Effective Date: 21 April 2022
Your Privacy and Smart Twenties Pty Ltd (ABN 78 620 167 759) trading as Sam Laura Brown (collectively and individually referred to as “Sam Laura Brown”, “we”, “us” or “our”).
WHO WE ARE AND HOW YOU CAN CONTACT US
You can contact us for privacy-related questions by emailing email@example.com.
We will only use your personal information in compliance with Australian Privacy Laws (Privacy Act (1988 (Cth)), Australian Privacy Principles and to the extent applicable, with the EU General Data Protection Regulation (GDPR) and any replacement legislation or regulation or guidelines and standards governing the use, storage or transmission of personal data.
OUR ROLE IN YOUR PRIVACY
As we are the providers of the products and services on these Sites, we determine how and why your data is processed. We do not sell or rent your details to any third parties. We are committed to protecting your privacy and we want you to know exactly what information is collected and how we use it.
WHEN AND HOW WE COLLECT DATA
From the moment you visit our Sites, we are collecting data, sometimes you might provide this data by completing a form or setting up an account, otherwise we might collect the data automatically. We may also collect data when:
- You purchase an online course, webinar, program or service
- You interact with us on social media
- You complete any sign-up forms, landing pages or send us a direct message via social media or an email to any of our nominated emails
- You participate in events, promotions and giveaways or any request for additional data such as customer surveys
- You accept our cookies and other tracking technologies on any device you use to interact with us
- You voluntarily submit your data to us for any reason
TYPES OF DATA WE MAY COLLECT
- Contact details (name, address, email)
- Financial Information (bank details when you are making a purchase)
- Your business name (sometimes)
- Basic information about your business and its history (sometimes)
- Data about the products or services you purchase
- Data about your experience with our Sites and our products and services
- Data relating to your circumstances and such other information that is relevant to the products or services we provide to you
- Data relating to your attendance at seminars or other events held by us (including webinars and podcasts)
- Data that identifies you (your IP address, login, browser type, time zone, browser plugins, geolocation, what operating system and version) – we do not link this with any personal Data
- Data on how you use our Sites (URL clicks, products and services views, how long you are on our pages and other actions)
USE AND DISCLOSURE OF YOUR DATA
Under data laws, we are only allowed to use your data for specific reasons and where we have the legal basis to do so.
We will use your data for the purposes it was collected and related purposes that include:
- Operating our Sites
- Providing you with products, information and services
- Customer support
- Tracking your purchase history
- Detecting and preventing fraud
- Improving our Sites
- Making your experience on our Sites more efficient and enjoyable
- Market research e.g. we may contact you for feedback about our products and services
- Provide you with information about events, other products or services or opportunities that may be of interest
- Marketing (with your consent)
- Monitoring your compliance with our Website Terms and Conditions
We may disclose your data for the purposes it was collected and also:
- As required by law subject to our obligations
- With your consent
- Within our business
- To send you marketing material (with your consent)
- To process your participation in any promotions and giveaways (including contacting you if you win, displaying your name online and on our social media platforms)
- Share with third parties to enable us to provide our products and/or services
We use Google Analytics functions. You can find out how your data is collected here and there are instructions here on how to opt-out of Google Analytics data tracking.
CHOOSING NOT TO PROVIDE PERSONAL DATA
You can choose not to provide us with any personal data. However, if you do this, we will not be able to provide you with any products or services, however, you can continue to use our Sites and browse the pages of our Sites.
TURNING OFF COOKIES
We will always let you know before we collect any data from you what the intended use is and if we intend to use it for marketing and if third parties are involved we will obtain your consent (which you can withdraw at any time). You can change your mind about marketing material by opting out by:
- emailing firstname.lastname@example.org; or
- unsubscribing within the email if you have previously subscribed to our newsletter.
You can exercise your rights at any time by emailing email@example.com.
ACCESSING INFORMATION WE HOLD ABOUT YOU
We will provide you with the information within 30 days of your request, unless doing so would adversely affect the rights and freedoms of others (e.g. another person’s confidentiality or intellectual property rights). We will tell you if we can’t comply with your request and why.
You can contact us to ask us to correct any information we hold about you that you believe is inaccurate.
OBJECTIONS TO USING DATA FOR PROFILING OR AUTOMATED DECISIONS
We may use your data to determine what products and services are relevant to you (e.g. tailoring our emails based on your behaviour). Otherwise, the only circumstances in which we will use this data is to provide our products and services to you.
THE RIGHT TO BE FORGOTTEN
You have the right to request for your data to be erased. This means we have to delete all information that we hold about you, except to the extent of any information we are required to hold due to our legal obligations.
MAKING A COMPLAINT
If you have any complaints regarding how your data is handled, please contact us by emailing firstname.lastname@example.org. If you are not satisfied with our response to your complaint you may seek a review by contacting the Office of the Australian Information Commissioner.
SECURITY OF THE DATA WE COLLECT
We realise that our customers trust us to protect their data and whilst we cannot guarantee the security of any information you transmit to us, or receive from us, we take that task seriously and maintain reasonable and appropriate physical, electronic and procedural safeguards to help protect your data. This includes the following:
- Password access to accounts
- Storing electronic data with reputable third party storage providers who have appropriate security protections
- Limit access to personal information to individuals who need to know.
- Using payment providers who are PCI DSS compliant
- We do not store your payment details
WHERE WE STORE DATA
HOW LONG WE STORE DATA FOR
We will keep your data for as long as we need it, and this period will also depend on your interactions with us. If you have made a purchase with us, we will keep a record of your purchase for the period necessary for invoicing and tax purposes. When we no longer need to keep your information, we will delete it permanently or anonymise Data which is no longer necessary.
THIRD PARTIES WHO ACCESS YOUR DATA
We share data with third parties in the following circumstances:
- Other companies in our group of companies, as necessary to operate our Sites
- Our suppliers and service providers working for us e.g. payment processors
- Our professional and legal advisors
- Third parties engaged in fraud prevention and detection
- Law enforcement or other government authorities
- Share with third parties who enable us to provide our products and services which may include:
- payment processors such as Stripe, PayPal, Xero who may process your payment for any products and services bought from us;
- Social media and analytics such as Facebook, Instagram and Google Adwords for purpose of custom audience generation and the development of targeting criteria;
- Other third parties such as Leadpages, LeadQuizzes, Teachable, Zoom, Active Campaign, Convertkit for processing and holding Data that enables us to ensure you are kept informed of all course information, logins and marketing material, offers, promotions, newsletters, blogs and video training.
- Where we have your consent to do so or otherwise where we are legally permitted to do so.
All of our real-time credit card authorisations are handled by secure third party gateway providers and these are secured by the highest level of security. The following measures are taken to protect your data:
- Payments are fully automated with an immediate response.
- Your complete credit card number cannot be viewed by us or any outside party.
- All transaction data is encrypted for storage within our third party gateway suppliers bank-grade data centre, further protecting your credit card data.
- Our third party gateway provider is an authorised third party processor for all the major Australian banks.
- Our third party gateway provider will at no time touch your funds, all monies are directly transferred from your credit card to the merchant account held by us.
We use third-party gateway providers that are widely respected for providing secure and reliable online payment solutions. We have chosen to deal with the best so you can feel safe that your personal information is kept safe and secure at all times. While we attempt to protect the information in our possession, no security system is perfect, and we cannot promise that information about you will remain secure in all circumstances.
The Payment Card Industry Data Security Standard (PCI DSS) is an information security standard for all organisations that handle branded credit cards from major card schemes. PCI DSS is a standard mandated by the card brands like Visa, Mastercard, American Express and Discover and is managed by the PCI Security Standards Council.
PCI-DSS requirements help ensure the secure handling of credit card information through our Sites and the service providers.
AGE OF CONSENT
By using the Sites, you warrant that you are at least the age of majority in your State or Territory of residence. Our Sites should not be used by anyone under the age of majority, and we do not knowingly collect data from anyone under the age of majority.
COOKIES AND HOW TO BLOCK THEM
We may use web beacons (or clear gifs) on our website and in our emails. So basically when we send emails, we can track behaviour such as who opened the emails, who clicked the links and collect information such as your IP address, your browser or email type, we then put this information together to improve the performance of our email campaigns and provide you with better and/or services specific to your needs. You will always have the ability to opt out of any emails we send just click the link in the email that says “unsubscribe”.