Privacy Policy

Privacy Policy

At WJM Associates, we care deeply about privacy. We believe in transparency, and we’re committed to being upfront about our privacy practices, including how we treat your personal information. We know you care about your privacy too, so we provide settings that allow you to choose how certain information is used by WJM Associates. This policy explains our privacy practices for https://www.wjmassoc.com, provided by WJM Associates, depending on your location ("WJM Associates," together with "we", "us", and "our"). We'll refer to the Site as the "Services". This policy does not apply to the practices of third parties who may also collect or receive data in connection with your use of the Services.

  1. Our Privacy Policy
  1. Information Collected or Received
  1. Messages from WJM Associates
  1. Information Uses, Sharing, & Disclosure
  1. Transfers
  1. Security
  1. Retention
  1. Your Rights & Choices
  1. Privacy Policy Changes
  1. Contact


1. Our Privacy Policy

We process your personal information to run our business and provide our users with the Services. By accepting our Terms of Use mentioned at (https://www.wjmassoc.com/terms) (and in some jurisdictions, by acknowledging this policy), you confirm that you have read and understand this policy, including how and why we use your information. If you don’t want us to collect or process your personal information in the ways described in this policy, you shouldn’t use the Services. We are not responsible for the content or the privacy policies or practices of any of our members, or third-party websites and apps.

WJM Associates’s Terms of Use require all account owners to be at least 18 years of age. Minors under 18 years of age are not permitted to use the Services.

By using the Services, you acknowledge that WJM Associates will use your information in the United States, European Countries and any other country where WJM Associates operates. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. We will transfer personal information only to those countries to which we are permitted by law to transfer personal information as more fully described in the "Transfers" Section of this policy.


2. Information Collected or Received

In the course of providing our Services, we collect or receive your personal information in a few different ways. We obtain the categories of personal information listed below from the following sources: directly from you, for example, from forms you complete or during registration; indirectly from you based on your activity and interaction with our Services, or from the device or browser you use to access the Services; or from your employer, or from our vendors and suppliers that help provide WJM Associates services you may interact with, and from our third party advertising and marketing partners. Often, you choose what information to provide, but sometimes we require certain information to provide you the Services. WJM Associates uses the personal information it receives and collects in accordance with the purposes described in this policy.


2.1 Registration, Account Setup, Service Usage: In order to use the Services, you will need to submit a valid email address, first name and last name associated with your account. You need to provide this information to enable us to provide you with the Services. Additional information, which includes your company name, your level/title in your company, location of your company (City, State or City, Country) and details regarding requirement of coaching is required to establish a coaching engagement with your company.

Further relevant information including billing contact name, address, telephone number, may be necessary in order for us to provide a particular service.

2.2 Automated Information: WJM Associates automatically receives and records information from your browser or your mobile device when you visit the Site, or use certain features of the Services, such as your IP address or unique device identifier, cookies, and data about which pages you visit and how you interact with those pages in order to allow us to operate and provide the Services. This information is stored in log files and is collected automatically. WJM Associates may also receive similar information (like, for example, IP addresses and actions taken on the device) provided by a connected Internet of Things device such as a voice-activated assistant or Smart TV. We may combine this information from your browser or your mobile device with other information that we or our advertising or marketing partners collect about you, including across devices. This information is used to prevent fraud and to keep the Services secure, to analyse and understand how the Services work for members and visitors, and to provide advertising, including across your devices, and a more personalised experience for members and visitors.

We also automatically collect device-specific information when you install, access, or use our Services. This information can include information such as the hardware model, operating system information and debugging information, browser information, IP address, and device identifiers. For more information about these online tools and how we use them, see our Cookies Policy and “Information Uses, Sharing, & Disclosure” Section below.

2.3 Data from WJM Associates Vendors, Suppliers, Customers (Your Employers): We also receive information from our vendors, suppliers and customers about you. Your employer (our customer) may provide your personal information which includes your first name, last name, your company name and your official email address for legitimate purposes like conducting executive coaching for you and adding you as recipient of executive coaching program.

2.4 Data Received from Vendors, Suppliers, Customers through Emails

The personal information mentioned under section 2.1 and 2.3 can also be received through official emails.

2.5 Data from Advertising and Marketing Partners: As described below, WJM Associates receives information from our advertising and marketing partners about you. This information can include attribution information via cookies, or to determine where a visit to WJM Associates comes from, responses to marketing emails and advertisements, responses to offers, and audience information from partners who you have given consent to share that information with us.

2.6 Analytics Information: We use data analytics software to ensure Site functionality and to improve the Services. This software records information such as how often you use the Site, what happens within the Site, aggregated usage, performance data, errors and debugging information. We do not link the information we store within the analytics software to any personally identifiable information that you submit to us.

2.7 Non-Member / Un-Registered User Information: WJM Associates receives or obtains information (for example, an email address or IP address) about a person who is not yet a registered user with us which is in connection with certain WJM Associates features, such as when visitor/ unregistered user chooses to subscribe to an WJM Associates newsletter, a registered user invites an unregistered user to visit the Site, a registered user uploads unregistered user information, a non-member engages in a transaction. Non-member information is used only for the purposes disclosed when it was submitted to WJM Associates, for purposes necessary to the functioning of WJM Associate’s Services or where WJM Associates has a legitimate interest, as disclosed in the “Information Uses, Sharing, & Disclosure” Section below, or to facilitate action authorised by a member or the non-member.

2.8 Data collected from Contact Us / Enquiry Forms and Newsletter Signups: WJM Associate’s receives the following information when you submit your enquiry through “Request a Conversation” – form:

Your Full Name, your Title, your Company Name, your e-mail address and your enquiry.

WJM Associate’s receives the following information when you submit your enquiry through “Find a WJM Coach” – form:

Your Full Name, your Title, your Company Name, your e-mail address, your enquiry and Executive to be Coached Information (like

  • Executive title/position
  • Executive location (City/State/Country)?
  • How long has this executive been in his/her current position? At the Company?
  • How many direct reports does this executive have?
  • What is the presenting situation? Why do you want to provide coaching?
  • Is this executive open to coaching? Have they been coached before?
  • List 2-3 developmental opportunities for this executive
  • and Coach Preferences information)

The above information is stored as per WJM’s data retention policy which is in compliance to privacy laws and up to an extent for 3 years when the concerned data subject is not under any sort of business transaction with WJM associates.

The data provided will be used to establish communication with you and provide answer to your queries / service requests.

The data collected will be used internally by WJM’s internal team members for legitimate purposes like providing answer to your enquiry and if required, establish further communication related to providing coaching engagements.

WJM do not share this information outside it’s organization with any third-party.

Subscription to WJM’s email newsletter

If you voluntary opt in for WJM email newsletter, then you will receive industry / domain specific updates through our newsletter emails.

You can opt out of this subscription anytime by clicking the “un-subscribe link on the bottom of the newsletter” link in the newsletter email or by accessing the “Data Subject Access Request” DSAR form available at: DSAR


3. Messages from WJM Associates

On occasion, WJM Associates will need to contact you. Primarily, these messages are delivered by email, for a variety of reasons, including marketing, transactions, advocacy, coach ratings, coaching feedback and service update purposes. If you no longer wish to receive these kind of emails, you can opt out of receiving by following the unsubscribe link in any email you receive. To ensure you properly receive notifications, we will need to collect certain information. Every account is required to keep a valid email address on file to receive messages. WJM Associates may also contact you by telephone to provide member support or for transaction-related purposes if you request that we call you. Additionally, and with your consent where required by applicable law, WJM Associates may send you an SMS (or similar) message, or reach out to you by telephone, in order to provide you with customer support, for research or feedback, or to provide you with information about products and features that you may find of interest. You can update your contact preferences by sending an email to [email protected]

Some messages from WJM Associates are service-related and necessary for members and users. You understand and agree that WJM Associates can send you non-marketing emails, WJM Associates Messages, or messages, such as those related to transactions, your account, security, or product changes. Examples of service-related messages include service feedback or coach rating emails, and correspondence with WJM Associates’ Support team.

When you subscribe to a newsletter, or provide us with your email address or phone number, you receive notice of and agree (in some jurisdictions and situations, by an additional unambiguous consent) to receive marketing emails and messages from us. You can unsubscribe at any time from marketing emails or messages through the Unsubscribe link included in marketing emails or messages. Please note that some changes to your account settings / preferences may take a few days to take effect.


4. Information Uses, Sharing, & Disclosure

We respect your privacy. WJM Associates will not disclose your name, email address or other personal information to third parties without your consent, except as specified in this policy.

You can update your privacy settings by writing to us at [email protected]. Please note that some changes to your privacy settings may take a few days to take effect.

Legal Bases

When you access or use the Services, we collect, use, share, and otherwise process your personal information for the purposes described in this policy. We rely on a number of legal bases to use your information in these ways. These legal bases include where:

  • Necessary to perform the contractual obligations in our Terms of Use and in order to provide the Services to you;
  • You have consented to the processing, which you can revoke at any time;
  • Necessary to comply with a legal or regulatory obligation, a court order, or to exercise or defend any impending or asserted legal claims;
  • Necessary for the purposes of our or a third party’s legitimate interests, such as those of visitors, members, or partners (described in more detail below);
  • You have expressly made the information public;
  • Necessary in the public interest, such as to prevent crime; and
  • Occasionally necessary to protect your vital interests or those of others (in rare cases where we may need to share information to prevent loss of life or personal injury).

We principally rely on consent (which can be withdrawn at any time)


Our Legitimate Interests


Where we process your information on the basis of legitimate interests, we do so as follows:

Providing and Improving our Services: We use your information to improve and customise our Services, including sharing your information for such purposes, and we do so as it is necessary to pursue our legitimate interests of improving our Services for our users. This is also necessary to enable us to pursue our legitimate interests in understanding how our Services are being used, and to explore and unlock ways to develop and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our Services, efficiency, interest in Services for users, and obtaining insights into usage patterns of our Services. As a core part of our Services, we have a legitimate interest in providing executive coaching to you by utilizing our online platform www.wjmassoc.com.

Providing Marketing Communications: We rely on our legitimate interest to send you marketing messages (where permitted independent of consent) and for WJM Associate’s advertising programmes (including WJM Associate’s on-site advertising and marketing).

Keeping our Services Safe and Secure: We use your information for safety and security purposes, which can include sharing your information for such purposes, and we do so because it is necessary to pursue our legitimate interests or those of a third party in ensuring the security of our Services, preventing harm to individuals or property, or crime, enforcing or defending legal rights, or preventing damage to WJM Associates’s systems, or those of our users or our partners. This includes enhancing protection of our community against spam, harassment, intellectual property infringement, crime, and security risks of all kinds. We use your information to provide and improve the Services, for billing and payments, for identification and authentication, and for general research and aggregate reporting. For example, in accordance with our existing case resolution process, we may use information you provide to resolve disputes with WJM Associates or other members.

Gathering Coaching Requests from Customers and Delivering Coaching Through Coaches: As part of the gathering coaching requests from our customers and delivering such coaching through WJM coaches, WJM Associates will facilitate the sharing of information with the customer HR personal involved in the transaction. This can also involve us sharing the concerned information with coaches to enable us to provide the Service to you. Since this is an important part of the Services we provide, we need to do this in order to perform our obligations.

Legal and Safety: WJM Associates may also retain, preserve, or release your personal information to a third party in the following limited circumstances: in response to lawful requests by public authorities, including to meet legitimate national security or law enforcement requirements; to protect, establish, or exercise our legal rights or defend against impending or asserted legal claims, including to collect a debt, or a material violation of our policies; to comply with a subpoena, court order, legal process, regulation, or other legal requirement; or when we believe in good faith that such disclosure is reasonably necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our rights or property, or violations of WJM Associates’ Terms of Use. For example, if permitted due to the forgoing circumstances, your information may be shared with tax authorities or other governmental agencies. In the cases set out above, our use of your information may be necessary for the purposes of our or a third party’s legitimate interest in keeping our Services secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage. Such use may also be necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims or to facilitate the collection of taxes and prevention of tax fraud. It may also be necessary in the public interest (such as to prevent crime) or to protect vital interests (in rare cases where we may need to share information to prevent loss of life or personal injury).

If WJM Associates receives a lawful, verified request for a customer/member’s records or information in one of the limited circumstances described in the previous paragraph, WJM Associates may disclose personal information, which may include, but may not be limited to, a member’s name, address, phone number, email address, company/trading name and, where appropriate, bank account and transaction details.

Aggregated Information: WJM Associates may share demographic information with business partners, but it will be aggregated and de-personalised so that personal information is not revealed.

Service Providers: WJM Associates also needs to engage third-party companies and individuals (such as IT companies for web development and hosting our online services, research companies, and analytics and security providers) to help us operate, provide, and market the Services. These third parties have only limited access to your information, may use your information only to perform these tasks on our behalf, and are obligated to WJM Associates not to disclose or use your information for other purposes. Our engagement of service providers is often necessary for us to provide the Services to you, particularly where such companies play important roles like helping us keep our Service operating and secure. In some other cases, these service providers aren’t strictly necessary for us to provide the Services, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Services better.

Business Reorganisation: In some cases, WJM Associates may choose to buy or sell assets. Such transactions may be necessary and in our legitimate interests, particularly our interest in making decisions that enable our business to develop over the long term. In these types of transactions (such as a sale, merger, liquidation, receivership, or transfer of all or substantially all of WJM Associates’ assets), member/customer information is typically one of the business assets that is transferred. If WJM Associates intends to transfer information about you, WJM Associates will notify you by email or by putting a prominent notice on the Site and the App, and you will be afforded an opportunity to opt out before information about you becomes subject to a different privacy policy.

Third Parties: Third-party plug-ins also collect information about your use of the Site. For example, when you load a page on WJM Associates that has a plug-in from a third-party site or service, you are also loading content from that third-party site. That site may request cookies directly from your browser. These interactions are subject to the privacy policy of the third-party site. In addition, certain cookies and other similar technologies on the Site are used by third parties for targeted online marketing and other purposes. These technologies allow a partner to recognize your computer or mobile device each time you use the Services. Please be aware that when you use third-party sites or services, their own terms and privacy policies will govern your use of those sites or services. WJM Associates chooses and manages these third-party technologies placed on its Sites. However, these are third-party technologies, and they are subject to that third party's privacy policy. We rely on your consent to drop and read these cookies when not technically necessary or when not required based on another purpose such as legitimate interest.

This policy does not apply to the practices of third parties (such as WJM executive coaches who deliver services, certain third-party providers on whom we rely to provide certain services) that WJM Associates does not own or control or individuals that WJM Associates does not employ or manage, except as otherwise provided for in the Terms or as required by law. If you provide your information to such third parties in connection with your use of the Services, different practices may apply to the use or disclosure of the information that you provide to them. While WJM Associates requires these third parties to follow WJM Associates’ privacy and security requirements, WJM Associates does not control the privacy or security policies of such third parties. To the full extent applicable in your jurisdiction, WJM Associates is not responsible for the privacy or security practices of these WJM coaches or other websites on the internet, even those linked to or from the Services. We encourage you to read the privacy policies and ask questions of third parties before you disclose your personal information to them. For the purposes of European law, these members and third party providers are independent controllers of data, which means that they are responsible for providing and complying with their own policies relating to any personal information they obtain in connection with the Services.

5. Transfers

WJM Associates operates a global service. Your personal information is controlled by WJM Associates 165 Broadway, Ste. 2301 New York, New York 10006. By using our Services, you understand that WJM Associates may share some of the information it gathers with other WJM Associates affiliates for purposes described in this privacy policy.

The United States, European Economic Area (“EEA”) Member States, and other countries all have different laws. When your information is moved from your home country to another country, the laws and rules that protect your personal information in the country to which your information is transferred may be different from those in the country in which you live. For example, the circumstances in which law enforcement can access personal information may vary from country to country. In particular, if your information is in the US, it may be accessed by government authorities in accordance with US law.

To the extent that WJM Associates is deemed to transfer personal information outside of the EEA, we rely separately, alternatively, and independently on the following legal bases to transfer your information:

Necessary for the Performance of the Contract between WJM Associates and its Members/Clients/Service Providers

WJM Associates provides a voluntary service; you can choose whether or not to use the Services. As we operate in countries worldwide and use technical infrastructure in the U.S. to deliver the Services to you, in accordance with the contract between us (our Terms of Use), we need to transfer your personal information to the U.S. and to other jurisdictions as necessary to provide the Services. Simply put, we can’t provide you with the Services and perform our contract with you without moving your personal information around the world. If you have any queries, then you can email us at [email protected] or call 212-972-7400

6. Security

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and after it is received (HTTPS encryption layer and encryption at database level). Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we can't guarantee its absolute security.

Your account information is protected by a password. It is important that you protect against unauthorised access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the Services.

If you have any questions about the security of your personal information, you can contact us at [email protected]


7. Retention


WJM Associates will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active (i.e., for the lifetime of your WJM Associates member account), or as needed to provide the Services to you.

If you no longer want WJM Associates to use your information to provide the Services to you, you may close your account by accessing the DSAR - Data Subject Access Request Form available at https://www.wjmassoc.com/data-access

WJM Associates will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. Please note that closing your account may not free up your email address or username for reuse on a new account. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site safety and security, to improve site functionality, or we are legally obligated to retain them for longer time periods.


8. Your Rights and Choices

Certain privacy laws around the world, including the European General Data Protection Regulation (GDPR) provide users with rights related to their personal information. Consistent with those laws, WJM Associates gives you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you. You may change or correct your WJM Associates account information through the DSAR - Data Subject Access Request Form available at https://www.wjmassoc.com/data-access . You can also request to permanently close your account and delete your personal information. Depending on your location, you may also benefit from a number of rights with respect to your information. While some of these rights apply generally, certain rights apply in limited cases.

Right to Access & Portability: You can access certain personal information associated with your account by accessing the DSAR - Data Subject Access Request Form available at https://www.wjmassoc.com/data-access . You can request a copy of your personal information in an easily accessible format and information explaining how that information is used.

Right to Correction: You have the right to request that we rectify inaccurate information about you. By by accessing the DSAR - Data Subject Access Request Form available at https://www.wjmassoc.com/data-access . you can correct and change certain personal information associated with your account.

Right to Restrict Processing: In certain cases, where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.

Right to Deletion: In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of WJM Associates.

Right to Object: If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can object using the unsubscribe link in such communications or changing your account email settings or by accessing the DSAR - Data Subject Access Request Form available at https://www.wjmassoc.com/data-access.

Right to Withdraw Consent: Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link or your account privacy preferences or by accessing the DSAR - Data Subject Access Request Form available at https://www.wjmassoc.com/data-access. This is without prejudice to your right to generally permanently close your account and delete your personal information.

If you would like to manage, change, limit, or delete your personal information, you can do so via by accessing the DSAR - Data Subject Access Request Form available at https://www.wjmassoc.com/data-access. Alternatively, you can exercise any of the rights above by contacting us through email. Just write your request to [email protected]. Once you contact us to exercise any of your rights, we will confirm receipt of your request.

Limiting use of, or deleting, your personal information may impact features and uses that rely on that information. However, we will not discriminate against you for exercising any of your rights, including otherwise denying you goods or services, providing you with a different level or quality of services, or charging you different prices or rates for services. If you need further assistance, you can contact WJM Associates through one of the channels listed below under “Contact.” We will respond to your request within a reasonable timeframe.

Please note that we may verify your identity before we are able to process any of the requests described in this Section, and in our discretion, deny your request if we are unable to verify your identity. As a part of this process, government or other identification may be required. You may designate an authorised agent to make a request on your behalf. In order to designate an authorised agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorised agent’s valid government issued identification, and we may verify the authenticity of the request directly with you.

Email & Messages

You may also control the receipt of certain types of communications from WJM Associates by accessing the DSAR - Data Subject Access Request Form available at https://www.wjmassoc.com/data-access. WJM Associates may send you messages about the Services or your activity. Some of these messages are required, service-related messages for members (such as transactional messages or legal notices). Other messages are not required, such as newsletters. You can control which optional messages you choose to receive by by accessing the DSAR - Data Subject Access Request Form available at https://www.wjmassoc.com/data-access., and you can learn more in the “Messages from WJM Associates” Section of this policy. If you no longer wish to use the Services or receive service-related messages (except for legally required notices), then you may close your account by accessing the DSAR - Data Subject Access Request Form available at https://www.wjmassoc.com/data-access.

Cookies

We use both technically necessary (for the functioning and security of the Services) and non-technically necessary cookies and similar technologies. A more detailed explanation of the technologies we use, and how to opt out when applicable, can be found in WJM Associates’ Cookies & Similar Technologies Policy.


9. Privacy Policy Changes

We may amend or update this policy from time to time. If we believe that the changes are material, we’ll let you know by doing one (or more) of the following:

  1. posting the changes on or through the Services
  2. sending you an email or message about the changes, or
  3. posting an update on the website itself under privacy policy section.

We encourage you to check back regularly and review any updates.


10. Contact

If you have any questions:

Contact WJM Associates’ Support team via our Help Center

Send an email to WJM Associates’ Support Team - Privacy Policy at [email protected]

or

Write to us at the following addresses:

WJM Associates Support Team – Privacy Policy

Kind Attn: MS. Elizabeth Edwards

WJM Associates

165 Broadway, Ste. 2301

New York, NY 10006

Contact No.: +1-212-972-7400

Last updated on 13th April, 2022