LAST
UPDATED
July 21,
2026
Upper Coaching ("we," "us," or
"our") is committed to protecting your privacy and personal
information. This Privacy Policy explains how we collect, use, store, share,
and protect your information when you visit our website, engage in our coaching
or consulting services, or interact with us online.
1. INFORMATION
WE COLLECT
A.
Information You Voluntarily Provide
We collect personal information that you explicitly submit
to us when you:
- Register
for account access, consultation calls, or coaching programs.
- Fill out
contact forms, schedule appointments, or subscribe to
newsletters/marketing materials.
- Participate
in surveys, webinars, or client assessment tools.
This information may include:
- Contact
Data: Name, email address, phone number, and mailing address.
- Billing
Data: Account credentials, billing addresses, and payment details
(processed securely through PCI-compliant third-party payment processors).
B. Information Collected Automatically
When you access or navigate our website, we automatically
log certain technical data. This technical data includes:
- Technical
Details: IP address, browser characteristics, device attributes,
operating system, language preferences, and referring URLs.
- Usage
Data: Pages viewed, links clicked, time spent on site, and operational
traffic metrics.
- Tracking
Technologies: Information collected via cookies, web beacons, and
similar tracking mechanisms.
C. Sensitive Data
We do not intentionally request or process sensitive
personal data (e.g., social security numbers, detailed health records, or
biometric data) through our public web services.
2. HOW WE
PROCESS YOUR INFORMATION
We process
your data for legitimate commercial and professional coaching purposes,
including:
- Service
Delivery: Providing, administering, and fulfilling our coaching
programs, consulting engagements, and client agreements.
- Communication:
Responding to inquiries, sending operational updates, and providing
promotional communications (where permitted).
- Security
& Quality Assurance: Preventing fraud, monitoring system
integrity, and maintaining network stability.
- Legal
Compliance: Complying with applicable legal, accounting, and
regulatory requirements.
3. LEGAL BASES
FOR PROCESSING (INTERNATIONAL VISITORS)
If you
access our website or engage our services from the European Economic Area
(EEA), United Kingdom (UK), Canada, or jurisdictions with similar data
protection regulations, we process your personal data under the following legal
bases:
- Consent:
When you have given explicit consent for us to process your data for a
specific purpose (such as subscribing to marketing).
- Contractual
Necessity: When processing your data is necessary to execute or
deliver a coaching contract or agreement.
- Legal
Obligations: When required by law to comply with tax, statutory, or
regulatory requirements.
- Legitimate
Interests: When processing is necessary for our legitimate business
operations, such as improving our services, securing our network, or
conducting internal analytics.
4. SHARING AND
THIRD-PARTY DISCLOSURES
Upper
Coaching does not sell, rent, or trade your personal information. We may
share your data strictly in the following operational scenarios:
- Service
Providers: Trusted third-party vendors who assist with website
hosting, cloud storage, payment processing, email communication,
scheduling applications, and web analytics.
- Business
Operations & Affiliates: Parent entities, subsidiaries, or
joint-venture partners operating under equivalent privacy practices.
- Business
Transfers: In connection with or during negotiations of any corporate
merger, acquisition, financing, or sale of business assets.
- Legal
Requirements: When required by law, court order, or governmental
authorities to protect our legal rights, property, or safety.
5.
INTERNATIONAL DATA TRANSFERS
Our primary
operations and servers are located in the United States. If you access our
services from outside the United States, your information will be transferred
to, stored, and processed in our U.S. facilities or those of our third-party
service providers. We take all necessary steps to ensure your data is
adequately protected in accordance with applicable privacy laws.
6. DATA
SECURITY & RETENTION
Security
Measures
We implement appropriate technical and organizational
safeguards—including standard data encryption, restricted server access,
regular security monitoring, and internal access controls—to protect your
personal data against unauthorized access or disclosure.
Retention Period
We retain personal data only as long as necessary to
fulfill the purposes outlined in this notice, for up to 60 months, unless a
longer retention period is required by law (such as for tax or legal
record-keeping). Once no longer required, data is safely deleted, anonymized,
or securely isolated.
7.
DO-NOT-TRACK (DNT) & COOKIES
- Do-Not-Track Signals:
Most web browsers offer a "Do-Not-Track" (DNT) browser setting.
Because a uniform technical standard for DNT implementation has not been
universally finalized, our systems do not currently respond to automated
DNT browser signals.
- Cookies:
You can adjust cookie preferences and track opt-outs at any time directly
through your individual web browser settings.
8. MINORS
& PRIVACY
Our
services are strictly intended for individuals aged 18 or older. We do not
knowingly solicit or collect data from children under 18. If we discover that
personal data from a minor has been collected, we will deactivate the account
and delete the data promptly.
9. YOUR
PRIVACY RIGHTS & CHOICES
Depending
on where you reside (including California, the EU, UK, and other
jurisdictions), you may hold specific rights regarding your personal data:
- Account
Updates & Deletion: You can review, update, or request the
deletion of your account data by contacting us.
- Marketing
Opt-Out: You may unsubscribe from marketing emails at any time by
selecting the "Unsubscribe" or "Opt-Out" link in any
promotional message.
- California
Residents ("Shine the Light" & CCPA): California
residents may request information regarding categories of personal
information shared with third parties, as well as request the specific
deletion or access to collected data.
10. UPDATES TO
THIS NOTICE
We may
update this Privacy Policy periodically to stay compliant with relevant legal
and operational requirements. The updated date at the top of this document
indicates when changes take effect.
11. CONTACT US
If you have
questions, privacy requests, or concerns regarding this policy, please contact
us at:
- Email:
contact@uppercoaching.org
- Contact
Form: Directly via our contact page on the website