Privacy & Cookie POLICY

UPDATED: February 17, 2023

BUSINESS INFORMATION

Legal Entity:
Sabine Biesenberger  |  P.O. Box 955  |  Helensvale QLD 4212  |  Australia

Brand:
Souldriven Solopreneur (also known as sds.) is a brand of Sabine Biesenberger.

Australian Business Number (ABN):
61 626 546 153

CONTACT DETAILS

Business Owner, Data Controller & Data Protection Officer:
Sabine Biesenberger  |  P.O. Box 955  |  Helensvale QLD 4212  |  Australia
policies@souldrivensolopreneur.com


Appointed European Union (E.U.) / European Economic Area (E.E.A.) / United Kingdom (U.K.) Data Protection Representative:
Thea Biesenberger  |  Germany
policies-eueeauk@souldrivensolopreneur.com

No. 01

// Introduction

Sabine Biesenberger dba Souldriven Solopreneur (sds.) (“Business”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data (also known as personal information) through this Privacy & Cookie Policy.

Personal data means any information capable of identifying an individual; it does not include anonymised data.

This Privacy & Cookie Policy governs your access to and use of souldrivensolopreneur.com / circle.souldrivensolopreneur.com, including any content, functionality and services offered on or through souldrivensolopreneur.com / circle.souldrivensolopreneur.com (collectively referred to as “Website”), whether as a guest or a registered user.

When accessing the Website, we will learn certain information about you, both automatically and through voluntary actions you may take during your visit. This policy applies to information we collect on the Website and via email/text, during calls or other electronic messages between you and the Website.

Please read the Privacy & Cookie Policy carefully before you start to use the Website. By using the Website or clicking to accept or agree to the Terms of Use when this option is made available to you, you accept and agree to be bound and abide by the Privacy Policy. If you do not want to agree to the Privacy & Cookie Policy, you must not access or use the Website.

No. 02

// Data Protection Principles

We strive to follow these data protection principles:

  • We will apply lawful, fair and transparent privacy protection principles. As such:
  • We will not sell, lease or rent your personal data with any third party for their own marketing purposes without your express consent.
  • We do not knowingly collect personal data from children under 18 (refer to the “Children’s Privacy Note” below for more details).
  • We do not carry out automated decision making or automated profiling that produces legal effects or similarly significantly affects you as an individual.
  • We do not collect any sensitive data about you. (Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic/biometric data.)
  • We do not collect any information about criminal convictions and offences.
  • We will only process personal data for the purpose for which it was gathered.
  • We will only collect and process the minimal amount of personal data required to fulfil the purpose.
  • We will not store your personal data for longer than needed.
  • We will do our best to ensure the accuracy of your personal data.
  • We will do our best to ensure the integrity and confidentiality of your personal data.

Children's privacy note

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its feature and/or registration forms, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address or any screen name or user name you may use.

If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us.

No. 03

// Your Rights

No matter where you are located in the world, we allow everyone to exercise the following rights when it comes to your personal data:

  • Information: You have the right to know what personal data was gathered about you, where it was obtained and why and by whom it was processed.
  • Access: You have the right to access the personal data collected from/about you; this includes your right to request and obtain a copy of the data gathered about you.
  • Rectification: You have the right to request rectification of your personal data if the data is inaccurate or incomplete.
  • Erasure: In certain circumstances, you can request that your personal data has to be erased from our records.
  • Restriction of Processing: Where certain conditions apply, you have the right to restrict the handling of your personal data.
  • Object: You have the right to object to using your personal data, for example, in the case of direct marketing.
  • Data Portability: You have the right to obtain your personal data in a machine-readable format or, if it is feasible, as a direct transfer from one processor to another.
  • Withdraw Consent: You have the right to withdraw any given consent for the handling of your personal data.
  • Prevent Sales: You have the right to opt out from selling certain personal data about you to third parties. (To exercise this right, please complete this form here).

If you wish to exercise any of the rights set out above, please contact us and clearly state your request. We will not discriminate against you for exercising your rights, and you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or we refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up the response process.

We try to respond to all legitimate requests within one (1) month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

You may also authorise an agent (referred to as “Authorised Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorised Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorised Agent when they make a request on your behalf.

Should you feel that your state- or country-specific privacy rights are not considered appropriately in this Privacy & Cookie Policy, please reach out us and share your concerns. If you are a resident of the following state/country, you can find more information about the applicable privacy laws and rights by clicking the link: European Union / European Economic Area Residents’ Rights  |  United Kingdom Residents’ Rights  |  Nevada Residents’ Rights  |  California Residents’ Rights

If you have already contacted us to discuss your query and feel that it cannot be resolved to your satisfaction, you have the right to complain to a relevant supervisory authority such as the Australian Information Commissioner’s Office (OAIC; https://www.oaic.gov.au) or any other equivalent.

No. 04

// Collection

When you access our Website and/or interact with us in any way or form, we will learn certain information about you. This may include information that can be used to identify you as specified below:

  • First Name
  • Last Name
  • Email Address
  • Mailing Address (Billing & Delivery Address)
  • Telephone and/or Mobile Phone Number
  • Birthday
  • Photo or Graphic Avatar
  • Demographic Information (for example, age, gender, interests, preferences, etc.)
  • Business Name & Details (for example, title, niche, business model, client base, success history, program details, pricing, business goals, etc.)
  • Website URL & Social Media Handles / Usernames
  • Credit Card Details (only collected when you purchase something on or through this Website)
  • History of your Purchases on or through this Website
  • Activities completed & Resources viewed on our Website
  • Information collected automatically
  • Information received from third parties
  • Information that is publicly available

In certain cases, we may request that you provide some of the information listed above in order to obtain specific resources from us, including, but not limited to, on or through this Website. If you choose not to provide the data we request, you may still use our resources, but you may be unable to access certain resources.

Please note that when you register to receive anything from us or provide information to us in any other manner, you agree to provide only true, accurate, current and complete information.

Automatically collected information

We may automatically receive and log certain types of information when you visit or interact with us, including browser information, operating system, mobile device information, IP address, internet service provider, content viewed, geographic location, time of visit, referring site/application/service, registration time, etc. This information is used for statistical purposes and will not include personal data.

We may automatically collect certain data from you as you use our Website by using cookies and similar technologies. To the extent that you voluntarily provide personal data to us, our systems will associate the automatically collected information with your personal data.

information received from third parties

If you choose to use any third-party website, platform or service that is integrated with our Website (including a third-party social networking site such as LinkedIn, Facebook, Instagram, etc.), or if you use any of the embedded applications we use on our Website provided through a third-party website, we may receive personal data from such third parties.

We are not responsible for compliance with the policies or practices of any third-party website. You should ensure that you are comfortable with the information such third-party websites may make available to us by reviewing those websites’ privacy policies/service terms and by modifying your privacy settings and preferences on those third-party tools.

Any information we receive from third-party websites will be governed by this Privacy & Cookie Policy.

publicly available information

We might gather information about you that is publicly available.

No. 05

// Usage & Processing

We use your personal data on legitimate grounds and with your consent to provide you with the requested resources, to fulfil your queries, to communicate with you, to improve our Website, to understand how you engage with us, to develop new resources you might be interested in, to tailor your experience with us, to operate our business and to protect you and us.

We may process the following categories of personal data about you:

  • Communication Data includes any communication/enquiries that you send to us, whether that be through forms on our Website, through email, text, social media messaging, social media posting or any other communication that you share with us. We process this data for the purposes of communicating with you, for record-keeping and the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
  • Prospect Data includes data relating to any sign-up for our free Website resources (through our Website or otherwise), such as your name, email address, phone number and contact details. Based on the consent you have given, we process this data for the purposes of us sending you the free resources and for record-keeping. Our lawful ground for this processing is our legitimate interests which in this case are to fulfil your requests and to keep records.
  • Client Data includes data relating to any purchases of Website resources such as your name, billing address, delivery address, email address, phone number, birthday, purchase details and your payment details. We process this data to supply the resources you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
  • Business Data includes data relating to your business situation, such as your title, niche, business model, client base, success history, program details, pricing, business goals, etc. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
  • User Data includes data about how you use our Website together with any data that you post for publication on our Website or through other online applications. We process this data to operate our Website and to ensure that relevant resources are provided to you, to ensure the security of our Website, to maintain back-ups of our Website and/or databases and to enable the publication and administration of our Website, resources and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our Website and our business.
  • Technical Data includes data about your use of our Website such as your IP address, your login data, details about your browser, length of visit to pages on our Website, page views and navigation paths, details about the number of times you use our Website, time zone settings and other technology on the devices you use to access our Website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our Website and other online applications, to administer and protect our business and Website, to deliver relevant Website resources and advertisements to you and to understand the effectiveness of advertising efforts. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our Website and our business, and to grow our business and to decide on the most effective marketing strategy.
  • Marketing Data includes data about your preferences in receiving marketing from us and your communication preferences. We process this data to enable you to partake in our promotions, to deliver relevant resources and advertisements to you and to measure or understand the effectiveness of these advertising efforts. Our lawful ground for this processing is our legitimate interests which in this case are to study how users/clients use our Website and/or advertisements, to develop them, to grow our business and to decide on the most effective marketing strategy.

We may use Prospect Data, Client Data, User Data, Technical Data and Marketing Data to deliver relevant Website resources, communications and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is our legitimate interests which are to grow our business.

We may also use such data to send other marketing communications to you if you agreed to receive marketing communications, and in each case, you have not opted out of receiving such communications since. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business). To opt out of receiving marketing communications from us, you can either email us to let us know which communications you would like to unsubscribe from specifically, tell us over the phone to opt out of receiving phone calls, reply STOP to any text message to opt out of text messaging or click the unsubscribe link located at the bottom of any marketing email you receive from us and follow the unsubscribe instructions to opt out from email marketing . Please note that if you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, registrations, etc.

Where we are required to collect personal data by law or under the terms of the contract between you and us, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver the requested Website resources to you). If you do not provide us with the requested data, we may have to cancel the Website resources you have ordered, but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. In case we need to use your details for an unrelated new purpose, we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

No. 06

// Disclosure, International Transfer & Storage

As a general rule, we do not sell, rent or lease your personal data, whether collected automatically or through your voluntary action.

We may disclose your personal data to our service providers for the purpose of providing our Website resources to you, to enhance your experience with us or to run our business and fulfil legal requirements (for more information, please refer to the International Data Transfer Note below).

We may disclose your personal data to professional advisors, including government bodies, fraud prevention agencies, credit rating agencies, lawyers, accountants, bankers, auditors, insurers and/or collection agencies, when necessary to report our business activities or to enforce our terms and conditions or any other agreement between you and us.

We may provide your information to any successor in interest in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of our assets and/or business.

We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights or when compelled by a Court or other governmental entity to do so.

international data transfer note

We may transfer data to countries outside of your home country depending on what Website resources you requested from us. However, we require all third parties to whom we transfer data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process and store your personal data for specified purposes and in accordance with our instructions.

Our trusted service providers are:
ActiveCampaign based in the U.S.  |  Apple based in the U.S. (service: Apple Pay)  |  Bonjoro based in Australia  |  Bunnynet based in the U.S.  |  Calendly based in the U.S.  |  CircleCo based in the U.S.  |  Gateway CFO Solutions based in the U.S. (service: Connect365)  |  Google based in the U.S. (services: Google Pay / Google Workspace / YouTube)  |  Intuit based in the U.S. (service: Quickbooks)  |  JN Projects based in the U.S. (here: HelloSign)  |  Loom based in the U.S.  |  ManyChat based in the U.S.  |  Medion Australia (service: ALDImobile)  |  Microsoft based in the U.S. (here: Skype)  |  OneTrust based in the U.S.  |  PayPal based in the U.S.  |  SiteGround based in Europe  |  Social Media Networks such as Facebook, Instagram, LinkedIn, Pinterest, TikTok, etc. based in the U.S.  |  Stripe based in the U.S.  |  Vimeo based in the U.S.  |  WebActix based in New Zealand (service: ThriveCart)  |  Whitesquare based in Switzerland (service: Thrive Themes)  |  Zimmplify based in the U.S. (here: Spotlightr)  |  Zoom based in the U.S.


Important Information: If you are a resident of the European Economic Area (E.E.A.) / United Kingdom (U.K.) and the General Data Protection Regulation (GDPR / UK-GDPR) applies to you, please be aware that we may transfer, process and store your personal data to and in countries where we have a data processing agreement with our service providers that incorporates (i) standard data protection clauses promulgated by the European Commission, (ii) binding corporate rules for data protection that align with the General Data Protection Regulation requirements, or (iii) adherence to an industry- or technology-specific approved code of conduct blessed by the European Commission. If none of the above safeguards is available, we may request your explicit consent to the specific transfer and storage. You will have the right to withdraw this consent at any time.

No. 07

// Security

We do our best to ensure the security of the information you provide to us and the information we collect automatically. This includes using standard security protocols (such as HTTPS / SSL). In addition, we monitor our systems for possible vulnerabilities and attacks and encrypt stored data when possible. We also use anonymising and pseudonymising where suitable.

We allow access to your personal data only to those third parties who have a business need to know such data. They will only process your personal data on our instructions, and they must keep it confidential. 

Even though we try our best, we cannot guarantee the security of your personal data; however, we have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to. 

No. 08

// Retention

We will only retain 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.

When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes, Australian law requires us to keep basic transactional information about our customers for five (5) years or more, depending on the lodgement date of our tax return.

In some circumstances, we may anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

No. 09

// Third-Party Links

Our Website may include links to third-party websites, platforms and other services/applications (“Linked Websites”). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these Linked Websites, and we are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy statement of every Linked Website you visit.

No. 10

// Email, Call & Text Policy

If you choose to correspond with us through email/text, we may retain the content of your email/text messages together with your email address/mobile phone number and our responses. We provide the same protection for these electronic communications that we employ in the maintenance of information received online, via mail and over the phone or via similar technologies. This also applies when you register for certain resources on our Website, sign up through any of our forms using your email address/mobile phone number or make a purchase on or through this Website.

We are committed to keeping your email address/mobile phone number confidential. We do not sell, rent or lease our contact list to third parties, and we will not disclose your email address to any third parties except as defined in clause “6. Disclosure, International Transfer & Storage” of this Privacy & Cookie Policy.

We will maintain the information you send via email/text in accordance with applicable law.

In compliance with current legislation (including the CAN-SPAM ACT), all emails sent from us will clearly state who the email is from and provide clear information on how to contact us. In addition, all email marketing messages will also contain concise instructions on how to remove yourself from our mailing list (for example, by clicking an unsubscribe link) so that you receive no further marketing communications from us. If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, registrations, etc.

If you opt in to receive any free resources, participate in any free training, register for a webinar, register for a live event, register for a seminar or purchase any program, products or services sold by the Business on this Website, we will only enrol you to receive our free email newsletter (also known as “Black Label Insights”) if you affirmatively consent to it. If you do not wish to receive this newsletter after consenting to it, you can unsubscribe anytime. We include an “unsubscribe” link at the bottom of every email we send. If you ever have trouble unsubscribing, you can send us an email requesting to unsubscribe from future editions of the newsletter.

You may opt out of any marketing or promotional phone calls by informing the caller that you would not like to receive future promotional calls. You do not have to continue to consent to receive promotional calls in order to use our Website.

You may opt out of text messages from us (other than certain transactional messages that we are required to send you and/or you explicitly agreed to receive, including, but not limited to, reminders and notifications) at any time by texting STOP in response to any such text message. You acknowledge that opting out of receiving text messages may impact your use of the Website.

PLEASE NOTE THAT EMAIL/text messages are NOT RECOGNISED AS A SECURE MEDIUM OF COMMUNICATION. FOR THIS REASON, WE REQUEST THAT YOU DO NOT SEND PERSONAL DATA TO US via EMAIL/text. HOWEVER, DOING SO IS ALLOWED, BUT AT YOUR OWN RISK. 

No. 11

// Cookie Policy

Our Website utilises standard technologies mostly in the form of cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively referred to as “cookies”) to collect information about how our Website is used. Information gathered through cookies may include the date and time of visits, the pages viewed, time spent on our Website and the websites visited just before and just after our own, as well as your IP address.

A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but - to protect your privacy - your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.

First-party cookies are cookies set by our Website. Some content or applications (including advertisement) on the Website are served by third parties, including advertisers, ad networks/servers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal data, or they may collect information, including personal data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. 

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, please contact the responsible provider/host directly.

Cookies can be categorised as followed:

  • Session Cookies - These are only stored on your computer during your web session, and they are automatically deleted when you close your browser. They usually store an anonymous session ID, which allows you to browse a website without having to log in to each page, but they do not collect any personal data from your computer; or
  • Persistent Cookies - A persistent cookie is stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.

If you are interested in checking out all the cookies we use on our Website, please click here.

cookie consent & settings

When you visit our Website for the first time or re-visit our Website after a certain period of time, you will be asked to consent to the use of all cookies or confirm your preferred settings via our cookie banner.

Even after you consented to all or a few selected cookies, you can always view and/or adjust your cookie settings by clicking the button below:

In addition, you can alter your cookie preferences at any time by clearing cookies in your browser. The next time you visit our Website, you will be asked again for your cookie preferences. You can also block cookies (including essential cookies) at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. 

PLEASE NOTE THAT IF YOU USE YOUR BROWSER SETTINGS TO BLOCK ESSENTIAL COOKIES, YOU MAY NOT BE ABLE TO ACCESS ALL OR PARTS OF OUR WEBSITE.

If you have any questions about the cookies we use, feel free to reach out to us.

No. 12

// 'Do Not Track' Policy

As there isn’t an industry or legal standard for recognising or honouring browser “Do Not Track” (DNT) signals, we do not monitor or respond to them at this time.

No. 13

// Variations

We may need to change this Privacy & Cookie Policy from time to time, so we encourage you to review this page periodically. We will indicate at the top of this page when we last updated this Privacy & Cookie Policy.

If we make significant changes to this policy, we will alert you to any such changes by placing a notice on our Website, by sending you an email or by some other means. Should you have opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of our Website, and you are still responsible for reading and understanding them.

If you use our Website after any changes to the Privacy & Cookie Policy have been posted, that means you agree to all of the changes.

No. 14

// Support

If you have any questions regarding this Privacy & Cookie Policy, please send an email to policies@souldrivensolopreneur.com.