Privacy Policy

Privacy Policy

Arden Coaching does not sell your information.

We handle your data the way we would want our data handled.

Arden Coaching is committed to protecting the privacy of our users. We want to provide a safe, secure user experience. We will use our best efforts to ensure that the information you submit to us remains private, and is used only for the purposes as set forth herein. The following reflects our commitment to you.

Information About All Arden Coaching Visitors

In general, we gather information about all of our users collectively, such as what areas users visit most frequently and what services users access the most. We only use such data in the aggregate. This information helps us determine what is most beneficial for our users, and how we can continually create a better overall experience for our users. We may share this information with our partners, but only in the aggregate, so that they too may understand how Arden Coaching users, collectively, use career areas and our site, so they may create a better overall experience for you.

Information About You Specifically

In some instances, such as when you sign up to use a service or enter into a contest we may need more specific information about you, such as name, address, e-mail address, telephone number, etc. We may use that information to make you aware of additional services which may be of interest to you, or to contact you regarding site changes. We may also ask you for other information, such as information on your interests, your likes and dislikes regarding the site, the types of jobs you are interested in, etc., in an effort to deliver to you the best possible site experience.

General Information Disclosure

We do not disclose information about your individual visits to Arden Coaching. But, we may record and share aggregated information with our partners. Also, if you input your information on a co-branded registration page, such as that of Arden Coaching and partner company-sponsored contest, then your information becomes the property of both Arden Coaching and the partner co-sponsoring the contest. In that instance, Arden Coaching is not responsible for the information that the partner company receives.

Privacy Commitment Changes

If we decide to change our privacy commitment for Arden Coaching, we will post those changes here so that you will always know what information we gather, how we might use that information, and whether we will disclose it to anyone.

Safe Harbor Data Privacy Policy

Arden Coaching respects the individual privacy of its clients and customers (and their clients and customers), employees, business partners and others who may use Arden Coaching’s services. In all cases, Arden Coaching treats personal information in a manner consistent with the laws of the countries in which Arden Coaching does business, but it also aims to uphold the highest applicable ethical standards in all its business activities.

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

Consistent with its commitment to protect personal privacy, Arden Coaching declares that it adheres to the Safe Harbor Principles embodied in the Safe Harbor Agreement concerning the transfer of personal data from the European Union to the United States of America. The United States Department of Commerce and the European Commission have agreed on the Safe Harbor Principles as they are articulated in a set of data protection principles and frequently asked questions as a means to enable U.S. companies to satisfy EU law requirements for adequate protection of personal information transferred from the EU to the United States. If there is a conflict between the provisions of this Privacy Policy and the Safe Harbor Principles, the Safe Harbor Principles will govern.

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

The following definitions apply to all statements throughout this Privacy Policy.

“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

Arden Coaching’s operations and processing of personal information conform to the following Safe Harbor Privacy Principles as stated below under the heading of each principle.

Notice and Choice

To the extent permitted by the Safe Harbor Agreement, Arden Coaching reserves the right to process personal information in the course of providing professional services to Arden Coaching’s clients and customers without the knowledge of individuals involved. If and when Arden Coaching collects personal information directly from individuals in the EU, Arden Coaching will inform them about the types of personal information it collects from them, the purposes for which Arden Coaching collects and uses it, and the types of non-agent third parties to which Arden Coaching discloses that information. Arden Coaching will also inform those individuals about the choices and means, if any, that Arden Coaching offers to limit the use or disclosure of their information.

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.

Data Security

To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use and confidentiality of information, either for its own purposes or on behalf of its clients, customers and business partners, Arden Coaching has put in place and rigorously enforces appropriate physical, electronic, and managerial procedures to safeguard and secure the information that Arden Coaching processes. However, Arden Coaching cannot guarantee the security of information on or transmitted via the Internet.

Data Integrity

Arden Coaching processes personal information only in ways compatible with the purpose for which it was collected or subsequently authorized by the individual. To the extent necessary for such purposes, Arden Coaching takes reasonable steps to make sure that personal information is accurate, complete, current, and otherwise reliable for its intended use.

Access and Correction

If an individual becomes aware that information Arden Coaching maintains about that individual is inaccurate, or if an individual would like to update or review that individual’s information, the individual may contact Arden Coaching using the contact information below. In every case, Arden Coaching will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate. The individual seeking to amend such information will need to provide sufficient identifying information, such as name, address, birthdate. Arden Coaching may request additional identifying information as a security precaution. In addition, Arden Coaching may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Agreement.

Enforcement and Dispute Resolution

Arden Coaching utilizes the self-assessment approach to assure its compliance with this Privacy Policy. Arden Coaching periodically verifies that this Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Safe Harbor Principles. Arden Coaching encourages interested persons to raise any concerns about its implementation of this Privacy Policy using the contact information below. Arden Coaching will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Privacy Policy.

For complaints and disputes that cannot be resolved between Arden Coaching and the complainant, Arden Coaching has agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities (DPAs) to resolve disputes pursuant to the Safe Harbor Privacy Principles, as well as to cooperate and comply with the Federal Data Protection and Information Commissioner of Switzerland. The panel may be contacted at ec-dppanel-secr@ec.europa.eu and individual EU DPAs may be contacted directly via the information provided at http://ec.europa.eu/justice/data-protection/bodies/authorities/eu/index_en.htm. The contact information for the Swiss FDPIC can be found at: http://www.edoeb.admin.ch/kontakt/index.html?lang=en.

Arden Coaching is also subject to the jurisdiction of the U.S. Federal Trade Commission.

Changes

Arden Coaching may change this Privacy Policy from time to time, consistent with the requirements of the Safe Harbor Principles or the United States Department of Commerce. Arden Coaching will post any revised privacy policy in its workplaces, train its employees about such changes and how to comply with them, and will publish any amended privacy policy on this Website or a similar Web site that replaces this Web site.

Information Subject To Other Policies Or Standards

Arden Coaching is committed to following the Safe Harbor Principles for all personal information within the scope of the Safe Harbor Agreement. Certain information, however, is subject to policies of Arden Coaching that may differ in some respects from the provisions of this Privacy Policy. Information subject to such additional policies includes information obtained from or relating to a client, customer or business partner or former client, customer or business partner that is subject to the terms of any privacy notice to or agreement with such client, customer or business partner, any engagement letter or letters with such client, customer or business partner, and applicable laws and professional standards.

Contact Information

Questions or comments regarding Arden Coaching’s Safe Harbor certification and this Privacy Policy should be submitted to Arden Coaching by mail or e-mail as follows:

Arden Coaching
Penn Plaza, Suite 6315
New York, NY 10119

-OR-

email to: info@ArdenCoaching.com

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