PRIVACY POLICY (RESIDENTS OF THE EUROPEAN ECONOMIC AREA)

Growth Consultancy Pty Ltd trading as The Queen of Confidence A.B.N.87 608 899 118 (we, or The Queen of Confidence) recognises and values the protection of your personal information.

We recognise that you have an interest in our collection and use of your personal information via our website, which is located at www.thequeenofconfidence.com (our Website). We have implemented this Privacy Policy in order to be open and transparent about how we collect, hold, and use your personal information, and under what circumstances we may disclose or transfer your personal information. This Privacy Policy also outlines your rights under the General Data Protection Regulation (GDPR).

Please note that this Privacy Policy forms part of the Terms of Use document, which is displayed at the footer of each page of our Website.

As a resident of a country that the GDPR applies to our activities, you have particular rights with respect to your personal information. This Privacy Policy sets out information about:

• information we collect and hold about you;
• our use and disclosure of your personal information;
• the legal basis we rely upon to process your personal information;
• your rights over your personal information;
• the security of personal information;
• our disposal of personal information, when no longer needed;
• overseas transfer of personal information;
• the use of cookies and online tracking technologies;
• privacy relating to persons aged under 16 years; and
• contacting us with any questions or concerns that you may have.

Information we collect and hold

Wherever possible, you can elect to remain anonymous, or use a pseudonym, in interacting with us (for example, when making an enquiry).

We may ask you to supply personal information such as your name, grade year (if applicable) or e-mail address. However, under no circumstances will we request any information from you that may disclose your:

• political, religious or philosophical opinions, beliefs, associations or affiliations;
• health and sexuality;
• racial or ethnic origin;
• membership of a trade union, or a professional or trade association; or
• criminal records.

We may also conduct surveys or market research and may seek other information from you on a periodic basis. These surveys will provide us with information that allows improvement in the types and quality of services offered to you, and the manner in which those services are offered to you.

How we collect your personal information

We use various methods to collect personal information about you, including:

Direct interactions - you may provide us with your personal information by filling in forms or by corresponding with us, in various ways.

Automated technologies or interactions - we may, as you interact with our Website, automatically collect information about your equipment, browsing actions and patterns. We collect this information by using cookies and other online technologies. Please see our Cookie Policy for further details.

Use and disclosure of your personal information

When we hold your personal information, it will be used for the following primary purposes:

1.     to ensure the proper functioning of the Website;

2.     to ensure the proper functioning of our business and operations; and/or

3.     to provide you with a free of charge letter and/or detailed personal report, as purchased via the Website.

We will not use or disclose (or permit the use or disclosure of) information that could be used to identify you in any circumstances, except:

• to ensure the proper functioning of our organisation and the Website;

• provide you with a free of charge letter and/or detailed personal report, as purchased via the Website;

• where the law requires us, or authorises us, or a company holding data on our behalf, to do so; or

• where you have given express consent to us for a prescribed purpose.

We will not sell, distribute, rent, licence, disclose, share or pass your personal information on to any third parties, other than those that are contracted to us, to keep the information confidential.

Should a third party approach us, with a demand to access your personal information, we will take reasonable steps to redirect the third party to request the information directly from you, wherever it is lawful and reasonable for us to do so.

If we are compelled to disclose your personal information, to a third party, we will take reasonable steps to notify you of this in advance, provided that it is lawful and reasonable for us to do so.

Legal basis we rely upon to process your personal information

The GDPR sets out numerous grounds upon which we may lawfully collect and process your personal information, including:

• where you have provided us with your consent to do so;
• where we need to perform a contract with you;
• where we are required to comply with the law;
• for payment processing purposes; and
• when processing of your personal information is in our legitimate interests and it’s not overridden by your rights.

Consent

We can collect and process your data if we have your consent. In many circumstances, if we rely on your consent as our legal basis for processing your personal data, you have the right to withdraw that consent, at any time.

Contractual obligations

In many circumstances, we require your personal information to comply with contractual obligations. For example, we collect your identity and contact information when we provide you with our goods or services. If you are unable to provide such information to us, we may not be able to perform the contract we have with you or your business, or enter into a contract with you or your business.

Legal compliance

We may need to collect and process your personal data, if the law requires us to. If you are unable to provide such information to us, we may not be able to perform the contract we have with you or your business, or enter into a contract with you or your business.

Legitimate interests

We will often require your personal information to pursue our legitimate interests, in a way which might reasonably be expected as part of running our business and which does not materially impact upon your rights, freedoms or interests.

Please email us if you require details of the specific legal ground we are relying on to process your personal information.

Your rights over your personal information

You have a number of rights with respect to the personal information that we hold about you. These rights are subject to certain exemptions and differ across the jurisdictions, in which we may operate.

Request access to the personal information that we hold about you

Subject to any applicable exceptions, we will provide you with a copy of your personal information, within the timeframes set out in relevant legislation. If you reside within the EU, then we will do this at no charge, in accordance with the GDPR.

Right to rectification

You have the right to have us rectify any inaccurate information that we hold about you.

Right to erasure

You will, in certain circumstances, have the right to request that we delete or remove your personal information. Whenever you have given us your consent to use your personal information, you have the right to change your mind, at any time, and withdraw that consent. In cases where we are processing your personal information on the basis of our legitimate interests, you can ask us to stop processing your information, for reasons connected to your individual situation. We must then do so, unless we believe that we have a legitimate reason to continue processing your personal information.

Right to data portability

You will, in certain circumstances, have the right to obtain your personal information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer your personal information, to a third party, without any hindrance from us.

Right to object

You will, in certain circumstances, have the right to object to our processing of your personal information. Where personal information is being processed for direct marketing purposes, you have a right to object at any time

Right to withdraw consent

You have the right to withdraw your consent, at any time, for us to process your personal information. We may ask you to verify your identity before responding to such requests.

Rights in relation to automated decision-making and profiling

You will, in certain circumstances, have a right not to be subject to a decision that is based on automated processing, where the decision will produce a legal effect, or a similarly significant effect on you.

To protect the confidentiality of your personal information, we will require you to verify your identity before proceeding with any request. If you have authorised a third party to submit a request to us on your behalf, then we will ask them to prove they have obtained your permission to act on your behalf.

Security of personal information

We may store personal information, both electronically, and in hard-copy form. We are committed to keeping your personal information secure, regardless of the format in which we hold it and we take all reasonable steps to protect your information from misuse, interference, loss, and unauthorised access, modification or disclosure. However, you use our Website at your own risk and we accept no responsibility, whether we are deemed to have been negligent or not, in the event of a security that affects your privacy.

Overseas transfer of personal information

We may transfer your personal information, and have it maintained on computers, outside of your state, province, country or other governmental jurisdiction, where 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.

We will take reasonable steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy, and no transfer of your personal information will take place to any organisation or country, unless there are adequate controls in place, including the security of your personal information.

Disposal of personal information not required

If we hold personal information about you, and we do not need that information for any purpose for which the information may be used or disclosed, we will take reasonable steps to destroy or de-identify that information, unless we are otherwise prevented from doing so by law.

Cookies data and online tracking technologies

We may use cookies, beacons, tags, scripts, and other online tracking technologies (collectively, referred to as Cookies) to collect and use personal information about you and to serve you with Internet-based advertising. For further information about the types of Cookies we use and why, as well as how you can control Cookies, please see our Cookie Policy.

Privacy relating to persons under the age of 16 years

We do not knowingly collect personally identifiable information from anyone under the age of 16. You must not provide us with your personal information, if you are under the age of 16, without the consent of your parent, guardian or educational institution.

Contacting us and complaints

If you have any questions or concerns about our Privacy Policy, or if you wish to lodge a privacy-related complaint, please email our Privacy Officer

Amendments of this Privacy Policy

We undertake to regularly review and update this policy. We therefore reserve the right to amend this Privacy Policy at any time. Should any significant amendments occur, notification will be provided by publication on our website 14 days prior to the changes being implemented (the Notice Period), unless the circumstances of the amendments makes it unreasonable to provide such a Notice Period. Your continued use after the Notice Period has lapsed indicates your consent to be bound by the amended Privacy Policy.

This Privacy Policy was last updated on 23 June 2020.