Last updated: January 13, 2021

Table of Contents

INTRODUCTION

Impro.AI (“Impro”, “we” or “our”) is disrupting the high cost, exclusive model of executive coaching to help people at all levels succeed in an era of continuous change. Impro enables 1:1 coaching at scale using a powerful, systemic approach. Impro’s objective is to improve each participant’s thinking, elevating their performance at work. Our customers are companies or organizations, who in turn make our coaching services available to their team members. In time, we also anticipate having an offering that individuals can subscribe to.

We take privacy and compliance with applicable privacy laws seriously, and are strongly committed to being transparent about our privacy practices. This policy (the “Privacy Policy”) explains how we collect, use, disclose and otherwise manage the personal information we collect from organizations and team members through our coaching sessions, our interactive coaching platform, this website and other channels for engaging organizations and team members (together, the “Services”). By using the Services, you agree to the collection, use and disclosure of personal information as set out in this Privacy Policy. 

We may make changes to our Privacy Policy from time to time.  When we do so, we’ll post the revised policy on our website and amend the “last updated” date at the top of the policy. We encourage you to check back on our website for the latest information on our Privacy Policy and practices. If we make significant changes to our Privacy Policy, we will take additional measures to bring these to your attention.  Following our posting of any changes to this policy, your continued use of the Services signifies your consent to the revised terms of this Privacy Policy.

If you have any questions about this Privacy Policy, please Contact Us.

TYPES OF PERSONAL INFORMATION WE COLLECT 

For the purposes of this policy, Personal information is any information about an identifiable individual, including any information that, alone or in combination with other information, could be used to identify an individual (“Personal Information”).  Personal Information does not include aggregated information, or any Personal Information that has been de-identified through the removal of potentially identifying details, such that the data may not be identified with a particular individual.

We collect Personal Information that team members and organizations share with us directly or provide by interacting with our platform or our website, or otherwise using the Services. The types of Personal Information we collect are as follows:

  • Information you share through the onboarding process. When you sign-up to participate as a team member, we ask you to provide information important to the coaching process, including your name, location and family status, as well as information about your personal and professional history, values, vision, hobbies, personality and challenges. You may also share links with us to your social media sites so that we can learn more about you. During the onboarding process we may ask you to complete a survey about your personality and perceived strengths and weaknesses. 
  • Information you share through our interactive platform: Most of our coaching is done through our interactive platform, which facilitates communication between you, as a team member, and your coach. We collect Personal Information that you share with your coach through this platform, which may include a range of Personal Information including personal or professional experiences and challenges. 
  • Information you share in coaching sessions. Coaches will host video sessions with team members from time to time. Before each session begins, coaches will ask you for your consent to record these sessions. This will enable our coaches to better study your circumstances and thus help you more effectively. We will collect Personal Information provided by team members to coaches through recorded sessions. 
  • Information organizations share about team members: Most of the Personal Information we collect will come directly from you. However, from time to time, we may receive information from organizations, such as high-level insights into your job performance to help facilitate effective coaching sessions. 
  • Information you provide when you contact us. When you contact us through our “Contact” portal,  email us, or otherwise communicate with us directly, we will collect your contact information and may collect additional Personal Information from you, depending on the nature of your inquiry. 
  • Information tracked through your website visits. We also use common technologies, such as cookies, which track your device’s interaction with our website, including device identifier, browsing and location information. More information about the collection and use of such information is described in our Cookies and Related Technologies section.

 

Other than some key information which we require to provide our coaching services, the Personal Information that you provide to us is optional. You can share as much as or as little as you are comfortable with – whether through the onboarding process, your use of the interactive platform or participation in any video sessions. Note, however, that the more relevant information you provide to us, the better we will be able to offer you a tailored and successful coaching experience.

HOW WE USE YOUR PERSONAL INFORMATION

Impro generally collects, uses and discloses your Personal Information to provide services to organizations and team members and to operate our business, including for the following purposes:

  • Provide Coaching Services: We use your Personal Information to provide coaching services aimed at improving your productivity, adaptability and creativity. We may also use your Personal Information to monitor and improve coaching performance.
  • Develop Better Coaching Technology. We use Personal Information to develop, operate and improve our machine learning technology that generates coaching insights for you and your organization. 
  • Communicate with Customers and Team Members.  We use Personal Information to communicate regarding the Services, including concerns or queries customers or team members may have.  We also communicate with team members at various stages in the coaching process, and may communicate revisions to this Privacy Policy.
  • Improve our Services. We may use your feedback, comments, questions and engagement to understand and analyze the interests, needs and preferences of customers and team members, to improve our Services and to tailor those Services to you. As noted below, we may also use cookies and related technologies to improve our website and collect statistical information about how this website is being used.

 

With your consent, or as may be permitted by law, from time to time, we may also use your Personal Information to send you email or other communications that may be of interest to you and to tailor communications to your interests. You may opt-out of marketing and promotional communications at any time by Contacting Us or select the unsubscribe option in any marketing and promotional communication that you receive.

In general, we may also use your Personal Information to ensure compliance with our policies and terms, to protect our property and business interests and the interests of other users and to comply with applicable legal and regulatory requirements.

We do not collect personal information for purposes other than those identified in this Privacy Policy, unless your additional consent is obtained, or as required or permitted by law.

DISCLOSURE OF PERSONAL INFORMATION

We value the confidential relationship established between you as a team member and our coach and we will not disclose to your employer any Personal Information you provide through the onboarding process, interactive platform or coaching sessions. The only personal details we will share with your employer will relate to whether you have engaged in the coaching process as well as the volume and types of performance breakthroughs you have realized as a result of the coaching process. 

From time-to-time, we may provide organizations with team-level insights respecting the coaching process and its impact; however, such information will be aggregated and will not contain any Personal Information or identify individual team members in any way, including by implication. 

We will not sell or lease your Personal Information to any third party marketers, or otherwise provide your information to third parties for their own use.

We may provide your Personal Information to a third party where reasonably required in the context of a sale, merger or amalgamation of all or part of our business. In any such case, the recipient parties will be contractually required to keep the information confidential and use it only for the purposes of the transaction, or proposed transaction, in question. In the event a business transaction is completed, assignees or successors of Impro or our business or assets, may use and disclose Personal Information only for the purposes as set out this Privacy Policy, unless further consent is obtained.

We and our service providers may disclose your Personal Information in response to a search warrant or other legally valid inquiry or order, or as otherwise required or permitted by applicable law, including the disclosure of Personal Information where necessary for the establishment, exercise or defense of legal claims or to prevent actual or suspected loss or harm to persons or property.

PROCESSING OF PERSONAL INFORMATION BY THIRD PARTIES

From time to time, Impro may share your Personal Information with third party contractors and service providers that we have engaged to provide us with services or to perform services on our behalf, based on our instructions, such as data processing and storage companies or individuals and organizations that provide professional and administrative services to us.  We will limit our disclosure of your Personal Information to such third parties to that which is reasonably necessary for the purpose or service for which the third-party service provider is engaged.  We will use contractual and other means to provide a comparable level of protection while the information is being processed by such third parties, including limiting such providers to using your Personal Information solely to provide Impro with the specific service for which those providers were engaged, and for no other purpose. You can obtain more information about our policies and practices with respect to the use of Personal Information by third party service providers by Contacting Us.

Some third-party service providers that we may engage, including cloud-based providers such as Amazon Web Services and Microsoft Azure, may store or process your Personal Information in the United States or other jurisdictions other than Canada, where it may be the subject of laws of the jurisdiction in which it is stored. 

COOKIES AND RELATED TECHNOLOGIES

We collect Personal Information related to your visits to our website. This information includes device, browsing and location information. This information is collected to facilitate a more optimal browsing web browsing experience and collect statistical information about how this website is being used.

Cookies

Like most websites, our website uses a technology called “cookies”. A cookie is a tiny element of data that our website can send to your browser, which is stored on your device and records your preferences and your use of the website so we can recognize you when you return. We use cookies to help us understand our website activity and which areas of our website are useful and which areas need improvement. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our website, you may not be able to take full advantage of all of the features of our website.

Tailored Ads

We use Google AdSense and other third party advertising tools to advertise online. Third party vendors, including Google, may show ads for Impro on websites that you visit across the Internet. We and our service providers, including Google, use cookies to inform, optimize, and serve ads on third party websites based on your past visits to our website. These cookies may also be used to report on ad impressions, other uses of ad services and interactions with these ad impressions and ad services related to visits to our website.

You can choose to opt-out of receiving tailored advertising from Google by visiting Google’s Advertising – Privacy & Terms page.  In Canada, you can choose to opt out of receiving tailored advertising from other advertising services by visiting the Digital Advertising Alliance of Canada’s Opt-Out Tool. If you opt-out of receiving tailored advertising from these third parties, you may still see Impro ads on other websites, but those ads will not be customized by the companies that you opt-out of and Impro may continue to customize your experience on our website using cookies.

DATA-DRIVEN COACHING

While we rely on our coaches to provide insights to you, our Services include machine learning and related technologies to assist our coaches in providing effective insights and judgments, by observing patterns and correlations. These technologies themselves do not make decisions about you, but rather provide our coaches with additional perspectives that they may consider in assisting you to meet your coaching objectives. Upon request, we will provide you with an explanation of the prediction, recommendation or decision made by our technologies and how the Personal Information that was used to make the prediction, recommendation or decision was obtained. Please Contact Us for more information.

HOW WE SAFEGUARD PERSONAL INFORMATION

We have implemented reasonable and appropriate physical, organizational and technological safeguards designed to protect against unauthorized access, use, modification and disclosure of Personal Information in our custody and control. Our safeguards include the use of encryption and de-identification tools.

While Impro makes strong efforts to safeguard your Personal Information and to secure your data, no transmission of data over the Internet can be guaranteed to be 100% secure.  

RETENTION OF PERSONAL INFORMATION

We retain your Personal Information only where required to fulfil the purposes set out in this Privacy Policy, and for no longer than necessary to fulfill those purposes, including retention for a reasonable period of time to facilitate your potential restart of services with us, or as otherwise permitted or required by law. Certain third party service providers, like payment processors, may have their own retention policies and legal requirements related to retention. When we no longer have a legitimate need to retain your Personal Information, we will securely destroy or irrevocably erase it. 

YOUR CHOICES & ACCESS TO YOUR PERSONAL INFORMATION

We value your choices when it comes to your Personal Information. You choose how much information to share with us through the onboarding process, interactive platform and video sessions. You generally have the right to withdraw your consent to any further collection, use or disclosure of any elements of your Personal Information, subject to legal and contractual requirements; however, such a withdrawal may reduce your ability to take full advantage of our Services.

As noted above, you also have the right to opt-out of marketing communications.  If you would like to discuss your privacy choices, including your ability to opt-out of providing certain information, please Contact Us.

You have the right to access and request correction or updating of your Personal Information in our custody and control, subject to limited exceptions prescribed by applicable laws. You may do so by Contacting Us.

HOW TO CONTACT US

If you have any questions, concerns or complaints regarding our Privacy Policy or the manner in which we or our service providers treat your Personal Information, please contact our Privacy Officer by email at privacy@impro.ai.