Privacy Policy

Effective Date: 1 June 2018

Insight Spending Planners is an Australian business providing money management coaching services (ABN 49 558 400 362) and is subject to the laws of Australia. Marlene Schmidt is a Certified Spending Planner and sole trader operating under the business name, Insight Spending Planners.

Insight Spending Planners (“us”, “we”, or “our”) operates the www.insightspendingplanners.com website. Residents of the EU may also subscribe to content offered by Insight Spending Planners by providing personal information. We aim to comply with the General Data Protection Regulations (GDPR) to ensure that your information is protected.

This Privacy Policy provides you with details of how we collect, process, use and disclose your Personal Data through your use of our site www.insightspendingplanners.com and as a consequence of your dealings with us. We will not use or share your information with anyone except as described in this Privacy Policy.

We do not knowingly collect any information from anyone under 18 years of age and by providing us with your data you warrant to us that you are over the age of 18 years.

We use your data to provide and improve our website and our services. By using our website, you agree to the collection and use of information in accordance with this Privacy Policy whether or not you have read it.

Data Controller Contact Information

Marlene Schmidt
Parraweena Court
Point Vernon Qld 4655
marlene@insightspendingplanners.com

Definitions

PERSONAL DATA

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA

Usage Data is data collected automatically either generated using the website or from the site infrastructure itself (for example, the duration of a page visit).

COOKIES

Cookies are small pieces of data stored on your device (computer or mobile device).

DATA CONTROLLER

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

DATE PROCESSORS (OR SERVICE PROVIDERS)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT (OR USER)

Data Subject is any living individual who is a client of ours or is using our website and is the subject of Personal Data.

1. Information Collection

We collect several different types of information for various purposes to provide and improve our service to you.

Personal Information We May Collect

We may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). We will only collect the minimum amount of information necessary for us to fulfil our obligation to you.

We may process certain types of Personal Data about you as follows:

1. A name and an email address so we can deliver our newsletter or marketing communications to you – you would be affirmatively consenting to this by providing this to us in our contact or opt-in forms.
2. Billing information including name, address, telephone number and credit/debit card information so that we can process payment to deliver our products or services to you under our contractual obligation.
3. A name and an email address if you complete our contact form with a question. We may send you marketing emails with either your consent or if we believe we have a legitimate interest to contact you based on your contact or question.

Please note that the Personal Data that you are giving to us is voluntary and by you providing this information to us you are giving consent for us to use, collect and process this Personal Data. You are welcome to opt-out or request for us to delete your Personal Data at any time by contacting us at marlene@insightspendingplanners.com.

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 offenses.

Contract Obligations

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 the time.

Other Information We May Collect

Anonymous Data Collection and Use

To maintain our website’s high quality, 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. Your IP address is the number assigned to computers connected to the Internet. 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.

Use of “Cookies”

We may use the standard “cookies” feature of major web browsers. We do not set any personally identifiable information in cookies, nor do we employ any data-capture mechanisms on our website other than cookies. You may choose to disable cookies through your own web browser’s settings. However, disabling this function may diminish your experience on our website and some features may not work as intended.

2. How we collect your data

We collect data about you through a variety of different methods including:

• Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by mail, phone, email or otherwise, including when you:
  • order our products or services;
  • subscribe to our newsletter;
  • request resources or marketing be sent to you;
  • download a document;
  • register for a live or recorded webinar event;
  • make an appointment via an online booking service;
  • enter a competition, giveaway, promotion or survey; or
  • give us feedback.
• Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies
• Social Media platforms such as Facebook/Instagram, Twitter, Pinterest
• Analytics providers such as Google; and
• Contact, Financial and Transaction Data from providers of payment and email automation services such as Paypal and MailChimp.

3. Use of data

We will only use your Personal Data for a purpose for which it was collected or a reasonably compatible purpose if necessary. In the event 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 when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights.

What we do with information we collect

Contact You

We may contact you with information that you provide to us based on these lawful grounds for processing:

1. We may contact you if you give us your clear, unambiguous, affirmative consent to contact you.
2. We will contact you under our contractual obligation to deliver goods or services you purchase from us.
3. Legitimate Interest. We may contact you if we feel you have a legitimate interest in hearing from us. For example, if you sign up for a webinar, we may send you marketing emails based on the content of that webinar. You will always have the option to opt-out of any of our emails.

Process Payments

We will use the Personal Data you give to us in order to process your payment for the purchase of goods or services under a contract. We only use third party payment processors that take the utmost care in securing data and comply with the General Data Protection Regulation (GDPR).

Targeted Social Media Advertisements

We may use the data you provide to us to run social media advertisements and/or create look-alike audiences for advertisements.

Share with Third Parties

We may share your information with trusted third parties such as our newsletter provider in order to contact you via email, our merchant accounts to process payments, and Google / social media accounts in order to run advertisements.

MARKETING COMMUNICATIONS

You will receive marketing communications from us if you have:

• requested information from us or purchased goods or services from us; or
• if you provided us with your details and given consent at the point of entry of your details for us to send you marketing communications; and
• in each case, you have not opted-out of receiving that marketing.

All email sent from us will clearly state who the email is from and provide clear information on how to contact the sender. In addition, all email messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further email communication from us. 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 marlene@insightspendingplanners.com at any time.

Where you opt out of receiving our marketing communications, this will not apply to Personal Data provided to us as a result of a product/service purchase.

EMAILS

If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received online, mail and telephone. This also applies when you register for our website, sign up through any of our forms using your email address or make a purchase on this site.

We are committed to keeping your email address confidential. We do not sell, rent, or lease our subscription lists to third parties, and we will not provide your personal information to any third-party individual, government agency, or company at any time unless strictly compelled to do so by law.

We will use your email address solely to provide timely information from and about Insight Spending Planners.

We will maintain the information you send via email in accordance with applicable laws.
Email is not recognised as a secure medium of communication. For this reason, we request that you do not send private information to us by email. However, doing so is allowed, but at your own risk. Some of the information you may enter on our website will be transmitted securely via a secure medium known as Secure Sockets Layer, or SSL.

4. Service Providers

We may employ third party companies to facilitate our service to you (“Service Providers”) to perform services on our behalf or to assist us in analysing how our website is used.

For example, if it is necessary to provide you something you have requested (like enable a feature such as recurring payments), then we may share your Personal Data with a Service Provider for that purpose. Examples of Service Providers include payment processors, hosting services and content delivery services.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

PAYMENTS

We may provide paid products and/or services and use third-party services for payment processing (e.g. payment processors).

Our third-party payment processors’ use of your personal information is governed by their Privacy Policy. The payment processors we work with are PayPal and eWay. Their privacy policies can be viewed here:

Paypal
eWay

ANALYTICS

We may use third-party Service Providers to monitor and analyse the use of our website.

GOOGLE ANALYTICS

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on our website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit Google Privacy Terms.

MAILCHIMP

The newsletter and marketing emails of Insight Spending Planners are delivered by our third-party service, MailChimp, and contain tracking pixels. MailChimp’s privacy policy is available here.

A tracking pixel is a miniature graphic embedded in such emails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns.

Based on the embedded tracking pixel, Insight Spending Planners may see if and when an email was opened by a data subject, and which links in the email were called up by data subjects.

Such Personal Data collected in the tracking pixels contained in the emails are stored and analysed by the controller in order to optimise the delivery of these emails, as well as to adapt the content of future newsletters/emails to better match your interests.

You can choose to opt-out of our newsletters and marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at marlene@insightspendingplanners.com at any time.

5. Links to other sites

Our website may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

6. Embedded content from other websites

Articles on our website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

7. Legal basis for processing personal data under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Insight Spending Planners’ legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Insight Spending Planners may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it’s not overridden by your rights
• For payment processing purposes
• To comply with the law.

Set out below is a description of the ways we intend to use your Personal Data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your Personal Data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at marlene@insightspendingplanners.com if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out below.

Purpose: To register you as a new client
Type of Data: Identity and Contact
Lawful Basis for Processing: Performance of a contract with you.

Purpose: To manage our relationship with you which will include: 1. Notifying you about changes to our terms or Privacy Policy. 2. Asking you to leave a review or take a survey
Type of Data: Identity, Contact, Profile, Marketing and Communications
Lawful Basis for Processing: Performance of a contract with you 1. Necessary to comply with a legal obligation. 2. Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.

Purpose: To process and deliver services including: 1. Manage payments, fees and charges. 2. Collect and recover money owed to us
Type of Data: Identity, Contact, Financial, Transaction, Marketing and Communications
Lawful Basis for Processing: 1. Performance of a contract with you. 2. Necessary for our legitimate interests to collect fees and/or recover debts owed to us.

Purpose: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of Data: Technical, Usage
Lawful Basis for Processing: Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy.

Purpose: To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of Data: Identity, Contact, Technical
Lawful Basis for Processing: 1. Necessary for our legitimate interests for running our business, network security and to prevent fraud. 2. Necessary to comply with a legal obligation.

Purpose: To enable you to partake in a giveaway, competition or complete a survey
Type of Data: Identity, Contact, Profile, Usage, Marketing and Communications
Lawful Basis for Processing: 1. Performance of a contract with you. 2. Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business.

Purpose: To deliver relevant content and promotional material to you and measure and understand the effectiveness of our marketing
Type of Data: Identity, Contact, Profile, Usage, Marketing and Communications, Technical
Lawful Basis for Processing: 1. Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy. 2. Necessary for our legitimate interests to offer related services and solutions for a fee that will compensate for the amount of work we put into providing free information.

Purpose: To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of Data: Identity, Contact, Technical, Usage, Profile
Lawful Basis for Processing: Necessary for our legitimate interests to develop our products/services and grow our business.

CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at marlene@insightspendingplanners.com.

If we need to use your Personal Data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your Personal Data without your knowledge or consent where this is required or permitted by law.

8. Protecting your data

We are committed to protecting your privacy as an online visitor to our website. We use the information we collect about you to maximise the services that we provide to you. We respect the privacy and confidentiality of the information provided by you and adhere to the Australian Privacy Principles.

You may change your details at any time by advising us in writing via email. All information we receive from our customers is protected by our secure server. Our secure server software encrypts all customer information before it is sent to us. Furthermore, all customer data collected is secured against unauthorised use or access. Credit card information is not stored by us on our servers.

We will use all reasonable means to protect the confidentiality of your Personal Data while in our possession or control. We will not knowingly share any of your Personal Data with any third party other than our Service Providers who assist us in providing the information and/or services we are providing to you. To the extent that we do share your personal information with a Service Provider, we would only do so if that party has agreed to comply with our privacy standards as described in this Privacy Policy. Some of our Service Providers may be overseas and may not be subject to Australian Privacy Laws. Please contact us if you require specific details.

9. Security of data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

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 such data. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Retention of data

Insight Spending Planners will retain your Personal Data only for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable taxation laws), resolve disputes, and enforce our legal agreements and policies.

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and potentially approve any follow-up comments automatically instead of holding them in a moderation queue.

Insight Spending Planners will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our website, or we are legally obligated to retain this data for longer time periods.

In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

11. Transfer of data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Australia and choose to provide information to us, please note that we transfer the data, including Personal Data, to Australia and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Insight Spending Planners will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

12. Disclosure of data

We do not and will not sell or deal in personal or customer information. We may however use in a general sense without any reference to your name, your information to create marketing statistics, identify user demands and assist in meeting customer needs generally.

We may have to share your Personal Data with the parties set out below for the purposes set out above:

• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Authorities who require reporting of processing activities in certain circumstances.

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.

BUSINESS TRANSACTION

If Insight Spending Planners is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different privacy policy.

DISCLOSURE FOR LAW ENFORCEMENT

Under certain circumstances, Insight Spending Planners may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

LEGAL REQUIREMENTS

Insight Spending Planners may disclose your Personal Data in the good faith belief that such action is:

1. required by subpoena, law, or other legal process;
2. necessary to assist law enforcement officials or government enforcement agencies;
3. necessary to investigate violations of or otherwise enforce our Legal Terms;
4. necessary to protect us from legal action or claims from third parties, including you and/or other users; or
5. necessary to protect the legal rights, personal/real property, or personal safety of our business, users, employees, and affiliates.

13. Your data protection rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights with respect to your Personal Data. Depending on the legal basis for processing your Personal Data, you may have some or all of the following rights:

• the right to be informed about the Personal Data we hold about you and how we process it
• the right of access to your Personal Data
• the right to rectification of inaccurate or incomplete Personal Data
• the right to request the removal or deletion of your Personal Data
• the right to restrict the processing of your Personal Data
• the right to be provided with a copy of the Personal Data that you provided to us and use it for your own purposes
• the right to object to our processing your Personal Data
• the right to withdraw your consent at any time where Insight Spending Planners relied on your consent to process your Personal Data.

If you wish to exercise any of the above rights, or you are unhappy with any aspect of how we handle your data, please contact us at marlene@insightspendingplanners.com.

We endeavour to respond to legitimate requests within 30 days. Please note that we may ask you to verify your identity before responding to such requests and we may charge a fee if you refuse to comply with our requirements in these circumstances.

14. Protecting children’s privacy

Even though our website is not designed for use by anyone under the age of 18, we realise that a child under the age of 18 may attempt to access our website. We do not knowingly collect Personal Data from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers. You acknowledge that we do not verify the age of our users nor do we have any liability to do so.

15. Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our website, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

16. Contact us

If you have any questions about our Privacy Policy, please contact us using the information at the top of this Privacy Policy.