Privacy Policy - Coaching Right Now

Our Privacy Commitment

TopLine Communication LLC (“company,” “we,” “us”) and its online coaching programs, such as Coaching Right Now, are committed to protecting and safeguarding your personal information.

Because our company is committed to personal privacy protection, we are an approved “Active Participant” (participant in good standing) in the Data Privacy Framework (DPF) program, administered by the International Trade Administration (“ITA”) within the U.S. Department of Commerce (“USDOC”) which became effective July 10, 2023.

We are an approved “Active Participant” (participant in good standing) in all three of the following Data Privacy Framework (DPF) programs administered by the International Trade Administration (“ITA”) within the U.S. Department of Commerce (“USDOC”):

EU – U.S. Data Privacy Framework (DPF) program (“EU-U.S. DPF”)
UK Extension to the EU-U.S. Data Privacy Framework (“UK Extension to the EU-U.S. DPF”)
Swiss – U.S. Data Privacy Framework (DPF) program (“Swiss-U.S. DPF”)

In this capacity, we comply with the Data Privacy Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the following countries to the United States (“U.S.”) in reliance on Data Privacy Framework (DPF) principles:

The European Union (“EU” – hereafter defined to include EU member states, plus European Economic Area (“EEA”) participating countries of Iceland, Liechtenstein, and Norway)
The United Kingdom (“UK” – hereafter defined to include the UK and Gibraltar)
Switzerland

In addition, we comply with the international General Data Protection Regulation (“GDPR”) as adopted and subsequently amended by law, as it pertains to the personal data privacy rights of individuals residing within the European Union (“EU” – hereafter defined to include EU member states, plus European Economic Area (“EEA”) participating countries of Iceland, Liechtenstein, and Norway), and the United Kingdom (“UK” – in accordance with UK GDPR). We also comply with Switzerland’s new Federal Act on Data Protection (“nFADP”), that became effective September 1, 2023.

Prior to our participation in these privacy programs, TopLine Communication LLC was also an approved “Active Participant” (participant in good standing) in the following predecessor privacy frameworks, administered by the U.S. Department of Commerce’s International Trade Administration:

EU–US Privacy Shield Effective 2016
Swiss-US Privacy Shield Effective 2017

Where applicable, we also comply with relevant privacy law requirements of U.S states as they are adopted and amended, regarding the personal information of individuals residing within those states.

Detailed information explaining our privacy policy, including specific Data Privacy Framework (DPF) and GDPR provisions, is described below.

Privacy Summary

This privacy policy includes a detailed discussion of the following privacy-related issues:

Our company’s name, contact information, and designated privacy representative.
Our commitment not to use your personal data for any purposes other than the business purposes for which it was originally collected unless we receive your advance consent.
Our commitment not to sell, rent, or trade your personal data.
The types of personal data we collect, the purposes for which this data is collected, and privacy policies that help safeguard how we collect, process, use, transfer, and/or retain personal data.
Our policies regarding customer choice, consent, and access to personal data.
How to contact us with questions, issues, complaints, or concerns regarding your personal data.
Our policies regarding data storage, processing, retention, transfer, deletion, and security.
Our policies describing relationships with third-party agents, such as business partners and data processors, who work with us and act on our behalf, to provide business programs and services.
Our website and marketing communication privacy practices, including cookie policies, and optout provisions.
Our adherence to the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce, as it pertains to residents of the European Union, the United Kingdom (UK), and Switzerland, whose data is being transferred into the United States, and policies regarding how to resolve data privacy questions and concerns.
Our adherence to the General Data Protection Regulation (GDPR) as it pertains to residents of the European Union and the United Kingdom (UK), and policies regarding how to resolve GDPRrelated data privacy questions and concerns.

Types of Personal Information We Collect

TopLine Communication LLC is a U.S.-based company that through its online management coaching program, Coaching Right Now, hosts, manages, and provides an online coaching platform and related leadership development training and coaching services for businesses, managers, and employees.

The personal information we obtain is used for the purposes of offering, fulfilling, and/or completing a variety of business, professional, and personal coaching services, such as training, advice, assessment, evaluation, consultation, feedback, instruction, leadership development, and other related business, professional, and personal development purposes, and/or the fulfillment of contractual obligations.

Personal information is collected in a variety of ways, including but not limited to, online registrations, contact forms, information requests, surveys, website visits, online forums, phone calls, conference calls, online video meetings, in-person meetings, conferences and video conference, emails, individual feedback, coaching sessions, written documents and reports, evaluations, questionnaires, assessments, analytical tools, and coaching and training platforms.

This personal information is provided by you through your website visits and the information you provide to us through a variety of means and methods. It is also provided on your behalf by related parties, such as coaches, employers, managers, and by our business partners and third-party service providers who work with us to provide you with our programs and services.

We collect a variety of information that includes, but is not limited to, name, address, email addresses, phone numbers, company information (company name, title, location, position responsibilities, etc.), resume information (such as employment history, education, work experience, qualifications, honors, awards, professional credentials, professional skills, language skills, memberships in professional organizations, prior training completed, goals, interests, etc.), and other related information.

In addition, we may collect personal data you provide to us through the content of your communications with us, including but not limited to, interactions with customer support, “Connect With Us” forms, newsletter requests, event registrations, social media, and similar means that allow us to interact with you, respond to your requests, send notices and updates, and provide you with our programs and services.

We may also collect the personal information you provide to us through any other means, including but not limited to, mail, email, in-person communications, social media platforms, surveys, website visits, messaging services, texts, etc. We are also permitted to collect publicly available personal information, such as the personal information available on any public forum, platform etc., including but not limited to, social media sites, online forums, online videos, blogs, message boards, job boards, website comments, newspapers, radio or television broadcasts, or publicly available information from any source of any kind.

We also collect personal data to improve our programs, offerings, and services, or for internal purposes, that include but are not limited to, accounting, tax and reporting obligations, audits, assessments, program reviews, and other analyses. If payments are required for individual programs, products, or events, we collect data such as your name, purchase details, and payment information.

You are not required to provide the personal data we request. However, if you choose not to do so, in most cases, we will be unable to provide you with the programs or services you desire and will be limited in our ability to service your requests.

Business-Related Access to Personal Data

Access to personal data collected by our company is limited to you and to those individuals and/or entities involved with offering and/or providing our programs and services. This may include, but is not limited to, your employer, managers, coaches, etc., and to our company employees, and to approved third party agents involved in maintaining, managing, updating, reviewing, processing, and storing personal data on our behalf, so we can provide you with the programs or services you have opted to receive.

A select number of coaches will work directly with you, and with your employer and managers, to coach, train, assess, evaluate, consult, instruct, review, and interpret your personal data as it relates to providing you with leadership development, coaching, and/or other related services.

To maintain the security of your personal data, we communicate privacy and security guidelines to our employees, provide training in privacy principles, and enforce privacy safeguards within our company.

Additionally, personal data may be provided to related third parties, including but not limited to business partners, 360-degree report vendors, online training services, e-learning platforms, etc., who are relevant to and/or consistent with the purposes of offering and/or providing the programs and/or services you have opted to receive, including but not limited to, coaching, assessing, advising, evaluating, consulting, training, and a variety of related options.

Data Integrity and Purpose Limitation

We process personal data 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 data collected is accurate, complete, current, and reliable for its intended use.

Limited Sharing of Personal Data

In accordance with Data Privacy Framework and GDPR provisions, we may share your personal data within our company in its various locations, on its various coaching platforms, and with all relevant employees, coaches, managers, companies, contractors, business partners, 360-degree report vendors, online training services, e-learning platforms, website service providers, IT support and hosting services, and any other individual or entity we believe is relevant to or consistent with offering and/or providing our programs and services to you (collectively: employees, clients, third-party agents, etc.)

Likewise, we may engage other third-party agents acting on our behalf, to process, store, or otherwise handle personal data needed in conjunction with offering and/or providing our programs, services, events, and other resources.

Employees and third-party agents are obligated to handle personal data in a manner consistent with this privacy policy and applicable Data Privacy Framework and GDPR requirements, including any addition instructions specifically requested by us.

TopLine Communication LLC and its online coaching programs, such as Coaching Right Now, respect your data privacy and we do not sell, rent, or trade your personal data to third parties.

Likewise, our third-party agents are not permitted to sell, rent, or trade your personal data or use the personal data we share with them for their own unrelated purposes.

Third-party agents are required to act under our direction, and must correct, amend, or delete personal data upon our request. If necessary, mechanisms such as contracts and/or signed agreements will be used to facilitate compliance.

We may be required to share personal data for purposes of national security or other lawful requests. We may also share personal data where disclosure is necessary or appropriate, such as in the event of a business reorganization, merger, sale, or similar matter.

We are also permitted to share personal data with others at your direction and with your explicit consent.

Aggregated and Anonymized Data

Aggregated and anonymized data is information that does not, by itself, identify someone as a specific individual. We may collect, compile, store, transfer, publish, report, or otherwise use and/or disclose aggregated and/or anonymized data, provided that such information does not personally identify specific individuals.

We do not correlate personal data with the aggregated or anonymized data we collect.

Therefore, aggregated and/or anonymized data is considered “non-personal” data for the purposes of this privacy policy. If in the future, any aggregated or anonymized data were to be correlated with personal data, that correlated data would be treated as personal data within the context of this privacy policy.

Website Privacy Standards

We appreciate the opportunity to connect with you on our website and are committed to protecting and safeguarding your privacy. In this section and in following sections, we explain the types of information we collect when you visit our website, how we use that information, information disclosed to third parties, and the choices you have regarding the use of that information.

Visitors can browse most portions of our website without revealing personal information such as your name, email address, phone number, etc. However, if you choose to voluntarily submit information on forms (such as the “Connect With Us” form, forms seeking employment or coaching opportunities, etc.), and/or if you choose to sign up for optional services (such as webinars, blogs, newsletters, etc.), you are giving your consent for us to use, store, process, and transfer the personal information that you voluntarily provide to us.

The information we collect is used for the purpose of offering you a variety of services and responding to your requests. We may choose to maintain a record of the personal information you provide in order to respond to your requests, provide information that may be of interest to you, and/or offer you a more customized user experience in the event you contact us again.

We collect website data which includes, but is not limited to, the URL of the website that referred you to us, IP address, operating system, and browser type. This data is primarily collected in an aggregated form for the purpose of website analytics and improving user experience.

By using our website, you acknowledge your acceptance of the privacy policy that is posted on our website and in effect at the time of use.

Website Cookie Polices and Related Technologies

The use of cookies and similar website technologies are standard and widely accepted website practices designed to improve user experience and website effectiveness. Therefore, our websites, online services, social media applications, and advertisements use cookies and related technologies for security and fraud prevention, and to better understand user behavior. For example, cookies indicate which sections of our websites users most often visit, which allows us to improve the services we provide to our customers.

From a technical perspective, a “cookie” is a small data file transferred to a computer’s hard drive that enables a website to interact with you in a user-friendly and responsive way, by gathering and storing information about your user preferences, so we can provide you with a smoother and more customized user experience.

Cookies also offer users the added convenience of not having to repeatedly re-enter information they have previously entered. In addition, certain personalized features (such as preferences or browsing functions) require the use of cookies or cookie-based authentication to verify authorized users.

Most standard internet browsers (such as Microsoft Internet Explorer, Google Chrome, Safari, Firefox, etc.) are automatically set to accept cookies. However, you have the option to adjust these cookie settings, if you wish to do so, by following the instructions on your own computer and/or mobile devices.

In addition, the cookie settings we use are designed to provide you with the best possible user experience on our website. We offer an opt-in, “cookie consent” option to website users, which gives you the ability to select the types of cookies you do or do not wish to use. However, please be aware that some websites features may not be available or may not display correctly, if functional or performance cookies are disabled.

Our website uses the following types of cookies:

Essential / Strictly Necessary Cookies: Cookies that are necessary for basic website functionality. Essential cookies remember users while they are browsing websites but do not store permanent information. Therefore, this type of cookie is often called a session cookie. For example, essential cookies allow us to display our websites in the correct language and format. Because they are considered essential to website operations, essential cookies do not require user consent under current “cookie laws” and privacy provisions.
Functional / Performance Cookies: Cookies used to improve a website’s functionality and performance but are not considered strictly necessary. Functional cookies provide users with a faster, smoother, and more positive website user experience. Although functional cookies are not strictly necessary, disabling them may decrease website performance, speed, or functionality by causing certain website features to be unavailable or not to display correctly. Functional cookies also play an important role in user authentication. Most of our functional cookies are first-party cookies with a limited number of third-party cookies (for plug-ins, etc.) that improve website performance. The primary purpose of these functional cookies is to optimize your user experience and website performance.
Analytics Cookies: Cookies used to monitor website activity for the purpose of website data analytics. Analytics cookies gather analytical data on website traffic, trends, etc., through Google Analytics and similar platforms. Much of this analytics data is aggregated and anonymized. Other uses of analytics cookies include, but are not limited to, helping us make improvements to our website and the programs and services offered to our customers, and optimizing user experience.
Advertising Cookies: Cookies used to allow companies to display ads on a website. Our company uses advertising cookies on a limited basis and places several restrictions on advertising cookies. We respect your privacy and do not sell, rent, or trade your personal data.

TopLine Communication LLC and our online coaching platforms, such as Coaching Right Now, are committed to safeguarding your internet privacy. Therefore, our company does not use “surveillance” cookies that track users’ internet activity when they’re browsing elsewhere on the web. The cookies we use are described above and are not designed to track your computer or mobile device activity elsewhere on the web.

We generally treat data collected using cookies and similar technologies as aggregated and non-personal data. However, we treat IP addresses and similar identifiers as personal data where required to do so. If we need to combine non-personal data with personal data, we treat the combined data as personal data within the context of this privacy policy.

Marketing Communications and Third-Party Media

If you have previously opted in to provide us with your contact information, email address, and/or other similar types of information, we may offer you select digital and/or other forms of communications we believe 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 these communications at any time through the “opt out” feature, which is typically located at the bottom of emails you receive from us.

Some email messages provide a direct link (“click-through URL”) that quickly and easily links you to relevant content on our website. When you click one of these links, you may pass through a separate server before arriving to our website. We analyze click-through URLs to determine the level of interest in various programs, services, and offerings. However, if you prefer, you are welcome to visit our website directly rather than using one of the links provided in our emails.

From time to time, you are also invited to voluntarily participate in certain optional programs or activities (such as user polls, surveys, questionnaires, etc.) which we use to obtain feedback and insights from our valued customers that allow us to improve the programs and services we offer to you.

We occasionally run limited third-party ads and/or host links (via our website, newsletters, social media, blogs, sponsored events, etc.) for companies with whom we have an existing business relationship. Links to third-party ads are provided for the benefit, information, and convenience of our customers. The ads and/or links placed on our website do not constitute an endorsement of the companies represented. These companies have their own privacy policies, and we recommend that you independently review the privacy policies of the websites and advertisers you visit online.

Data Security

The security of your personal information is a high priority to our company. We protect this information by taking reasonable steps in maintaining physical, technical, procedural, and organizational safeguards and measures to protect your personal information from loss, misuse, error, unauthorized access or disclosure, alteration, and destruction.

Access to the information collected and maintained by us is limited to you, your employer and managers, and to our select company employees, business partners, and third-party agents (as defined above) who are directly involved with the use, management, processing, updating, and/or review of your data.

One or more of our trained coaches may also work with you, your employer, and your managers to perform activities such as coaching, training, instructing, consulting, evaluating, assessing, discussing, reviewing, advising, interpreting information in your data profile, and/or other related activities.

Because your username and password are specific to you and under your own control, you acknowledge sole responsibility for any and all use of our website and/or any applications or platforms conducted with your username and password. It is your responsibility to safeguard the username and password that you use to access our website and/or any applications or platforms; and to promptly advise us if you suspect your username and password have been compromised.

As an added layer of security, we use a self-assessment approach to review our privacy policies to ensure they are accurate, properly displayed, consistent with privacy principles, and appropriate for the purposes for which the personal data was collected.

Data Storage and Retention

Personal data is stored and maintained on secure and limited-access company sites hosted by TopLine Communication LLC, located in the United States.

Access to stored data is limited to the specific company employees, coaches, and other individuals who require access to that data to perform the purposes for which the data was collected or as required to maintain the integrity of the data and/or the sites. A limited amount of data may also be stored offline in secure and access-controlled locations.

Data is securely stored and retained for as long as it is needed to perform the purposes for which it was collected and/or as required by law. This retention period includes time allotted to complete follow-up reviews and analyses after the close of active projects or engagements. In situations where we expect to have ongoing business or professional relationships with companies and/or their employees, in order to provide improved customer service, we may choose to maintain all relevant current and prior data in a secure and access-controlled location for as long as the business or professional relationships with these companies and/or their employees are expected to continue.

You may request to have your data deleted by sending a written request to the contact listed below.

TopLine Communication LLC
Attn: Mr. Jeff Hayden, Privacy Coordinator
3 Golf Center, #371
Hoffman Estates, IL 60169
Email: jeff@coachingrightnow.com

We will respond to your request within a reasonable timeframe, regarding the expected timing and the degree to which we expect to be able to complete your request. Requests will be honored whenever possible, except where the burden or expense of providing such a request would be disproportionate to the risks to the individual’s privacy regarding their specific request, or where restricted by law, or to protect the rights of persons, other than the individual, from being violated.

Access to Your Personal Data

In accordance with the GDPR and Data Privacy Framework Principles, residents of the EU, UK, and Switzerland have a right to access their personal data to review, amend, edit, change, or delete it, by sending a written request to the contact listed below.

TopLine Communication LLC
Attn: Mr. Jeff Hayden, Privacy Coordinator
3 Golf Center, #371
Hoffman Estates, IL 60169
Email: jeff@coachingrightnow.com

You also have the right to obtain confirmation regarding whether personal data pertaining to you is processed or stored in the U.S.

Customer Choice

In accordance with the GDPR and Data Privacy Framework Principles, we offer individuals the ability to withdraw consent (“opt-out”), where relevant, from having their personal data disclosed to a non-agent third party or used for a purpose that is incompatible with the purposes for which the data was originally collected or subsequently authorized by the individual. In the event your personal data is intended to be used for purposes that are incompatible with the purposes for which it was originally collected or subsequently authorized by you, we will notify you and offer you the ability to “opt out” of such uses and/or disclosures.

If we need to disclose information that is classified as sensitive personal information to a non-agent 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 explicit (“opt in”) consent.

“Opt-out” requests to limit the use and disclosure of your personal data, must be submitted in writing to the contact listed below.

TopLine Communication LLC
Attn: Mr. Jeff Hayden, Privacy Coordinator
3 Golf Center, #371
Hoffman Estates, IL 60169
Email: jeff@coachingrightnow.com

Data Transfers

Our company’s third-party agents are expected to comply with all relevant GDPR and Data Privacy Framework Principles. When personal data is transferred from the EU, United Kingdom, or Switzerland to third-party agents acting on our behalf and under our direction, we require those third-party agents to adhere to all relevant GDPR and Data Privacy Framework Principles.

Several third-party agents, such as 360 assessment providers, are selected in advance by our customers.

TopLine Communications LLC is responsible for the personal data it receives and subsequently transfers to third-party agents, as stipulated in the GDPR and Data Privacy Framework Principles, and the company remains responsible and potentially liable as stipulated in the GDPR and Data Privacy Framework Principles, if a third-party agent who processes personal data on our behalf, does so in a manner inconsistent with the GDPR and Data Privacy Framework Principles, unless TopLine

Communications LLC is able to reasonably demonstrate we were not a party to or liable for the event or events giving rise to the aforementioned claim.

To fulfill the purposes for which your personal data was originally obtained, some or all of this data may need to be transferred to non-EU countries, including but not limited to, the United States. By providing your personal data to us as part of your program participation, website visits, emails, phone calls, or through any other means, you are authorizing your consent for data transfers and data processing to occur to and within non-EU countries, including but not limited to the United States, and in various countries around the world in which we have a business or coaching presence.

Statutory or Contractual Requirements or Obligations

We will inform you whether the provision of your personal data is part of a statutory or contractual requirement or obligation and the possible consequences of failing to provide your personal data under those circumstances. However, given the nature of our business, it is unlikely this situation will occur.

Law Enforcement and Legal Disclosures

In certain situations, TopLine Communications LLC may be required to disclose personal data in response to lawful requests by public authorities, including requests pertaining to national security or law enforcement requirements. For example, we may be required to provide personal data in response to court orders, subpoenas, government investigations, or other matters of legal, investigative, or national security importance. We also reserve the right to report to law enforcement agencies any activities that we in good faith suspect to be in violation of the law. We may also release personal data when such release is reasonably necessary to protect the rights, property, safety, or lives of others or ourselves.

If TopLine Communications LLC or any of its current or future related entities engage in discussions or negotiations regarding a merger, sale, or acquisition by another business entity, or if the company’s assets are acquired, or under consideration to be acquired, we may need to share personal data with companies involved in these actions, especially if a company may be assuming the role of serving you in the future.

Affirmation of Data Privacy Framework Principles

TopLine Communication LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.

TopLine Communication LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.

TopLine Communication LLC has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.

With respect to the personal data of residents of the European Union, the United Kingdom (UK), and Switzerland that have been transferred to the United States, we acknowledge the following principles in relation to the Data Privacy Frameworks:

The company adheres to the notice provisions, as required under the Data Privacy Frameworks.
You have the right to request erasure of personal data that was processed in violation of Data Privacy Framework Principles.
We do not sell, rent, or trade your personal data to non-agent third parties or use this information for any purposes other than the business purposes for which it was originally collected. If this process should ever change in the future, we will update our privacy policy accordingly and provide you with the appropriate “opt-out” or “opt-in” choice prior to sharing your personal data.
We are responsible for the personal data we receive and subsequently transfer to third-party agents as described in the GDPR and Data Privacy Framework (DPF) Principles, and the company remains responsible and potentially liable as stipulated in the GDPR and Data Privacy Framework (DPF) Principles, if a third-party agent who processes personal data on our behalf does so in a manner inconsistent with the GDPR and Data Privacy Framework (DPF) Principles, unless TopLine Communications LLC is able to reasonably demonstrate we were not a party to or responsible for the event or events giving rise to the damages.
We share personal data with a select number of business partners and other entities described above (“third-party agents”) who work under our direction to enable us to provide programs, services, and other offerings to you. Please refer to the Privacy Policy section entitled, “Sharing of Personal Data” for additional information.
You have the right to access your personal data and to update anything that is inaccurate. Please refer to the Privacy Policy section entitled, “Access to Your Personal Data,” for instructions regarding how to exercise this right.

If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the relevant Principles shall govern.

To learn more about the Data Privacy Framework (DPF) program, and to view our certification page, please visit: https://www.dataprivacyframework.gov/.

Complaint Resolution and Independent Recourse Mechanism (IRM)

TopLine Communication LLC values your privacy. Therefore, in compliance with the EU-U.S Data

Privacy Framework (EU-U.S DPF), the UK Extension to the EU-U.S DPF, and the Swiss-U.S Data Privacy Framework (Swiss-U.S DPF) Principles, TopLine Communication LLC commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the EU-U.S. DPF, the UK extension to the EU-U.S. DPF, and the Swiss-U.S Data Privacy Framework Principles.

European Union, United Kingdom, and Swiss individuals with inquiries or complaints are required to first contact TopLine Communication LLC directly at the following address to attempt to achieve a satisfactory resolution, prior to pursuing other courses of action.

TopLine Communication LLC
Attn: Mr. Jeff Hayden, Privacy Coordinator
3 Golf Center, #371
Hoffman Estates, IL 60169
Email: jeff@coachingrightnow.com

Most written requests will receive a response within seven to ten days. In other cases, we may require additional information or let you know that we will need more time to respond.

TopLine Communication LLC has further committed to refer unresolved privacy complaints under the

Data Privacy Framework program to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit the https://bbbprograms.org/programs/all programs/dpf –consumers for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved after pursuing both of these channels, in the order stated above, you may be eligible under certain limited and legally defined conditions, to invoke binding arbitration for some residual claims not resolved by other redress mechanisms. Please refer to the following link for additional information: https://www.dataprivacyframework.gov/s/article/ANNEX –I –introduction –dpf .

With respect to personal data received or transferred to the United States from residents of the European

Union, the United Kingdom (UK), and Switzerland, in accordance with U.S. Data Privacy Frameworks, TopLine Communication LLC is subject to the investigatory and enforcement powers, as applicable, of the U.S. Federal Trade Commission (USFTC).

Please note that the Data Privacy Frameworks outlined in this privacy policy and described on the Data Privacy Framework website (https://www.dataprivacyframework.gov/) apply only to the personal data of residents of the European Union, the United Kingdom (UK), and/or Switzerland whose personal data is transferred to the United States pursuant to Data Privacy Framework international transfer mechanisms.

GDPR Framework and Principles

TopLine Communication LLC adheres to the General Data Protection Regulation (“GDPR”), which can be viewed in its entirety at https://gdpr.eu.

Our company adheres to the GDPR’s Core Principles for processing personal data, which are:

Principle 1: Personal data must be processed lawfully, fairly, and transparently.
Principle 2: Purpose Limitations: Personal data must be collected and processed only for specific and legitimate purposes.
Principle 3: Data collection should be minimized (collect only what is necessary for business purposes).
Principle 4: Data Accuracy: The accuracy of personal data should be monitored, and efforts should be made to rectify incorrect data and comply with reasonable and legitimate data management requests.
Principle 5: Data should only be stored for as long as necessary to fulfill business purposes.
Principle 6: Integrity and Confidentiality: Appropriate security measures should be implemented to protect personal data processing.

We are committed to resolving complaints about data privacy matters and the use of your personal data transferred to the United States pursuant to applicable GDPR provisions.

Although residents of the European Union (including Iceland, Liechtenstein, and Norway) and the United Kingdom (UK) who have GDPR-related data privacy questions, concerns, or complaints may contact the relevant Data Protection Authority (DPA) at any time; in order to receive the fastest possible issue resolution, individuals residing in these locations are encouraged by their DPAs to first directly contact the specific company with whom they have a data privacy question, concern, or complaint.

Therefore, to provide you with the best possible service, if you have any GDPR-related data privacy questions, concerns, or complaints pertaining to TopLine Communication LLC, please contact us at the following address as your first step to achieve a satisfactory resolution to your concerns, prior to pursuing other courses of action:

TopLine Communication LLC
Attn: Mr. Jeff Hayden, Privacy Coordinator
3 Golf Center, #371
Hoffman Estates, IL 60169
Email: jeff@coachingrightnow.com

In accordance with GDPR provisions, we will investigate your concerns and attempt to satisfactorily answer your questions and resolve any complaints or concerns you have regarding the use or disclosure of personal data for residents of the European Union (including Iceland, Liechtenstein, and Norway) or the United Kingdom (UK).

With respect to personal data received or transferred according to GDPR, TopLine Communication LLC is subject to the jurisdiction and enforcement authority of the U.S. Federal Trade Commission (USFTC).

If a complaint or dispute cannot be adequately resolved through our internal processes, TopLine Communication LLC, will upon your written request, refer unresolved data privacy complaints to the relevant Data Protection Authority (DPA) which can be found at the following link: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Please note that the GDPR rights, responsibilities, and provisions, as outlined in this privacy policy, and as described on the GDPR website (https://gdpr.eu) apply only to residents of the European Union (including Iceland, Liechtenstein, and Norway) and the United Kingdom (UK). To learn more about the GDPR, please visit https://gdpr.eu .

Contact Information

This privacy policy may be amended from time to time as required in a manner consistent with the EUU.S Data Privacy Framework (EU-U.S DPF), the UK Extension to the EU-U.S DPF, and the Swiss-U.S Data Privacy Framework (Swiss-U.S DPF), GDPR, and/or U.S. state provisions.

Our current privacy policy can be reviewed at either of the following website locations:

Company Website: https://www.coachingrightnow.com
U.S. Department of Commerce, Data Privacy Framework Website: https://www.dataprivacyframework.gov/s/participant –search .

If needed for accessibility purposes, you may obtain an oral copy of our privacy policy free of charge upon request.

If you have any questions, comments, or concerns regarding this privacy policy, please contact us at:

TopLine Communication LLC
Attn: Mr. Jeff Hayden, Privacy Coordinator
3 Golf Center, #371
Hoffman Estates, IL 60169
Email: jeff@coachingrightnow.com

Effective Date: 9/2/2024