Privacy policy
VERSION: 30 JUNE 2023
About Us
James Holden trading as Real Love (“We/Us”) whose registered office is 6/6 Grafton Crescent, Dee Why, NSW, 2099 operates the website(s) https://real-love.org/ and provides personal transformational guidance sessions, workshops and courses (together “services”).
We are committed to providing quality services to you and in the course of providing you with our services we will collect and process information that is commonly known as “Personal Data”.
The purpose of this Privacy Policy
This Privacy Policy does the following:
1. Describes how we collect, use, share, retain and safeguard Personal Data,
2. Policy sets out your individual rights; we explain these later in the Policy but in summary these rights include your right to know what data is held about you, how this data is processed and how you can place restrictions on the use of your data,
3. Outlines our ongoing obligations to you in respect of how we manage your Personal Data, and
4. Explains what kind of information we collect in connection with our services, the purposes for which we use the information and how we may share this information.
This Policy applies when you may share personal data in contact with us via our website, online forms, email, social media accounts, the telephone, when writing to us directly or where we provide you with paper-based forms for completion or we complete a form in conjunction with you.
To provide a high standard to our client’s personal data and privacy, we adopted and aim to comply with the Privacy Act 1988 (Cth, Australia) and any other applicable privacy legislation (collectively the “Data Acts”).
A data ‘controller’ means the individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data.
A data ‘processor’ means the individual or organisation which processes personal data on behalf of the controller.
We are the controller of any personal data gathered by your use of our website and services.
Where we use third parties to process your data, we have a contract with these third parties for the provision of these services.
New South Wales, Australia is identified as the named territory where the processing of personal data takes place.
You can learn more about your privacy rights at Australian Information Commissioner Office at https://www.oaic.gov.au/
What is Personal Data?
Personal Data is information relating to an identified or identifiable natural person. Examples include an individual’s name, age, address, date of birth, gender and contact details.
Sensitive Personal Data may contain information which is known as special categories of personal data. This may be information relating to and not limited to, an individual’s health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and biometric data, or data relating to sexual orientation.
We are legally required to comply with specific data processing requirements for Personal and Sensitive Data.
What personal data is collected by Us?
As a provider of personal transformation coaching services, we will process the following categories of data:
(a) Personal Data:
● Your name,
● Contact details including address, email, telephone,
● Date of birth,
● Gender.
(b) Sensitive Personal Data:
● Relationship status,
● Current health and details of historic injuries or illnesses (physical and psychological),
● Photographs, audio and visual,
● Associations, beliefs and memberships,
● Aspects of your health that may affect your participation or our provision of services to you.
If you object to the collection, sharing and use of your personal data we may be unable to provide you with our services.
We may record your communications with us when contacting our team. We may collect information about your visits to us to help us personalise your experience with us. By providing this information to us you are consenting our use in the manner set out in this policy.
We do not knowingly accept information or attendance of anyone under the age of 18 years old.
Why do we collect Personal Data?
Personal Data is obtained in many ways including interviews, online calls, text message, online chat, correspondence, by telephone, by email, via our website, from your website, from media and publications, from other publicly available sources, from cookies and from third parties, including but not limited to social media platforms such as Facebook, Instagram, Twitter and LinkedIn. We don’t guarantee website links or policy of authorized third parties.
By providing this information to us you are consenting our use in the manner set out in this Policy.
We collect your Personal Data for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Data for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing or email as below.
When we collect Personal Data we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it. Please ask if you do not understand.
Third-Party Suppliers
Where reasonable and practicable to do so, we will collect your Personal Data only from you.
However, in some circumstances, we may be provided with information by third parties. We may use third-party suppliers for management of specific services e.g. payment processing, and they may store some of your Personal Data to provide such service to you. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party or that you can access your account to check this information directly yourself.
We use third-party software to securely store your data to perform specific functions to support our services (“third-party suppliers”). Third-party suppliers have access to personal information needed to perform their functions but may not use it for other purposes. Their privacy policy is linked below as to how they handle data as part of the service we use. With all of the third-party suppliers you can ask us to review your stored data to ensure that it is accurate and best serves you.
We do not sell or pass your personal information on to third parties.
Data Management
We use the following third-party providers for our service to you. Their privacy policy is linked within as to how they handle data as part of the service we use. With all of the below suppliers you can ask us to review your stored data to ensure that it is accurate and best serves you.
Client records as paper documentation are stored securely at our premises to ensure that they are safe and secure. A digital version is stored with Google. We may keep your records on remote digital devices that are encrypted and password protected.
Communications with us via email are stored in our account with Squarespace.com.
Any telephone or online calls may be recorded with your permission and stored in your client record as a digital file.
To schedule appointments, we use Acuity Scheduling. You can opt out of this and manage your data in this system at any point by logging into the booking confirmation email.
Payments for our services can use third-party payment facilitators Stripe. Stripe are PCI DSS v 3.2.1 compliant to ensure your financial data is secure and we can never access your full payment details.
Marketing from us may include:
Facebook and Instagram may be used by us. If you follow, like and interact with our social media accounts then your comments may be public depending on your personal privacy settings within that social media platform. Please check this if you are concerned about your privacy on any social media platform. Please let us know if you do not wish to be tagged in any of our posts.
We have installed a Facebook Pixel on our website so that we can see who visits our website from a Facebook link. You can find out what information is collected by Facebook on their site.
We use involve.me for The Elements quiz which is embedded using an iFrame into our website. This collects data on the answers only and is anonymised.
We may conduct surveys using third parties to collect information in the survey to get an idea of the market. You do not have to participate, and you can choose to complete your name and email address or leave it anonymous.
Our email list via Squarespace.com ensures that we only send emails to those who want to hear from us. We email monthly with content relating to our services. You can unsubscribe at any time by clicking on the unsubscribe button in the emails sent.
Our website is hosted by Squarespace.com. While using our website, we may ask you to provide us with certain personally identifiable information that might be collected through our website provider Squarespace.com. This includes the collection of your unique online electronic identifier; this is commonly known as an IP address, browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages and other statistics. Squarespace.com uses cookies to provide the website and ensure necessary function of our services. Your information is not collected via cookies until you have accepted them via our website banner.
Links to Other Websites
Our services may include links to third party websites. When you click on this link you have left our website and services. We do not have control over what cookies or beacons or other technology these sites may use to track activity into their website, and do not have control over what data they may collect or their privacy policy. Use of their websites and clicking on those links is at your sole risk. We are not responsible for the protection and privacy of any information that you provide whilst visiting such sites and these sites are not governed by this Privacy Policy. We suggest that you read their privacy statement before using the website.
We do not provide any personally identifiable customer information to these sites.
Disclosure of Personal Data
We may release personal data where we believe that it is appropriate in a number of circumstances, including the following:
Third parties where you consent to the use or disclosure;
Where required or authorized by law;
To enforce or apply our agreements with you;
To protect the rights, property or safety of us, our clients or others; and
With your consent following specific notice or request from us.
This includes fraud protection, but not selling, sharing or otherwise disclosing personally identifiable information from clients for commercial purposes in a way that is contrary to this
Security of Personal Data
Your Personal Data is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure. We do this using New South Wales, Australia.
Duration Period
If you have received Services with us we will store your data for 6 years from your last purchase with us (“Duration Period”), as required by our insurers AJ Gallagher for any potential claims.
When your Personal Data is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Data. However, most of the Personal Data will be stored in client files which will be kept by us for the Duration Period.
Access to your Personal Data
You may request a copy of all data that we store about you at no cost at connect@ real-love.org. In order to protect your Personal Data we may require identification from you before releasing the requested information. Repeated, unfounded or excessive requests may be challenged by us.
There are some circumstances that may limit the information that we can provide to you in a request, for example, public interest, law enforcement, legal and or health related matters. Please also bear in mind that we rely on third parties for some of your information in the flow of data. It may take us the full calendar month permitted to provide a full response to your request.
Your rights in such a request include:
1. Right to access
2. Right to rectification of errors
3. Right to deletion (may be limited)
4. Right to object to processing
5. Right to restrict processing
6. Right to withdraw consent
7. Right to object to marketing
8. Right to complain to relevant data protection authority
Maintaining the Quality of your Personal Data
It is important to us that your Personal Data is up to date. We will take reasonable steps to make sure that your Personal Data is accurate, complete and up to date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
International Data Transfers
Our services are not available internationally. We control and manage Personal Data in New South Wales, Australia. We may transfer data outside of Australia to our suppliers to provide the service to you. We ensure that their service meets the minimum requirements set out in the Privacy Laws. You can request to learn more about what data and which services may have access to your Personal Data.
Policy Updates
We reserve the right to update and amend this Privacy Policy at any time, effective upon posting an updated version on the Website.
We will publish such updates on our website and may email notifications to you. Continued use of the Website after any such changes shall constitute your consent to such changes.
Privacy Policy Complaints and Enquiries
If you have any queries or complaints about our Privacy Policy please contact us at:
James Holden
Should you have a complaint about the way that we have handled your Personal Data, you may submit this to the Australia Information Commissioner at https://www.oaic.gov.au/