PRIVACY POLICY

Introduction

Azraella Raphael (“us”, “we”, “our”, “her”, or “Name”) is committed to protecting the information about you that we collect, store and use when you provide it to us on our website: azraellaraphael.com (Site).

References to “you” or “your” shall relate to a client or customer of Azraella Raphael that uses our products or services, or otherwise use this Site as described herein.

We respect your rights to privacy under the Privacy Act 1988 (Cth) (Privacy Act) and so in accordance with this Act, we are compliant with its requirements in respect of the collection, management and disclosure of your Personal Information.

We also uphold your rights to privacy if you are based in the European Union, in accordance with the General Data Protection Regulation (GDPR) (EU). Your rights under the GDPR are listed below.

If you do not wish to provide Personal Information to us, then you do not have to do so. However, this may affect your use of this Site or any products and services offered on it.

Definitions

  • Site: Site refers to any product or service hosted at azraellaraphael.com, operated by Azraella Raphael
  • Personal Information:Personal Information means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
  • Usage Data: Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit).
  • Cookies (Cookie): Cookies (Cookie) are small pieces of data stored on your device (computer or mobile device).
  • Data Protection Officer: Data Protection Officer means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Protection Officer of your Personal Information.
  • Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Protection Officer. We may use the services of various Service Providers in order to process your data more effectively.
  • Data Subject (or User): Data Subject (or User) is any living individual who is using our Site and is the subject of Personal Information.

1. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Site to you. This page informs you of our policies regarding the collection, use, and disclosure of Personal Information when you use our Site and the choices you have associated with that data.

When used in this Privacy Policy, the term “Personal Information” has the meaning given to it in the Privacy Act and GDPR. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered Personal Information.

We may also collect some information that is not Personal Information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our Site.

We are committed to ensuring that your Personal Information is protected. If we ask you to provide certain information by which you can be identified when using this Site, it will only be used in accordance with this Privacy Policy, the Australian Privacy Principles and GDPR. If you do not wish to provide Personal Information to us then you do not have to do so, but it may affect your use of this Site or the products and services offered on it.

We use your data to provide and improve the Site. By using the Site, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from azraellaraphael.com/terms-and-conditions/

Your Personal Information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

2. Types of Data – Personal Information Collected

Personal Information

While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Information”). Personally identifiable information may include, but is not limited to:

  1. Contact information, including email address;
  2. First name and last name;
  3. Phone number;
  4. Age or birth date;
  5. Profession or occupation;
  6. Demographic information such as address, postcode, preferences and interests;
  7. Cookies and Usage Data; and
  8. Other information relevant to customer surveys and/or promotions.

We collect Personal Information about you so that we can perform our business activities and functions and to provide best possible quality of customer service. We collect, hold, use and disclose your Personal Information for the following purposes:

  1. To provide our services to you;
  2. To send communications requested by you;
  3. To answer enquiries and provide information or advice about existing and new services;
  4. To provide you with access to protected areas of our website; and
  5. To comply with any Law, rule, regulation, Lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority.

You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email or communications we send, or by contacting us at admin@azraellaraphael.com

If we receive your Personal Information from third parties, we will protect it as set out in this Privacy Policy.

Collecting your Personal Information

We collect your Personal Information directly from you unless it is unreasonable or impracticable to do so. When collecting Personal Information from you, we may collect in ways including:

  1. When you make an enquiry about our services;
  2. Through your access and use of our Site, including when you register as a member of our Site;
  3. During conversations between you and our representatives;
  4. When you ask to be placed on one of our subscription/mailing lists; or
  5. When you become a client or customer of ours or otherwise use our products or services.

If you do not provide us with the Personal Information described above, some or all of the following may happen:

  1. We may not be able to provide our products or services to you, either to the same standard or at all;
  2. We may not be able to provide you with information about services that you may want, including information about special promotions; or
  3. We may be unable to tailor the content of our Site to your preferences and your experience of our Site may not be as enjoyable or useful.

Usage & Location Data

We may also collect information on how the Site is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, your communications with our Site, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages; the type of operating system you are using and the domain name of your Service Provider; other unique device identifiers and other diagnostic data. We may do this to analyse trends, administer the Site, track users’ movements, and gather broad demographic information.

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Site, to improve and customise our Site. You can enable or disable location services when you use our Site at any time, through your device settings.

3. Service Providers

We may employ third party companies and individuals to monitor, analyse and facilitate our Site (“Service Providers”), to provide the Site on our behalf, to perform Site-related services or to assist us in analysing how our Site is used.

These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Site. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

We may use tracking software to review and improve your experience of our Site. In particular, we may use Facebook, click funnels, Infusionsoft by Keap and Google Analytics Advertising products: Remarketing with Google Analytics and Google Analytics Demographics and Interest Reporting. Google Analytics collects data about our Site traffic via Google Advertising cookies and anonymous identifiers. Data collected via these Google products is not linked with any personally identifiable information you submit while on our Site.

If you wish to opt out of the Google Analytics data collection, you may do so on Google’s Site at https://tools.google.com/dlpage/gaoptout/. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

4. Tracking & Cookies Data

We may use Cookies on this Site from time to time and similar tracking technologies to track the activity on our Site and hold certain information. Cookies are sent to your browser from a website and stored on your device.

Cookies are text with a small amount of data which may include an anonymous unique identifier, placed in your computer’s browser to store your preferences. This enables us to recognise your computer and greet you each time you visit our website without bothering you with a request to register. It also enables us to keep track of services you view so that, if you consent, we can send you news about those services.

Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information. However, once you choose to furnish the Site with personally identifiable information, this information may be linked to the data stored in the Cookie. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Site.

You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some portions of our Site. If you do not wish to receive cookies, you can set your browser so that your device does not accept them.

We may use web beacons on this Site from time to time. Web beacons or clear .gifs are small pieces of code placed on a web page to monitor the behaviour and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a Cookie to the browser of a visitor viewing that page.

5. Use of Data

Azraella Raphael uses the collected Personal Information for various purposes:

  1. To provide, maintain and improve our Site;
  2. To notify you about changes to our Site;
  3. To allow you to participate in interactive features of our Site when you choose to do so;
  4. To provide customer support by better understanding your needs, enabling us to improve our products and services;
  5. To deliver our subscriptions, services and products;
  6. To monitor the usage of our Site and to customise the website according to your interests;
  7. To detect, prevent and address technical issues;
  8. To provide you with direct marketing, such as news, special offers and general information about other goods and services which we offer that are similar to those that you have already purchased or enquired about, unless you have opted not to receive such information;
  9. To send you promotional information about third parties which we think you may find of interest;
  10. To contact you (by telephone, email or mail) for market research purposes; and
  11. For internal record keeping.

We also use cookies to measure traffic patterns, to determine which areas of our Site have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online services.

6. Legal Basis for Processing Personal Information Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Azraella Raphael’s legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.

Azraella Raphael may process your Personal Information because:

  1. We need to perform a contract with you;
  2. You have given us permission to do so;
  3. The processing is in our legitimate interests and it’s not overridden by your rights;
  4. For payment processing purposes; and
  5. To comply with the law

7. Retention of Data

Azraella Raphael will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Azraella Raphael will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer time periods.

8. Links, Groups and Forums

We provide links to websites outside of our Site, as well as to third party websites (such as social media sites). These linked sites are not under our control, and we cannot accept responsibility for the conduct of companies linked to our website. Before disclosing your Personal Information on any other website, we advise you to examine the terms and conditions of using that website and its Privacy Policy. Third party websites are responsible for informing you about their own privacy practices.

If you participate in a discussion forum, chat room, webinar or live video, you should be aware that the information you provide there will be made broadly available to others, potentially inside or outside Azraella Raphael, who have access to that discussion forum or chat room. Also, please recognise that individual forums and chat rooms may have additional rules and conditions. Each participant’s opinion on a forum, chat room, webinar or live video is his or her own and should not be considered as reflecting the opinion of Azraella Raphael.

Please be advised that for any forums, webinars or live videos you attend, recordings can be enabled by a meeting, webinar or live video host. By signing up for any of Azraella Raphael’s, or any other host authorised by Azraella Raphael’s services or otherwise using them in any way, including without limitation by attending any Azraella Raphael meeting, webinar or live video, you expressly acknowledge that we may make and store Recordings for meetings or webinars, and may make such recordings available to hosts and other Attendees at the direction of Azraella Raphael. If you do not want to be recorded, you can choose to leave the meeting, webinar or live video.

9. Transfer of Data

Your information, including Personal Information, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Azraella Raphael will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and that no transfer of your Personal Information will take place to an organisation or a country unless there are adequate controls in place including the security of your Personal Information and other Personal Information.

10. Disclosure of Data

Business Transaction

If Azraella Raphael is involved in a merger, acquisition or asset sale, your Personal Information may be transferred. We reserve the right to transfer to the extent permissible at law of our user databases, together with any Personal Information and non-Personal Information contained in those databases. This information may be disclosed to a potential purchaser. We would seek to only disclose information in good faith and where we have sought to maintain confidentiality.

Disclosure for Law Enforcement

Under certain circumstances, Azraella Raphael may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Azraella Raphael may disclose your Personal Information in the good faith belief that such action is necessary:

  1. To our employees, contractors or service providers for the purposes of operating our Site or our business, fulfilling requests by you, and to otherwise provide services to you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, and professional advisors such as accountants, business advisors and consultants;
  2. To comply with a legal obligation to credit reporting agencies and courts, tribunals, regulatory authorities where customers fail to pay for goods or services provided by us to them;
  3. To courts, tribunals, regulatory authorities, solicitors and law enforcement officers as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
  4. To third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located outside of Australia;
  5. To protect and defend the rights or property of Azraella Raphael;
  6. To prevent or investigate possible wrongdoing in connection with the Site;
  7. To protect the personal safety of users of the Site or the public;
  8. To protect against legal liability; and
  9. To provide services to customers.

Where we disclose your Personal Information to third parties for these purposes, the third party will be obligated to use that Personal Information in accordance with this Privacy Policy.

11. Security of Data

We are committed to ensuring that the information you provide is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. The security of your Personal Information is important to us, but note that no method of transmission over the Internet, or method of electronic storage is 100% secure.

While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security of any information that you transmit to us, or receive from us. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that Personal Information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any Personal Information held by us.

We may hold your information in either electronic or hard copy form. Personal Information is destroyed or de-identified when no longer needed or when we are no longer required by Law to retain it (whichever is the later).

You may choose to restrict the collection or use of your Personal Information in the following ways:

  1. Whenever you are asked to fill in a form on the Site, look for the box that you can click to tick and indicate that you do not want the information to be used for direct marketing purposes; and
  2. If you have previously agreed to us using your Personal Information for direct marketing purposes, you may change your mind at any time with writing to us at admin@azraellaraphael.com

You may request details of Personal Information that we hold about you, in certain circumstances set out in the Privacy Act 1988 (Cth). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). An administrative fee may be payable for the provision of information. We will not charge for simply making the request and will not charge for making any corrections to your Personal Information.

There may be instances where we cannot grant you access to the Personal Information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

If you would like a copy of the information which we hold about you please write to admin@azraellaraphael.com. We will respond within a reasonable timeframe. We may refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.

If you believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, then you may request us to amend it at admin@azraellaraphael.com. We will respond to any request within a reasonable time and will endeavour to promptly correct any Personal Information found to be incorrect so that the Personal Information is accurate, up to date, complete, relevant and not misleading. If we do not agree that there are grounds for correction, then we will add a note to the Personal Information stating that you disagree with it.

Direct Marketing Materials

We may send you direct marketing communications and information about our services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS and email, in accordance with applicable marketing Laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us at admin@azraellaraphael.com or by using opt-out facilities provided in the marketing communications, and we will then ensure that your name is removed from our subscription/mailing list.

We do not provide your Personal Information to other organisations for the purposes of direct marketing.

Length of time Personal Information is Retained

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By Law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for five years for Australian Tax Law purposes.

In some circumstances you can ask us to delete your data; see your legal rights below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

12. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Azraella Raphael aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information.

If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us at admin@azraellaraphael.com

In certain circumstances, you have the following data protection rights:

  1. The right to access, update or to delete the information we have on you.Whenever made possible, you can access, update or request deletion of your Personal Information directly within your account settings section. If you are unable to perform these actions yourself, please contact us at admin@azraellaraphael.com
  2. The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  3. The right to object.You have the right to object to our processing of your Personal Information.
  4. The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
  5. The right to data portability.You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  6. The right to withdraw consent. You also have the right to withdraw your consent at any time where Azraella Raphael relied on your consent to process your Personal Information.
  7. The right in relation to automated decision making and profiling. A right you have for us to be transparent about any profiling we do, or any automated decision making.

These rights are subject to certain rules around when you can exercise them. If you wish to exercise any of the rights set out above, please contact us at admin@azraellaraphael.com. Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).

13. Payments

We may provide paid products and services within the Site. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your Personal Information is governed by their privacy policy. These payment processors 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 payment information.

The payment processors we work with are:

  1. PayPal: Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full
  2. Book Like A Boss: Their Privacy Policy can be viewed at https://booklikeaboss.com/privacy
  3. Infusionsoft by Keap: Their Privacy Policy can be viewed at
    https://keap.com/legal/privacy-policy

14. Links to other Sites

Our Site may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s website. We strongly advise you to review the privacy policy of every website you visit.

We do not have any control over those third party websites. We are not responsible for or liable for the protection and privacy of any information which you provide whilst visiting such websites, and such websites are not governed by this Privacy Policy.

15. Children’s Privacy

Our Site does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Information, please contact us admin@azraellaraphael.com. If we become aware that we have collected Personal Information from children without verification of parental consent, we take steps to remove that information from our servers.

16. Withdrawing Consent to this Privacy Policy

You may withdraw your consent to this Privacy Policy at any point. If you wish to withdraw your consent to our collection and retention of your data, please contact our Data Protection Officer at admin@azraellaraphael.com and we can arrange for your data to be deleted.

You may choose to restrict the collection or use of your Personal Information. If you have previously agreed to us using your Personal Information for direct marketing purposes, you may change your mind at any time by contacting us at admin@azraellaraphael.com

To unsubscribe from our e-mail database, or opt out of any communications, please contact us at the email address listed at admin@azraellaraphael.com with “Unsubscribe” in the subject line of the e-mail.

17. Breach of Privacy Policy

If you believe that your privacy has been breached, please contact at admin@azraellaraphael.com and provide details of the incident so that we can investigate it. We will treat your complaint confidentially, investigate your complaint and aim to ensure that we contact you and your complaint is resolved within a reasonable time (and in any event within the time required by the Privacy Act and/or GDPR, if applicable).

18. Changes to this Privacy Policy

This Privacy Policy sets out how Azraella Raphael uses, discloses and protects any Personal Information that you provide or that we collect, when you use this Site or that we collect directly from you.

We may change this policy from time to time by updating this page. In using this Site, it is recommended you view this page regularly to ensure that you are at all times aware of the current policy.

Your continued use of our Site following any such amendments will be deemed to be confirmation that you accept those changes.

19. Privacy Policy Breach

If you have any questions about this Privacy Policy, any concerns or a complaint regarding the treatment of your privacy, or believe that we have breached the Australian Privacy Principles and wish to make a complaint about that breach, then please contact us at admin@azraellaraphael.com, setting out details of the breach.

We will promptly investigate your complaint, treat your requests or complaints confidential, and respond to you in writing setting out the outcome of our investigation, what steps we propose to take to remedy the breach and any other action we will take to deal with your complaint in a timely manner.

Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.

20. Privacy Policy Changes

We may change this Privacy Policy from time to time, however we will notify you of any changes to our Privacy Policy. Any updated versions of this Privacy Policy will be posted on our website and will be effective from the date of posting.

21. Contact Us

If you have any questions about this Privacy Policy, please contact us at admin@azraellaraphael.com

This Privacy Policy was last updated on April 2, 2019