TopLine Communication LLC

Privacy Promise:
GDPR & Privacy Shield

 
 

TopLine Communication LLC (“Company,” “we,” “us”) and its online coaching programs, such as Coaching Right Now, want to safeguard your personal information. Therefore, we are adopting applicable General Data Protection Regulation (GDPR) requirements, which became effective May 25, 2018. In addition, we are an approved “Active Participant” (a participant in good standing) in the U.S. Department of Commerce’s “Privacy Shield” program framework for U.S. companies.

This policy describes our privacy practices regarding our website and the collection, use, storage, and transfer of information from individuals residing in European Union (“EU”) member countries and Switzerland, in connection with services provided by our Company.

Website Privacy Standards

We appreciate the opportunity to connect with you on our website and are committed to protecting and safeguarding your privacy. We wish to inform you about 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, when you choose to submit the “Contact Us” form on our website or sign up for any optional services (such as blogs, newsletters, etc.), you are providing your consent for us to use and retain all the personally identifiable information that you submit to us. This information is collected for the purpose of providing you services and responding to your request. 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 do not rent, sell, or trade this information to third parties or use this information for anything other than the business purposes for which it is intended.

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

Your Email Address

If you have previously provided us with your contact information, we may offer 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 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 customers in order to improve the products and services we offer.

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 (which is a number that is automatically generated and assigned to your computer or mobile device when you surf the web), your operating system and browser type, any search terms you enter, etc. Our web server uses this aggregated information to monitor the level of internet activity, evaluate our internet effectiveness, and other similar activities to improve our webite content and make your website visit a user-friendly and enjoyable experience.

We may collect, compile, store, 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.

Use of Cookies

A “cookie” is a small data file transferred to your computer’s hard drive that allows a website to respond to you as an individual, by gathering and storing information about your user preferences in order to provide a more customized user experience based on your likes and dislikes. Cookies also offer users the convenience of not having to re-enter information they have already provided over and over again.

Most internet browsers (such as Microsoft Internet Explorer, Google Chrome, Firefox, etc.) are automatically set to accept cookies. However, we wish to inform you that you may adjust these cookie settings by following the instructions on your own computer or mobile devices, if you desire. Types of adjustment include: notifying you of cookie placement requests, refusing certain types of cookies, or turning off the cookie function. Please note that some websites features may not be available or may not display correctly, if cookies are turned off completely.

Certain personalized features (such as select ordering or browsing functions) require that a cookie be sent to the user’s computer hard drive and/or use cookie-based authentication to verifier properly registered users. However, the use of cookies is considered a standard and acceptable website practice. Our use of cookies does not provide us with access to your computer or mobile device. In addition, our Company has chosen not use “surveillance” cookies which are designed to track users’ internet activity elsewhere on the web.

Use of Third-Party Media and Related Companies

Our website may run limited third-party ads and/or links (on our website, in blogs, in newsletters, etc.) for partners with whom we link. Links to third-party ads are provided for the information and convenience of our users and do not constitute an endorsement.

This Privacy Policy does not cover the data security practices of other websites that may have links to our website, nor do we control their content or privacy policies. Therefore, we suggest you review the privacy policies of every website you visit.

The Sharing of Personally Identifiable Information

We are legally permitted to share the personally identifiable information you provide to us internally within our company and its various locations and online coaching platforms, and with our trusted contractors, business partners, and processors, as necessary to complete the purposes for which the personally identifiable information was originally obtained, as well as with those who provide services to our website (collectively: “our Partners”).

Our Partners, with whom any personally identifiable information is shared, are expected to abide by all applicable requirements of GDPR and the Privacy Shield framework. Mechanisms are in place to help ensure compliance, such as contracts and/or signed agreements.

Law Enforcement and other Legal Compliance Requirements

From time to time, 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 believe to be unlawful. We may release personally identifiable information when we believe that such release is reasonably necessary to protect the rights, property, and/or safety of others and ourselves.

Should our Company or its related entities ever merge with or be acquired by another business entity, or its respective assets be acquired, we may need to share some or all of 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.

Non-EU Countries

In order to fulfill the purposes for which your personally identifiable informaiton is obtained, some or all of your information may need to be involved in data transfers to various non-EU countries around the world, including the United States of America. By submitting your personally identifiable information to us via our website, emails, program participation, or through any other means, you authorize your consent to such transfers to non-EU countries and to the potential processing of this information in various countries around the world.

EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework - Overview

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, concerning the transfer of personal data from the European Union (“EU”) to the United States of America.

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/

Privacy Shield Framework Principles

TopLine Communication LLC has certified to the DOC that it adheres to the Privacy Shield Principles of Notice; Choice; Data Integrity and Purpose Limitation; Security; Accountability for Onward Transfer; 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.

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, including a variety of training platforms.

Access to the information collected and maintained on the Company site is limited to your employer and to 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, online training and eLearning platforms, 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.

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.

Customer Choice

In accordance with the Privacy Shield framework, we offer individuals the opportunity to choose (opt out) whether their personal information is to be disclosed to a third party or to be used for a purpose that is materially different from the purposes for which it was originally collected or subsequently authorized by the individuals. It is not necessary to provide choice when disclosure is made to a third party acting as an agent to perform tasks on behalf of and under the instructions of the Company, when the third party is also adhering to GDPR requirements and to the Privacy Shield framework.

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 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 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 user name 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 user name and password. It is your responsibility to safeguard the user name and password you use to access our website and/or any applications or platforms, and to promptly advise us if you suspect your user name and password have been compromised.

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 GDPR AND EU-U.S. and Swiss-U.S. Privacy Shield provisions. Any company with which we have a contractual agreement is expected to observe the intent of GDPR requirements and the Privacy Shield framework. TopLine Communications LLC may be liable for the appropriate onward transfer of personal information to third parties.

Customer Access

We recognize your right to access your own 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 matters 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 are required to first contact TopLine Communication LLC at the following address to communicate all 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 Communications 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 (DOC) Privacy Shield 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 GDPR and Privacy Shield provisions. We will make all updated privacy policies available upon request and post them on our company website and post them on our Privacy Shield Certification page on the U.S. Department of Commerce (DOC) Privacy Shield website at: https://www.privacyshield.gov.

Effective Date: 5/25/2018