Privacy & Cookie Policy

1. Introduction

Guiding Star Communications and Consulting Inc. ("Guiding Star," "we," "us") provides Coaching Digs, a 360-degree assessment platform that explores the ability of individuals to receive coaching. We are committed to protecting the privacy of our Candidates/Participants (those being coached), Referees (those providing feedback on coachability), and Client Organizations (employers seeking insights into coachability).

2. Information We Collect

• Account Information: Name, professional (or personal) email, and job title for all users.
• Assessment Data: Candidate self-assessments and Referee survey responses.
• Corporate Data: In Corporate accounts, we collect name, organization name, professional email of (prospective) managers or HR representatives.
• Technical Data: IP addresses, browser types, and cookies to ensure platform security.

3. Special Notice to End Users (Employer-Sponsored Accounts)

If you use Coaching Digs through your employer or organization:

• Data Visibility: Your organization acts as the primary Data Controller. Authorized representatives of your employer will have access to your scores across the 12 Coachability Domains.
• Confidentiality: Unless otherwise stated by your organization's specific program, Referee feedback is typically aggregated or anonymized to protect the identity of those providing feedback.
• Administrator Control: Your organization's administrator may have the ability to access, restrict, or terminate your account and view targeted (i.e., employer-level views) reports generated within the platform.

4. How We Use and Share Data

We use your data solely to provide the coaching service. We do not sell your data.

• Internal Sharing: Candidate scores are shared with authorized (with consent controlled by the Candidate) employer representatives as part of the 360-degree process.
• Third-Party Sub-Processors: We use Hetzner Online GmbH for secure data hosting within the European Union (EU). We may use anonymized, aggregated data to improve our coaching benchmarks, but this data never identifies an individual or organization.

5. Cookie Policy

Coaching Digs uses "cookies" (small text files) to function effectively:

• Necessary Cookies: Required for you to log in and remain authenticated during your session. These cannot be disabled.
• Performance Cookies: We use tools like Google Analytics to understand how users move through the app so we can improve the interface.
• Your Choice: You can block cookies via your browser settings, but the Coaching Digs platform will not function correctly without Necessary Cookies.

6. Security and Global Compliance

• Data Residency: Your data is stored in the EU (Germany/Finland), providing high-level GDPR protection by default.
• Canada (PIPEDA): We comply with Canadian federal privacy standards.
• Security: We utilize SSL encryption, regular backups, and strict access controls. Access to raw database records is limited to essential technical staff under strict NDAs.

7. Your Rights

Regardless of your location, you have the right to:

• Request a copy of the data we hold about you.
• Correct inaccurate profile information.
• Request account deletion (subject to your employer's data retention policies if they are the account sponsor).

Inquiries should be sent to info@guidingstarcc.com.

8. Legal Terms

• Limitation of Liability: Guiding Star is not liable for indirect, incidental, or consequential damages arising from the use of Coaching Digs.
• Governing Law: This policy is governed by the laws of Ontario, Canada. Any disputes shall be settled via binding arbitration in Ontario.