Privacy Policy

Effective Date:1/1/2022


At, privacy is a top priority and we are firmly committed to guarding the confidence you have placed in us and to use, responsibly and professionally, any information you provide. We won’t ask you for Personal Data(defined below) unless we feel it is necessary to provide our Services. We won’t share your Personal Data with anyone except to comply with the law, develop our products and services, or protect our rights.

This Privacy Policy applies to information gathered when you access or use our Services. The purpose of this Privacy Policy is to notify you of what information of yours is collected; how the information is used; with whom the information may be shared; what choices are available to you regarding collection, use and distribution of the information; what kind of security procedures are in place to protect the loss, misuse or alteration of Information under our control; and how you can correct any inaccuracies in the information.

In this Privacy Policy, the terms “”, “we”, “us” and “our” mean ROCS Global, Inc. which is providing the Services to you ("you," "your," or "yourself), whether as a “Member” or “Coach”.  Capitalized terms not otherwise defined in this Privacy Policy shall have the meanings specified in our Terms of Use. We may choose to update this Privacy Policy at any time by providing an email notice to you. We encourage you to review this Privacy Policy periodically, as your continued use of the Services will mean you accept those changes, whether you have read them or not.

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your Personal Data with us.


 “Personal Data” means any information that may be used to identify you, including your name, email address, phone number, billing information, resume information (e.g., work history, educational history), and information discussed in sessions between Coaches and Members. Note that sessions between Coaches and Members may be recorded for Coaches or Members to review on their own time and may serve as evidence in the event of any disputes.

Unless specified otherwise in this Privacy Policy, is the controller of your Personal Data, which means that decides why and how your Personal Data is processed. is responsible for processing your Personal Data on the Services.

If you have any questions about this Privacy Policy, including any requests to exercise any of your legal rights, you can contact us

On our Services we process Personal Data as follows:


Source Personal Data we Process Purpose/Legal Justification
A.    When you use our Services anonymously

B.    When you do not register on our Services and contact us

C.    When you register on our Services and use our Services

D.    Information obtained from third parties in connection with the above processing, information collected at tradeshows or conferences; information obtained from vendors, linked websites/ mobile applications; information transmitted by you through boards, chats, pools or other means

Browser type, device and platform information

Email address, name (as you share) in addition to category A

Full name, email address, gender, year of birth, city/country of residence for all users in addition to category A

In addition, we collect payment information from Members and expertise/ financial information from Coaches.

Additional information we may be obtain.

Manage our security and offer our Services

Receive/respond to your queries and market our Services

Provide and market our Services for all users

In addition, to select Coaches for our Services.

Market our Services




Storage Period:  We consider several factors to determine how long we keep Personal Data connected with users or potential users. We consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. Once we determine we no longer have a need for your Personal Data, we will securely destroy it in accordance with our standards and applicable laws and regulations.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so or seek your consent, providing you with a clear, and readily available mechanism for you to exercise choice. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us

Please note that we may process your Personal Data without your knowledge or consent where required or permitted by law.

1.1  For Users Outside of the US

Our business is located primarily in the United States. If you provide information to us, the information will be transferred out of your nation to the United States. By providing Personal Data to us, you are consenting to its storage and use as described in this Privacy Policy and our Terms of Use.

  1. HOW DO WE USE YOUR INFORMATION? will only disclose your Personal Data as described in this Privacy Policy. We may disclose your Personal Data to our partners and affiliates as necessary to contact you, provide you with requested services, and/or for administrative purposes. We do not sell your Personal Data to third parties. We may disclose Personal Data to third-party service providers, including but not limited to professional advisors, advertisers, analytics providers, third parties who provide employment related services for us, including reference, qualification, and criminal record checking (where required), evaluation or skills tests, IT and system administration service providers, and investors, for the purpose of conducting our business and providing tailored content to you. We have carefully selected these service providers and entered into data processing agreements with them. We may also disclose your Personal Data to government regulators and other authorities who require reporting of processing activities in certain circumstances. We seek to ensure that all third parties respect the security of your Personal Data and to treat it in accordance with applicable laws. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

Note: In no event will Coaches ever have access to payment information (credit card numbers, etc.) of a Member.

We may collect, use and share aggregated data such as statistical or demographic data for purposes which include monitoring how we are doing against our diversity and equality targets. Aggregated data is not Personal Data as this data does not directly or indirectly reveal your identity.

By submitting a DMCA infringement notification, counter notice or other communication, as further described below, you consent to have this communication forwarded to the person or entity that stored or transmitted the content addressed by your communications. For notices other than DMCA infringement notifications and counter notices, you may request that we edit out your name and contact information. However, DMCA infringement notifications and counter notices (including any personal information set forth in the notifications) will be forwarded as submitted to us without any deletions. will only disclose your Personal Data to other data controllers that process the Personal Data for their own purposes if necessary and permitted by applicable law. may disclose your information to third parties when obligated or permitted to do so by law in order to investigate, prevent, or take action regarding suspected, or actual unlawful activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person, or to authorities or law enforcement agencies to comply with legal obligations or to support external audits.

We may also use your Personal Data to send you newsletters, offers or other marketing emails to keep you up to date with our news, events and products that may be of interest. Depending on the nature of your interaction with us and the laws of the country where you live, you may have actively given your consent for this by opting in or we may be entitled to rely to legitimate interests to contact you with relevant marketing information. The opportunity to opt out of future marketing emails will always be provided, and information on how to do this is given when your Personal Data is collected and on every marketing email sent. Further information on how you can change your marketing preferences is provided below.

We may host discussions or other moderated forums for users who can help each other with technical and general questions. Topics for discussion may include technical support questions and problems, suggestions for improvement, or anything else that relates to the Services. Please remember that any information that is disclosed in this area becomes public information and you should exercise caution when deciding to disclose your Personal Data.

2.1  Infringement

You may notify us of alleged copyright infringement in accordance with the Digital Millennium Copyright Act (the “DMCA”). We will respond promptly to notices of alleged infringement sent pursuant to the DMCA.

In order to notify us of a copyright infringement claim pursuant to the DMCA, you must include:

  • a physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed;
  • identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works on the Services are covered by a single notification, a representative list of such works;
  • a description of the material that is claimed to be infringing or to be the subject of infringing activity, and information reasonably sufficient to permit us to locate the material;
  • your address, telephone number, and email address;
  • a statement by you that you have a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law; and
  • a statement made under penalty of perjury by you that the information in the notification is accurate, and that you are authorized to act on behalf of the owner of the copyright involved.

The notice described above should be sent to us at

Please note that in order to facilitate resolution of the dispute, we may provide your contact information to the user or entity that posted the Content that you are reporting; or in the event that you are the alleged infringer and provide a counter-notice, to the user or entity that filed the original claim. Please also note that you may be liable for damages (including costs and attorneys' fees) if you knowingly and materially misrepresent that material or an activity is infringing your copyright.


We do not sell or rent your Information to third parties without your consent, except as otherwise noted in this Privacy Policy. We view protection of privacy as a critical community principle. We understand clearly that your information and your trust is one of our most important assets. If we ever change how we use your Personal Data, we will notify you with an email notice. We store and process your information on server/cloud systems that are protected by physical as well as technological security devices.

Please note that if links to third-party sites on our Services are used, your privacy rights willbe governed by the privacy policy of that third-party site.

3.1.  Content and other Material you Choose to Reveal

If you are a Coach or a Member, you may share Content on our Services. Coaches and Members may share Personal Data with each other and may also share other information electronically. Coaches and Members can also share Content related to the Services with others on social platforms, email, text, etc.

The information submitted by you to our Services, including Personal Data, may be viewed by other users or the public. This includes video and audio recordings captured from cameras on devices you or others use during recorded sessions of our events and activities. Accordingly ,we urge you to use good judgment in your sharing and participation. Do not post any information, including, without limitation, Personal Data, that you do not want other users to know. Many internet connections are public and/or not secure, and other users using that same connection may have access to your information; please make sure that you are using a secure internet connection.


We and other users may retain and continue to use, host, display, store, cache, reproduce, publish, transmit, modify, re-format, re-arrange, distribute, and create derivative works of any of your Content that you have posted to the Services. If the potential for public dissemination of your Content concerns you, please do not share that Content.

3.2  Special Cases in Which we Share Personal Information

We may disclose Personal Data when we determine that such disclosure is necessary to comply with applicable law, to cooperate with law enforcement officials or to protect the interests or safety of our company or visitors to, or users of the Services. We also may disclose your Personal Data to our subsidiary, affiliated and parent companies (if any). Whenever Personal Data is disclosed under this paragraph, we may also disclose your demographic information along with it. If there exist any subsidiary, affiliated or parent companies, and they receive your Personal Data or demographic information from us, they will comply with and be bound by the terms of this Privacy Policy with respect to their use and disclosure of such information.




 We may use device identifiers in our Services. A device identifier is an alphanumeric string that uniquely identifies a device to us. A device identifier may deliver information to us or to a third-party partner about how you browse and use the Services. This can help us provide reports or personalized content and ads via the Services.

5.1        Third Parties’ Use of Personal Identifiers and Device Identifiers

The Services may include third-party advertising, links to other sites, and other content from third-party businesses. These third-party sites, businesses, advertisers, or advertising companies working on their behalf, may use device identifiers and personal identifiers to measure the effectiveness of their ads, personalize or optimize advertising content and to track users who link from their respective websites to the Services.

We do not have access to or control over such identifiers that these third parties may use. We are not responsible for the privacy practices or the content of these third-party sites. You are encouraged to review the privacy policies of the different sites you visit.

Some third-party advertising companies may provide a mechanism to opt-out of their technology.  For more information about the opt-out process, you may visit the Network Advertising Initiative website, available at


We use appropriate technical and organizational security measures to protect your Personal Data from unlawful destruction, loss, alteration, and unauthorized disclosure or access. We regularly review the information collection, storage and processing practices, including physical security measures, provided by our hosting providers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you must take reasonable steps to keeping this password confidential. We ask you not to share a password with anyone. If you use another account to log on to a secure part of our Services, then please take reasonable steps to keep that password secure too. If you think that any of your passwords might have been compromised, then please let us know immediately

Our staff will never proactively reach out to you and ask for any personal account information, including your password. You should never share devices. This will help protect your information entered on public terminals from disclosure to third parties.

All chats between Coaches and Members, and all document sharing, is encrypted. We don’t currently use a third-party service to enable a chat feature, so any chat data shared between coaches and members would also be stored servers used by any Coaches and Members engaging each other in those services. Documents uploaded during chats between Coaches and Members using independent services are not d stored on our servers.

We use KEAP to process financial transactions. All financial information (e.g., credit card information) is securely stored on KEAP servers.

All data transmission is encrypted, but it cannot be guaranteed to be 100% secure in the event you use untrusted networks such as public Wi-Fi connection, unverified SIM cards etc. As a result, we cannot guarantee the security of any information you transmit, and you do so at your own risk. If you have any further questions on this issue, please refer to our Terms of Use. We expressly disclaim any liability that may arise should any other individuals obtain the information you submit.


 You have a number of rights regarding the processing of your Personal Data, if applicable statutory requirements are fulfilled. You may:

  1. Request access to the Personal Data that we process about you, including the following:
  • The categories of sources for the Personal Data(defined in the CCPA, referenced below) we collected about you.
  • Our business or commercial purposes for collecting or selling that Personal Data.
  • The categories of third parties with whom we share that Personal Data.
  • The specific pieces of Personal Data we collected about you (also called a data portability request).
  • If we sold or disclosed your Personal Data for a business purpose, two separate lists disclosing:
    • sales, identifying the Personal Data categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained.
  1. Request correction or rectification of your Personal Data,
  1. Request erasure of your Personal Data, as set forth below,
  1. Request restriction of Processing of your Personal Data,
  1. Object to the Processing of your Personal Data,
  1. Request to receive your Personal Data in a structured, commonly used and machine-readable format (right to data portability), or
  1. Withdraw any future consent with future effect. You also have the right not to be subject to a decision based solely on automated processing, including profiling.

7.1  Erasure or Deletion of Information

You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Data from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the Personal Data, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug services to identify and repair errors that impair existing intended functionality.
  • Exercise free speech rights, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Provide instructional or training content to Members, in which you participated with foreknowledge and willing participation that it was being recorded.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Please be advised that you or a person authorized by applicable law to act on your behalf can make a verifiable consumer request related to your Personal Data. You may also make a verifiable consumer request on behalf of your minor child, and you may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

7.2  Response Timing and Format.

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response electronically at the email address you provided us. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

Please direct all your requests to exercise your rights above Further, you may submit a complaint to the responsible data protection supervisory authority if you believe that we cannot sufficiently help you.

7.3        Non-Discrimination. We will not discriminate against you for exercising any of your applicable data privacy rights. Unless permitted by your local laws, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 This Section applies to visitors, users, and others who reside in the State of California. We adopt these provisions to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

8.1  Information we Collect. We collect Personal Data as described in Section 1 of this Privacy Policy. For clarity regarding compliance with the CCPA, we have collected the following CCPA categories of Personal Data from consumers within the last twelve (12) months (or will collect such Personal Data in the next 12 months):


Category Examples Collected
Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. YES
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. YES
Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES
Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. NO
Geolocation data. Physical location or movements. NO
Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
Memberand Coach employment-related information. Current or past job history or performance evaluations. YES
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
Inferences drawn from other Personal Data. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO


Under the CCPA, personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA's scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Personal Data covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

8.2  Use and Sharing of Personal Information. We may use or disclose Personal Data as specified in section 2 and 3 above. Also as stated in section 2, we will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 As stated earlier, we may disclose your Personal Data to a third party for a business purpose. Over the next twelve (12) months, we may disclose the following categories of Personal Data for a business purpose:

Category :    California User Records Personal Data categories.

Category :    Protected classification characteristics under California or federal law.

We may disclose your Personal Data for a business purpose to the following categories of third parties:

  • User name and photo while sharing user content on social media or other marketing platforms.
  • Third parties to whom you or your agents authorize us to disclose your Personal Data in connection with services we provide to you.

In the preceding twelve (12) months, we have not sold any Personal Data.

8.3 Your Rights and Choices. The CCPA provides California residents with specific rights regarding their Personal Data. Section 7 above describes your CCPA rights and explains how to exercise those rights.

 8.4  Deletion Request Rights. You have the right to request that we delete any of your Personal Data that we collected from you and retained in accordance with Section 7 of this Privacy Policy. Please be advised that under California privacy laws, only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data

8.5  Exercising Access, Data Portability, and Deletion Rights. You may exercise your rights to access and delete Personal Data as set forth herein.

8.6   Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not discriminate as specified in Section 7.


8.7.1  Age Restriction. understands the importance of protecting children’s privacy in the interactive online world. Our Services are not designed for, or intentionally targeted at, children of 13 years of age or younger. We do not therefore knowingly collect or maintain Personal Data relating to children of 13 years of age or younger. Our Terms of Use expressly limits registration on our Services to those 18 and older.

In compliance with the California Online Privacy Protection Act (CalOPPA) while we strive to offer you choice when using our Services, we do not promise that we will be able to receive or honor web browser “Do Not Track” signals.

8.7.2  Deidentification. We may process Personal Data for the purpose of creating a deidentified data set. We may then process that deidentified data set for business purposes, including improving our products and services, without further notice to you. The processing of your Personal Data for this purpose is based on our legitimate interests.

8.7.3 Algorithmic Profiling. We use algorithm-based technologies to personalize dynamic web content based on your explicit and/or implicit interests. We carry out general profiling such as segmentation, non-automated and automated decision-making based on profiling for the purpose of providing you with a more relevant experience and for the purposes of our legitimate interests as a commercial organization. Solely automated decision making is never used in any way that produces a legal or similarly significant effect. Depending on the laws of the country where you live, you may have rights related to our decision. For example, if you live in the European Union, you may have the right not to be subject to our decision, or you may have the right to insist on human intervention in the process, express your point of view or contest the decision. To exercise any such right, contact us via one of the methods set out above. In some cases, we may have the right to continue with our decision, in accordance with applicable laws. This will be explained if it is the case. Otherwise, we will respond to your request as promptly as reasonably possible.


We may change this Privacy Policy from time to time, in our sole discretion. Any changes we make to our Privacy Policy in the future will be posted on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Non-material changes and clarifications will take effect immediately, and material changes will take effect within 30 days of their posting on the website. The date of the most recent revisions will also appear on this page. Please check back regularly to make sure you are comfortable with our Privacy Policy. If you do not agree to the changes to this Privacy Policy, you should consider requesting deletion of your Personal Data by contacting us Where language on our Services or Terms of Use contradicts that found in this Privacy Policy, this Privacy Policy shall prevail. 


If you have any questions about this Privacy Policy, ourpractices, or your dealings with us, you may contact us at: