1 WHO ARE WE?
HighPerforming.Coach is the operating name of a company registered in Australia: Maxwell Marketing (Digital) Pty Ltd. This company exists to provide coaching, training and information products that help people launch and run online businesses.
Maxwell Marketing (Digital) Pty Ltd. also engages in other activities for other businesses such as Digital Marketing and online advertising.
2 WHO'S IN CONTROL?
3 WHAT KIND OF DATA IS COLLECTED AND HOW IS IT DONE?
What is non-personal information and how is it collected?
Non-personal information is information that cannot identify you. If you visit this web site to read information, such as information about one of our services, we may collect certain non-personal information about you from your computer’s web browser. Because non-personal information cannot identify you or be tied to you in any way, there are no restrictions on the ways that we can use or share non-personal information.
What is personal information and how is it collected?
Personal information is information that identifies you as an individual, such as:
• your full name;
• your mailing address and postcode;
• your email address;
• your telephone number
• your fax number;
• your password;
• your credit card information;
• your digital marketing preferences.
• Your date of birth
• Your age
• Your gender
We may collect personal information from you in a variety of ways:
• We collect data that you send us in a filled application form;
• We collect data about transactions that you conduct with us, our affiliates, or other parties included, as stated in the contract we have signed with you;
• We collect information about you in support of a transaction, such as credit card information;
• We collect data that you voluntarily provide us with data via this website - you have the opportunity to send us personal information about yourself, to elect to receive particular information, to purchase access to one of our products or services, or to participate in an activity and data about those activities are stored;
• We collect information about how you use digital marketing tools provided by us, including information about all accounts on social networks that are opened and managed by HighPerforming.Coach on behalf of your company. This includes your viewing history, IP addresses, device identifiers, information about how long you have stayed on certain pages or what pages you have clicked on (Behavioural Data). You can find more detailed information about this in our Cookies Policy.
• We also collect some data about you from third parties (Third Party Data). This includes:
Data provided by other companies who have obtained your permission to share data with us, such as advertisers or other companies you have collaborated with; and or reputable third party data pairing providers, that will be specifically named in the contract signed between us and you or your company. The data we obtain from these parties will be collected through publicly available records such as the electoral roll, or, with your consent, from surveys or other brands and companies that you engage with. This data also includes information that we will collect through surveys and forms that you collect from your clients and followers via your social networks accounts managed by us (Survey Data). This data may include data such as:
▪ (a) Basic demographic information (for example, age and gender)
▪ (b) Regional location
▪ (c) Household status (for example, owning or renting a property)
▪ (d) Household makeup and composition (for example, the number of people in the household)
▪ (e) Financial status and information about life stage (for example, if subject is married or have children)
▪ (f) Media habits (for example, which newspapers or TV channels subjects prefer)
▪ (g) High level purchasing behaviours and personal interests (for example, the hobbies subject have or how often they like to eat out)
▪ (h) Credit information.
• We also collect anonymised publicly available information from social networking sites such as Facebook, Twitter and Instagram - for example likes, shares, tweets and posts about you or your company. This information is provided to us by a third party and is fully anonymised so we cannot see who has posted the information. This information is used for internal analysis purposes;
• We also log and use information about any service errors or interruptions that you have experienced in order to help us create fixes and to make technical improvements to your accounts.
4 ARE COOKIES OR OTHER TECHNOLOGIES USED TO COLLECT PERSONAL INFORMATION?
A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you register with us, a cookie helps HighPerforming.Coach to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same HighPerforming.Coach website, the information you previously provided can be retrieved, so you can easily use the features that you customized.
A web beacon is a small graphic image that allows the party that set the web beacon to monitor and collect certain information about the viewer of the web page, web-based document or e-mail message, such as the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to and the time the web beacon was viewed. Web beacons can be very small and invisible to the user, but, in general, any electronic image viewed as part of a web page or e-mail, including HTML based content, can act as a web beacon. We may use web beacons to count visitors to the web pages on the web site or to monitor how our users navigate the web site, and we may include web beacons in email messages in order to count how many messages sent were actually opened, acted upon or forwarded.
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the HighPerforming.Coach websites you visit.
5 HOW DOES HighPerforming.Coach USE COLLECTED DATA?
HighPerforming.Coach may keep and use collected data from or about you for following purposes:
• To provide you with access to this website or other products or services
• To respond to your requests, complaints or comments that you have and to make sure that these are appropriately dealt with (for example when you contact Client Enquiries on our website);
• To provide you with recommendations for future activities, based on Behavioral data and the Third party data collected from your partners and clients;
• To bill you for products/services you purchased (by using your credit card data);
• To provide ongoing service and support (via your email, and based on Voluntary data and Survey data provided by you through our website);
• To manage your accounts on social networks and digital marketing tools that are created or managed by us, which means that we will use Behavioral Data, Voluntary data and Survey data from you and your clients to help us monitor and analyse your digital marketing position on the market;
• To contact you with information that might be of interest to you, including information about products and services of ours and of others; This means that your personal data, Behavioral Data, Voluntary data and Survey data will be used for creating and sending personalised advertisements to you (and your clients, but only if you opt for this service);
• To ask for your opinion about our products or the products of others, for record keeping and analytical purposes (for example, to improve and customize our services for you);
• To analyse your competitors and compare statistic (for example, to compare your company with competitors participating in a competition; these pieces of information could be found in Competition data);
• To archive data that may be of historical or statistical value and to use this data in the future for internal purposes or to allow third parties access to this data for research purposes, for example if someone is writing a book and the data we hold in our archives is useful for that book. Occasionally this may include copies of Voluntary Data that you have provided on public areas of our website. We will only ever capture personal data that has already been made publicly available in this way and for these purposes. Where possible, when the sites are archived we anonymise or remove personal data;
• To help us understand what type of content you and your clients like and to share with you so that you could estimate how effective the advertising of your company is. For this purpose we use aggregated and anonymised data, which does not enable you or any other client of yours to be identified;
• To research, develop and improve programs, products, services and content of HighPerforming.Coach;
• To protect our rights or property, or to protect someone’s health, safety or welfare, and to comply with a law or regulation, court order or MoreCommittedClients legal process.
Additionally, we would like to point out that personal information that we collect on our website online may be combined with information you provide to us through other sources. We may also remove your personal identifiers (your name, email address, social security number, etc). In this case, you would no longer be identified as a single unique individual. Once we have de-identified information, it is non-personal information and we may treat it like other non-personal information.
6 DOES HighPerforming.Coach SHARE PERSONAL INFORMATION WITH OTHERS?
We will not sell, exchange or publish your personal information, except in conjunction with a corporate sale, merger, dissolution, or acquisition that is confirmed by you or your company to us. For some sorts of transactions, in addition to our direct collection of information, our third party service vendors could be:
• Credit card companies,
• Service providers who help us to manage our Client Enquiries process,
• Companies that are supporting us in managing customer database and their online accounts,
• Marketing and advertising agencies that we collaborate with on your behalf,
• IT companies that are managing our online applications and tools and ensure that they are secure.
The companies who may provide services listed above may collect personal information directly from you to assist you with your transaction. We do not control how these third parties use such information, but we do ask them to disclose how they use your personal information before they collect it. We will always notify your company before we share your data with these third parties and ask for your explicit consent to do so.
We may cooperate with law enforcement authorities in investigating and prosecuting web site visitors who violate our rules or engage in behavior, which is harmful to other visitors (or illegal). We may disclose your personal information to third parties if we feel that the disclosure is necessary to protect our rights or property, protect someone’s health, safety or welfare, or to comply with a law or regulation, court order or other legal process. As discussed in the section on cookies and other technologies, from time to time we may allow a third party to serve advertisements on this web site.
7 HOW IS PERSONAL INFORMATION USED FOR COMMUNICATIONS?
We may contact you periodically by email, mail or telephone to provide information regarding programs, products, services and content that may be of interest to you. In addition, some of the features on this web site allow you to communicate with us using an online form. If your communication requests a response from us, we may send you a response via email. The email response or confirmation may include your personal information. We cannot guarantee that our emails to you will be secure from unauthorized interception.
At any point in time, you may decide to opt out from the communication with us that includes using your personal information. You can do this by clicking on the ‘unsubscribe’ link at the bottom of all our email communications or by sending us an email to help@HighPerforming.Coach and you will receive a questionnaire within 24h, to choose which specific notifications you would like to stop receiving. From the moment you send us this questionnaire filled in, it will take 48 hours for changes to take effect.
8 WHAT IS OUR LEGAL BASIS FOR USING YOUR DATA?
According to GDPR, we are obliged to explain you the legal basis that we rely on to when we process your personal data for the purposes that we have notified to you.
HighPerforming.Coach will process all personal data lawfully, fairly and in a transparent manner. If we process personal data of you, your company or your clients, it will always be compliant with one of the following six lawful basis:
1) Consent: You and your client gave clear consent for processing of your personal data to us, for one of the specific purposes listed in chapter 2 of this Policy.
2) Contract: You and HighPerforming.Coach have signed the contract that requires from us to perform a service which includes processing of your data; or you asked us to perform a certain service including this process before signing the contract.
3) Legal obligation: If necessary, we will process the data provided by you or your clients to comply with the law (including, but not limited to, Consumer protection law).
4) Vital interests: We will process data provided by you or your clients if it is necessary to protect someone’s life. It is highly unlikely to apply this rule, except in cases when emergency medical treatment is needed.
5) Public task: The processing of your data must be done if it is needed for performing a task in the public interest and the task or function has a clear basis in law, like in the case of the administration of justice, exercising a function of: House of Parliament, a person by an enactment or rule of law, the Crown, a Minister of the Crown or a government department, or an activity that supports or promotes democratic engagement.
6) Legitimate interests: We will process data provided by you and your clients to make sure that we provide you relevant digital marketing service, to improve it and customize it according to your preferences and deliver it to you in an optimal way.
9 HOW IS PERSONAL INFORMATION SECURED?
We have implemented generally accepted standards of technology and operational security in order to protect personally-identifiable information from loss, misuse, alteration, or destruction.
Only authorized personnel and third party vendors have access to your personal information, and these employees and vendors are required to treat this information as confidential. All of these service providers must guarantee that the processing of your data is in compliance with the requirements of the GDPR and rules set by this Policy, which is always checked before signing of the contract between HighPerforming.Coach and third parties.
10 YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA
This section applies regardless of your location. In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
• Breach Notification. According to this Policy, if a data breach happens, with a likely “risk for the rights and freedoms of individuals”, your company will be notified about it “without undue delay”, within 72 hours from the moment HighPerforming.Coach becomes aware of the breach.
• Right of access and portability. The right to obtain access to and to receive your personal information that are saved within our base, under “Client Account settings”. These data can be accessed on your request at any time, but request must be written and addressed to: help@HighPerforming.Coach
• Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete. This means that you may ask the contact person (appointed to you in your contract), at any time, to organize update or correction of your personal data in our database.
• Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed. For example, after a digital marketing campaign is completed, you may opt for erasure of relevant personal information given by you or your clients.
• Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
• Right to object. The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing. This includes all of your personal data and the right can be exercised in relation to any of the purposes we are using you data for, in accordance with this Policy.
We will respond to any requests related to your rights as soon as we can and no later than one month from receiving your request and any necessary proof of identity or further information. If your request is particularly difficult or complex, or if you have made a large volume of requests, we may take up to three months to respond. If this is the case we will let you know as soon as we can and explain why we need to take longer to respond.
Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
11 HOW CAN A USER ACCESS, CHANGE, AND/OR DELETE PERSONAL DATA?
You may access, correct, update, and/or delete any personally-identifiable information that you submit to the website. You may also unsubscribe from mailing lists or any registrations on the website. To do so, please either follow instructions on the page of the web site on which you have provided such information or subscribed or registered or contact us at help@HighPerforming.Coach.
12 HOW LONG DO WE KEEP YOUR DATA FOR?
HighPerforming.Coach keeps all your personal data for as long as you are using some of our services and have access to digital marketing tools or accounts created or managed by us. You can close your accounts at any time by sending a request by email to help@HighPerforming.Coach. If you do this, we will anonymise all your Account Data as soon as we can. All other information about you, such as Behavioural Data, will also be fully anonymised.
We may need to keep your data after account closure for limited purposes, for example if we need your data in order to respond to any complaints or claims that you make. If this is the case, we will only keep the data for as long as we need to in order to fulfil those purposes.
If your account is inactive for a period of one year, we will send you a reminder email to remind, to check if you would like to continue using your account. If you still do not use your account, we will send a further reminder email before deleting your account and anonymising your personal data as set out above.
Any Voluntary Data, Behavioral Data, Survey data or Competitor data you submit to us by any of the ways listed in chapter 2 of this Policy, will be retained for a period of two years from submission, after which it is anonymised.
This site contains links to other sites that provide information that we consider to be interesting. HighPerforming.Coach is not responsible for the privacy practices or the content of such websites.
14 PUBLIC DISCUSSIONS
This site may provide public discussions on various business valuation topics. Please note that any information you post in these discussions will become public, so please do not post sensitive information in the public discussions. Whenever you publicly disclose information online, that information could be collected and used by others. We are not responsible for any action or policies of any third parties who collect information that users disclose in any such forums on the web site. HighPerforming.Coach does not agree or disagree with anything posted on the discussion board. Also remember that you must comply with our other published policies regarding postings on our public forums.
15 CHILDREN’S PRIVACY
HighPerforming.Coach will not intentionally collect any personal information (such as a child’s name or email address) from children under the age of 13. If you think that we have collected personal information from a child under the age of 13, please contact us.