Privacy Policy We do not sell your information

Information About All Arden Coaching Visitors

Information About You Specifically

General Information Disclosure

Privacy Commitment Changes

Safe Harbor Data Privacy Policy

Effective May 21, 2018, this Privacy Policy sets forth the privacy principles that Arden Coaching follows with respect to the protection and transfers of personal information, whether it is in electronic, paper or verbal format, between the United States and the EU. This statement applies to all personal information Arden Coaching processes (except as noted below), including on-line, off-line, and manually processed data. Any employee whom Arden Coaching determines is in violation of this Privacy Policy will be subject to disciplinary process, up to and including termination.

Safe Harbor

Arden Coaching complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Arden Coaching has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.

Definitions

“Personal information” means any information or set of information that is transferred from the EU to the United States, is recorded in any form, pertains to or is about any individual, and can be linked to or used to identify that individual. Personal information does not include information that is encoded, anonymized, or publicly available information that has not been combined with non-public personal information. Personal information does not include information that pertains to or is about a specific individual, but from which that individual could not reasonably be identified.

“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. For purposes of this Privacy Policy, Arden Coaching will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

The Privacy Principles

Notice and Choice

Disclosures and Transfers

Arden Coaching will not disclose an individual’s personal information to third parties, except when one or more of the following conditions is true:

* Arden Coaching has the individual’s permission to make the disclosure;
* The disclosure is required by law or professional standards;
* The disclosure is reasonably related to the sale or disposition of all or part of Arden Coaching’s business;
* The information in question is publicly available;
* The disclosure is reasonably necessary for the establishment or defense of legal claims; or
* The disclosure is to another Arden Coaching entity or to persons or entities providing services on Arden Coaching’s or the individual’s behalf (each a “transferee”), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:
* is subject to law providing an adequate level of privacy protection;
* has agreed in writing to provide an adequate level of privacy protection; or
* subscribes to the Safe Harbor Principles.

Permitted transfers of information, whether to third parties or within Arden Coaching, include the transfer of data from one jurisdiction to another, including transfers to and from the U.S. Because privacy laws vary from one jurisdiction to another, personal information may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the information originated.