will occur.

    Privacy Shield – Dispute Resolution and Enforcement Provisions

    TopLine Communication LLC commits to resolve complaints about your privacy matters or the collection or use of your personal information transferred to the United States pursuant to applicable Privacy Shield Principles.

    Residents of EU member countries, the United Kingdom, and Switzerland who have any Privacy Shield related inquiries or complaints are required to first directly contact TopLine Communication LLC at the following address to communicate their questions or concerns, and attempt to achieve satisfactory resolution, prior to pursuing any other course of action.

    TopLine Communication LLC
    Attn: Ms. Kelly Ellis, Privacy Coordinator
    3 Golf Center #371
    Hoffman Estates, Illinois, 60169
    Email: kelly@coachingrightnow.com

    We will investigate and attempt to satisfactorily answer your inquiries and resolve any complaints or disputes regarding the use or disclosure of the personal information of EU, United Kingdom or Swiss residents in accordance with the Privacy Shield Framework 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 Privacy Shield Principles to an Independent Dispute Resolution Mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit the following link for more information and/or to file a complaint. This service is provided to you free of charge.

    https://bbbprograms.org/programs/all-programs/bbb-eu-privacy-shield-consumers/ProcessForConsumers

    With respect to personal data received or transferred in accordance with Privacy Shield frameworks, TopLine Communication LLC is subject to the investigation and enforcement authority of the U.S. Federal Trade Commission (“USFTC”).

    If a Privacy Shield complaint cannot be resolved through the above channels, it may be possible for individuals under certain limited and legally defined conditions, to invoke binding arbitration for some residual claims not resolved by other redress mechanisms. For additional information, please see the Privacy Shield framework section entitled “EU-U.S. Annex I (Binding Arbitration)” which can be found at: https://www.privacyshield.gov/EU-US-Framework

    Please note that these Privacy Shield rights, responsibilities, and provisions, as outlined in this privacy policy, and as described on the Privacy Shield website (https://www.privacyshield.gov/) apply only to the personal data of EU, United Kingdom, and Swiss residents whose personal data is transferred to the United States pursuant to Privacy Shield Policies.

    To learn more about the Privacy Shield program, and to view our Privacy Shield Certification page, please visit https://www.privacyshield.gov/

    GDPR – Dispute Resolution and Enforcement Provisions

    TopLine Communication LLC commits to resolve complaints about your privacy matters or the collection or use of your personal information transferred to the United States pursuant to applicable GDPR provisions.

    Residents of EU member countries and the United Kingdom who have any GDPR-related inquiries or complaints are required to first directly contact TopLine Communication LLC at the following address to communicate their questions or concerns, and attempt to achieve satisfactory resolution, prior to pursuing any other course of action.

    TopLine Communication LLC
    Attn: Ms. Kelly Ellis, Privacy Coordinator
    3 Golf Center #371
    Hoffman Estates, Illinois, 60169
    Email: kelly@coachingrightnow.com

    We will investigate and attempt to satisfactorily answer your inquiries and resolve any complaints or disputes regarding the use or disclosure of the personal information of EU or United Kingdom residents in accordance with the GDPR provisions 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 to the relevant Data Protection Authority (DPA) which can be found at the following link:

    http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

    With respect to personal data received or transferred in accordance GDPR, TopLine Communication LLC is subject to the investigation and enforcement authority of the U.S. Federal Trade Commission (USFTC).

    Please note that the GDPR rights, responsibilities, and provisions, as outlined in this privacy policy, and as described on the GDPR website (https://gdpr.eu) apply only to residents of the EU and the United Kingdom.

    To learn more about the GDPR, please visit https://gdpr.eu.

    Contact Information

    This privacy policy may be amended from time to time as required in a manner that is consistent with Privacy Shield and GDPR provisions. All updated privacy policies will be posted on our company website at https://www.coachingrightnow.com and our Privacy Shield Certification page on the U.S. Department of Commerce Privacy Shield website: https://www.privacyshield.gov.

    If desired, you may obtain an oral copy of our privacy policy free of charge upon request.

    f you have any questions, comments, or concerns regarding our privacy policy or data collection and processing practices please contact us at:

    TopLine Communication LLC
    Attn: Ms. Kelly Ellis, Privacy Coordinator
    3 Golf Center #371
    Hoffman Estates, Illinois, 60169
    Email: kelly@coachingrightnow.com

     

    Effective Date: 9/15/2020