privacy policy

Effective: May 25, 2018

Business Information

Contact details

1. Introduction

Sabine Biesenberger (referred to as “we”, “us” or “our” in this Privacy Policy) is an Australian-based business that is committed to keeping your personal data safe. This Privacy Policy has been prepared based on provisions of multiple legislations, including the Australian Privacy Act 1988 (Cth), the Australian National Privacy Principles and the E.U. General Data Protection Regulation (GDPR).


This Privacy Policy provides you with details of how we collect and process your personal data through your use of our website, including but not limited to subpages, embedded forms as well as programs, products, services, opt-in gifts, e-books, videos, webinars, blog posts, e-newsletters, consultations, e-mails, social media and/or other communication (collectively referred to as “website”), whether as a guest or registered user:

This policy (together with our Terms of Use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. Please read the following terms carefully to understand our views and practices regarding your personal data. By using our website, you accept this policy and agree to abide by it. If you do not agree to this policy, please do not use our website.


Our website is not directed to individuals under 16. We do not knowingly collect personal data from children under 16. If we become aware that a child under 16 has provided us with personal data, we will take steps to delete such information. If you become aware that a child has provided us with personal data, please contact us.


It is important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at policies@sabinebiesenberger.com.

2. Data Collection, Categories, Purpose, Processing & Legal Ground

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

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

  • Communication Data that includes any communication and/or 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 send us. We process this data for the purposes of communicating with you, for record keeping and for 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 that includes data relating to your sign up for any of our free 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 resource(s) 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.
  • Customer Data that includes data relating to any purchases of products/services such as your title, name, billing address, delivery address, email address, phone number, contact details, date of birth, purchase details and your payment details. We process this data to supply the products/services you have purchased, keep records of such transactions and inform you about updates to the products/services. 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 as well as our legitimate interests which in this case are to inform you about updates to the products/services, to keep records and to establish, pursue or defend legal claims.
  • Business & Financial Data that includes data relating to your past, current and/or future business matters such as your website, social media profiles, stats, reports, analytics and/or any other resources that you communicate to or share with us by using various communication channels and tools. We process this data to tailor the products/services you have requested. 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 (obtained through cookies or other third-party online services) that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services 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 that includes data about your use of our website and online services 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 services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. 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 our marketing strategy.
  • Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

In relation to your data in general that we process in order to comply with legal requirements or as required by government authority, the processing is necessary for compliance with a legal obligation to which we are subject to.


In relation to keeping records, this processing is either necessary for compliance with a legal obligation that we are subject to or for our legitimate interests in responsible business operations or defending, pursuing or establishing a legal claim.


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 products/services to you). If you do not provide us with the requested data, we may have to cancel a products/services 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. For more information on this, please email us at policies@sabinebiesenberger.com. 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.


We do not carry out automated decision making or automated profiling that produces legal effects or similarly significantly affects you as an individual.

Advertisement

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content 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. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Sensitive Data

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 and biometric data. We do not collect any information about criminal convictions and offences.

3. Collection of Personal Data

We may collect data about you by you providing the data directly to us (for example by filling in forms on our website, sharing resources with us such as uploading content or commenting publicly, or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our Cookie Policy for more details about this.


We may receive data from third parties such as analytics providers (such as Google based in the U.S.), advertising networks (such as Facebook based in the U.S.), such as search information providers (such as Google based in the U.S.) and/or providers of technical, payment and delivery services.

4. Marketing Communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).


We may send you marketing communications from us if (i) you made a purchase or asked for information from us about our product/services or (ii) you agreed to receive marketing communications and, in each case, you have not opted out of receiving such communications since. However, you can still opt out of receiving marketing emails from us at any time.


Before we share your personal data with any third party for their own marketing purposes, we will get your express consent.


You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at policies@sabinebiesenberger.com at any time.


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.

5. Disclosure of Personal Data

We may have to share your personal data with the parties set out below:

We require all third parties to whom we transfer your 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 your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

Your data is processed at our headquarters in Queensland, Australia, and in any other places where our third-party service providers involved in the processing are located.


Depending on your location, data transfers may involve transferring your data to a country other than your own, including data transfers to a country outside Australia and/or the EU.


Whenever we transfer your personal data internationally, we do our best to ensure a high degree of security of data by checking that at least one of the following safeguards is in place:

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7. Data Security

We use reasonable technical precautions and have implemented business processes to protect your personal data from misuse, loss, unauthorised access, modification and disclosure. We also allow access to your personal data only to those third-party service providers 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.


We have procedures in place to deal with any suspected personal data breach as following:

8. Data 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 contractual, 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, the Australian law requires us to keep basic information about our customers (including contact, identity, financial and transaction data) for a minimum of five (5) years.


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.

9. Access Rights

You have rights about your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.


If you wish to exercise any of the rights set out above, please email us at policies@sabinebiesenberger.com.


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 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 any person 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 our response.


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.


If you have already contacted us and feel that your complaint cannot be resolved between the two of us, you can also submit your complaint to a relevant supervisory authority for data protection issues (such as the Australian Information Commissioner’s Office (OAIC; https://www.oaic.gov.au) or any other equivalent).

10. Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about cookies, please go to our Cookie Policy.

12. Variations

We may change this Privacy Policy from time to time. If we do so, we will post any relevant changes on this page and, if the changes are significant, we will send you an email notification. Also, we will keep prior versions of this Privacy Policy in an archive for your review. We encourage you to review our Privacy Policy whenever you use the website to stay informed about our practices and the ways you can help protect your privacy.


If you disagree with any changes to this Privacy Policy, you will need to stop using the website and contact us to delete your information.

13. Support

More details concerning the collection or processing of your personal data can be requested from us (refer to contact details at the top of this page).

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