Welcome to the Traveling Coaches, Inc. Privacy Notice.

Traveling Coaches, Inc. (“Traveling Coaches,” “us,” “we,” or “our”) knows that you care about your privacy and protecting your personal data. Traveling Coaches has developed this Privacy Notice to explain how we collect, store, process, share and transfer your personal data when you visit our websites, www.travelingcoaches.com (the “Site”) and www.travelingcoaches.lmscheckout.com (the “LegalMind® Personal Learning Portal,” or the “Portal”) (collectively, the “Websites”) and to help you in making informed decisions when using our Websites. Supplemental information may be found in our Cookie Policy. By using our Websites, you are accepting the practices described in this Privacy Notice.

This Privacy Notice is provided in a layered format so you can click through to the specific areas. To make it easier for you to review the parts of this Privacy Notice that apply to you, we have divided up the document into sections that specifically relate to the Site (Section 2) and to the Portal (Section 3). Sections 1, 2 and 5 are applicable to everyone who visits the Websites.

For purposes of this Privacy Notice, “Personal Data” means any information about an individual from which that person can be identified. It does not include data where identity is removed (anonymous data).

  1. Important information and who we are
  2. Privacy Notice for www.travelingcoaches.com (the "Site")
    A. Information we collect
    B. How we collect your Personal Data
    C. How we use Cookies and similar technology
    D. How we use your Personal Data
  3. Privacy Notice for www.travelingcoaches.lmscheckout.com (the "Portal")
    A. Information we collect
    B. How we collect your Personal Data
    C. How we use Cookies and similar technology
    D. How we use your Personal Data
  4. General Information
    A. How we share your Personal Data
    B. How we protect your Personal Data
    C. Your legal rights
    D. How to opt-in and opt-out of marketing materials
    E. Third-party links
    F. International transfer of your Personal Data
    G. How we store your Personal Data
    H. Updates to this Privacy Notice
    I. How to contact us

1. Important information and who we are

Purpose of this Privacy Notice

This Privacy Notice aims to give you information on how Traveling Coaches collects and processes your Personal Data, including any data that you provide through the Websites, or when you engage us to provide a service or a product.

Our Websites are not intended to be used by children; and we do not knowingly collect personally Personal Data from children.

It is important that you read this Privacy Notice so that you are fully aware of how and why we are using your Personal Data. 

Controller

Traveling Coaches is the controller and responsible for your Personal Data. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us at privacy@travelingcoaches.com.

2. Privacy Notice for www.travelingcoaches.com (the “Site”)

A. Information we collect

On the Site, we collect, use, store and transfer different kinds of Personal Data including, but not limited to:

  • Identity Data includes first name, last name, title, and firm or company name.
  • Contact Data includes firm or company name, email address, telephone numbers, and physical business address.
  • Technical Data includes internet protocol (IP) address, browser type and version, time, date and use of the Site, location data, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site.
  • Profile Data includes your interests and preferences. 
  • Site Use Data includes information about how you use our Site, and services. Like many organizations, we place a "cookie" (a small data file) on your computer when you connect to our Site. This allows us to recognize your computer’s IP address on return visits, helps us understand traffic patterns on our Site and improve our Site. For more information about cookies and guidance about how to refuse cookies, see Section 2.C, “How we use cookies and similar technologies” and our Cookie Policy.
  • We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Site Use Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Notice.

    We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

    If you fail to provide Personal Data

    Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data 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 products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

    B. How we collect your Personal Data?

    We use different methods to collect Personal Data from and about you including through:

  • Direct interactions. You give us your Identity, Contact and Profile Data by filling in forms available on our Site. This includes Personal Data you provide when you: 1) Complete the “Contact Us” form on our Site; 2) Subscribe to “Sign Me Up!” on our Site; or 3) Sign up to “Feed Your Read” on our Site.
  • Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies. Please see Section 2.C, “How we use cookies and similar technologies” and our Cookie Policy for further details.
  • Third parties or publicly available sources. We may receive Personal Data about you from analytics providers such as Google based outside the European Union (“EU”). For more information about cookies and guidance about how to refuse cookies, see Section 2.C, “How we use cookies and similar technologies” and our Cookie Policy.

    C. How we use Cookies and similar technology

  • Cookies: When you visit our Site, we may send a cookie to your computer. A cookie is a small data file stored by your computer to help improve functionality or tailor information to provide visitors with more relevant information. We also analyze Site traffic to identify what visitors visit so we can tailor our Site accordingly. For details about the cookies we use, please see our Cookie Policy, which is part of this Privacy Notice.
  • Other tracking technologies: We and our third-party service providers may use other, similar technologies from time to time, like web beacons, pixels (or “clear gifs”) and other tracking technologies. These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Site or, in the case of web beacons, opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Site to another and to improve Site performance. While you may not have the ability to specifically reject or disable these tracking technologies, in many instances, these technologies are reliant on cookies to function properly; thus, in those instances, declining such cookies will impair functioning of these technologies.
  • Do not track signals and requests:  ‘Do not track signals and requests’ are sent from your browser to websites you visit indicating that you do not want to be tracked or monitored. Websites are not required to accept these requests and many do not. At this time, our Site does not honor ‘do not track signals or requests.’
  • D. How we use your Personal Data

    We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in circumstances including:

  • Where it is necessary to administer customer service and relations;
  • Where we need to administer our Site;
  • Where it is necessary for us to perform our contractual obligations;
  • and Where we need to comply with a legal or regulatory obligation.
  • Purposes for which we will use your Personal Data

    We have set out below a description of some of the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your Personal Data.

  • Purpose/Activity: To respond to your inquiries and process your subscription to our news
  • Type of data: Identity, Contact, Profile
  • Lawful basis for processing including basis of legitimate interest: Administration of customer service

  • Purpose/Activity: To manage our relationship with you which might include: Notifying you about changes to our terms or privacy notice
  • Type of data: Identity, Contact, Profile
  • Lawful basis for processing including basis of legitimate interest: Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

  • Purpose/Activity:  To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • Type of data: Identity, Contact, Technical
  • Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise); Necessary to comply with a legal obligation

  • Purpose/Activity: To use data analytics to improve our Site, services, customer relationships and experiences
  • Type of data: Technical, Usage
  • Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of customers for our services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
  • 3. Privacy Notice for www.travelingcoaches.lmscheckout.com (the “Portal”)

    A. Information we collect

    On the Portal, we collect, use, store and transfer different kinds of Personal Data including, but not limited to:

  • Identity Data includes first name and last name.
  • Contact Data includes email address.
  • Technical Data includes internet protocol (IP) address, browser type and version, time, date and type of use of OnGuard® and/or LegalMind® Services and location data, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Portal.
  • Portal Use Data includes information about how you use our Portal and services. A session Cookie is placed on your computer to facilitate login to our Portal. The Cookie allows the Portal to remember who you are once you have passed over to our system from your IDP. It holds a session Cookie based on a randomly generated session ID and does not store any user details. Find out more about our use of Cookies, see our Cookie Policy which is part of this Privacy Notice.
  • We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

    If you fail to provide Personal Data

    Where we need to collect Personal Data by law, or to provide you with products or services under the terms of a contract we have, and you fail to provide that data when requested, we may not be able to provide you with such products or services. In this case, we may have to cancel such products or services, but we will notify you if we do.

    B. How we collect your Personal Data?

    We use different methods to collect data from and about you including through:

  • Direct interactions. You will give us your Identity, Contact and Profile Data by filling in forms available on our Portal. This includes Personal Data you provide when you 1) Activate your account on our Portal; and 2) Login to your account on our Portal.
  • Automated technologies or interactions. As you interact with our Portal, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies. Please see Section 3.C, “How we use cookies and similar technologies” and our Cookie Policy for further details.
  • Third parties or publicly available sources. We may receive Personal Data about you from analytics providers such as Google based outside the European Union (“EU”). For more information about cookies and guidance about how to refuse cookies, see Section 3.C, “How we use cookies and similar technologies” and our Cookie Policy.
  • C. How we use Cookies and similar technology

  • Cookies: When you visit our Portal, we may send a cookie to your computer. A cookie is a small data file stored by your computer to help improve functionality or tailor information to provide visitors with more relevant information. We also analyze Portal traffic to identify what visitors visit so we can tailor our Portal accordingly. For details about the cookies with use, please see our Cookie Policy, which is part of this Privacy Notice.
  • Do not track signals and requests: "Do not track signals and requests" are sent from your browser to websites you visit indicating that you do not want to be tracked or monitored. Websites are not required to accept these requests and many do not. At this time, our Portal does not honor "do not track signals or requests."
  • D. How we use your Personal Data

    We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in circumstances including:

  • Where it is necessary to administer customer service and relations;
  • Where we need to administer our Portal;
  • Where it is necessary for us to perform our contractual obligations;
  • and Where we need to comply with a legal or regulatory obligation.
  • Purposes for which we will use your Personal Data

    We have set out below a description of some of the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we will process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your Personal Data.

  • Purpose/Activity: To manage our relationship with you which might include: Notifying you about changes to our terms or privacy notice
  • Type of data: Identity, Contact
  • Lawful basis for processing including basis of legitimate interest: Performance of a contract with you or with your employer; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

  • Purpose/Activity: To administer and protect our business and this Portal (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • Type of data: Identity, Contact, Technical
  • Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise); Necessary to comply with a legal obligation

  • Purpose/Activity: To use data analytics to improve our Portal, services, customer relationships and experiences
  • Type of data: Technical, Usage
  • Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of customers for our services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
  • 4. General Information

    A. How we share your Personal Data

    We will share the Personal Data we collect as described in this section of the Privacy Notice. We may share this data for reasons including, but not limited to:

    With employees, contractors and agents that provide services to us: We may share the Personal Data that we collect with our employees, contractors and agents, including third-party service providers, that perform services and functions at our direction and on our behalf, but their use of such data shall be limited to the performance of their duties and is consistent with our purposes for using such information.

    Our third-party service providers follow:

  • For the Site: Squarespace, Inc.; Salesforce; The Rocket Science Group LLC d/b/a MailChimp; 123FormBuilder S.R.L.; and Manzama Inc.
  • For the Portal: Envisiontel LLC; and Amazon Web Services, Inc. (“AWS”)
  • With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for our business purposes or as permitted or required by law, including: (a) to comply with a law, legal process or regulations; (b) responding to or cooperating with law enforcement authorities, other government officials or other third parties pursuant to a subpoena, a court order or other legal process; (c) to protect our property, services and legal rights; (d) with a potential buyer and its agents and advisors in case of a sale, merger, consolidation, liquidation, reorganization, or acquisition (in that event, any acquirer will be subject to our obligations under this Privacy Notice); (e) with any other person with your consent; and (f) to support our audit, compliance and governance functions.

    B. How we protect your Personal Data

    We maintain suitable physical, technical and administrative safeguards for our Websites designed to protect against loss, misuse, unauthorized access, disclosure, alteration or destruction of the information we collect through our Websites. When we share your Personal Data with third-party service providers, we put in place a written agreement which commits our third-party service providers to keep your Personal Data confidential, and to put in place appropriate security measures to keep your Personal Data secure. However, the transmission of Personal Data to our Websites may not be completely secure and any transmission is at your own risk. If you have any questions about the security of our Personal Data, please contact us at privacy@travelingcoaches.com.

    C. What are your legal rights

    Some jurisdictions (state, federal, national and international), such as California, Canada, and the European Economic Area (under the General Data Protection Regulation (“GDPR”)), provide individuals with certain rights regarding their Personal Data. To exercise any rights your jurisdiction may provide, contact us at privacy@travelingcoaches.com

    Also, you may click on this link to find out more about these rights under the GDPR: https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en.

    D. How you opt-in to and opt-out of marketing materials

    If you have opted-in to our newsletters, but no longer want to be contacted by us, you can opt-out of receiving our newsletters at any time by clicking the “unsubscribe” link at the bottom of our newsletter or contact us directly at privacy@travelingcoaches.com

    E. Third-party links

    The Websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Websites, we encourage you to read the privacy notice of every website you visit.

    F. International transfer of your Personal Data

    This section is intended only for those of you in the EEA.

    Though we do not seek actively to transfer Personal Data of EU residents outside the EU, some of the external third parties we deal with are based outside the EU or process Personal Data outside the EU, so their processing of your Personal Data will involve a transfer of data outside the EU.

    Whenever we transfer Personal Data of EU residents out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.

    We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: “Adequacy of the protection of personal data in non-EU countries.”

    Where we use certain service providers, we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: “Model contracts for the transfer of personal data to third countries.” 

    G. How we store your Personal Data

    Personal Data will be stored as long as the information is required to fulfil our legitimate business needs or the purpose for which the information was collected, or for as long as is required by law. Our retention policies will vary depending on the type of data involved. Generally, we will refer to the following criteria to determine retention period:

  • Whether the data is necessary to provide our services; or
  • Whether we have a legal or contractual need to store the data.
  • H. Updates to this Privacy Notice

    We may update or change this Privacy Notice. The effective date at the top of this page states when this Privacy Notice was last revised. Any change to this Privacy Notice will become effective when we post the revised Privacy Notice on our Websites.

    If any change will materially and negatively affect the privacy of your Personal Data, we will use reasonable efforts to notify you in advance and give you a reasonable time to object to any changes.

    We encourage you to periodically review this Privacy Notice to stay informed about how we collect, use, and share Personal Data.

    I. How you may contact us

    Use the contact information below if you (a) would like to exercise any individual rights you may have about your Personal Information, (b) have questions, concerns or complaints about this Privacy Notice or our privacy practices or (c) would like additional information about Traveling Coaches privacy practices.

    You may email us at privacy@travelingcoaches.com, or contact us at:

    Frank Barnard
    Director of Operations and Client Services
    2805 Dallas Parkway, Suite 150
    Plano, TX 75093
    fbarnard@travelingcoaches.com

    Thank you for reading Traveling Coaches Privacy Notice.