At The Breakthrough Year, we are committed to safeguarding and preserving the privacy of our visitors to the best of our ability.
Please read this document carefully to understand how your personal data is collected, used, processed and stored. Please don't hesitate to get in touch at firstname.lastname@example.org if you have any questions.
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 email@example.com.
The Website and its Content is owned by Samantha Bell of Brand It Girl (“Company”, “we”, or “us”). The term “you” refers to the user or viewer of http://branditgirl.com (“Website”) and any products of Brand It Girl, including http://thebreakthroughyear.com.
When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number, credit card information, Website URL, Social Media or other details to help you with your experience. We aim to keep the Confidential Information that you share with us confidential. Please note that we may disclose such Confidential Information if required to do so by law or in the good-faith belief that:
(1) such action is necessary to protect and defend our rights or property or those of our users or licensees;
(2) to act as immediately necessary in order to protect the personal safety or rights of our users or the public; or
We collect information from you when you register on our site, place an order, subscribe to a newsletter, respond to a survey, fill out a form or enter information on our site. Additionally, we will collect information from you if you provide us with feedback on our products or services.
VIEWING BY OTHERS
Note that whenever you voluntarily make your Confidential Information or Other Information available for viewing by others online through this Website or its Content, it may be seen, collected and used by others, and therefore, we cannot be responsible for any unauthorized or improper use of the Confidential Information or Other Information that you voluntarily share.
SUBMISSION, STORAGE, AND SHARING OF PERSONAL DATA
To use our Website or its Content, we may seek personal data including your name, e-mail address, street address, city, state, billing information, or other personally identifying information (“Confidential Information”), or you may offer or provide a comment, photo, image, video or any other submission to us when visiting or interacting with our Website and its Content (“Other Information”). By providing such Confidential Information or Other Information to us, you grant us permission to use and store such information.
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
- To personalize your experience & allow us to deliver the content and product offerings in which you are most interested;
- To improve our website in order to better serve you;
- To allow us to better service you in responding to your customer service requests;
- To administer a contest, promotion, survey or other site feature;
- To quickly process your transactions; and
- To ask for ratings and reviews of services or products.
Your Confidential Information is stored through by us internally or through a data management system. Your Confidential Information will only be accessed by those who help to obtain, manage or store that Information, or who have a legitimate need to know such Confidential Information.
There may be an occasion where we may ask for demographic information such as gender or age, but if you choose not to provide such data and information, you may still use the Website and its Content, but you may not be able to use those services where demographic information may be required.
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible and is hosted on the Squarespace platform.
Your personal information is contained in secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology. All transactions are processed through a gateway provider and are not stored or processed on our servers.
INFORMATION COLLECTED, WHY AND HOW WE PROCESS IT
In running and maintaining our website we may collect and process the following data about you:
- Customer Data - data relating to any purchases of goods and/or services (including The Breakthrough Year memberships and coaching packages) such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details. Brand It Girl, The Breakthrough Year or Samantha Bell processes this data to supply the goods, services and/or memberships 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.
- Communication Data - any communication that you send to Brand It Girl, The Breakthrough Year or Samantha Bell whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. Brand It Girl, The Breakthrough Year or Samantha Bell processes 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 to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- User Data - data about how you use our website and any online services together we engage with you on (including social media) with any data that you post for publication on our website or through other online services. Brand It Girl, The Breakthrough Year or Samantha Bell processes 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 - 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 (for example via a Facebook pixel) 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, to grow our business and to determine our marketing strategies.
- Marketing Data - data about your preferences in receiving marketing from us and our third parties, including your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, 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, and/or membership. This allows us to develop offerings that better help our audience and community and aids us in growing our business and to make informed decisions regarding our marketing strategy.
- Advertising - We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook advertisements or other paid 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 in grow our business and providing our community with quality information. 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).
To use certain features of the Website or its Content, you may need a username and password – this includes, but is not exclusive to passwords for training programs and resource libraries. You are responsible for maintaining the confidentiality of the username and password, and you are responsible for all activities, whether by you or by others, that occur under your username or password and within your account. You agree to notify us immediately of any unauthorized or improper use of your username or password or any other breach of security. To help protect against unauthorized or improper use, make sure that you log out at the end of each session requiring your username and password.
It is your responsibility to protect your own username and password from disclosure to others. We cannot and will not be liable for any loss or damage arising from your failure to protect your username, password or account information. If you share your username or password with others, they may be able to obtain access to your personal information at your own risk.
By using our Website and its Content you agree to enter true and accurate information on the Website and its Content. If you enter a bogus email address, we have the right to immediately inactivate your account.
We will use our best efforts to keep your username and password(s) private and will not otherwise share your password(s) without your consent, except as necessary when the law requires it or in the good-faith belief that such action is necessary, particularly when disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to others or interfering with our rights or property.
We often carry out surveys, quizzes and questionnaires to better understand you (our audience) and the community as a whole. This allows us to build a successful business and serve our community by providing the products, services, membership and free content that you'll benefit from the most. It's important to note that some of the questions we ask may provide us with sensitive data about you. We will also collect sensitive data from you if you join our membership or subscribe to our list - either directly, by requesting a free download or by requesting a ticket to a free event hosted by The Breakthrough Year, Brand It Girl, or Samantha Bell.
We require your explicit consent for processing sensitive data.
Where we are required to collect personal data by law, or under the terms of the contract between 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 goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at that time.
We will only use your personal data for the purpose it was collected for or a reasonably compatible purpose if necessary. Generally the two key reasons will be for communication and to process your payments and deliver goods/service. In the event that we need to use your details for an unrelated or new purpose we will let you know and explain the legal grounds for processing. Your personal details will never be sold, shared or given to another party without your consent. The only exception is that we may process your personal data without your knowledge or consent where this is required or permitted by law.
For more information on this please email us at firstname.lastname@example.org.
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 will not add you to our email list without your consent.
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods, services or memberships or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since opt in.
We use ConvertKit for our email marketing and G Suite for our email service provider. Your personal data and information may be stored on either one of those providers - please see their privacy policies for specific privacy protection information.
You can opt out of receiving marketing emails from us at any time. You can ask us to stop sending you marketing messages at any time by clicking on the unsubscribe link at the bottom of our emails or by emailing us directly at email@example.com.
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 and subscription etc.
You are given the opportunity to unsubscribe to our e-newsletters or updates at any time through the unsubscribe link at the footer of all email communications. You will find this unsubscribe link at the bottom of all email communications. We manage email lists through a list management system called ConvertKit. If you have questions or are experiencing problems unsubscribing, please contact us at firstname.lastname@example.org.
We will not tolerate spam and have an anti-spam policy in place within The Breakthrough Year. As per above, we will provide you with the ability to opt-out of our communications by selecting the unsubscribe link in the footer of all emails.
CALIFORNIA ONLINE PRIVACY PROTECTION ACT
According to CalOPPA, we agree to the following:
- Users can visit our site anonymously, unless they want to access member's only content.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE
Our website and its Content is directed to individuals who are at least 13 years old or older. In compliance with the Children's Online Privacy Protection Act (COPPA), we do not collect any information from anyone under 13 years of age.
ANONYMOUS DATA COLLECTION AND USE
Your IP address is the number assigned to computers connected to the Internet. We may use your IP address to help diagnose problems with our server and to administer the Website by identifying which areas of the Website are most heavily used, and to display content according to your preferences. This is essentially “traffic data” which cannot personally identify you, but is helpful to us for marketing purposes and for improving our services. Traffic data collection does not follow a user’s activities on any other websites in any way. Anonymous traffic data may also be shared with business partners and advertisers on an aggregate basis.
USE OF “COOKIES”
- Understand and save user’s preferences for future visits;
- Keep track of advertisements; and
- Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third party services that track this information on our behalf.
If you turn cookies off, some features will be disabled. It may affect the user’s experience that makes your site experience more efficient and may not function properly. However, you will still be able to place orders.
PRIVACY POLICIES OF OTHER WEBSITES
We have no responsibility or liability for the content and activities of any other individual, company or entity whose website or materials may be linked to our Website or its Content, and thus we cannot be held liable for the privacy of the information on their website or that you voluntarily share with their website. Please review their privacy policies for guidelines as to how they respectively store, use and protect the privacy of your Confidential Information and Other Information.
THIRD PARTY DISCLOSURE
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 and if you have questions about their privacy policies, please contact the third party provider directly.
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites - contact us on email@example.com if any third party provider causes you alarm.
We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users: https://support.google.com/adwordspolicy/answer/1316548?hl=en
We may in the future use Google AdSense advertising on our website.
We process payments on this site via Squarespace. Your payment may also be processed by PayPal or Stripe.
ASSIGNMENT OF RIGHTS
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers
- Government bodies that require us to report processing activities.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets. (Please note at this time, this is not in our foreseeable future).
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.
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a function that requires them to 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 and will notify you and any applicable regulator of a breach if we are legally required to.
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, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
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.
YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to 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.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org to discuss further.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
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 to let you know about the delay.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (http://www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
Please note - we are based in Australia and there may be some time differences and delays. Please allow up to 7 working days for all other enquires and up to 30 days for legitimate change requests.
NOTIFICATION OF CHANGES
Full name of legal entity: Samantha Bell
Address: 6/92 Great Western Highway, Kingswood, 2747
Last Updated: May 21st, 2018