Privacy Policy
Introduction
Welcome to Composure Coach ("we," "us," "our"). We are committed to protecting the privacy of our users ("you," "your"). This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information when you visit our website (www.composurecoach.com), create an account, purchase our digital courses, sign up for our emails, or otherwise interact with us.
This policy is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada and other applicable privacy laws in Ontario.
By using our website and services, you agree to the collection and use of information in accordance with this policy.
Information We Collect
We collect information in the following ways:
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Information You Provide Directly: When you create an account, purchase a course, sign up for our email list, or contact us, we collect:
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Personal Identifiers: First Name, Last Name.
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Contact Information: Email Address.
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Account Credentials: Your chosen password (stored securely in hashed format) to access your account.
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Billing Information: Billing address details necessary for payment verification purposes, processed via our third-party payment processor (Wix). We do not directly collect or store your full payment card details.
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Communications: Information you provide when you contact us via email (support@composurecoach.com) or other communication channels.
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Marketing Preferences: Your choices regarding receiving marketing emails.
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Information Collected Automatically: When you visit our website, our platform provider (Wix) and integrated tools may automatically collect certain information:
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Log and Usage Data: IP address, browser type and version, operating system, device information, the pages you visit on our site, the time and date of your visit, time spent on those pages, referring URLs, and other diagnostic statistics.
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Cookies and Tracking Technologies: Information collected via cookies, web beacons, pixels (including the Meta Pixel), and similar technologies used by us or our service providers (like Wix, Google Analytics, and Meta). This helps with website functionality (e.g., login sessions, shopping cart), performance analytics, understanding user interactions, measuring ad effectiveness, and delivering targeted advertising. (See Section 7 for more details).
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How We Use Your Information
We use the personal information we collect for the following purposes:
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To Provide and Manage Services: To create and manage your user account, grant access to purchased digital courses, process your payment transactions securely via Wix, and fulfill our contractual obligations to you.
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To Communicate With You: To send transactional emails (e.g., purchase confirmations, password resets, important course access information, policy updates) and respond to your inquiries or support requests.
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For Marketing and Promotions: With your explicit opt-in consent, to send you marketing communications via email (using our email marketing service provider) about newsletters, new courses, special offers, etc. We also use information collected via tools like the Meta Pixel to measure the effectiveness of our advertising campaigns and potentially deliver targeted advertising on platforms like Facebook and Instagram. You can withdraw consent or opt-out at any time (see Sections 7 and 9).
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To Improve Our Services: To analyze website usage, trends, and user interaction (using tools like Wix Analytics and Google Analytics) to understand how our services are used, troubleshoot issues, and improve user experience and offerings.
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To Ensure Security: To monitor for and prevent fraudulent transactions, security incidents, and protect the integrity of our services.
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To Comply with Legal Obligations: To meet applicable legal, regulatory, tax, or accounting requirements.
Legal Basis for Processing
We collect and process your personal information based primarily on:
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Your Consent: You provide consent when you agree to this policy, create an account, provide information, explicitly opt-in to marketing, and consent to the use of cookies/tracking technologies (where applicable).
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Contractual Necessity: Processing is necessary to fulfill our contract with you (i.e., delivering the purchased course and managing your account).
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Legitimate Interests: We may process information for our legitimate interests, such as improving our services, conducting marketing analysis, and preventing fraud, provided these interests are not overridden by your rights and interests.
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Legal Obligations: Processing is necessary to comply with the law.
Information Sharing and Disclosure
We respect your privacy and do not sell your personal information. We may share your information only in these limited circumstances:
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Third-Party Service Providers: We share necessary information with trusted third parties who perform services on our behalf. These include:
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Wix: Our website hosting platform, course delivery system, and payment processor.
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Google Analytics: To analyze website traffic and usage patterns.
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Meta (Facebook/Instagram): To measure advertising effectiveness and potentially deliver targeted advertising via the Meta Pixel.
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Klaviyo To manage and send email marketing communications.
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We require these providers, where feasible, to protect your information and use it only for the purposes we specify. Review their respective privacy policies for details on their data handling.
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Legal Requirements: If required by law, subpoena, court order, or other legal process, or to protect our rights or the safety of others.
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Business Transfers: In connection with a merger, acquisition, financing, or sale of all or a portion of our business assets, your information may be transferred to the acquiring entity.
Data Security
We implement reasonable administrative, technical, and physical security measures designed to protect your personal information from unauthorized access, use, alteration, or disclosure. Our platform provider, Wix, also employs security measures. However, please be aware that no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security. You are also responsible for maintaining the confidentiality of your account password.
Cookies and Tracking Technologies
Our website (www.composurecoach.com), hosted on Wix, uses cookies (small text files stored on your device) and similar technologies (like web beacons and the Meta Pixel). These are used for:
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Essential Functions: Operating the site, enabling login, managing purchases, and maintaining security.
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Performance and Analytics: Understanding how users interact with our site (e.g., using Wix Analytics and Google Analytics) to improve performance and content.
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Marketing/Advertising: Measuring the effectiveness of advertising campaigns (e.g., via Meta Pixel), delivering relevant advertising on third-party platforms (like Facebook/Instagram), and supporting email marketing efforts.
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Your Choices:
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Cookie Consent Tool: You may be able to manage preferences for non-essential cookies and tracking technologies via a consent banner or tool when you first visit our site. (Confirm this is active in your Wix settings).
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Browser Settings: Most browsers allow you to control cookies through settings, letting you refuse or delete them. Disabling essential cookies may affect site functionality.
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Analytics Opt-Out: To opt-out of Google Analytics tracking, visit: https://tools.google.com/dlpage/gaoptout.
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Advertising Opt-Outs: You can often manage preferences for interest-based advertising via tools provided by third parties like the Digital Advertising Alliance (DAA) opt-out pages (available for US, Canada, Europe) or through settings within platforms like Facebook/Instagram.
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We recommend reviewing the privacy and cookie policies of Wix, Google, and Meta for details on their specific technologies and data practices.
Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes outlined in this policy, including providing you with access to our services, maintaining your account, supporting marketing activities you've consented to, complying with our legal obligations (e.g., for tax and accounting purposes), resolving disputes, and enforcing our agreements. When your information is no longer needed for these purposes, we will securely delete or anonymize it.
Your Privacy Rights (Under PIPEDA)
Under PIPEDA and applicable Ontario laws, you have rights regarding your personal information:
· Right to Access: Request access to the personal information we hold about you.
· Right to Correction: Request correction of inaccurate or incomplete information.
· Right to Withdraw Consent: Withdraw your consent to our processing of your information at any time (especially for marketing emails via the "unsubscribe" link or by contacting us, and potentially for certain cookies/tracking via consent tools), subject to legal or contractual restrictions. Note that withdrawal may impact service delivery.
· Right to Challenge Compliance: Lodge a complaint regarding our compliance with PIPEDA with us or with the Office of the Privacy Commissioner of Canada.
· Exercising Your Rights: To exercise these rights, please contact us using the details in Section 14. We will respond to your request in accordance with applicable laws.
· Users in Other Jurisdictions: If you reside outside of Canada (e.g., in the United States), you may have additional rights under your local laws. Please contact us with any inquiries regarding your data.
Third-Party Websites
Our website operates on Wix, uses various third-party tools (like Google Analytics, Meta Pixel, Klaviyo), processes payments via Wix (or another processor), and may link to other websites. This Privacy Policy applies primarily to the information we directly collect and control. We are not responsible for the privacy practices of these third parties. We encourage you to review their respective privacy policies.
Children's Privacy
Our services are not intended for or directed at individuals under the age of 13 (or the relevant age of digital consent in your jurisdiction). We do not knowingly collect personal information from children. If we learn we have inadvertently collected such information, we will take steps to delete it.
International Data Transfers
Your personal information may be transferred to, stored, and processed in countries outside of your province or country of residence (including Canada and the United States), where data protection laws may differ. Our service providers (like Wix, Google, Meta, [Your Email Marketing Service Provider Name]) operate internationally. By using our services, you consent to the transfer of your information to these locations as necessary to provide the service and fulfill the purposes outlined in this policy.
Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of significant changes by posting the updated policy on our website and revising the "Effective Date" at the top. We encourage you to review this policy regularly.
Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact our Privacy Officer:
Composure Coach Attn: Privacy Officer
Email: support@composurecoach.com
Website: www.composurecoach.com