Privacy Policy

This website is ran by Strada Collaborative, LLC doing business as InsideTrack (hereinafter, “InsideTrack,” “we,” “our,” or “us”). We respect your privacy and are committed to protecting your information. The data privacy policy below discloses our practices regarding information collection and usage for our website insidetrack.org and the coaching platform used by our coaches called the “weCoach Platform” (collectively, the “Services”). This data privacy policy does not apply to any other websites, apps, or services provided by us, or our affiliates or clients, unless it appears on such website, app, or service.

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This data privacy policy aims to give you information on how we collect and process your information through your use of the Services, including any data you may provide through the website or through weCoach, or when you contact us using the contact information below.

This data privacy policy is provided in a layered format set out below:

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• Information Collection, Use & Sharing
• Third-party Links and Social Networking Services
• Data Security
• Data Retention
• Your Rights & Choices
• Rights of EU Data Subjects
• Data Relating to Children Under 13
• Cross Border Transfer
• California Shine The Light Law
• Updates to this Privacy Policy

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Information Collection, Use & Sharing

Categories of Personal Information We Collect:

We may collect certain information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household (“Personal Information”).  Personal Information does not include de-identified or aggregated consumer information. 

The following types of Personal Information may be collected.

• Identifiers, such as name, postal address, unique personal identifier, internet protocol address, email address, social security number, driver’s license number, signature, telephone number, education or employment history, financial account information, or other similar identifiers.
• Demographic information, such as race, national origin, citizenship, marital status, medical condition, physical or mental disability, or sex (including gender or gender identity).
• Commercial information, including products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.
• Internet or other similar network activity, including browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement.
• Geolocation data is gathered when users interact with our website as IP addresses are obtained when users interact with our Services, and IP addresses provide information about users’ approximate location.
• Audio information may be gathered from use of our Services when a user communicates on the weCoach platform.
• Professional or employment information may be gathered from use of our Services when such content is uploaded by users of our Services.
• Education information, such as personally identifiable information under the Family Educational Rights and Privacy Act.
• Profile information, such as inferences drawn from Personal Information reflecting a user’s preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes.

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Categories of Sources for Personal Information We Have Collected:

• We have received Personal Information from users of the Services through their direct interactions with our Services, including by downloading the weCoach mobile app, interacting with coaches as part of our Services, or by submitting a request for information from a school or institution that is a customer of InsideTrack.
• We have collected Personal Information, such as technical data, usage data, and location data, through automated technologies and users’ interactions with our Services, and from service providers that have collected information about users’ interactions with our Services and from whom we have received such information.
• We have received Personal Information from partners with which we have contractual relationships, such as educational institutions and other organizations, about users of our Services.

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Our Business or Commercial Purposes for Collecting Personal Information, and Categories of Third Parties to Whom the Information was Disclosed:

• Identifiers are collected to market to individuals and to provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, to administer your account and process your payments for Services, and to respond to direct inquiries. We may share this Personal Information with our parent company, Strada, any of Strada’s subsidiaries, affiliates, and divisions, and our service providers that assist us to provide users with the Services, or with partners such as educational institutions and other organizations with which we have contracts to provide Services.
• Demographic information is collected to market to individuals and to provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, and to respond to direct inquiries. We may share this Personal Information with our parent company, Strada, any of Strada’s subsidiaries, affiliates, and divisions, and our service providers that assist us to provide users with the Services, or with partners such as educational institutions and other organizations with which we have contracts to provide Services.
• Commercial information is collected to provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, to process payments for Services, and to respond to direct inquiries. We may share this Personal Information with our parent company, Strada, any of Strada’s subsidiaries, affiliates, and divisions, and our service providers that assist us to provide users with the Services, or with partners such as educational institutions and other organizations with which we have contracts to provide Services.
• Internet or other similar network activity is collected to market to individuals and to provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, to administer your account and process your payments for Services, and to respond to direct inquiries. We may share this Personal Information with our parent company, Strada, any of Strada’s subsidiaries, affiliates, and divisions, and our service providers that assist us to provide users with the Services and to provide fraud protection, or with partners such as educational institutions and other organizations with which we have contracts to provide Services.
• Geolocation data is collected to market to individuals and to provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, and to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity. We may share this Personal Information with our parent company, Strada, any of Strada’s subsidiaries, affiliates, and divisions, and our service providers that assist us to provide users with the Services and to provide fraud protection, or with partners such as educational institutions and other organizations with which we have contracts to provide Services.
• Audio information is collected to provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, and to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity. We may share this Personal Information with our parent company, Strada, any of Strada’s subsidiaries, affiliates, and divisions, and our service providers that assist us to provide users with the Services and to provide fraud protection, or with partners such as educational institutions and other organizations with which we have contracts to provide Services.
• Professional or employment information is collected to market to individuals and to provide users with our Services, to improve the quality, safety, and security of the Services, and to customize and improve our Services. We may share this Personal Information with our parent company, Strada, any of Strada’s subsidiaries, affiliates, and divisions, and our service providers that assist us to provide users with the Services and to provide fraud protection, or with partners such as educational institutions and other organizations with which we have contracts to provide Services.
• Education information is collected to provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, and to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity.  We may share this Personal Information with our parent company, Strada, any of Strada’s subsidiaries, affiliates, and divisions, and our service providers that assist us to provide users with the Services, or with partners such as educational institutions and other organizations with which we have contracts to provide Services.
• Profile information is collected to market to individuals and to provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, and to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity. We may share this Personal Information with our parent company, Strada, any of Strada’s subsidiaries, affiliates, and divisions, and our service providers that assist us to provide users with the Services and to provide fraud protection, or with partners such as educational institutions and other organizations with which we have contracts to provide Services.

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In addition, where consistent with applicable laws and regulations, we may disclose Personal Information in all categories above:

• To prepare, negotiate, or perform a contract with users;
• To respond to subpoenas, court orders, or other legal process or otherwise as required by law or the competent government or judicial authorities;
• To protect life and safety against the threat of serious injury or death;
• To establish or preserve a legal claim or defense;
• As part of corporate restructuring, sale of assets, merger or divestiture; or
• To prevent fraud or other illegal activities, such as willful attacks on our information technology systems.

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No Sale of Personal Information

In the preceding 12 months, we have not sold and will not sell (as that term is defined in the California Consumer Privacy Act) any Personal Information to non-affiliated third parties without your consent.  We also have not and will not sell the Personal Information of minors under 16 years of age to non-affiliated third parties without affirmative consent.

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Third-Party Links and Social Networking Services

Our Services may contain links to other websites.  If you use these links to leave our site, you should note that we do not have any control over that website, and that website’s privacy practices are not governed by this privacy statement.  You should exercise caution and review the privacy statement applicable to such websites to learn more.

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Data Security

We have put in place reasonable security measures to prevent information about you from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed; however, due to the inherently open nature of the Internet, we cannot ensure or warrant the security of any information provided online.

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Data Retention

We will only retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.  In some circumstances you can ask us to delete your data: see Your Rights & Choices below for further information. 

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Your Rights & Choices

We provide users with specific rights regarding their Personal Information.  This section describes the rights that we provide and explains how to exercise those rights.

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Choices and Access

Your choices regarding our use and disclosure of Personal Information 

We give you certain choices regarding our use and disclosure of your Personal Information for promotional purposes.  You may opt out from receiving electronic communications from us by contacting us at privacy@insidetrack.org.  If you no longer want to receive promotional-related emails from us, you may opt out according to instructions in such communications.  Please note that if you opt out of receiving marketing-related messages, we may still send you important administrative messages. You can also unsubscribe from further communications from a coach by informing them that you no longer wish to receive messages via weCoach. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of weCoach may no longer be available to you.

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Opting Out of Cookies

If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of the Services, including weCoach, or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your device without your knowledge.

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Opting Out of Location Tracking

You may also adjust the settings on your mobile device to allow or restrict the sharing of location information. For example, the “location” permissions on your mobile device may allow you to elect whether to never share location information with us, to share location information only while you are using the weCoach mobile app, or always share location information even if you are not using the weCoach mobile app. If you elect to not share your location information, you may be unable to access some features of our Services that are designed for mobile devices. Also, in the event that you prevent the sharing of location information, we may still estimate your general location based on the IP address you use to access our Services.

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Access, Change, or Deletion of Personal Information

To the extent applicable law provides you with the right to review, correct, update, or delete Personal Information that you previously have provided to us, please contact us at privacy@insidetrack.org to do so.  We will respond to your request consistent with applicable law.

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Rights of EU Data Subjects

Our role as data controller and data processor

InsideTrack generally acts as the data controller of your Personal Information submitted through the Services, including weCoach; however, under certain circumstances, the schools and institutions we are contracted with may engage us to provide them with certain processing services related to Personal Information owned or controlled by the school and institution. We are not responsible for any school’s or institution’s use of Personal Information for which it is an owner or controller. As processor for a school or institution, we only act under their instruction with respect to the processing of your Personal Information. To learn more about how a specific school or institution may use Personal Information, you should review its respective privacy policy.

If you are situated in the EU and have any complaints regarding our privacy practices as a data controller, you have the right to make a complaint at any time to your local supervisory      authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us first. Please see our contact details below in the section titled “Contact Us,” If you are situated in the EU and have a complaint, please contact us at privacy@insidetrack.org.

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Provision of Personal Information and Failure to Provide Personal Information

Where we need to collect Personal Information by law or under the terms of a contract we have with you and you fail to provide that Personal Information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services). In this case, we will not be able to provide our Services to you.

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Legal Basis for Our Processing of Your Personal Information

We rely on your Personal Information for the legitimate commercial purposes of providing our Services to you, to provide you the best service/product and the best and most secure experience, or to perform our responsibilities under a contract with you or your educational institution. We also may rely on your consent to collect, use, or disclose your Personal Information. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at privacy@insidetrack.org.

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Change of Purpose

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at privacy@insidetrack.org. If we need to use your Personal Information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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Withdrawing Your Consent

If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time by contacting us at privacy@insidetrack.org

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Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Information. You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that we will notify you about, if applicable, at the time of your request.
• Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
• Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

To exercise your rights, please contact us at privacy@insidetrack.org.

Additionally, in the situation where a school or institution is the data controller and you would like the school or institution to delete Personal Information they have collect about you, we encourage you to contact the school or institution directly. If you are unsuccessful in reaching the appropriate contact at the school or institution, please contact us at privacy@insidetrack.org and we will do our best to connect you with the right person who can help you.

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Data Relating to Children Under 13

Our Services are not directed at, and we do not knowingly collect Personal Information from anyone under the age of 13 (or such other age as may be restricted under local law). If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.

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Cross Border Transfers

Our website is maintained in the United States. If you are visiting from regions with laws governing data collection and use that may differ from those in the United States, please note that you may be transferring your information to the United States and to other countries around the world. You freely and specifically give us your consent to export and use your information within the United States and in other countries as specified in this privacy policy. You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States. If you are situated in the EU, whenever we transfer your personal data to processors outside of the EU, we ensure appropriate and suitable safeguards are used in such transfer. We may use specific contracts approved by the European Commission that give personal data the same protection it has in the EU. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

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California Shine the Light Law

If you are a California resident, this section applies to you.  Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship (a) a list of the categories of personally identifiable information, such as name, email address and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please contact us at privacy@insidetrack.org.

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Updates to this Privacy Policy

We reserve the right, at our discretion, to change, modify, add, or remove portions from this privacy policy at any time. However, if at any time in the future we plan to use your Personal Information in a way that materially differs from this privacy policy, we will post such changes here or email you. We encourage you to periodically review the website for the latest information on our privacy practices. You are bound by any changes to the privacy policy when you use our Services after such changes have been first posted.

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CONTACT US

Strada Collaborative, LLC, d/b/a InsideTrack

10 W. Market St., Suite 1100

Indianapolis, IN 46204

privacy@insidetrack.org

Effective August 16, 2024

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