Effective Date: June 14th, 2021

We at Coach My Idea Inc. (CMI) take the protection of your privacy seriously. This policy describes what information we collect, from whom we collect it, when we collect it, how it is used and shared, and the choices users have in how this information is managed.  Given the changes to our previous policy, a short summary is provided with respect to each section of this policy. 

A. Purpose

[Summary. This policy describes how CMI and its affiliates collect and use the personal information of its users.]

This policy describes how CMI and its affiliates collect and use personal information to provide our services. This policy applies to all users of our apps, websites, features or other services anywhere in the world, unless covered by a separate privacy policy and to the extent inconsistent with such other policy. 

The practices described in this policy are subject to applicable laws in the places in which we operate. This means that we only engage in the practices described in this policy in a particular country or region if such practices are permitted under the laws of those places.

B. Scope of Application

[Summary. This policy applies to users of CMI’s services anywhere in the world, including users of CMI’s apps, websites, features or other services.]

This policy applies to the following persons and entities: (a) users of CMI who request or utilize CMI’s platform services; and (b) persons and entities who provide information to CMI in connection with an application to use our services, or whose information CMI otherwise receives in connection with its services. All those subject to this policy are referred to as “users” for purposes of this policy.

C. Data Controller

[Summary. CMI provides services to users worldwide. The data controller for such user’s information is CMI.]

CMI processes data inside and outside of the United States. The data controller for the information you provide or that is collected by CMI or its affiliates is:

Coach My Idea Inc.
33W, 60th ST, Fl-2

New York, NY 10023

Questions, comments and complaints about CMI’s data practices can be submitted to CMI’s data protection office through here. 

D. Information Collected

[Summary. The information collected by or on behalf of CMI is comprised of information you provide, information created when you use our products and services, and information from other sources (in each case, as more carefully detailed below).]

The following information is collected by or on behalf of CMI:

1. Information you provide. This may include:

  • User profile: We collect information when you create or update your CMI account. This may include your name, phone number, email, address, payment or banking information (including related payment verification information), login name and password, government identification numbers, birth date, photo and signature. This also includes the preferences and settings that you enable for your CMI account. This information may be collected by a vendor on CMI’s behalf, including our payment processing and gateway service and technology providers.

  • User content: We may collect information that you submit when you provide ratings for or feedback in connection with other users, contact CMI customer support, or otherwise contact CMI

  • Demographic data: We may collect demographic information about you, including through user surveys. In some countries, we may also receive demographic information about you from third parties.

  • Address book or calendar: If you permit the CMI app to access the address book on your device, we may collect names and contact information from your address book for purposes such as facilitating social interactions through our services. If you permit the CMI app to access the calendar on your device, we collect calendar information such as event title and description, your response (Yes, No, Maybe), date and time, location, and number of attendees.

2. Information created when you use our services. This may include:

  • Transaction Information. We collect transaction details related to your use of our services, including the type of services you requested or provided, your order details, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if someone uses a promotion code we provide or may provide to you in future, we may associate your name with that person.



  • Usage information. We collect information about how you interact with our services. This includes information such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or service you were using before interacting with our services. In some cases, we collect this information through cookies, pixel tags, and similar technologies that create and maintain unique identifiers.

3. Information from other sources. These may include:

  • User feedback and ratings.

  • Users providing your information in connection with referral programs or requesting services for or on your behalf.

  • Users or others providing information in connection with claims or disputes.

  • CMI business partners through which you create or access your CMI account, such as payment providers, social media services, or apps or websites who use CMI’s APIs or whose API CMI uses (such as when you order a ride through Google Maps).

  • Financial services providers

  • Partner transportation companies

  • Publicly available sources.

  • Marketing service providers.

CMI may combine the information collected from these sources with other information in its possession.

E. How We Use Your Information

[Summary.  CMI collects and uses information to enable reliable and convenient platform and other products and services, as well as:

  • To enhance the safety and security of our users and services

  • For customer support

  • For research and development

  • To enable communications to or between users

  • To provide promotions or contests

  • In connection with legal proceedings

CMI does not sell or share your personal information to third parties for third party direct marketing purposes.]

CMI uses the information it collects for purposes including:

1. Providing services and features.  CMI uses the information we collect to provide, personalize, maintain and improve our products and services. This includes using the information to:

  • Create and update your account.

  • Verify your identity.

  • Enable features to personalize your CMI account, and to enable quick access to previous destinations.

  • Enable platform and other services.

  • Process, facilitate, manage and distribute payments for those services.

  • Offer, obtain, provide or facilitate insurance and/or financing in connection with our services.

  • Enable features that allow you to share information with other people.

  • Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing, and research, to monitor and analyze usage and activity trends, and to manage payment claims and matters (including chargeback claims).

2. Customer support.  CMI uses the information we collect (which may include recordings of customer support calls after notice to you and with your consent) to assist you when you contact our customer support services, including to direct your questions to the appropriate customer support person, investigate and address your concerns, and monitor or improve our customer support responses

3. Research and development. We may use the information we collect for testing, research, analysis and product development. This allows us to improve and enhance the safety and security of our services, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

4. Communications among users. CMI uses the information we collect to enable communications between our users.

5. Communications from CMI.  CMI may use the information we collect to communicate with you about products, services, promotions, updates, events, studies, surveys or news. CMI may also use the information to promote and process contests and sweepstakes, fulfill any related actions or verifications required to implement them, fulfill any awards associated with them, and/or serve relevant ads and content about our services and those of our business partners to users. You may receive some of these communications based on your profile as an CMI user.

6. Legal proceedings and requirements. We may use the information we collect to investigate or address claims or disputes relating to your use of CMI’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries. We may also use the information we collect to investigate or address claims or disputes relating to your use of CMI’s services, or to the services provided by our payment and security vendors and partners to manage, prosecute, defend, manage or resolve security, data or payment claims (including, for example, chargeback claims).

F. Cookies and Third Party Technologies

[Summary. CMI and its partners may deploy cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this policy.]

Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements. CMI, in certain instances, will use cookies and similar technologies for purposes such as:

  • Authenticating users

  • Remembering user preferences and settings

  • Determining the popularity of content

  • Delivering and measuring the effectiveness of advertising campaigns

  • Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, SDKs, and other technologies to identify your device when you visit our site and use our services, as well as when you visit other online sites and services.

G. Information Sharing and Disclosure

[Summary. Some of CMI’s products, services and features require that we share information with other users or at your request. We may also share your information with our affiliates, subsidiaries and business partners, for legal reasons or in connection with claims or disputes.]

CMI may share the information we collect:

1. With other users. If you choose to complete a profile, we may share any information associated with that profile, including information that you submit.

2. At your request. This includes sharing your information with other people at your request. This also includes sharing your information with CMI business partners (for example, if you requested a service through a partnership or promotional offering made by a third party, CMI may share your information with those third parties). This may include, for example, other apps or websites that integrate with our APIs or services, or those with an API or service with which we integrate, or business partners with whom CMI may partner with to deliver a promotion, a contest or a specialized service.

3. With the general public when you submit content to a public forum. We love hearing from our users, including through public forums such as CMI blogs, social media, and certain features on our own or our partners’ networks. When you communicate with us through those channels, your communications may be viewable by the public.

4. With the owner of CMI accounts that you may use. If you use a profile associated with another party we may share your information with the owner of that profile.

5. With CMI subsidiaries and affiliates. We share information with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf.

6. With CMI service providers and business partners. CMI may provide information to its vendors, consultants, marketing partners, research firms, and other service providers or business partners.

7. For legal reasons or in the event of a dispute. CMI may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing your information with law enforcement officials, government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms and Conditions, user agreements, or other policies, to protect CMI’s rights or property or the rights, safety or property of others, or in the event of a claim or dispute relating to your use of our services. If you use another person’s credit card, we may be required by law to share information with that credit card holder, including trip information.

This also includes sharing your information with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

8. With your consent. CMI may share your information other than as described in this policy if we notify you and you consent to the sharing.

H. Information Retention and Deletion

[Summary. CMI retains user profile and other information for as long as you maintain your CMI account.

CMI retains transaction, location, usage and other information for 7 years in connection with regulatory, tax, insurance or other requirements in the places in which it operates. CMI thereafter deletes or anonymizes such information in accordance with applicable laws.

If you withdraw consent to the collection or use of personal information for optional features, such as features that use your calendar or address book, CMI deletes such personal information.

Users may request deletion of their accounts at any time. Following such request, CMI deletes the information that it is not required to retain and restricts access to or use of any information it is required to retain.]

CMI requires user profile information in order to provide its services and retains such information for as long you maintain your CMI account.

CMI retains certain information, including transaction, location, device and usage information, for a minimum of 7 years in connection with regulatory, tax, insurance and other requirements in the places in which it operates. Once such information is no longer necessary to provide CMI’s services, enable customer support, enhance the user experience or other operational purposes, CMI takes steps to prevent access to or use of such information for any purpose other than compliance with these requirements or for purposes of safety, security and fraud prevention and detection.

You may request deletion of your account at any time through the Privacy Settings in the CMI app, or via CMI’s website.

Following such request, CMI deletes the information that it is not required to retain. In certain circumstances, CMI may be unable to delete your account, such as if there is an outstanding credit on your account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, CMI will delete your account as described above.

CMI may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, if CMI shuts down a user’s account because of unsafe behavior or security incidents, CMI may retain certain information about that account to prevent that user from opening a new CMI account in the future.



I. Special Information for EU Users

[Summary. This section summarizes CMI’s grounds for processing personal information under the General Data Protection Regulation (“GDPR”) which will apply as of May 25, 2018 to the personal data and rights of EU users as relates to CMI’s handling of personal information.]

The processing of personal data of users in the European Union is subject to the EU General Data Protection Regulation (“GDPR”) as of May 25, 2018. This section provides information as relates to EU users’ rights, and CMI’s responsibilities, under this regulation.

1. EU User Rights. If you are an CMI user in the EU, you have the following rights with respect to CMI’s handling of your personal information. To exercise these rights, please see below or submit your request at 33W 60th ST, Fl-2, New York, NY 10023, Users outside the EU may also request explanation, correction, deletion or copies of their personal data at the same email address.

a. Explanation and copies of your data

  • You have the right to request an explanation of the information that CMI has about you and how CMI uses that information.

  • You also have the right to receive a copy of the information that CMI collects about you if collected on the basis of consent or because CMI requires the information to provide the services that you request.

b. Correction

  • If CMI has information about you that you believe is inaccurate, you have the right to request correction of your information. Please see the section titled “Explanation, Copies and Correction” below for more information on correcting, or requesting correction of, your information.

c. Deletion

  • Users may request deletion of their accounts at any time. Users may requests deletion through the Privacy Settings menu in the CMI app, or via CMI’s website. We may retain certain information about you as required by law and for legitimate business purposes permitted by law.

  • Please see the “Information Retention & Deletion” section above for more information regarding CMI’s retention and deletion practices.

d. Objections and complaints

  • Users in the EU have the right to object to CMI’s processing of personal data, including for marketing purposes based on profiling and/or automated decision making. CMI may continue to process your information notwithstanding the objection to the extent permitted under GDPR.

  • You may also submit questions, comments or complaints to CMI’s Data Protection Officer here 33W 60th ST, Fl-2, New York, NY 10023,

2. Grounds for Processing

The GDPR requires that we process the personal data of EU users on the basis of specific legal grounds. CMI processes the information of EU users based on one or more of the grounds specified under the GDPR, as described below:

a. The processing is necessary to provide the services and features you request

  • CMI must collect and use certain information in order to provide its services. This includes:

    • User profile information that is necessary to establish and maintain your account, including to verify your identity; enable communications with you about your orders and accounts; and to enable you to make payments or receive earnings.

    • Transaction information, which is necessary to generate and maintain in connection with your use of CMI’s services.

    • Usage information, which is necessary to maintain, optimize and enhance CMI’s services, including to determine, sometimes in combination with other information, incentives, connect riders and drivers, and calculate costs of trips and driver earnings.

  • Collection and use of this information is a requirement for using CMI’s apps.

b. The processing is necessary to protect the vital interests of our users or of others

  • CMI may process personal information, including disclosing data with law enforcement authorities in case of threats to the safety of users or of others.

c. The processing is necessary for CMI’s legitimate interests. CMI collects and uses personal information to the extent necessary for its legitimate interests. This includes collecting and using information to: 

(i) prevent, detect and combat fraud in connection with the use of our services (for example, CMI uses user profile, location, device and usage information, to identify and prevent circumstances when users attempt to defraud CMI or other users); 

(ii) maintain and enhance our users’ safety and security (for example, by monitoring chargeback events) and prevent use of our services by users who have engaged in inappropriate or dangerous behavior (for example, by retaining information of banned users to prevent their use of CMI’s apps); 

(iii) provide customer support

(iv) inform law enforcement officials regarding criminal acts or threats to public safety,

(v) optimize or enhance existing products and/or services, or develop new products and/or services. 

(vi) enforce CMI’s Terms and Conditions. 

CMI’s collection and use of personal information to the extent necessary for its legitimate interests also includes collecting and using information for: 

(vii) research and analytical purposes (for example, to analyze usage trends to improve the user experience and enhance the safety and security of our services), and

(viii) direct marketing purposes. This includes, for example, analysing data to identify trends and tailor marketing messages to user needs.

d. The processing is necessary for the legitimate interests of other persons or parties. CMI collects and uses personal information to the extent necessary for the interests of other persons or the general public. This includes sharing information in connection with legal or insurance claims, to protect the rights and safety of others. CMI may also process personal information when necessary in regard to a substantial public interest, on the basis of applicable laws.

e. The processing is necessary to fulfill CMI’s legal obligations. CMI is subject to legal requirements in the jurisdictions in which it operates that require us to collect, process, disclose and retain your personal data. CMI uses your information to comply with such laws to the extent they apply to your use of the CMI apps.  CMI may also share information with law enforcement, or requests by third parties pursuant to legal processes.

f. Consent. CMI may collect and use your information on the basis of your consent. You may revoke your consent at any time.  If you revoke your consent, you will not be able to use any service or feature that requires collection or use of the information we collected or used on the basis of consent.  CMI relies on consent in connection with data collections or uses that are necessary to enhance the user experience, to enable optional services or features, or to communicate with you.



J. Privacy Settings, Permissions and Other

[Summary. CMI provides you with the ability to see and control the information that CMI collects. You may also request that CMI provide you with explanation, copies or correction of your data.]

1. EXPLANATIONS, COPIES AND CORRECTION

You may request that CMI:

  • Provide an explanation regarding the information CMI has collected about you and how it uses that information.

  • Make available a copy of the information CMI has collected about you.

  • Make a correction of any inaccurate information that CMI has about you, which you can provide in supporting written documentation.

You can make these requests by contacting CMI here.