Privacy Policy

This Privacy Policy explains how we collect, use, share, and protect personal information when you visit this website, complete the Find Your Gap™ assessment, subscribe to the newsletter, submit a speaking or contact inquiry, or enroll in a program.

1. Who We Are

This site is operated by The Hayes Project, 9333 Baseline Rd, Suite 290, Rancho Cucamonga, CA 91730 (“we,” “us,” “our”). Coach Key is a brand name used by The Hayes Project. For any privacy question, write to info@strategicbehaviorconsultants.com.

2. Information We Collect

Information you give us. Your name, email address, organization, role, phone number (if you provide it), event details, message content, and the answers you submit in the Find Your Gap™ assessment.

Information collected automatically. IP address, browser and device type, referring page, pages viewed, and approximate location derived from IP. This is collected through server logs and cookies or similar technologies.

Information from service providers. Our hosting, database, email delivery, and payment providers may pass us transaction status, delivery status, and basic security signals.

We do not knowingly collect Social Security numbers, government identifiers, precise geolocation, biometric data, or health records through this site. Please do not send clinical or medical records through the contact forms.

3. How We Use Your Information

We use personal information to respond to inquiries; to deliver assessment results; to send the newsletter and program updates you asked for; to provide, bill for, and support programs; to keep the site secure and prevent abuse; to understand which content is useful; and to meet legal and recordkeeping obligations.

We do not sell personal information, and we do not share it for cross-context behavioral advertising.

4. Legal Bases for Processing

Where the EU or UK GDPR applies, we rely on: your consent (newsletter, optional cookies), performance of a contract (program delivery and billing), our legitimate interests (site security, service improvement, responding to inquiries you send us), and legal obligation (tax and accounting records). You may withdraw consent at any time without affecting prior processing.

5. How We Share Information

We share personal information only with service providers who process it on our behalf under contract — website hosting and database, email delivery, scheduling, payment processing, and analytics. We may also disclose information when required by law, to enforce our terms, or in connection with a merger, acquisition, or sale of assets, in which case we will give notice before your information becomes subject to a different policy.

6. Cookies and Tracking

We use strictly necessary cookies to operate the site and may use functional and analytics cookies to remember preferences and measure usage. You can control cookies through your browser settings. See our Cookie Policy for details and for our Do Not Track and Global Privacy Control statements.

7. Data Retention

We keep inquiry and assessment records for up to twenty-four months after your last interaction, newsletter records until you unsubscribe, and program and billing records for as long as required by tax and contract law (generally seven years). After those periods we delete or de-identify the data.

8. Your Privacy Rights

Subject to your location and applicable law, you may request access to the personal information we hold about you, correction of inaccurate information, deletion, a portable copy, and restriction of or objection to certain processing. To make a request, email info@strategicbehaviorconsultants.com with the subject line “Privacy Request.” We will verify your identity by replying to the email address on file and respond within the time the law allows (generally forty-five days in California, thirty days under GDPR). We will not discriminate against you for exercising these rights.

9. California Privacy Rights

If you are a California resident, the CCPA as amended by the CPRA gives you the right to know the categories and specific pieces of personal information we collect, the right to delete, the right to correct, and the right to opt out of sale or sharing. In the twelve months before the date above we collected identifiers, internet activity information, professional information, and the content you voluntarily submit. We did not sell or share personal information for cross-context behavioral advertising and we do not knowingly collect or sell the personal information of anyone under sixteen. You may use an authorized agent to submit a request; we will ask for written proof of authorization.

10. Children’s Privacy

This site is intended for adults. We do not knowingly collect personal information from children under thirteen. If you believe a child has provided information, contact us and we will delete it.

11. Security

We use encrypted transport (HTTPS), access controls, and reputable processors to protect personal information. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

12. International Transfers

We operate in the United States, and our service providers may process information there. If you access the site from outside the United States, you understand that your information will be transferred to and processed in the United States, where data protection law may differ from that of your country. Where required, we use Standard Contractual Clauses with our processors.

13. Changes to This Policy

We may update this policy. When we do, we will revise the “Last updated” date above, and for material changes we will provide additional notice on the site or by email.

14. How to Contact Us

The Hayes Project, 9333 Baseline Rd, Suite 290, Rancho Cucamonga, CA 91730. Email info@strategicbehaviorconsultants.com.