Privacy Policy

Updated at 2021-01-19

Privacy Policy

Version 1.1, 2021-01-19

Your privacy is important, both for you and for us. We will do our very best to ensure that the data you let us process is handled in a secure way, with your integrity in focus. The Coaching Wheel (“we,” “our,” or “us”) is committed to protecting your privacy.

This Privacy Policy applies to our website,, and its associated subdomains (collectively, our “Service”) alongside our application The Coaching Wheel. By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.


For this Privacy Policy:

  • You is referred to the person who accessed the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to the Coaching Wheel.
  • Website is referred to The Coaching Wheel, accessible from
  • Service is referred to the website.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Third-party Social Media Service could be any website or social network website in which a User can log in or create an account to use the Service.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Cookies are a small amount of data generated by a website and saved by your web browser. Its purpose is to remember information about you, similar to a preference file created by a software application.
  • Device could be any device with internet who can access the service such as a mobile phone, a computer or a digital tablet.
  • Usage Data it’s referred to the data that’s been collected automatically, either generated by the use of the Service or from the Service infrastructure itself. For example, how many times the user accessed the website or how many .

What Information Do We Collect?

We collect information from you when you visit our website, register on our site, place an order, subscribe to our service, fill out a contact form or respond to a survey.

Depending on who you are, we collect:

  • Contacts - such as Email address, Name / username, Social media profile information
  • Interaction Information – meaning information on how you use the Services and your system activities (dates, times and details of log-on and log-off including information on your history with the Coaching Wheel, plan upgrate dates, etc.; technical data such as page response times, your interactions with the customer service, etc.
  • Device Information – e.g. IP address, user agent, browser settings, operating system and platform and screen resolution. We may, for example, use an IP address received from your browser or device to determine approximate location.
  • Third-Party Information – in your interaction with our Services we use third-party platforms to collect some information, analyze so that it enables us to give you relevant communication and services. Examples of third party information are details regarding connected third party accounts (such as the e-mail or username for a connected PayPal or Google account).
  • Additional Information – means other information, when and to the extent submitted to our Websites or if you, for example, participate in a focus group, contest, request support, leave reviews or otherwise communicate with the Coaching Wheel and any other personal information that you choose to send to us.
  • Cookie Information – Please see our Cookie Policy for more information

You (or your organization as our Customer) are liable for personal data included in information submitted by you to a workspace in your use of the Application (e.g. Text, rates, etc. submitted electronically), including also personal data provided by Audience in their interaction with your group session. The Coaching Wheel will only store such personal data to the extent provided and as a result of your use of the Application.

How Do We Use The Information We Collect?

The typical situations when we process your data are listed below:

  • To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you)
  • To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs)
  • Contacts, Device Information, Third Party Information can be used to communicate with you and/or provide you support through email; maintain a good record keeping in the day-to-day business activities. This information can be processed with the legal basis being legitimate interest
  • Contacts, Device Information, Cookie Information and Interaction Information can be processed with the purpose to provide appropriate security measures, to detect multi-use, fraudulent behavior and other acts in violation of the Terms. The purpose of processing of this data is the legal basis being contractual obligations.
  • Contacts and Device Information can be processed to set up your Account with your identifying information and to send you invoices; This information is processed with the legal basis being contractual obligations.
  • Third Party Information can be processed to conduct marketing activities with the legal basis being legitimate interest.
  • Cookie Information can be processed to conduct marketing activities and provide appropriate security measures, as examples, please read our full Cookie Policy for more information. Cookie Information can be processed with the legal basis being legitimate interest and your consent.
  • All collected information can be used to process transactions, to administer a contest, session, coaching wheel, life wheel, decision wheel or other site feature; to conduct monitoring and incident / issue tracking, such as to troubleshoot the Services, detect errors and other issues.

Payment related data

We use PayPal (Braintree) who is a level 1 PCI compliant third-party vendor to process credit card payments. We never store, handle or access any payment related data other than described herein. We may collect some limited information, such as your email address and transaction history. In addition, PayPal generally provides us with limited information related to you, such as a unique token that enables you to make additional purchases using the information they’ve stored, and your type of card, expiry date and last four digits as well as IP address and VAT number, where applicable. If you choose to pay by invoice, we may need to collect and transfer additional information, like your company name, registration number and phone number, to our invoicing service provider to enable credit checks and send you invoices. PayPal is controllers and responsible for the personal data that they collect. The use of your data by our invoicing service providers is subject to their own privacy policies. We have data processing agreements with PayPal in place.

How Do We Use Your Email Address?

By submitting your email address on this website, you agree to receive emails from us. We only send emails to people who have authorized us to contact them, either directly by sending us email via contact form, or through a third party. We do not send unsolicited commercial emails, because we hate spam as much as you do.

How Long Do We Keep Your Information?

We keep your information only so long as we need it to provide The Coaching Wheel to you and fulfill the purposes described in this policy. This is also the case for anyone that we share your information with and who carries out services on our behalf. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we’ll either remove it from our systems or depersonalize it so that we can't identify you.

You can at all times delete your projects and coaching wheels when you are logged into our Application. You may delete your contacts and other personal data including the entire Account on request by email to We will comply with your request promptly and at the latest within 30 days. We store personal data as long as needed for the purpose described in this Privacy Policy but please note that we may store personal data for a longer period of time if needed to fulfil legal requirements.

How Do We Protect Your Information?

We implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information. We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. After a transaction, your private information (credit cards, social security numbers, financials, etc.) is never kept on file. We cannot, however, ensure or warrant the absolute security of any information you transmit to The Coaching Wheel or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or managerial safeguards.

Where We store personal information?

Personal information that you submit through the Services may be stored, processed and transferred to countries other than where you live, for example, to our servers or our authorized service providers in the European Economic Area (EEA) or the United States of America. By submitting your personal information to us, you consent to these transfers, storing and processing. We will take all reasonable efforts to ensure that your data is treated securely and in accordance with this policy.

Governing Law

The laws of Bulgaria, excluding its conflicts of law rules, shall govern this Agreement and your use of the website. Your use of the website may also be subject to other local, state, national, or international laws.

Your Consent

By using our site, registering an account, or making a purchase, you consent to this Privacy Policy.

Links to Other Websites

Our service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.


The Coaching Wheel uses "Cookies" to identify the areas of our website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We use Cookies to personalize the Content that you see on our website. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our website correctly or at all. We never place Personally Identifiable Information in Cookies.

Kids' Privacy

The Services are addressed to organizations and individuals being sixteen years of age or older. By registering an Account, you warrant and represent that you have that legal age as further described in the Terms. If You are a parent or guardian and You are aware that Your child under sixteen has provided Us with Personal Data without your permission, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from Our servers.

Changes To Our Privacy Policy

This Privacy Policy is not part of the Terms and we may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, we will provide additional notice through the Services. If you disagree with the changes to this Privacy Policy, you should send us a request to delete your Account.

Third-Party Services

We may display, include or make available third-party content (including data, information, applications and other products services) or provide links to third-party websites or services ("Third- Party Services").

You acknowledge and agree that The Coaching Wheel shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof. The Coaching Wheel does not assume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services.

Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely at your own risk and subject to such third parties' terms and conditions.

Third-Party Service Providers

We engage third party companies or individuals as service providers or business partners to process your Account to support our business. These third parties are our processors and may, for example, provide and help us with computing and storage services. From time to time, we may remove or engage new processors and when we do the Coaching Wheel will ensure that the processor may access and use your data only to deliver the services the Coaching Wheel has retained them to provide and is prohibited from using such data for any other purpose. Please see our entire list of processors below.

  • Hosting Services - We use, Inc. and its affiliate Heroku for application and data hosting and contents services (Contact Address: Salesforce Tower, 415 Mission St. San Francisco, California 94105).

  • Data analytics Services - We have engaged with Google, LLC. (Google Analytics, Google Optimize) as a service provider for Data analytics, tracking, communication and advertising (Contact Address: 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA).

  • Internal management - We use Google, LLC. (Gmail) services for external & internal communication (email) (Contact Address: 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA).

  • Invisible reCAPTCHA - Invisible reCAPTCHA by Google, LLC. analyzes activity on a job post (e.g. mouse movements and typing patterns) to determine if a user is a robot. Invisible reCAPTCHA service may collect information from Your device. The information gathered by Invisible reCAPTCHA is held in accordance with its Privacy Policy

  • Financial services - PayPal (Europe) S.à.r.l. (Braintree) - we do not collect, access, or store credit card information. We use PayPal (Braintree) as third party payment processors. Please refer to Braintree website for details on how your financial information is handled and protected (Contact Address: et Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxembourg).

Your Rights Under General Data Protection Regulation (GDPR)

For the purpose of this Privacy Policy, we are a Data Controller of your personal information.

If you are from the European Economic Area (EEA), our legal basis for collecting and using your personal information, as described in this Privacy Policy, depends on the information we collect and the specific context in which we collect it. We may process your personal information because:

  • We need to perform a contract with you, such as when you use our services
  • You have given us permission to do so
  • The processing is in our legitimate interests and it's not overridden by your rights
  • For payment processing purposes
  • To comply with the law

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the personal information we have on you
  • The right of rectification
  • The right to object
  • The right of restriction
  • The right to data portability
  • The right to withdraw consent

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your personal information. For more information, please contact your local data protection authority in the European Economic Area (EEA).

California Residents

The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it, which we have explained above.

We are also required to communicate information about rights California residents have under California law. You may exercise the following rights:

  • Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information we collect, use, or share; (2) purposes for which categories of Personal Information are collected or used by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you.
  • Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
  • Right to Delete. You may submit a verifiable request to close your account and we will delete Personal Information about you that we have collected.
  • Request that a business that sells a consumer's personal data, not sell the consumer's personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

We do not sell the Personal Information of our users.

For more information about these rights, please contact us.

California Online Privacy Protection Act (CalOPPA)

According to CalOPPA, personal information is defined as any data that may be used to identify a person

Under the CalOPPA, California consumers have the right to:

  • Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
  • Request that a business delete any personal data about the consumer that a business has collected.
  • Request that a business that sells a consumer's personal data, not sell the consumer's personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

Contact Us

Don't hesitate to contact us if you have any questions.