1. Notice at Collection: Categories of Personal Information We Collect
In the preceding 12 months, and on an ongoing basis, we may collect the following categories of personal information, as defined by the CCPA:
● Identifiers, such as name, mailing address, email address, telephone number, and online identifiers;
● Customer records information, such as billing and payment information, and signatures on forms or agreements;
● Commercial information, such as records of services purchased or considered;
● Internet or other electronic network activity information, such as interactions with our website, collected through cookies and similar technologies (see our Cookie Policy);
● Audio, electronic, visual, or similar information, such as photos, video, or voice recordings you voluntarily provide, for example for a testimonial;
● Education information, such as school or program information you choose to share as part of coaching intake;
● Inferences, drawn from the categories above to create a profile about your preferences, for example to tailor coaching topics to your goals;
● Sensitive personal information, such as information you voluntarily disclose about health, mental or emotional well-being, or similar sensitive topics during coaching sessions; we do not collect government identification numbers, precise geolocation, or account log-in credentials except as reasonably necessary to operate the Site.
We do not collect protected classification characteristics (such as race, religion, or sexual orientation), biometric identifiers, or genetic information, except to the extent you voluntarily disclose such information to us in the course of coaching, and we do not use any such voluntarily disclosed information to infer characteristics about you for advertising purposes.
2. Sources of Personal Information
We collect personal information directly from you (for example, through intake forms, applications, scheduling, and communications), and from service providers that support our operations.
3. Purposes for Collecting and Using Personal Information
We collect and use personal information for the business and commercial purposes described in our Privacy Policy, including to provide and administer coaching services, process payments, communicate with you, maintain business records, ensure safety, and comply with legal obligations. We do not use personal information for purposes incompatible with these disclosed purposes without providing notice as required by law.
4. Categories of Personal Information Disclosed for a Business Purpose
In the preceding 12 months, we disclosed the following categories of personal information to service providers and other recipients for a business purpose: identifiers, customer records information, commercial information, internet or network activity information, and, where applicable, audio/visual information, education information, inferences, and sensitive personal information. We disclosed these categories to the service provider categories described in our Privacy Policy (payment processors, scheduling platforms, CRM systems, email marketing providers, and website hosting and analytics providers), as well as to professional advisers and government agencies where required by law.
5. We Do Not Sell or Share Personal Information
Project GRW does not sell personal information for money, and does not “share” personal information (as that term is defined under the CPRA) for cross-context behavioral advertising. In the preceding 12 months, we have not sold or shared personal information, and we do not knowingly sell or share the personal information of minors under 16 years of age. If our practices change, we will update this Notice and provide any required opt-in or opt-out mechanism before doing so, including honoring applicable opt-out preference signals such as Global Privacy Control where required by law.
6. Retention of Personal Information
We retain each category of personal information described above for as long as reasonably necessary and proportionate to the purposes described in this Notice and our Privacy Policy, including to provide services, maintain business and tax records, resolve disputes, comply with legal obligations, and protect our rights. Retention periods vary depending on the category of information, the nature of our relationship with you, the sensitivity of the information, and legal or operational requirements, as described in more detail in our Privacy Policy.
7. Your California Privacy Rights
Subject to certain exceptions and verification requirements, California residents may have the right to:
● Right to Know / Access and Data Portability: request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purpose for collecting it, the categories of third parties with whom it is shared, and, where required, provide a copy of your personal information in a portable and, to the extent technically feasible, readily usable format;
● Right to Delete: request deletion of personal information we have collected from you, subject to certain exceptions;
● Right to Correct: request that we correct inaccurate personal information we maintain about you;
● Right to Opt Out of Sale or Sharing: request that we not sell or share your personal information (Project GRW does not currently engage in either activity);
● Right to Limit Use of Sensitive Personal Information: request that we limit our use and disclosure of sensitive personal information to purposes permitted by the CCPA, to the extent we use or disclose sensitive personal information for purposes that trigger this right;
● Right to Non-Discrimination: you will not receive discriminatory treatment, such as denial of services or different pricing, for exercising any of your CCPA rights.
8. How to Submit a Request
To submit a request to know, access, obtain a portable copy, delete, correct, opt out, or limit the use of your personal information, please contact us using the information in Section 12 below and include enough information for us to reasonably identify your records (for example, your name and email address associated with your enrollment or inquiry). We will verify your request using information already on file, and may ask for additional information reasonably necessary to verify your identity. You may designate an authorized agent to submit a request on your behalf; we may require proof of the agent’s authority and separately verify your identity.
We will respond to a verifiable consumer request within the time period required by the CCPA, currently 45 days, which may be extended by an additional 45 days when reasonably necessary, with notice to you of the extension.
9. Financial Incentives
We do not currently offer any financial incentive or price or service difference in exchange for the collection, sale, or sharing of personal information.
10. “Shine the Light” Disclosure
California Civil Code Section 1798.83 (“Shine the Light”) permits California residents to request certain information about disclosures of personal information to third parties for their own direct marketing purposes. Project GRW does not disclose personal information to third parties for their own direct marketing purposes.
11. Changes to This Notice
We may update this Notice from time to time to reflect changes in our practices or applicable law. The updated version will be indicated by a revised effective date.
12. Contact Us
To exercise your California privacy rights, ask questions about this Notice, or request this Notice in an alternative format, please contact:
Project GRW LLC
3025 Capri Ln.
Costa Mesa, CA 92626
Email: brian@projectgrw.com
Phone:949-227-9200
