This Privacy Policy explains the information that Coach-sultancy collect's when you use its services, how that information is used, with whom it may be shared, and your privacy choices.

1. Introduction
Who we are and what we do
This Privacy Policy covers Promo Video, a registered company in the Commonwealth of Virginia (collectively, doing business as “Coach-sultancy",” “we” “us” or “our”). We provide coaching and consulting services. 

Acceptance and Changes
By registering for, or using our services, you accept this Privacy Policy, which is part of our Terms of Service. If you created an account prior to February 7, 2022, this Privacy Policy is effective as of May 19, 2024. We may modify this Privacy Policy from time to time. We will post any modified version of our privacy policy at https://coach-sultancy.com/privacy-policy. If we change the Privacy Policy in a way that materially lessens our commitments to you, we will provide notice to registered users by email or other methods.

2. Children’s Privacy
We do not knowingly collect personal information from individuals who are under the minimum required ages specified herein. You must be at least 16 years old or the age of majority in your jurisdiction, whichever is greater, to use our services. Individuals under the applicable age may use our services only through a parent or legal guardian's account and with their involvement. If you are a parent or legal guardian who believes your child has provided personal information to us without your consent, you may ask us to delete such information by contacting us at video@promo-videos.com.

3. Data We Collect About You
We collect information about you when you use our services. In addition, third parties may collect information about you when you use our services. Collected information may include or reflect personal information that could identify you, as well as non-personal information. We refer to your information as "your data" for short.

Account Information
To create an account, you must provide a valid email address. If you choose to sign-up and/or authenticate using a third-party account (e.g., Google), you authorize us to obtain account information from the third-party platform.

Financial Information
To make a purchase, you may need to provide a valid payment method (e.g., credit card or PayPal account). Your payment information will be collected and processed by our authorized payment vendors. We do not directly collect or store credit or debit card numbers ourselves in the ordinary course of processing transactions. If we allow purchase through a third-party platform (i.e. in-app purchase), the payment method stored with the third-party platform will be charged.

Content You Submit
You may upload content such as videos, text, photographs, and artwork. Your videos may be viewed and otherwise accessed by others, and associated metadata (e.g., titles, closed captions, descriptions, tags, etc.) may be viewable by others, depending on if and how you have shared them. For more details, see Section 9.

Other Information You May Submit
You may submit data to us for limited purposes such as requesting customer support; participating in a survey; entering contests or sweepstakes; applying for a job; or signing up to receive communications from us.

If you request a demo of our services, we will ask you to provide some or all of the following details: name, email, company, type of company, company size, role, country and phone number. We may collect additional personal information if you participate in a sales call, which may be recorded.

Automatically-Collected Information
We automatically collect certain types of data when you use our services, regardless of whether you have an account. This data includes your IP address, geolocation information, technical information about your device (e.g., browser type, operating system, basic device information), the web page you visited or search query you entered before reaching us, and your activities. We may track your activities using cookies and similar technologies. By using our services, you agree to our use of these methods as set forth here and in our Cookie Policy.

Information Collected by Third Parties
Some third parties may collect data about you when you use our services. This may include data you submit (such as payment information) or automatically-collected information (in the case of third-party analytics providers and advertising partners).

4. How We Use Your Data
We may use your data for the following purposes:

Identification and authentication: We use your data to verify you when you access your account.
Operating our services: We use your data to provide our services, process and fulfill orders, provide customer support, and to otherwise comply with our contractual obligations to you. We (and/or our third-party vendors) use your financial information to process purchases made by you and to pay you amounts you have earned.
Communicating with you: We use your data when we communicate with you (e.g., when we respond to a customer support or other inquiry).
Improving our services: We use your data to understand how our services are being used and how we can improve them.
Customizing your experience: We use your data to personalize the service to you. This may include remembering your preferences for language or volume.  Marketing and advertising: Depending on your stated preferences, we may use your data to send you marketing communications.
Exercising our rights: Where reasonably necessary, we use your data to exercise our legal rights and prevent abuse of our service. For example, we may use your data to detect and prevent fraud, spam, or content that violates our Terms of Service. Legal compliance: We use your data where we are legally required to do so. For example, we may need to gather your data to respond to a subpoena or court order. Protecting your information: Where appropriate, we may anonymize, backup, and delete certain data.  We may use algorithms and other automated means to implement any of the above.

Whenever we process your data for one of these purposes, we have determined that one or more of the following lawful bases apply:

Performance of a contract;
Legitimate commercial interest;
Compliance with a legal obligation; or
Consent
If you require further information about the balancing test that Promo Video has undertaken to justify its reliance on legitimate interest as a lawful basis of processing, see Section 14 for information on how to contact us.

5. With Whom We Share Your Data
We share data with third parties as follows:  As you instruct: We may make your profile and videos available to others as you instruct in using our services. We may share your video with persons to whom you have granted access via a shareable link or otherwise.  With your consent: We may share your data with third parties where we have obtained your express consent to do so.  Authorized vendors: We may share your data with third-party vendors that help us operate our services, process orders, and comply with your instructions and our contractual obligations. This includes payment processors, content delivery networks (CDNs), cloud-based hosting services, monitoring services, email service providers, quality assurance and testing vendors, fraud and abuse prevention vendors, and customer relations management (CRM) vendors. Analytics: We may share your data with analytics providers which help us understand how customers are using our services. Affiliates and advisors: We may share your data with our auditors and advisors for planning, financial reporting, accounting, auditing, tax filings, and legal compliance.  Certain legal situations: We may share your data where we believe disclosure is necessary to comply with a legal obligation or in connection with a corporate transaction as discussed in Section 6. Aggregated or anonymized information: We may publicly disclose non-personal aggregated or anonymized information such as our number of visitors and registered users. We use reasonable efforts to vet vendors for their privacy and data security practices. We require that such vendors agree to protect the data we share.

6. Legal and Safety-Related Disclosures
We may disclose your data in response to official requests (e.g., court orders, subpoenas, search warrants, national security requests, etc.) ("requests") that we receive from government authorities or parties to legal proceedings.

We handle U.S. requests in accordance with U.S. law. If the request originates from a foreign jurisdiction, we will typically disclose information where we in good faith believe that disclosure is permitted by both U.S. law and local law. In all cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

We may disclose user data where we reasonably believe that someone's life is at risk. For example, if we become aware of a person threatening to commit suicide, we may share that person's data with appropriate entities that may have the ability to help.

We may disclose user data to report suspected crimes. We report content suspected of exploiting minors to the National Center for Missing and Exploited Children (NCMEC) along with the data identifying the uploading user.

We may disclose user data in situations involving legal claims against us or one of our users. If you submit a Digital Millennium Copyright Act (DMCA) or other takedown notice, we may share that notice with the affected user. If you challenge such a notice, we may share your response with the complainant.

We may share your data with potential transaction partners, advisors, and others in the event our company is, in whole or part, acquired by a third party. In such case, we will use reasonable efforts to require the acquiring entity to comply with this Privacy Policy.

7. Data Retention
We retain your data for as long as you have an account. When you close an account, we will delete its content, including its videos. We may retain logs of automatically collected information (for internal analytics and security purposes); your email address; your tax information; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymize it.

Once you delete a video, we may not be able to recover it. If you have previously made a video public, the video or its thumbnail may be discoverable in a search engine's cache for a time. We have no control over search engines; however, we will, upon request, send a request for deletion to major search engines.

If we receive legal process pertaining to your account, we will retain your data for as long as we in good faith believe is necessary to comply with the legal process. Similarly, if we believe that your account has been involved in wrongdoing, we may preserve your data to defend or assert our rights.

8. Your Privacy Choices
We enable you to make numerous choices about your data:

You may choose not to provide us with certain information. For example, you may choose not to create an account or not to provide optional account information. You may change or correct information voluntarily submitted to us. We encourage you to keep your data current by viewing your settings page. You may opt out of receiving commercial emails from us. See Section 10 for more details. You may limit the use of cookies. See our Cookie Policy for options. You may close your account (which will delete all videos) or delete certain videos.
Users in certain jurisdictions may have additional rights. See Section 13 for more details.

9. Account and Video Privacy Settings
As part of our services we offer you the ability to limit the distribution of your content, including your videos.  Profile: Your profile information is not publicly available or accessible by other Promo Video users.

10. Communications from Us
If you create an account, you may receive commercial emails from us. This includes newsletters and offers. You may always opt out from receiving commercial messages via the unsubscribe link in the footer of the message. Please note that any opt-out request may take several days to process and you will continue to receive transactional emails from us (e.g., emails confirming transactions and/or providing information about your account).

11. Protecting Your Information
We use physical, technical, and organizational security measures to safeguard your data from unauthorized or accidental disclosure. Despite these efforts, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Users also have a role to play in keeping their data safe. We encourage you to use a unique and hard-to-guess password for your account and to not share it with others. You should only grant access rights to people who you know and trust, and, even then, you should be careful in granting all access rights. You should monitor your account regularly. If you believe that someone has gained access to your account without your permission, please contact us immediately so that we can investigate.

12. Third-Party Services
We may provide links to online services that we do not own or operate. These services fall outside of this Privacy Policy and we have no control over the data they collect. Once on a third-party site, your data may be collected by others. We encourage you to read the privacy policies of such services before using them.

You may use our service through third-party sites and to send you offers. For example, you may watch a video that is embedded on a third-party site. This Privacy Policy covers our video player but does not cover any third-party site or any third-party video player.

13. International Data Transfers and Certain User Rights
13.1 Location of Data
Promo Video provides services globally using computer systems, servers, and databases located in the U.S. When you use our services from outside of the U.S., your information may be transferred to and processed in the U.S. Please note that U.S. data and privacy laws may not be as comprehensive as those in your country. Residents of certain countries may be subject to additional protections as set forth in Sections 13.2 below.

13.2 GDPR (EEA and UK Users)
This Section 13.2 applies only to natural persons residing in the European Economic Area and the United Kingdom (for the purpose of this section only, "you" or "your" shall be limited accordingly). It is Promo Video's policy to comply with the EEA's General Data Protection Regulation (GDPR). In accordance with the GDPR, we may transfer your personal information from your home country to the U.S. (or other countries) based upon the following legal bases:

Legitimate business interests: We could not provide our services or comply with our legal obligations without transferring your personal information to the U.S. Our use of Standard Contractual Clauses (also known as "Model Clauses") where appropriate.
You have the right to: access, correct, delete, restrict, or object to our use of your personal information; be forgotten; port your data; and withdraw consents. We enable exercise of these rights primarily through our services (which we reserve the right to modify). For example, we allow users to change their information, download their videos, and close their accounts. We also fulfill our obligations in response to direct requests. We will endeavor to process requests within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe any other person's rights. We reserve the right to request appropriate identification. We will process requests free of charge unless they would impose an unreasonable cost on us.

If you have a request, complaint or inquiry, please contact our Data Protection Officer at the address listed in Section 14. We are committed to working with you to obtain a fair resolution of any issue. You also have the right to file a complaint with the supervisory data protection authority of your jurisdiction.

13.3 California Users
Under California’s “Shine the Light” law, California residents have the right to opt out of disclosing information to third parties for the purpose of allowing such third parties to directly market their products and services. At this time, we do not engage in this type of disclosure.

13.4 Nevada Users
Nevada residents have the right to opt out of the sale of certain "covered information" collected by operators of websites or online services. We currently do not sell covered information, as "sale" is defined by such law, and we don't have plans to sell this information.

14. How to Contact Us
For any questions, inquiries, or complaints relating to your privacy, please contact us at: jeff@coach-sultancy.com