PROGRESS – Leadership & Lifestyle – Privacy Policy

Effective Date: March 6, 2026 Last Updated: March 6, 2026

The PROGRESS – Leadership & Lifestyle program is operated through PTBA Coaching Services – FZCO (“we”, “us”, “our”), runs the website progress-leader.com (the “Site”). We are committed to protecting your privacy and handling your personal data responsibly.

This Privacy Policy explains what personal data we collect, why we collect it, how we use and share it, how long we keep it, and your rights. It applies to all visitors, users, and customers worldwide, including in the EU/EEA/UK (where GDPR applies), the UAE, and other regions.

We process personal data in compliance with applicable laws, including the General Data Protection Regulation (GDPR), UAE Federal Decree-Law No. 45/2021 on the Protection of Personal Data, the California Consumer Privacy Act (CCPA/CPRA) (where thresholds met), and other relevant data protection laws.

Our Details Data Controller: PTBA Coaching Services – FZCO (operating as PT Business Academy / PROGRESS) Address: Flexi Desk, DUQE Square Business Center Quarter Deck, MINA RASHID, Dubai, UAE Email: info@progress-leader.com or info@ptba.ae

1. Personal Data We Collect

We collect personal data directly from you or automatically.

Data You Provide

• First and last name, company name (optional), address, phone number, email address
• Payment/billing details (name, address, tax/VAT number if required) for program purchases or coaching
• Message/content from forms, contact inquiries, scheduling (e.g., Calendly), or emails
• Account/registration details (including password – stored securely)
• Coaching/program data (e.g., progress notes, mindset assessments, lifestyle details, check-in responses)
• Newsletter or updates subscription details

Automatically Collected Data

• Server logs (IP address, browser/OS, pages visited, timestamps).
• Usage/device data via cookies and similar tracking technologies (detailed in the Cookies & Tracking section below).
• Aggregated analytics via tools such as Google Analytics (IP anonymized where possible).

We do not collect sensitive data unless voluntarily provided (and only as needed for coaching purposes).

2. How We Use Your Personal Data & Legal Bases

We use your data for:

• Delivering the PROGRESS coaching program, leadership & lifestyle mentoring, mindset development, accountability check-ins, and support
• Processing registrations, payments, and scheduling
• Transactional emails, support responses, and bi-weekly updates
• Marketing/newsletters (consent-based)
• Site improvement, security, fraud prevention
• Analytics/insights (aggregated)

Legal bases (GDPR/UAE focus):

• Contract for coaching services, program delivery, and related activities.
• Consent for marketing and certain cookies – you can withdraw consent anytime.
• Legitimate interests for security, logs, and basic analytics (balanced against your rights).
• Legal obligation for invoicing, tax, and record-keeping.

3. Sharing & International Transfers

We do not sell your personal data. Sharing is limited to:

• Service providers/processors (with data processing agreements): payment gateways (e.g., Stripe, PayPal), email/scheduling tools (e.g., Calendly, Mailchimp), analytics tools (e.g., Google), behavior insights (e.g., Hotjar), video platforms (e.g., YouTube).
• Our internal team/network for operational purposes only.
• Authorities if legally required.

Data may be stored/processed in the UAE, EU, or other jurisdictions. International transfers use appropriate safeguards (e.g., Standard Contractual Clauses or adequacy decisions) to ensure protection.

4. Data Retention

We retain your data only as long as necessary:

• Account, coaching, and program data: for the duration of our relationship plus periods required by law (e.g., 5–10 years for financial/tax records).
• Marketing data: until you withdraw consent.
• Server logs and inquiries: up to 12–24 months for security purposes.
• After the purpose ends, data is anonymized or deleted.

5. Data Security

We implement industry-standard security measures (encryption, access controls, regular audits). No method of transmission or storage is 100% secure. In the event of a data breach that affects your rights, we will notify you and relevant authorities as required. If you suspect any compromise (e.g., stolen credentials), please contact us immediately.

6. Your Rights

You have the right to:

• Access, correct, or delete your personal data (available to all users).
• For EEA/UK residents (GDPR): rectification, restriction of processing, data portability, objection to processing, and withdrawal of consent at any time. We respond within one month.
• For UAE residents (under Federal Decree-Law No. 45/2021): similar rights to access, correct, delete, restrict, and object, with requests handled promptly.
• For California residents (CCPA/CPRA): know what categories of data we collect, delete your data, opt-out of sale/sharing (we do not sell or share personal data as defined by CCPA/CPRA), and non-discrimination for exercising rights. We respond within 45 days (extendable if needed).

To exercise your rights, email info@progress-leader.com or info@ptba.ae with proof of identity.

7. Cookies & Tracking

Our website uses cookies and similar tracking technologies to provide essential functionality, improve user experience, analyze usage, and deliver personalized marketing (where applicable). We use a consent management banner that allows you to accept or reject non-essential cookies. Essential cookies are always active as they are necessary for the site to function properly.

You can also manage cookies through your browser settings at any time, though blocking essential cookies may affect how the site works.

What are cookies? Cookies are small text files placed on your device by websites. They help the site remember information about your visit (e.g., preferences, login status).

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