Last Updated, 19 December 2023
We at Empower Consulting Services PTY LTD (ABN 78636530964) have created this privacy policy (this “Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy applies to our information collection and use practices in connection with: (i) our websites, including, without limitation caromonroy.com and academy.caromonroy.com (the “Websites”); and (ii) the information you provide to us offline, including, without limitation, via phone and email.
Description of Users and Acceptance of Terms
This Privacy Policy applies to visitors to the Websites, who view only publicly-available content (“Visitors”), and users who register with us (“Registered Users”) and wish to purchase a product or service through one of our Websites.
By visiting any of our Websites, Visitors are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use.
By registering with us and purchasing a product or service through one of our Websites, each Registered User is agreeing to the terms of this Privacy Policy and the accompanying Terms of Use.
By providing us information offline, you are also agreeing to the terms of this Privacy Policy.
Capitalised terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use and the Terms and Conditions of Purchase.
How to Contact Us Regarding This Policy
If you have any concerns or complaints about the manner in which your personal information has been collected, used or disclosed by us, we have put in place an effective mechanism and procedure for you to contact us so that we can attempt to resolve the issue or complaint.
We can be e-mailed at support@caromonroy.com, cm@caromonroy.com and dr@caromonroy.com and we will then attempt to resolve the issue as soon as possible.
We recommend that you keep this information for future reference.
This section outlines the types of information we collect or receive, as well as the intended purpose behind the collection and utilisation of such data.
- Contact Information Collection and Use
When you choose to engage with us, such as signing up for newsletters, participating in surveys, enrolling in classes, enrolling in free webinars, making product, service or webinar purchases, we may request specific details, referred to as “Contact Information.” This may include your name, address, email address, social media details and phone number. The Contact Information is crucial for delivering the requested products or services and for communicating with you regarding current and future offerings through direct marketing.
- Order Information
When you place an order, you are required to furnish specific details about the products and services you intend to acquire. This information is referred to as “Order Information.” The primary purpose of collecting Order Information is to facilitate the fulfilment of your order.
- Billing Information
For product or service purchases, additional details, beyond Personal Information and Order Information, are needed. This set of information, termed “Billing Information,” includes debit card numbers, credit card numbers, expiration dates, billing addresses, activation codes, and similar data. The collection and processing of Billing Information are handled by our third-party payment processor, acting as our agent (refer to “Onward Transfers to Third Parties”). It’s important to note that we do not directly obtain or process any Billing Information.
- Other Information
In addition to the above information, we may collect supplementary data, collectively termed as “Other Information.” This category encompasses:
a. Information Voluntarily Provided by You:
Additional details that you choose to disclose voluntarily, such as household income range, gender, product and service preferences, obtained through means like surveys and or one on one sessions. This information does not personally identify you.
b. Information from Your Activity:
Automatically collected data during your use of the Websites, including IP addresses, browser type, referring and exit pages, URLs, date and time, duration of page visits, and device information.
c. Information from Cookies:
Data collected through “cookie” technology, where small packets of data are stored on your computer’s or mobile device’s hard drive to enhance your browsing experience. We use both session cookies (expire upon closing the web browser) and persistent cookies (remain until deletion) for data collection.
d. Third-Party Analytics:
We employ third-party analytics services, such as Google Analytics, to assess your use of the Websites. These services use cookies and other technologies to analyze and provide us with data related to website and mobile usage. By accessing and using the Websites, you consent to the processing of data by these analytics providers as outlined in this Privacy Policy. Opting out of these services may impact the full functionality of the Websites.
We utilize the following analytics providers to enhance our understanding of user experiences. Please note that this list may be subject to change as we refine our approach to user analytics. We are committed to updating this information diligently. You can explore the provided links to learn more about each provider and, if available, find instructions on how to opt-out from their analytics collection:
For Google Analytics, please visit: https://www.google.com/analytics
For Vimeo, please visit: https://vimeo.com/privacy
For MarcoPolo, please visit: https://www.marcopolo.me/privacy-policy/
e. From Other Sources:
We may also gather information from external sources or receive data from third parties, including platforms such as Facebook, LinkedIn and/or other social media sites. This additional information broadens our understanding and helps us enhance the quality of our services.
Information Collected by or Through Third-Party Advertisers/Remarketers:
We may share additional information, termed “Other Information,” with third parties, including advertising and remarketing providers or other brand partners. This sharing is intended to personalise and enhance our understanding of your interaction with ads or other content. Third parties may employ technologies such as cookies, pixel tags (web beacons or clear gifs), or other methods to collect Other Information. This information is used to customise, target (behavioural, contextual, retargeting, and remarketing), analyse, report on, and manage advertising campaigns or other initiatives.
For instance, when a browser visits a site, pixel tags enable us and these third parties to identify specific cookies stored within the browser, helping us understand which ads or content lead a user to a particular site. Additionally, we may receive Other Information from these third parties, including advertising identifiers, IP addresses, and post-conversion data, through their service providers.
Below is a list of advertising/remarketing providers that we currently use. However, please be aware that this list may change based on our campaigns, and we are committed to updating it diligently. Utilise the provided links to gain more insights about each provider and, if available, discover how to opt-out from their targeted ads or other personalisation features. It’s important to note that opting out may not necessarily exempt you from all advertising or content; you may still receive generic ads or content.
For Facebook, please visit: http://www.facebook.com/about/privacy
For LinkedIn, please visit: https://www.linkedin.com/legal/privacy-policy
For Google, please visit: https://support.google.com/ads/answer/2662922?hl=en
Information Not Covered by This Privacy Policy
You have the option to post and/or share information, including comments, utilising forums, and other similar features provided by the Websites. It’s important to note that NONE of the information you submit using these features is protected by this Privacy Policy. THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION (INCLUDING PERSONAL INFORMATION) THAT YOU PROVIDE USING ANY SUCH FEATURES. All information shared through these features is considered public information and may be viewed, collected, or used by any user of the Websites.
If you choose to post and/or share information on our Websites through your Facebook account, or any other social media platform, please be aware that such information will be subject to each social media privacy policy. Your interactions and shared content on the Websites through social media are governed by the terms and conditions outlined in each social media privacy policy.
Aggregate Data
As part of our continuous commitment to gaining insights into our visitors, customers, and the performance of our products and services, we may analyse Order Information and Other Information in aggregate form. This analysis helps us operate, maintain, manage, and enhance the Websites and/or our products and services. It’s important to note that this aggregate information does not identify you personally.
We may share this aggregated data with our affiliates, agents, and business partners. Furthermore, we reserve the right to disclose aggregated user statistics to describe our products and services to current and prospective business partners and other third parties for various lawful purposes. This sharing of information is done in a manner that ensures individual identification remains confidential.
Additional Uses
The information gathered in accordance with this Privacy Policy serves various purposes, including:
Provision of Services:
We use the collected information to deliver our services, ensuring the fulfillment of Orders and the effective administration of rewards and promotional programs.
Website Maintenance and Enhancement:
Information is utilised to maintain and improve the functionality of our Websites and services, ensuring an optimal user experience.
Feedback Solicitation:
We may use the data to seek your feedback, facilitating continuous improvement and customization of our offerings.
Communication about Products and Services:
Information collected may be employed to inform you about our products and services, as well as those offered by our third-party marketing partners.
This ensures that we not only meet your expectations in delivering services but also keep you informed about relevant updates and offerings aligned with your preferences.
Business Transfer
In the event of a merger, dissolution, or a comparable corporate occurrence, or the sale of all or a substantial portion of our assets, it is anticipated that the information we have collected and/or received, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. These transfers will be conducted in adherence to our commitments regarding the privacy and confidentiality of such personal information, as outlined in this Privacy Policy. Your personal information remains safeguarded in accordance with the terms established herein, even in the context of significant corporate changes or asset transfers.
Disclosures to Public Authorities
In specific circumstances, we may need to divulge personal data in response to lawful requests made by Australian public authorities, particularly to fulfill national security or law enforcement obligations. Additionally, we may disclose personal information to other third parties when mandated by government authorities or obligated by Australian law or regulations. This includes, but is not limited to, compliance with court orders and subpoenas.
Accessing and Modifying Personal Information, and Communication Preferences
If you wish to access, modify, or verify the processing of your personal information, please send a request to support@caromonroy.com. We will promptly confirm whether we are processing your personal information and provide the data to you within a reasonable timeframe. You possess the right to rectify, amend, or erase inaccurate personal information or data processed in violation of this Privacy Policy. Please note that a non-excessive fee may be required to cover our expenses in responding to your request. We appreciate your patience as we work to address your inquiries and requests.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Information You Share on Public Forums
We currently feature, or may in the future, feature public forums such as message boards, web logs, webinars, classes, telephone conferences, coaching calls, user comments, chat rooms, and similar activities collectively referred to as “Public Forums.” Participants in these forums have the option to voluntarily post and share information. It’s important to note that NONE of the information provided through Public Forums or these features is safeguarded by this Privacy Policy, including any personal information. THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION (INCLUDING PERSONAL INFORMATION) THAT YOU PROVIDE USING ANY SUCH FEATURES. ALL SUCH INFORMATION IS PUBLIC INFORMATION AND MAY BE VIEWED, COLLECTED, USED, MODIFIED, AND/OR DISCLOSED FOR ANY PURPOSE BY US, ANY USER OF THE PUBLIC FORUM, AND THE PUBLIC.
We strongly advise you to carefully consider before disclosing any information in any Public Forum, as it becomes public information and may be accessible, collected, utilised, modified, and disclosed by various entities, including us, other users of the Public Forum, and the general public.
How We Protect the Information
We take commercially reasonable measures to protect the Information from loss, misuse, and unauthorised access, disclosure, alteration, or destruction. These measures take into consideration the inherent risks associated with data processing and the nature of such data. Our efforts are conducted in compliance with applicable laws and regulations.
It is important to understand, however, that while we take substantial steps to enhance security, no security system is entirely impenetrable. We cannot provide an absolute guarantee regarding the security of our databases. Furthermore, we cannot assure that the Information you supply will not be intercepted during transmission to and from us over the Internet. Specifically, please be aware that email communication with the Websites may not be entirely secure. Therefore, exercise caution when determining the type of information you choose to send to us via email.
Retention of Personal Information
We will retain your personal information, in a form that identifies you, only for the duration necessary to fulfill the purpose(s) for which it was initially collected, as outlined in this Privacy Policy, subsequently authorized, or as permitted under applicable law. Once the original purpose(s) have been fulfilled, we will take measures to appropriately dispose of or anonymise the information, ensuring compliance with privacy and data protection regulations.
Important Notice to Non-Australian Residents
Please take note that the Websites and their servers are managed in Australia. If you are situated outside of Australia, it’s important to be aware that any information provided to or collected by us, including personal information, will be transferred from your country of origin to Australia. Data Privacy Framework Principles, your decision to provide such data to us or permit us to collect such data through our Websites signifies your consent to this data transfer.
Children
We do not intentionally collect personal information from individuals under the age of 18 through the Websites. If you are under 18, please refrain from providing any personal information. We encourage parents and legal guardians to supervise their children’s Internet activities and reinforce our Privacy Policy by instructing their children not to disclose personal information on the Websites without their permission. If you have reason to believe that a child under the age of 18 has provided personal information to us, please contact us, and we will make reasonable efforts to promptly delete that information from our databases.
External Websites
The Websites may feature links to third-party websites. We do not have control over the privacy practices or content of our business partners, advertisers, sponsors, or other websites to which we provide links. Consequently, we are not accountable for the content or privacy policies of those third-party websites. It is advisable to review the pertinent third-party privacy policy and terms of use when visiting any other websites.
Changes to this Privacy Policy
This Privacy Policy is effective as of the date indicated at the top of this document. We reserve the right to modify this Privacy Policy periodically. If you access the Websites and/or utilise our services after such modifications have been made, you are considered to have accepted these changes. It’s important to note that, in accordance with applicable law, our use of the Information is bound by the Privacy Policy in effect at the time of information collection. We recommend checking this Privacy Policy regularly for updates.