This Policy tells you how sheIQ Life collects and uses your personal data when you visit our website, interact with us, and buy our goods and services. The Policy governs the online information collection practices of sheIQ Life Pty Ltd (the “Company,”). Specifically, it outlines the types of information that we gather about you while you are using www.sheiqlife.com and websites operated by the Company (collectively, the “Site”), and the ways in which we use this information.
Personal data, or personal information, means any information about you as an individual from which that person can be identified. It does not include any data where the identity has been removed (anonymous data).
We may collect and store a variety of information that you voluntarily supply to us online while using the Site (e.g. while on the Site or in responding via email to a feature provided on the Site).
The Site only contacts individuals who specifically request that we do so or in the event that they have signed up to receive our messaging, attended one of our events, or have purchased one of our products.
Personal data which we collect about you
The Site collects personally identifying information from our users during online registration and online purchasing. Generally, this information includes name and email address for registration or opt-in purposes and name, postal address, and credit card information when registering for our events or purchasing our products. All of this information is provided to us by you.
We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Sign up to receive the sheIQ Life newsletter;
- Make enquiries or request information be sent to you;
- Create an account on our website;
- Order our products or services;
- Ask for marketing information to be sent to you;
- Engage with us on social media;
- Enter a competition, promotion or survey;
- Contact customer services; or
- Leave comments or reviews on our products or services
As you interact with us, including via the www.sheiqlife.com website, we may automatically collect technical data about your equipment, browsing actions and patterns. We may also collect tracking data when you use our Site, or when you click on one of our adverts (including any shown on third party websites).
We may receive personal data about you from various types of third parties, including:
- Technical data and/or tracking data from analytics providers, advertising networks and search information providers;
- Contact, financial and transaction data from providers of payment and fraud prevention services;
- Identity and contact data from data partners; and
- Data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites. We will only use your personal data when the law allows us to do so.
How we use your personal data
Most commonly, we will use your data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you purchase our products, that’s a contract.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, when we carry out fraud screening as part of the check-out process.
- Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
Advertising, marketing and communication preferences
We may use your identity, contact, technical, tracking, usage and profile data to form a picture of what we think you may want or need, or what may be of interest to you. This is how we decide what products, services and offers may be relevant for you and tell you about them. This is what we call direct marketing.
We may carry out direct marketing by email, phone, text or post. For example, you might have the Smart with Life newsletter hit your inbox or a cool promotion land on your door mat.
On our Site, we always try hard to make it really clear what we are doing and what communications your will be sent, whether it’s you deciding to sign up to the Smart with Life newsletter or as part of the purchase journey – and you have the right at any time to change your mind and say no thank you and opt out (but we’d be really sorry to see you go!). The easiest way to manage your preferences or to opt out is to use the manage your preferences or the unsubscribe link at the bottom of the communication.
There are lots of different ways you may see advertisements for sheIQ Life out and about, and not of them are based on using personal data – sometimes they’re simple advertisement placements in traditional print, websites and social media. If you see sheIQ Life advertisements on websites and in social media they may not be specifically directed at you, we might just have bid for the space. Here’s some examples of things we may do that might be specifically directed at you:
- Emails – for example the Smart with Life newsletter;
- Text messages, for example with discount codes;
- Promotions by post, such as great money off shipping offers, or from our trusted partners; and or
- Phone calls to tell you something that might be relevant to you.
Tracking data, and in particular cookies, help us to deliver website and social advertising that we believe is most relevant to you and to potential new customers of sheIQ Life. The cookies used for this purpose are often placed on our Site. This includes remarketing.
Cookies can also tell us if you have seen a specific advert, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts (so we don’t become annoying). Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you don’t read.
Disclosure of your personal data
We may share your personal data with the parties set out below for the purposes set out in this Policy. We may also share your personal data if the law otherwise allows it.
- Suppliers and service providers (such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services);
- Auditors and professional advisers like bankers, lawyers, accountants and insurers; and
- Government, regulators and law enforcement.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow out third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
sheIQ Life uses third party payment processors PayPal to process payments made for products and services via the Site. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards (which are high!). and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them.
Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors. This means that the payment form is either off-site or displayed in a frame on the payment page.
For all program services where monthly payment plans are entered into a form is filled in by you detailing your credit card details. The form details the amount and number of payments that are authorised by you and the form is then stored for further payments to be made.
For PayPal we only store the tokens required to identify the transaction with PayPal, issue refunds and identify transactions made using PayPal.
Whenever we transfer your personal data internationally, we will comply with the applicable data protection law.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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 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 seven years after they stop being customers for tax purposes.
In some circumstances you can ask us to delete your data; see your legal rights below for further information.
Your legal rights
If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:
- The right of access – that’s a right to make what’s known as a ‘data subject access request’ for copy of the personal data we hold about you;
- The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;
- The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);
- The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;
- The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
- The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
Rights in relation to automated decision making and profiling – that’s 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 (see how to contact sheIQ Life about privacy).
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. Alternatively, we may 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 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 and keep you updated.
How to contact sheIQ Life about privacy
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can do this by managing your preferences.