Version August 2020
We are the controller of any personal information gathered by your use of our website and services. Our website is a general audience website, intended for users of all ages. Where we use third parties to process your data, these parties are known as processors of your personal data. We have a contract with these third parties for the provision of these services.
We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information. For the purposes of meeting the Privacy Act territorial scope requirements, New South Wales, Australia is identified as the named territory where the processing of personal data takes place. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au
We have also identified that we have European clients and recognise the General Data Privacy Regulations (“GDPR”). Australia is identified as the named territory where the processing of personal information takes place.
A data ‘controller’ means the individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal information.
A data ‘processor’ means the individual or organisation which processes personal information on behalf of the controller.
THE PURPOSE OF THIS POLICY
In the course of providing you with our services we will collect and process information that is commonly known as Personal Data.
This Policy describes how we collect, use, share, retain and safeguard Personal Data. This Policy sets out your individual rights; we explain these later in the Policy but in summary these rights include your right to know what data is held about you, how this data is processed and how you can place restrictions on the use of your data.
This Policy applies when you may share personal data in contact with us via our website, online forms, email, social media accounts, the telephone, when writing to us directly or where we provide you with paper based forms for completion or we complete a form in conjunction with you.
WHAT IS PERSONAL DATA?
Personal Data is information relating to an identified or identifiable natural person. Examples include an individual’s name, age, address, date of birth, gender and contact details.
Sensitive Personal Data may contain information which is known as special categories of personal data. This may be information relating to and not limited to, an individual’s health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and biometric data, or data relating to sexual orientation.
We are legally required to comply with specific data processing requirements for Personal Data.
WHAT PERSONAL DATA IS COLLECTED BY US?
As a provider of educational services, we will process the following categories of data:
Personal Data including individual’s name, address, date of birth, gender, and contact details, registered business details and tax identification numbers.
Special categories of personal data including: as spiritual, social, religious, beliefs, associations or memberships, and aspects of your social interactions that may affect your participation or our provision of services to you.
We do not knowingly accept information or attendance of anyone under the age of 18 years old.
Why do we collect your Personal Data?
Where reasonable and practicable to do so, we will collect your Personal Data only from you. However, in some circumstances we may be provided with information by third parties. We may use third party suppliers for management of specific services e.g. payment processing, and they may store some of your Personal Data to provide such service to you. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party or that you can access your account to check this information directly yourself.
Links to Other Websites
We do not provide any personally identifiable customer information to these sites.
Why do we collect Personal Information?
Personal Information is obtained in many ways including interviews, online calls, text message, online chat, correspondence, by telephone, by email, via our website, from your website, from media and publications, from other publicly available sources, from cookies and from third parties, including but not limited to social media platforms such as Facebook, Instagram, and LinkedIn. We don’t guarantee website links or policy of authorised third parties.
We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing or email as below.
When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
Sensitive information will be used by us only:
For the primary purpose for which it was obtained,
For a secondary purpose that is directly related to the primary purpose,
With your consent; or where required or authorised by law.
We do not sell or pass your personal information onto third parties.
Client records about our appointments, documents and notes are stored as digital records only and saved in Google Drive. They provide TLS standard encryption to protect your Personal Information and a two-step authentication process. We may keep your records on remote digital devices that are encrypted and password protected. Storage of these files is necessary as a legal requirement by our insurer Aon.
Communications with us via email are stored in our account with Google. Any telephone or online calls may be recorded with your permission and stored in your clients records as a digital file. We have followed Google’s security check-list for security on all our files, communications and calendars.
To schedule appointments we use Google Calendars and Acuity to book appointments with clients. We only use your email for this booking to provide the Service. You can update your details in Acuity by logging into your own account.
Service provision for consultations, group meetings and some webinars is via Zoom. You do not need an account for this, but it will require you to register a name when logging in.
To host members only content for The Teachers Club, Lost-to-Launch (aka Business 101 Yoga Teacher Training) and all other programs we use Kajabi. You can update your details in Kajabi by logging into your own account.
Payments for our services can use third party payment facilitators Stripe, Xero and Paypal. All are PCI DSS v 3.2.1 compliant to ensure your financial data is secure and we can never access your full payment details.
If you contact us via our website, you may provide us with personal data when completing online health or contact forms. This form is hosted by Kajabi.
We may promote our services to you using the information you provide to us, including email or text. If you wish to receive promotional offers please opt in by completing the form on our website, on social media to ‘Cora Geroux'‘ or by emailing [email protected] to request to be added.
If you opt in to receive our emails you will receive service updates and offers occasionally. You can unsubscribe from this at any time from within one of these email. Our email marketing supplier, Kajabi will store information that you have submitted in your sign up. You can unsubscribe at any time by clicking on the unsubscribe button in the emails sent.
If you follow us on any social media platforms, your privacy settings in your social media account control what you share with others. Please be aware that our settings are to ‘Public’ where you leave reviews, comments and we will tag you where appropriate. Please check this if you are concerned about your privacy on any social media platform. Please let us know if you do not wish to be tagged in any of our posts or wish a tag to be removed.
We may conduct surveys using third parties to collect information in the survey to get an idea of the market. You do not have to participate, and you can choose to complete your name and email address or leave it anonymised.
If you contact us for a quote or request details on the services we provide, we consider ourselves as having a legitimate business interest to provide you with further information about our products and services. You may request that we stop this at any time with the contact details below.
We will also use your personal data to manage your account, perform statistical analysis on the data we collect, for business forecasting purposes and to develop new and market existing products and services.
Data Retention/ Disclosure of Information
We may release personal information where we believe that it is appropriate in a number of circumstances, including the following:
Third parties where you consent to the use or disclosure;
Where required or authorised by law;
To enforce or apply our agreements with you;
To protect the rights, property or safety of us, our clients or others; and
With your consent following specific notice or request from us.
If you have received Services with us we will store your data for seven (7) years from your last appointment with us (“Duration Period”), as required by our insurers (AON) for any potential claims.
You may have access to this information stored, but this falls under the circumstances where your Right to Request Erasure may be denied. Please see the OAIC guidance on this exception: https://www.oaic.gov.au/privacy/guidance-and-advice/australian-entities-and-the-eu-general-data-protection-regulation/#:~:text=The%20right%20to%20erasure%20(which,collected%2C%20or%20where%20the%20individual
You have legal rights about your personal data. You grant use of your data under the contract and terms herein through your active conduct and use of our services. At any time you have the right to know what personal data relates to you that is held by us, for what purpose, how it is collected and used, with whom it is shared, where it is located, to object to its processing, to have the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing. You can also request the deletion of their personal data.
You may request the following at any time about your data held by us with regards to the services that we provide:
The right to be informed about the personal data being processed;
The right to rectification of your personal data
The right to erasure of your personal data
The right to restrict processing of your personal data
The right to data portability (to receive an electronic copy of your personal data)
The right to object to the processing of your personal data
The right to access your personal data
In accordance with the General Data Protection Regulations (“GDPR”), you may request a copy of all data that we store about you at no cost at [email protected] In order to protect your Personal Data we may require identification from you before releasing the requested information. Repeated, unfounded or excessive requests may be challenged by us.
There are some limited circumstances that may limit the information that we can provide to you in a request, for example, public interest, law enforcement, legal and or health related matters.
Please also bear in mind that we rely on third parties for some of your information in the flow of data. It may take us the full calendar month permitted to provide a full response to your request.
If you require further information on your Individual Rights or you wish to exercise your Individual Rights, please contact [email protected]
Maintaining the Quality of your Personal Information
It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
International Data Transfers
Our services are available internationally. We control and manage Personal Information in Australia. We may transfer data outside of Australia to our suppliers to provide the service to you.
Where we require consent, your rights and what you are consenting to will be clearly communicated to you. Where you provide consent, you can withdraw this at any time by contacting our Data Privacy Representative at [email protected]
Such parties are not permitted to use your personal data for any other purpose than for what has been agreed with us. These parties are also required to safeguard your personal data through the use of appropriate technical and organisational data security measures and are prohibited from disclosing or sharing your data with other third parties without our prior authorisation, or unless as required by law. Please contact our data privacy representative for further information on the measures undertaken to safeguard your data.
DATA PRIVACY REPRESENTATIVE
To ensure data privacy and protection has appropriate focus within our organisation we have a Data Privacy Officer who is the sole trader of Cora Geroux. The Data Privacy Officer is Cora Geroux, who may be contacted at: [email protected]
ENQUIRIES AND COMPLAINTS
If you are dissatisfied with how our Data Privacy Officer handles your matter. You have the right to complain to the Office of the Australian Information Commissioner. The OAIC may be contacted via its website which is https://www.oaic.gov.au/