DEFINITIONS “Account” means an account required to access and/or use certain areas and features of Our Site; “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below; “Our Site” means this website, www.josiecarin.com; www.themigrainenaturopath.com.au and www.naturology.care “Australian and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and Privacy Act 1988 (Privacy Act) and Australian Privacy Principles (APPs); “We/Us/Our” means Josie Carin Gruber, trading as Josie Carin, Naturopath; Naturology and The Migraine Naturopath registered in Australia whose registered address is 2/11 San Simeon Circuit, Sapphire Beach NSW 2450 and whose main trading address is 2/11 San Simeon Circuit, Sapphire Beach NSW 2450.
WHAT WE COLLECT Information That Is Provided to Us Directly By You. Examples include: Shared Public Content: Our Sites may permit you to publicly interact with us and other users, share content, post Comments, and ask or answer questions. Such shared content may be publicly viewable by others depending on where it is posted. If such information is shared on a third-party platform, such as a social media site, the collection, use, and sharing of your data will also be subject to the privacy policies and related agreements of that third party. Quizzes, Forms, and Surveys: We may offer you the opportunity to complete a quiz, form, survey, provide feedback, either through our Sites or a third-party platform. If you participate, we will collect and store the data you provide us as part of your participation, such as your name and email address and any other requested feedback and any other relevant information. If you submit this information via a third- party platform, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party. User Account Data: When you purchase or are given access to one of our products or programs, you may be required to create a User Account and provide information like your email address and password. We collect data regarding which products you have access to, how much you paid for those products or services, the first date you signed into your User Account, the number of times you’ve signed into your User Account, the date of your last activity in your User Account and which lessons you’ve completed. Payment Data: If you purchase a Company product or service, we collect certain data about your purchase as necessary to process your request. You must provide certain payment and billing data directly to our third-party payment processing partners, including your name, credit card number, security code, expiration date, billing address, and post code.
Email Information: If you choose to receive email notifications from us, we collect your name and email address so that we can send you email communications about the requested information, products, and services.
Customer Support Information: If you contact us (via email, phone, text, messaging platform, or through our social media channels), we may collect and store your name, email address, telephone number, the content of your message, information about your business and any other data you provide. Some Site transactions may require us to telephone or text the customer. We will not contact you by telephone without your prior consent.
Web Beacons: We use web beacons and single-pixel GIFS to track and data for marketing purposes. We also may use third-party analytic tools like Google Analytics that employ cookies to collect information about your use of our Services.
We use these tracking technologies to deliver, measure, and improve our Site – whether accessed through a browser or a mobile device – in various ways. In particular, these technologies help make our Site easier to use, navigate and share, let us customize our Site to your interests; better understand you and how to deliver the best experience; present advertising based better tailored to your behaviour on our Site; render better customer service, and compile anonymous, aggregated information that allow us to better understand our customers and visitors.
You can opt out of Google Analytics. For more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.
To learn how to manage privacy and storage settings for Flash cookies, visit http://www.macromedia.com/support/documentation/ en/flashplayer/help/settings_manager07.html.
Additional information about deleting and blocking cookies can be found at http://www.allaboutcookies.org.
HOW WE USE YOUR INFORMATION We use collected information in a number of ways, including product and service order fulfillment, communicating about our products, services and offerings, processing responses to quizzes, forms and surveys, customer service, marketing and sales (including lead generation, market research, and managing advertising and marketing campaigns); optimising business operations.
The legal basis for processing your personal information as described above will be either your consent; execution of a contract with you or a relevant party; our legitimate business interests; or compliance with our legal requirements.
WHO WE SHARE YOUR INFORMATION WITH Publicly Shared Information: Any information you share in a public area of our Site will be available to anyone who can access that content.
Company Employees and Contractors: We may share your personal information within the Company to our employees and contractors in order to deliver our services and products to you.
Third-Party Service Providers: We use third-party service providers to collect and process personal information from or about you on our behalf. Examples include data analysis, marketing and advertising services, email and hosting services, customer services and support, hosting User Accounts, processing credit card payments, and collecting customer research or satisfaction surveys. They will have access to the personal information needed to perform their functions.
Online Advertising Services: We use third-party advertising services, like Facebook® and Instagram®, to deliver advertising about our products and services on our Sites, as well as other websites and applications you use.
The ads may be based on information we have collected (as outlined above) and information these advertising providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services and may be tailored to your interests.
Advertising providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services and may be tailored to your interests.
Analytic Services: We use analytics services like Google Analytics® on the Site. These services use tools to help us analyse your use of the Site, including information like the third-party website you arrive from, how often you visit, events within the Site, usage and performance data, and purchasing behaviour. We use this data to improve the Site and provide information, products and services that may be of interest to you.
Legal Enforcement, Legal Process, and Compliance: We may disclose personal information about you (1) if we are required or permitted to do so by applicable law or legal process, (2) to law enforcement authorities or other government officials to comply with a legitimate legal request,(3) when we believe disclosure is necessary to prevent physical harm or financial loss, (4) to establish, exercise or defend our legal rights, (5) in connection with an investigation of suspected or actual fraud or illegal activity or (6) otherwise with your consent.
Change of Ownership: We reserve the right to transfer to relevant third-parties any information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business combination. In such case, we will require the relevant third parties to provide comparable levels of protection as we provide with respect to the information we share.
KEEPING YOUR INFORMATION SECURE The transmission of information via the internet or email is not completely secure.
Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted through the Sites or over email; any transmission is at your own risk.
YOUR RIGHTS You have rights in relation to the personal information we hold about you. Below is an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.
Your Choice About the Use of Your Data: You can choose not to provide certain data to us, but you may not be able to use certain features of the Sites
Marketing Email Communications: You always have the opportunity to opt out of our marketing communications with you or change your preferences by following a link in the footer of all marketing email messages from us or by contacting us at firstname.lastname@example.org
Transactional or Service Email Communications: Some communications from us are considered transactional or service communications (for example, important account notifications, product updates, and billing information), and your Company products and services are provided to you upon the condition that you receive these communications from us.
If you do not wish to receive any transactional or service communications from us, you must cancel your User Account for Company products and services. To cancel your User Account, you can mark this preference in your Account Settings.
You may still receive marketing communications from us even after you cancel your User Account unless you also opt-out of our marketing communications, as described above.
Navigation Information: You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.
Information from Third Parties: To manage the information we receive about you from a social media site or other third parties, you will need to follow the instructions from that party for updating your information and changing your privacy settings, where available.
Cookies: To get information and control cookies used for tailored advertising from participating companies, see the consumer opt-out pages referenced above under “Automatically Collected Information through Tracking Technologies.”
ACCESSING, UPDATING, TRANSFERRING AND DELETING YOUR DATA You can update your personal information as follows: You can update your User Account information (if applicable) by logging into your User Account and updating your settings.
To update other data, please contact us at email@example.com. Where you request correction, please explain in detail why you believe the personal information we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. If you wish to access any personal information we hold about you, or to request that we delete or transfer any information about you that we have obtained, you may contact us at firstname.lastname@example.org. Please allow up to 15 business days for a response.
For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request. Please note that we retain certain data where we have a lawful basis to do so, including for mandatory record- keeping and to complete transactions.
At any time, you may object to the processing of your personal information, on legitimate grounds, except if otherwise permitted by applicable law.
If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact us at email@example.com. You also may have a right to lodge a complaint with data protection authorities.
THIRD-PARTY SITES The Sites may contain features or links to web sites and services provided by third parties.
Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Sites.
We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Sites.
We encourage you to learn about third parties’ privacy and security policies before providing them with information.
DATA TRANSFERS In order for us to provide the products and services to you, your personal information will be stored and processed in Australia.
Where data is shared with third-party data processors, your data will be captured, transferred, stored and processed in accordance with their policies, practices and in compliance with their local regulatory laws.
DATA RETENTION We will retain your information for as long as your account is active, as necessary to comply with our legal obligations, to resolve disputes, and enforce our agreements.
We purge non-customer email subscribers who have not engaged with the Company’s email marketing communications after five years.
If you wish to delete your information, please contact us at firstname.lastname@example.org
CHILDREN We only offer our Services to Users over 18 years of age. We do not intentionally or knowingly collect Personal Data from anyone under the age of 18.
If you are a parent or guardian of a child under 18 and believe they disclosed Personal Data to us, please contact us immediately at email@example.com
If you are a resident of the European Economic Area (“EEA”) which requires consent to processing Personal Data, we will not knowingly process Personal Data for Users under the age of consent established by EEA data protection law.
If we discover that we processed any Personal Data covered by these laws, we will cease such processing and take prompt reasonable measures to remove it from our records.
CHANGES AND UPDATES TO THIS POLICY Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time.
If we modify the Policy, we will make it available here, and indicate the date of the latest revision.
Your continued use of the Sites after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.