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Privacy Policy

Full Bloom Coaching, LLC (“Full Bloom Coaching”) last updated this Privacy Policy (“Privacy Policy”) on October 3, 2023.

 

Full Bloom Coaching takes your privacy very seriously.  We respect your privacy, and we want to inform you about how and why we collect, use, or share your data.   This Privacy Policy applies to all the activities you engage in with Full Bloom Coaching (“Services”).  Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.

 

We collect, use, and are responsible for certain personal information about you. When we offer services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a “controller” of that personal information for the purposes of the GDPR. We are responsible for your personal information as a “business” under the CCPA/CPRA.

 

Please see sections 9 and 10 for policies specific to California and the EU respectively.

1. DATA YOU GIVE US

Full Bloom Coaching may collect different data from or about you, depending on how you use Full Bloom Coaching’s Services.  Some of the data we may collect includes:  (1) data related to your contact information, including your e-mail address, gender, date of birth, etc.; (2) data related to any user profile you create, including a photo, website link, social media profile link, your testimonials about Full Bloom Coaching’s Services, etc.; (3) deliverables you request or receive; (4) payment and billing data; (5) communications you have with Full Bloom Coaching; (6) technical data related to your device, including your type of device used to access Full Bloom Coaching’s services, your IP address, browser type, etc.; (7) data showing your usage of our Services, including pages you visited, materials you downloaded, etc..  We may store this information in a manner that associates it with you.

2. HOW WE RECEIVE YOUR DATA

Full Bloom Coaching and service providers acting on its behalf (like Google Analytics and third-party advertisers) use server log files and automated data collection tools like cookies, tags, scripts, customized links, and device or browser fingerprints when you access and use the Services. These methods automatically track and collect certain data when you use Full Bloom Coaching’s Services. In some cases, Full Bloom Coaching ties data gathered through those Data Collection Tools to other data that we collect as described in this Privacy Policy.  Full Bloom Coaching uses cookies (small files that websites send to your device to uniquely identify your browser or device or to store data in your browser) for things like analyzing your use of the Services, personalizing your experience, and recognizing you when you return.

 

Full Bloom Coaching also uses third-party browser and mobile analytics services like Google Analytics. These services use data collection tools to help us analyze your use of the Services, including information like the third-party website you arrive from, how often you visit, events within the Services, usage and performance data, and where the application (if any) was downloaded from. We use this data to improve the Services, better understand how the Services perform on different devices, and provide information that may be of interest to you.

3. HOW WE USE AND SHARE YOUR DATA

Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

  • To comply with our legal and regulatory obligations

  • For the performance of our contract with you or to take steps at your request before entering a contract

  • For our legitimate interests or those of a third party, or 

  • Where you have given consent

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A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.


As a general matter, Full Bloom Coaching uses your data in several ways, including but not limited to the following:  Provide and administering the Services, including to display customized content and facilitate communication with you and others; Process your requests and submissions to meet with Full Bloom Coaching to receive specific Services, or information; Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse; Solicit feedback from users; Market and administer surveys and promotions administered or sponsored by Full Bloom Coaching; Learn more about you by linking your data with additional data through third-party data providers or analyzing the data with the help of analytics service providers; Identify unique users across devices; Tailor advertisements across devices; Improve our Services and develop new products, services, and features; Analyze trends and traffic, track purchases, and track usage data; Advertise the Services on third-party websites and applications; As required or permitted by law; or As Full Bloom Coaching, in its sole discretion, otherwise determines to be necessary to ensure the safety or integrity of its users, employees, third parties, the public, or Full Bloom Coaching’s Services.

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Full Bloom Coaching may share your data with third parties as follows:  

  • Full Bloom Coaching shares your data with third-party companies who perform services on Full Bloom Coaching’s behalf, like payment processing, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.

  • Full Bloom Coaching may disclose your data to third parties if Full Bloom Coaching (in our sole discretion) have a good faith belief that the disclosure is:  Permitted or required by law; Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding; Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request; Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements; Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or Reasonably necessary in Full Bloom Coaching’s discretion to protect against imminent harm to the rights, property, or safety of Full Bloom Coaching, its users, employees, members of the public, or its Services.

  • If Full Bloom Coaching undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all your data to the successor organization during such transition or in contemplation of a transition (including during due diligence)

  • With your consent, Full Bloom Coaching may share data to third parties outside the scope of this Privacy Policy.

4. SECURITY

Full Bloom Coaching takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data. Unfortunately, however, no system can be 100% secure, so Full Bloom Coaching cannot guarantee that communications between you and Full Bloom Coaching regarding the Services or materials, or any information provided to Full Bloom Coaching in connection with the data we collect through the Services, will be free from unauthorized access by third parties.

5. YOUR RIGHTS​

You can choose not to provide certain data to Full Bloom Coaching, but you may not be able to use certain features of the Services.  To opt out of receiving any promotional communications from Full Bloom Coaching, you can use the “unsubscribe” mechanism included in the communication.  Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, important updates about the Services, scheduling emails, and notices about our policies.  Any other “opting out” would need to be completed by you through your internet browser settings.

 

After termination of your relationship with Full Bloom Coaching, some or all your data may still be visible to Full Bloom Coaching and others. We retain your data for as long as Full Bloom Coaching has a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce Full Bloom Coaching’s agreements. We may retain and disclose such data pursuant to this Privacy Policy after your relationship with Full Bloom Coaching has been terminated.

 

To request to access, correct, or delete your personal data, email us at aneetrah@fullbloom.coach.  Please allow up to 30 days for a response. For your protection, Full Bloom Coaching may require that the request be sent through the email address associated with your account, and Full Bloom Coaching may need to verify your identity before implementing your request.

6. UPDATING THE PRIVACY POLICY AND INCORPORATION OF TERMS

When Full Bloom Coaching deems it appropriate, it may update this Privacy Policy to clarify its practices or to reflect new or different practices.  Full Bloom Coaching reserves the right in its sole discretion to modify and/or make changes to this Privacy Policy at any time. If Full Bloom Coaching makes any material change, it will notify you using prominent means such as by email notice sent to the email address you provided to Full Bloom Coaching or by posting a notice through its website.  Modifications will become effective on the day they are posted unless stated otherwise.

 

Your continued use of our Services after changes become effective shall mean that you accept those changes. Any revised Privacy Policy shall supersede all previous Privacy Policy.  The terms and conditions contained within Full Bloom Coaching’s Terms of Service & Use are incorporated herein.

7. CONTACTING US

Please contact us by email or telephone if you have any questions about this Privacy Policy or the information about you we retain.

 

Our email is: aneetrah@fullbloom.coach.

8. DO YOU NEED EXTRA HELP?

If you would like this notice in another format for example: audio, large print, braille, please contact us (see “How to contact us” above).

9. JURISDICTION-SPECIFIC RULES & NOTICES — CALIFORNIA

If you are a California resident, you have the right to request certain details about what personal information Full Bloom Coaching shares with third parties for those third parties’ direct marketing purposes. To submit your request, send an email to aneetrah@fullbloom.coach with the phrase “California Shine the Light” or “California CCPA Request” and include your mailing address, state of residence, and email address.


In addition, know that the California Consumer Privacy Act of 2018 (“CCPA”) provides California resident consumers with specific rights regarding their personal information.  Under the CCPA, you have the following rights:

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1. Access to Information and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.

  • The categories of sources for the personal information we collected about you.

  • Our business or commercial purpose for collecting or selling that personal information.

  • The categories of third parties with whom we share that personal information.

  • The specific pieces of personal information we collected about you (also called a data portability request).

  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

    • Sales, identifying the personal information categories that each category of recipient purchased; and

    • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

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2. Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained (with certain exceptions). Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.


We may deny your deletion request if retaining the information is necessary for us or our service providers to:  complete the transaction for which we collected the personal information; provide a good or service that you requested; take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; debug products to identify and repair errors that impair existing intended functionality; exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.); engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; comply with a legal obligations; make other internal and lawful uses of that information that are compatible with the context in which you provided it.


To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by e-mailing aneetrah@fullbloom.coach.  Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.


You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:  provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.


We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

3. Response Timing and Format

We try to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing via email or mail.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.  We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

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4. Non-Discrimination

Full Bloom Coaching will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

10. JURISDICTION-SPECIFIC RULES & NOTICES — THE EU

1. ​​​Promotional Communications 

We may use your personal information to send you updates by email, text message, or telephone about our services, including exclusive offers, promotions, or new services.

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We have a legitimate interest in processing your personal information for promotional purposes (see above “How We Use and Share your personal Data"”. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

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We will always treat your personal information with the utmost respect and never sell it to other organizations for marketing purposes.  You have the right to opt out of receiving promotional communications at any time by:

 

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

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​2. ​​​Your Rights under the EU GDPR

  • Right to Be Informed: The right to know or be notified about the collection and use of your personal information.

  • Right to Access: The right to be provided with a copy of your personal information (the right of access).

  • Right to Rectification: The right to require us to correct any mistakes in your personal information.

  • Right to be Forgotten: The right to require us to delete your personal information—in certain situations.

  • Right to Restriction of Processing: The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data

  • Right to Data Portability: The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations.

  • Right to Object:

    • At any time to your personal information being processed for direct marketing (including profiling).

    • In certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests

  • Right Not to be Subject to Automated Individual Decision-Making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

 

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the EU General Data Protection Regulation.

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​3.​​​Location of Data Storage

Full Bloom Coaching is headquartered in North Carolina, United States and to provide the Services to you we must transfer your data outside of the European Economic Area to the United States and process it there. By visiting or using Full Bloom Coaching’s Services, you consent to storage of your data on servers located in the United States. If you are using the Services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries. Specifically, personal data collected in Switzerland and the European Economic Area (“EEA”) is transferred and stored outside those areas.  By submitting your data or using our Services, you consent to the transfer, storage, and processing by Full Bloom Coaching and its processors and agents.

 

For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA.”​

 

4.​​​Transferring Your Personal Information Out of the EEA.

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

  • With our offices outside the EEA

  • With your and our service providers located outside the EEA

  • If you are based outside the EEA, or

  • Where there is an international dimension to the services we are providing to you

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These transfers are subject to special rules under European and UK data protection law.  If you would like further information, please contact us (see “How to Contact Us” above).

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​5. ​​​How to File a GDPR Complaint. 

We hope that we can resolve any questions or concerns you raise about our use of your information.

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However, the General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in the European Union or European Economic Area state where you work, normally live, or where any alleged infringement of data protection laws occurred. The supervisory authority in the country is the entity who may be contacted at aneetrah@fullbloom.coach.

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