This Privacy Policy explains how Real-Time Teamwork, Inc., doing business as Real-Time Coaching™ (“Company”, “we”, or “us”), collects, uses, shares, and protects personal information in connection with our website and assessment, coaching, and workplace-integration services (together, the “Services”). This Policy applies to information we collect directly and does not apply to third parties that are not acting on our behalf. We may update this Policy from time to time as described in Section 11 below.
We aim to comply with applicable data protection laws, including the General Data Protection Regulation (“GDPR”) and the UK GDPR, for individuals located in the European Economic Area and United Kingdom.
1. Who We Are; Data Controller
For most personal information described in this Policy, Company acts as the data controller responsible for determining why and how personal information is processed. Where we process personal information on behalf of an organization Customer as part of the Services (for example, employee profile or assessment data an organization administers), the organization Customer may act as the data controller and Company acts as its data processor, subject to the terms of our agreement with that organization.
If you have questions about this Policy or wish to exercise a privacy right, contact us at contact@rtcoaching.com.
2. Information We Collect
We collect the following categories of personal information:
Account and Contact Information
Name, email address, phone number (optional), job title, organization name and type, employee count, and login credentials.
Assessment Data
Results from our proprietary (or third-party) assessments, and any comparable assessment results you choose to enter that you previously took elsewhere (collectively, “Assessment Data”).
Coaching Content
Messages and other input you provide through coaching features, and the guidance, notes, and summaries generated for you through the Services, which may reference your Assessment Data and, where applicable, limited profile information about colleagues you are matched or paired with within your organization.
Calendar and Scheduling Data
If you connect a calendar or workplace-communication account to the Services, we collect limited scheduling information — event titles, times, and the names and email addresses of meeting attendees who are also users of the Services within your organization — to power coaching features tied to your meetings. This is limited to information about you and other subscribed users of the Services within your organization; we do not retain or store information about meeting participants who are not subscribed users, other than the total number of attendees on a meeting.
Billing Information
Where the Services are purchased, we (or our payment processor) collect billing contact details and subscription information. Full payment card details are collected and stored by our payment processor, not by us.
Usage and Device Data
Information collected automatically through cookies and similar technologies, such as IP address, browser and device type, pages visited, and general usage patterns. See Section 4 (“Cookies and Similar Technologies”).
3. How We Use Information
We use personal information to:
- Provide, maintain, and improve the Services, including generating coaching guidance and notes using artificial intelligence and machine learning technologies;
- Create and manage accounts and organization profiles;
- Process orders, invoices, and payments;
- Communicate with you about the Services, respond to inquiries, and provide customer support;
- Send product updates and, where you have opted in or as otherwise permitted by law, marketing communications;
- Maintain the security, integrity, and proper functioning of the Services; and
- Comply with legal obligations and enforce our agreements.
We do not use identifiable Assessment Data or Coaching Content to train general-purpose artificial intelligence models. We may use de-identified or aggregated information for analytics and product improvement as described below.
We do not sell personal information, and we do not use Assessment Data or Coaching Content to make decisions about individuals’ eligibility for credit, insurance, employment, or similar benefits.
Legal Bases for Processing: Where applicable law requires a legal basis for processing personal information, we rely on one or more of the following: performance of a contract or steps taken at your request before entering into a contract; our legitimate interests in providing, securing, improving, and supporting the Services; compliance with legal obligations; and consent where required by law. Where we rely on consent, you may withdraw it at any time, without affecting processing that occurred before withdrawal.
4. Cookies and Similar Technologies
We use cookies and similar technologies to keep you signed in (session/functional cookies) and to understand how the Services are used through analytics and tracking technologies, which may be provided by us or by service providers acting on our behalf. Analytics data may be combined with other information we hold about you. Most browsers let you limit or block cookies, though doing so may affect certain features of the Services.
5. How We Share Information
We share personal information with:
- Service providers and subprocessors who perform functions on our behalf, such as cloud hosting and infrastructure, artificial intelligence and machine learning processing used to generate coaching content, identity and calendar integration providers, messaging and notification delivery, and payment processing. These providers are authorized to use personal information only as necessary to provide their services to us and are bound by confidentiality and data protection obligations. A list of subprocessor categories is available upon request;
- Your organization and its authorized users, where Assessment Data, Coaching Content, or profile information is shared within a team or organization as configured through the Services;
- Professional advisors, auditors, and successors in the event of a merger, acquisition, financing, or sale of assets;
- Government authorities or third parties, where required by law, legal process, or to protect our rights, users, or the public; and
- Any other party with your consent.
6. International Data Transfers
We are based in the United States, and personal information we collect may be transferred to, stored, and processed in the United States or other countries that may not provide the same level of data protection as your home jurisdiction. Where we transfer personal information from the European Economic Area, United Kingdom, or Switzerland, we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses or equivalent mechanisms, to protect that information.
7. Data Retention
We retain personal information for as long as needed to provide the Services and for legitimate business or legal purposes, including the following:
- Calendar events we sync are retained only on a short rolling basis and are deleted automatically once they fall outside that window; disconnecting a calendar or ending a subscription results in prompt deletion of synced calendar events rather than gradual expiration. Coaching conversations that reference your meetings are retained with your Coaching Content as described below;
- Server and technical logs are retained for a limited period, generally no more than 30 days;
- Assessment Data, Coaching Content, and account information are retained for as long as your account or your organization’s account has not been deleted, and are deleted following a verified deletion request; and
- We may retain limited information for longer where necessary to comply with legal, tax, or accounting obligations, or to resolve disputes.
Where feasible, we may retain de-identified or aggregated data derived from personal information for analytics and product-improvement purposes without further time limit.
8. Children
The Services are not directed to, and are not intended for use by, anyone under 18 years of age. We do not knowingly collect personal information from children under 18. If we learn we have collected personal information from a child under 18 without appropriate consent, we will take reasonable steps to delete it.
9. Your Privacy Rights
Depending on your location, you may have the right to: access the personal information we hold about you; correct inaccurate information; request deletion; object to or restrict certain processing; and receive a portable copy of your information. To exercise any of these rights, contact us at contact@rtcoaching.com. We will respond in good faith and within the time required by applicable law. If you are located in the European Economic Area or United Kingdom, you also have the right to lodge a complaint with your local data protection supervisory authority.
Depending on your jurisdiction and subject to applicable exceptions, you may also have rights to obtain information about categories of personal information we collect, use, or disclose; opt out of certain processing where applicable; and appeal a decision we make regarding a privacy request. We will not discriminate against you for exercising rights provided by applicable privacy law.
Where Company processes personal information on behalf of an organization Customer as a data processor, we will direct your request to that organization or assist the organization in responding, as appropriate.
10. Security
We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, or disclosure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
11. Changes to This Policy
We may update this Policy from time to time. If we make material changes, we will update the “Last Revised” date above and, where required by law, provide additional notice. Continued use of the Services after changes take effect constitutes acceptance of the updated Policy.
12. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at contact@rtcoaching.com.