- We respect your privacy
- Promotable You Pty Ltd atf WE Trust t/as Promotable You (abn: 43 282 599 168) (Promotable You) respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. This policy sets out how we collect and treat your personal information.
- We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and to the extent applicable, the EU General Data Protection Regulation (GDPR).
- "Personal information" is the information we hold which is identifiable as being about you. This includes information such as your name, email address, identification number, or any other type of information that can reasonably identify an individual, either directly or indirectly.
- You may contact us in writing at [email protected] for further information about this Privacy Policy.
- What personal information is collected
- Promotable You will, from time to time, receive and store the personal information you submit to our website, provided to us directly or given to us in other forms.
- You may provide basic information such as your name, phone number, address and email address to enable us to send you information, provide updates and process your product or service order.
- We may collect additional information at other times, including but not limited to, when you provide feedback when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.
- Additionally, we may also collect any other information you provide while interacting with us.
- How we collect your personal information
- Promotable You collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website and when we engage in business activities with you. We may receive personal information from third parties. If we do, we will protect it as set out in this Privacy Policy.
- By providing us with personal information, you acknowledge that you have read and understood this Privacy Policy. Where we rely on consent as the legal basis for processing your personal information, you consent to the collection, use and disclosure of that information in accordance with this Privacy Policy. You may withdraw your consent at any time by contacting us at [email protected].
- How we use your personal information
- Promotable You may use personal information collected from you to provide you with information about our products or services. We may also make you aware of new and additional products, services and opportunities available to you.
- Promotable You will use personal information only for the purposes for which it was collected (or for a related secondary purpose where you would reasonably expect such use), or as otherwise permitted or required by law, or with your consent. This may include to:
- provide you with products and services during the usual course of our business activities;
- administer our business activities;
- manage, research and develop our products and services;
- provide you with information about our products and services;
- communicate with you by a variety of measures including, but not limited to, by telephone, email, sms or mail; and
- investigate any complaints.
- If you do not provide us with the personal information we request, we may not be able to provide you with our products and services, or you may not be able to fully access certain features of our website. We will inform you at the time of collection if the provision of personal information is required by law or contract, and the consequences of not providing such information.
- We may disclose your personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, legal proceedings or in response to a law enforcement agency request.
- If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer, to the extent permissible at law, our user databases, together with any personal information and non-personal information contained in those databases. We will provide you with notice of any such transfer and, where required by law, seek your consent or provide you with the opportunity to opt out of such transfer.
- Disclosure of your personal information
- Promotable You may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this privacy policy.
- If we do disclose your personal information to a third party, we will protect it in accordance with this privacy policy.
- General Data Protection Regulation (GDPR) for the European Union (EU)
- Promotable You will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use, where we process personal information of individuals located in the European Union or where the GDPR otherwise applies.
- We process your personal information as a Processor and/or to the extent that we are a Controller as defined in the GDPR.
- We must establish a lawful basis for processing your personal information under the GDPR. The legal basis for which we collect your personal information depends on the data that we collect and how we use it. Our lawful bases for processing may include: consent, performance of a contract, compliance with legal obligations, protection of vital interests, performance of a task in the public interest, or our legitimate interests (provided your interests and fundamental rights do not override those interests). We will inform you of the specific lawful basis at the time of collection.
- Where we rely on consent as a lawful basis, we will only collect your personal information with your express consent for a specific purpose. In all cases, any data collected will be adequate, relevant and limited to what is necessary for the purposes for which it is processed (data minimisation). We will keep your data safe and secure and retain it only for as long as necessary to fulfill the purposes for which it was collected, or as required by law.
- We will also process your personal information if it is necessary for our legitimate interests, or to fulfill a contractual or legal obligation.
- We process your personal information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law.
- We do not collect or process any personal information from you that is considered "Sensitive Personal Information" under the GDPR, such as personal information relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent, or if it is being collected subject to and in accordance with the GDPR.
- You must not provide us with your personal information if you are under the age of 18 (or 16 for EU residents where we rely on consent as the lawful basis for processing) without the consent of your parent or guardian. We do not knowingly collect or process the personal information of children under these age thresholds without appropriate parental or guardian consent. If we become aware that we have collected personal information from a child without appropriate consent, we will take steps to delete that information.
- Your rights under the GDPR
- If you are an individual residing in the EU, you have certain rights as to how your personal information is obtained and used. Promotable You complies with your rights under the GDPR as to how your personal information is used and controlled if you are an individual residing in the EU.
- Except as otherwise provided in the GDPR, you have the following rights:
- to be informed how your personal information is being used;
- access your personal information (we will provide you with a free copy of it);
- to correct your personal information if it is inaccurate or incomplete;
- to delete your personal information (also known as "the right to be forgotten");
- to restrict the processing of your personal information;
- to retain and reuse your personal information for your own purposes;
- to object to your personal information being used; and
- to object against automated decision-making and profiling.
- Please contact us at any time to exercise your rights under the GDPR at the contact details in this Privacy Policy.
- We may ask you to verify your identity before acting on any of your requests.
- Hosting and International Data Transfers
- Information that we collect may from time to time be stored, processed in or transferred between parties, platforms or sites located in countries outside of Australia, including the United States.
- We may use third-party cloud-based software platforms and service providers to deliver our products and services, including platforms used for coaching, communication, application tracking, automation and customer support. These providers may store or process personal information on servers located outside of Australia.
- You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
- Security of your personal information
- Promotable You is committed to ensuring that the information you provide to us is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
- Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the GDPR and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft.
- While we implement appropriate technical and organisational measures to protect your personal information, the transmission of information via the internet is not completely secure. We cannot guarantee absolute security of information transmitted to our website, and any transmission is at your own risk. However, once we receive your information, we will use strict procedures and security features to prevent unauthorised access. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and, where required, the relevant supervisory authority in accordance with applicable law.
- Access to your personal information
- You may request access to personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth), and to the extent applicable, the EU GDPR. We will respond to your request within a reasonable period (and in any event within 30 days for GDPR requests or 30 days for Privacy Act requests, unless an extension applies). If you would like a copy of the information that we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at [email protected]. We will provide access free of charge, except where permitted by law to charge a reasonable fee.
- We reserve the right to refuse to provide you with access to information that we hold about you in certain circumstances set out in the Privacy Act or any other applicable law, such as where providing access would be unlawful, would have an unreasonable impact on another person's privacy, or where the request is frivolous or vexatious. If we refuse your request, we will provide you with written reasons for the refusal (unless it would be unreasonable to do so) and inform you of the mechanisms available to complain about the refusal.
- Complaints about privacy
If you have any complaints about our privacy practices, please feel free to send in details of your complaints to [email protected]. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.
- Changes to Privacy Policy
Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.
- Website
13.1. When you visit our website
When you come to our website www.promotableyou.com.au we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
13.2 Cookies
- We may from time to time use cookies on our website. Cookies are very small files that a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website.
- Our website may from time to time use cookies to analyse website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third-party services such as Google AdWords. These ads may appear on this website or other websites you visit.
13.3 Third-party sites
Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third-party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Promotable You is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each website that collects personally identifiable information.