last updated December 31, 2018
2. Collection of Personal Information
We collect personal information that you enter on our Site or otherwise volunteer to us when you contact us to, among other things, make purchases, request information or participate in our programs. You can choose not to provide certain information, but then you might not be able to take advantage of many of our features.
For purposes of this Policy, "Personal Data" means information relating to a living individual (whether stored electronically or in paper based filing systems) who can be identified from that data (or from that data and other information in our possession). Personal Data can be:
factual – such as a name, address, email, phone, or date of birth
sensitive – such as financial account information, protected health or medical details or information about your racial or ethnic origin, li religious or similar beliefs, physical or mental health or condition, or sexual life
opinion – such as the results of a self-assessment test.
Institute of OM collects only that Personal Data that is relevant for the purposes for which the data is requested. Institute of OM does not use your Personal Data in any way that is incompatible with the purposes for which it was collected or for which you have consented.
3. Use of Personal Information
We may use your Personal Data in the following ways:
To provide you with the information, products, and services that you request from us
To carry out our obligations arising from any contracts entered into between you and us
To communicate about promotions, upcoming events, and other news about products and services offered by us
To welcome you to a course upon signing up, conduct an intake call leading up to a course and conduct follow-up calls after the course is completed
To assess your suitability for participation in our in-person courses, and to determine additional services or events to recommend and market to you
To record details about the products and services you order from us
To contact you in the future to provide you with information about other goods and services we offer, or that are offered by our licensees or third party vendors
To respond to comments, suggestions, and questions and provide customer service
To send information including confirmations, invoices, logistical course information, technical notices, updates, security alerts, and support and administrative messages
You can visit our Site without telling us who you are or revealing any Personal Data. But in some circumstances we may ask you for and you may submit Personal Data.
When you contact us through our Site, or by corresponding with us by phone, e-mail, or otherwise, or meet us at an in-person event, we may collect Personal Data including:
Contact information, such as name, address, email, and phone
Financial information, such as credit card and account information collected when you purchase products or services
Identification information, such as gender and date of birth
Self-assessment data and results, such as information you input when taking self-assessment quizzes
Information about your health that you may disclose to us prior to participating in our programs
Personal information about your desires for our products, services, and courses
For current or prospective licensees, certified coaches, coach trainees, and contractors, personal information such as social security number, federal tax ID number, or other relevant information, as applicable
4. Sharing of Personal Information
We do not sell your Personal Data to any third parties.
We may provide Personal Data to Certified Coaches who provide coaching as part of our programs that include coaching, to the extent necessary for them to provide the world class coaching we provide our Customers. These parties are only permitted to use this information for the purpose for which it was originally provided to us.
By visiting our Site or attending our events and sharing your Personal Data, you agree that we have the right to share your personal information as follows:
We may share personal information in compliance with any applicable law
We may share personal information for legal, protection, information security, and safety purposes. Examples include enforcing contracts or policies, reporting on security breaches, or assisting with investigating and preventing fraud or security issues
We may share information with those who need it to do work for us. An example is granting an Institute of OM employee the necessary access in order to perform his/her duties
We may share aggregated or anonymized data. We may disclose or use aggregated or anonymized data for any purpose. An example would would be for marketing, analytics or research purposes
We will not share personal information with investors of the Company beyond any personal information that such investors are entitled to for customary legitimate business purposes.
We share personal data with with third party companies or individuals as service providers to process information and support our services, such as providers that provide cloud storage service. We take security measures to ensure that your data stored with such services remains safe.
We may also share your information in one of the following circumstances:
In the event that we sell or buy any business or assets, we may disclose your Personal Data to the prospective seller or buyer of such business or assets as part of the purchase, transfer, or sale of services or assets;
If we sell all or substantially all of our assets to a third party, personal information about our customers will be one of the transferred assets;
Whenever we share information with third parties, we will take steps to ensure that the third parties put in place adequate measures to safeguard your Personal Data, and they will be required to use any Personal Data for only the intended purpose for which it was shared.
5. Storage of your Personal Data
Institute of OM uses reasonable and appropriate measures to protect your Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing undertaken and the nature of the Personal Data we collect.
We will keep your personal data for as long as we need it, or as otherwise prescribed by law, for the purposes set out above. This period will vary depending on your interactions with us. We may also keep a record of correspondence with you (for example if you have made a complaint about a product) for as long as is necessary to protect us from a legal claim.
You may unsubscribe from any of our online e-mail updates and marketing by following the unsubscribe instructions in the body of any e-mail message we have sent to you. We will take commercially reasonable steps to implement your unsubscribe requests promptly, but you may still receive promotional e-mail from us for up to ten days. You may also continue to receive information from those third parties to whom we have previously disclosed your Personal Data.
Please note that when you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.
6. Links to Other Websites
7. Cookies and Other Technologies
Our website, services, apps, email communications and advertisements may use "cookies" and other technologies such as "pixel tags" and "click-through URLs".
We use the information we collect in this manner to better understand our users’ interaction with our website and to optimize the user experience. You can disable cookies in your browser settings, but please note that certain features on our website may not be available as a result.
In our email communications, we may use other technologies like "pixel tags" and "click-through URLs" in order to determine if an email has been opened and which links have been clicked. We use this information to help us determine interest in particular topics and improve the effectiveness of our communications, and to reduce or eliminate messages sent to customers. Pixel tags are small images shown inside an HTML email; you can disable tracking by disabling HTML in your email client. A link with a click-through URL, when clicked, first sends the user to a web server which records the click, and then to the link’s destination. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
As you access our services, we gather some information automatically on our servers and store it in log files. This information includes your browser type, version, and language, your operating system, the referring and exit websites, IP address, a date/time stamp of the request, and the requested resource (file name and URL). We use this information in anonymized form for statistical analysis, to administer our site, and to improve our product and services, without directly associating this data with individual users.
8. Age Limitations
Institute of OM’s Site is intended for adults over the age of 18 years, and the Services are not available to anyone under 18 years. If we learn that anyone younger than 18 has provided us with Personal Data, we will takes steps to delete such information.
9. Additional Policies in Compliance with the EEA Privacy Laws
9.1 GDPR Definitions
"Controller" means the Company which is the organization that determines the purposes for which, and the manner in which, any Personal Data is Processed and used in its business.
"Processor" means any Person Processing Personal Data.
"Person" means a natural person, corporation, association, organization, partnership, or other legal entity.
"Processing" is any activity that involves use of the Personal Data. It includes, without limitation, obtaining, recording or holding the Personal Data, or carrying out any operation or set of operations on the Personal Data including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring Personal Data to third parties.
9.2 The Legal Basis for Processing Your Personal Data
In order to comply with the GDPR, we are required to set out the legal basis for the processing of your Personal Data. In accordance with the purposes for which we collect and use your Personal Data, as set out above, the legal basis for processing your Personal Data will typically be one of the following:
our own legitimate business interests, or the legitimate business interests of our third party partners, promoters, affiliates, distributors, suppliers, vendors, and subcontractors, such as, for example, providing direct marketing to our customers of our products and services that we think would be of interest, permitting prospective employees to search and apply for job opportunities, handling inquiries from our licensees, affiliates, or other instances where we have carried out a legitimate interests assessment and have established an existing legitimate interest;
the performance of a contract that we have in place with you;
your consent where appropriate; or
compliance with our legal obligations, including to meet national security or law enforcement requirements.
9.3 Where We Store Your Personal Data
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
9.3 Addendum to How Long We Store Your Personal Data
In some cases, there is a legal requirement to keep Personal Data for a minimum period of time. Except in those circumstances, we do not keep your Personal Data for any longer than is necessary for the purposes for which the Personal Data was collected or for which it is to be further processed.
9.4 Your rights with Respect to Your Personal Data
Subject to certain exceptions, you have the following rights with respect to your Personal Data:
To receive a copy of the Personal Data that we hold about you
To request that any inaccurate or incomplete Personal Data be corrected or supplemented
To have your Personal Data erased, unless we have a legitimate reason to retain the Personal Data (such as if we are required to do so for legal reasons) and
To ask us not to process your Personal Data for a particular purpose, including for marketing.
All of these rights are subject to certain conditions and exemptions. For example, Institute of OM will not be obligated to erase your Personal Data if we need to retain it to protect ourselves in the event of a legal claim.
To exercise any of these rights, please submit a written request to us using the contact information set forth below. The Company reserves the right to charge a fee in dealing with such a request as permitted by applicable law and regulations. You may also opt out of receiving additional marketing information by using the unsubscribe feature in any marketing email we send you.
11. Contacting Us
Institute of OM, 116 W 23rd Street, 5th Floor, New York, NY 10011