Privacy Policy
Karen Vivarelli Pty Ltd (ACN 642 236 128) trading as Karen Vivarelli of PO Box 200 Kingsway WA 6065 (“Karen Vivarelli”) (“us”, “we”, “our”).
Effective Date from 1 October 2015
INTRO
Who we are and how you can contact us
We are Karen Vivarelli Pty Ltd trading as Karen Vivarelli. We are committed to protecting the privacy of our clients, customers, suppliers and employees. This Privacy Policy applies to the products and services we provide, including on our Site https://www.karenvivarelli.com.au (Site), and our social media channels, and on the Kajabi platform and explains how we collect, hold, use and disclose data to carry out the services we provide and constitutes part of our Website Terms & Conditions. This Privacy Policy does not cover information that you submit on other websites, even if we communicate with you on those sites. For example, if you post something on Instagram, Facebook, Pinterest, Twitter, or YouTube, that information is governed by the privacy policies on those websites, and is not governed by this Privacy Policy.
You can contact us for privacy related questions by emailing us at [email protected] or completing this form.
We will only use your personal information in compliance with Australian Privacy Laws Privacy Act (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
If you are a client, customer, subscriber or just a visitor on our Site, this Privacy Policy will apply to you.
Our Responsibilities
As we are the providers of the products and services on this Site, 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.
Your Responsibilities
- Please read this Privacy Policy and the Website Terms & Conditions.
- If you provide us with any data relating to a third party, you confirm that you have the right to authorise us to process that data on your behalf in accordance with this Privacy Policy.
When and How we collect Data
From the moment you visit our Site, 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 have set out some examples below of how we may collect data from you:
- When you send us an enquiry form
- When you complete a questionnaire
- When you subscribe to our newsletter
- When you set up an account
- When you attend a seminar or other event we may organise
- From our clients – when they register an enquiry, request an appointment for the purposes of obtaining our Services, purchase or book our Services or associated package, purchase a product, or otherwise in the course of providing our Services at any other time from time-to-time
- From third party service providers – when they are engaged to supply services to us (such as professional services), provide information to us or invoice us for the provision of services.
Types of Data we may collect
- Contact details (name, address, email)
- Financial Information (bank details when you are making a purchase)
- Data about the products or services you purchase
- Data that identifies you (your IP address, login, browser type, time zone, browser plug ins, geolocation, what operating system and version)
- Data on how you use our Site (URL clicks, products and services views, how long you are on our pages and other actions)
- Data about your experience and satisfaction with our Site and the legal products and/or services that you have purchased from us or others
- Data about any information we gather that relates to your attendance at seminars or other events held by us (including webinars and podcasts)
- Data relating to your circumstances and such other information that is relevant to the matter(s) in which we are instructed by you
- If you are an employee or prospective employee, data relating to your qualifications, skills and experience
- If you are a supplier of goods and services or a prospective supplier, information about your products, services and pricing
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 included:
- To run our Site
- provide you with products, information and services
- Customer support
- Track your purchase history
- Detect and prevent fraud
- Improve our Site
- Marketing (with your consent)
- Make your experience on our Site 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
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
- In order to sell our business (if we were to ever sell, we may need to transfer data held to the new owner)
Google Analytics and Facebook
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.
Our use of Google Analytics may include but is not limited to display advertising and remarketing. You may see our adverts across the internet, this is due to the use of tracking technologies (cookies) to optimise and serve our adverts based on past visits to our Site. When you log onto our Site, we, with the help of Google Analytics, use your browsing behaviour to connect this with other data that you previously provided to us in accordance with this privacy policy.
We use Facebook Insights to track your interaction with our Facebook page here, this will allow us to track usage and improve the performance of our page. We will use Facebook Analytics to better measure, track and understand customer user experience to enable us to improve our products and services that we offer. You can check out Facebook’s privacy policy here and if you want to opt out of seeing ads on Facebook based on information we have received, you can control this in your ad preferences here.
What are your choices?
Don’t provide us with 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 Site and browse the pages of our Site.
Turning off cookies
Our Site uses cookies and similar technologies to provider certain functionality to our Site. You can turn off cookies by activating the setting in your browser that allows you to do this. You can also delete cookies through your browser settings. If you do decide to turn off cookies, you can continue to use the Site, however, certain services may not work as effectively.
Don’t want marketing?
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 anytime). You can change your mind about marketing material by opting out by (a) completing the contact us form on our contact page or by unsubscribing within the email if you have previously subscribed to our newsletter.
What are your rights?
You can exercise your rights at anytime by contacting us via the contact us page on our Site here or via email [email protected].
You can access 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 cant comply with your request and why.
Inaccurate information
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.
You have 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.
You have the right to make a complaint regarding the use of your data
If you have any complaints regarding how your data is handled, please contact us via our contact page here or via email to [email protected]. 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 using the information available at https://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint
How secure is the data collected
We realise that our customers trust us to protect their personal information. We take that task seriously and maintain reasonable and appropriate physical, electronic and procedural safeguards to help protect your personal information. For example this includes:
- 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.
Where do we store data
We use service providers based around the world. Consequently, your data may be processed in countries outside of Australia. If we transfer personal data outside of Australia, we will ensure that your privacy rights are adequately protected by ensuring these service providers have the same or similar measures in place to protect data shared.
How long do we store data
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.
Third parties who process your data
We share data with third parties in the following circumstances:
- Other companies in our group of companies, as necessary to operate our Site
- Our suppliers and service providers working for us e.g. payment processors
- Third parties engaged in fraud prevention and detection
- Law enforcement or other government authorities
- Where we have your consent to do so or otherwise where we are legally permitted to do so.
Payment Security
Our Site is hosted on Bluehost and we use the WordPress Woocommerce for payments. As well as Kajabi for hosting course content and materials.
If you choose a direct payment gateway to complete your purchase, such as Stripe or PayPal then they each store your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.
All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover.
PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
Age of consent
By using this Site, you represent that you are at least the age of majority in your State or Territory of residence. Our Site 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.
Use
We may use Personal Information collected to provide our Services, operate our Website, send you our newsletter, respond to feedback and complaints, communicate with third party service providers, develop new Services, or if needed to enforce our Terms of Use with you.
If you are a third-party service provider, we will use your Personal Information to email you to accept your offer to provide Services, correspond with you in relation to the provision of Services and to pay your invoices.
In all cases, unless you have opted out, you consent to us using your Personal Information for direct marketing purposes by us alone in order to tell you about our Services. We may contact you by mail, telephone, email or SMS to market our products and Services. We will always give you the opportunity to opt out of receiving any future direct marketing correspondence.
You expressly agree that we may disclose Personal Information to third parties for purposes associated with your purchase of our Services and to third party service providers we engage to help us deliver our Services and for our own marketing purposes. We will only disclose Personal Information to additional third parties with your consent or if permitted or authorised to do so by law. Some places outside of Australia may have inadequate data protection laws or may offer differing levels of protection of Personal Information which are not as high as in Australia. We agree only to use data processers who provide sufficient guarantees and that they will implement appropriate technical and organisational measures that ensure compliance with the GDPR and protect the rights of the data subject, and only to third parties who agree to comply with this Privacy Policy.
You may authorise to stop processing your Personal Information at any time.
Data security, protection and quality
We protect the Personal Information we collect and hold from misuse, loss and interference and from unauthorised access and modification, and to make sure it is accurate, complete and up-to-date when we collect, use or disclose it.
We have procedures of monitoring the security and safety of data as well as procedures in place for dealing with any data breaches, and the associated requirements of notifying you and appropriate authorities where that data security of your Personal Information is breached.
To assist us, please ensure you provide us with your correct details, and let us know if you believe the information we have about you is inaccurate, incomplete, out of date or misleading (and we will take reasonable steps to correct the information). We may take steps to destroy or permanently de-identify information when it is no longer needed for any purpose for which it may be used or disclosed.
Cookies
We may use “cookies”, technology to store data on your computer or device using the functionality of your browser. Many websites do this because cookies allow the website publisher to do useful things like find out whether the user has visited a website before.
You can modify your browser to prevent cookie use – but if you do this our Service (and our Website) may not work properly. The information stored in the cookie is used to identify you. This enables us to operate an efficient service and to track the patterns of users of our Website.
In the course of serving advertisements to our Website (if any), third-party advertisers or ad servers may place or recognise a unique cookie on your browser. The use of cookies by such third-party advertisers or ad servers is not subject to this Privacy Policy, but is subject to their own respective privacy policies.
For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
Changes to this Privacy Policy
This Privacy Policy forms part of our Terms of Use and therefore the agreement between you and us (either in your capacity as a client or a third-party service provider). We may, from time to time, amend this Privacy Policy, in whole or part, in our sole discretion. Any changes to this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy on website https://www.karenvivarelli.com.au. Depending on the nature of the change, we may announce the change on the https://www.karenvivarelli.com.au homepage or by email (if we have your email address). However, in any event, by continuing to use the Website and/or our service following any changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Privacy Policy, as amended from time to time, in whole or part, you must terminate your use of the Website and inform us immediately prior to any further receipt of our Services.
Contact us
If you have any questions about this Privacy Policy, or if you wish to request access to your Personal Information, correct or update you details or raise any privacy concerns you may have, please contact us at [email protected]
For further information on your privacy rights go to: http://www.privacy.gov.au
For further information on the GDPR, go to:
https://ec.europa.eu/info/law/law-topic/data-protection_en
