Privacy Policy
1 General
1.1 BAM Digital Pty Limited ACN 616 356 588 trading as She Serves (She Serves, we or us) recognises that your privacy and the protection of your personal information is important to you. This policy sets out how we collect, use, disclose and secure your personal information. It also sets out your rights to access and correct your personal information held by us.
1.2 At She Serves, we take our privacy obligations seriously and are committed to ensuring that we handle personal information in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Privacy Act) and other data protection legislation as appropriate under this Privacy Policy.
1.3 This policy covers all of our business activities, including:
(a) this website, our social media accounts and our apps; and
(b) our products and services, including our business and marketing ebooks, online courses, live events and seminars, coaching and consulting services and community membership products and services.
1.4 Our business activities are not intended for children and we do not knowingly collect data relating to children.
2 What is personal information
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
3 Collection of your personal information
3.1 We will usually collect your personal information directly from you. In certain circumstances, we may also collect your personal information from third parties (such as service providers or partners), where you have consented to this.
3.2 We usually collect personal information in the following ways:
(a) directly from you via our website, social media accounts and apps, or by telephone, email or in person;
(b) if you use or purchase our products or services, or attend our events;
(c) through your other dealings with us, including your enquires, feedback, questions, complaints, or employment applications;
(d) if you enter or complete one of our competitions, offers or surveys;
(e) from third party service providers, where you consent to this;
(f) from publicly available sources of information;
(g) from government and other agencies, where necessary depending on the nature of our relationship (e.g. from credit reporting agencies); and
(h) via any other method permitted by law and where you have given your consent.
3.3 The types of information we collect will depend on the nature of our relationship with you and may include your:
(a) name, address, email address, phone number, gender, occupation and age;
(b) educational background;
(c) image;
(d) social media identifiers;
(e) financial details; and
(f) other personal information, as necessary.
3.4 You do not need to give us personal information, but if you don’t, we may not be able to provide you with products or services, or allow you to participate in an advertised activity.
3.5 We will not collect personal information in a way that would be unlawful or where such information is unnecessary or unrelated to our business activities.
4 Sensitive information
4.1 We do not actively collect sensitive information such as information about your racial or ethnic origin, political opinions, criminal history, religious or philosophical beliefs, trade union membership, sexual orientation or health.
4.2 We will only collect sensitive information if you have given your consent for us to do so and the information is reasonably necessary for us to carry out our functions or activities, or as otherwise permitted under the Privacy Act.
4.3 If we hold any sensitive information about you, that information will only be used and disclosed by us for the purpose that you provided it for.
5 Use and disclosure of your personal information
5.1 We use and disclose the personal information we collect for our business purposes and to fulfil our legal obligations. This may include the following:
(a) to provide you with information about our products and services, including information of a marketing nature;
(b) to send you information about special offers, publications and newsletters;
(c) to verify your identity;
(d) to provide you with the products and services you request;
(e) to facilitate your entry and participation in competitions, promotions and offers;
(f) to process employment applications;
(g) to improve and manage our business, products and services;
(h) to customise your experience when using our websites, apps, products and services;
(i) to address and answer any enquiries or questions that you might have; and
(j) in accordance with applicable laws, including the Australian Privacy Principles.
5.2 We may disclose your personal information to our employees and third party service providers, as we deem necessary to enable our business activities and to facilitate our dealings with you. Service providers we may disclose personal information to include:
(a) legal and other advisors;
(b) promotional agencies;
(c) website and database developers;
(d) cloud service providers;
(e) membership community hosting providers;
(f) sales and ordering platforms;
(g) payment processors;
(h) CRM and marketing tools providers;
(i) platforms that host our online courses and live videos; and
(j) web hosts
6 Direct marketing
Unless you opt out, we may use your personal information to inform you about products, services and special offers by post, telephone or any form of electronic communication. We may also contact you on behalf of external business partners about particular offerings that may be of interest to you unless you opt out. In those cases, your personal information will not be transferred to the third party.
7 Anonymity
You may, in some circumstances, have the option of not identifying yourself or using a pseudonym when you deal with She Serves, such as if you are making a general enquiry about us. However, if you choose not to provide your personal information, we may not be able to provide you with a product, program or service you request.
8 Cookies and analytics
8.1 A cookie is a small file which asks permission to be placed on your computer's hard drive. The cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs and preferences by collecting and remembering information about you.
8.1.1 We use cookies to provide our website and to identify which pages are being used and how you use them. This helps us analyse information about web page traffic and improve our website by tailoring it to your needs. A cookie does not give us access to your computer or any information about you, other than the data you provide to us.
8.1.2 We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.
You can find more information about the individual cookies we use and the purposes for which we use them below:
Cookie originator: Facebook
Purpose: Marketing
More information: https://www.facebook.com/policies/cookies
Cookie originator: Squarespace
Purpose: Functional and required cookies to operate the site
More information: We rely on third party provider Squarespace to provide certain functionality on the website, and full details of their cookies are set out: https://support.squarespace.com/hc/en-us/articles/360001264507-The-cookies-Squarespace-uses
Cookie originator: Circle App
Purpose: Functional and required cookies to operate certain app function
More information: We rely on Circle to provide certain chat functionality, and details of their cookies are set out https://app.circle.so/cookie-policy
Cookie originator: ClickFunnels
Purpose: Functional and analytics cookies to operate sales pages
More information: We rely on ClickFunnels to support pages which enable you to purchase items. Details of their cookies, including Google Analytical cookies are available: https://www.clickfunnels.com/privacy-policy
Cookie originator: Kajabi
Purpose: Functionality and analytics cookies for content
More information: We use Kajabi apps to provide some of our content – these rely on various functional, advertising and analytical cookies as set out: https://kajabi.com/policies/cookie-notice
Cookie originator: Stripe
Purpose: Functionality and analytics cookies
More information: Our payment services are provided by Stripe, whose privacy notice is available at: https://stripe.com/en-gb/privacy
Cookie originator: Zoom
Purpose: Functionality and analytics
More information: Online conferencing facilities are provided via Zoom, who have their own privacy notice, and details of the relevant cookies are available at: https://explore.zoom.us/en/cookie-policy/
Cookie originator: ActiveCampaign
Purpose: Functionality, performance, analytics and marketing
More information: We use ActiveCampaign the support marketing activities and functionality Information on their cookies is at : https://www.activecampaign.com/legal/cookie-policy
Cookie originator: Baremetrics
Purpose: Functionality and analytics cookies
More information: We rely on Baremetrics to notify customers of failed payments for subscriptions and payment plans, details of their cookies are set out https://baremetrics.com/privacy
8.2 You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. This may, however, prevent you from using the full capabilities of the website.
8.3 We may also use third-party analytics tools, including those provided by Facebook and Google Analytics, to provide us with information about how you use our website. These analytics tools may place or access cookies on your device, which allows them to monitor your web browsing activity. More information regarding the services provided by Facebook and Google, including their privacy policies and information about opting out is available on their websites:
Facebook: https://www.facebook.com/policies/cookies
Google: https://policies.google.com/technologies/partner-sites
9 Storage and security of your personal information
9.1 She Serves may hold your personal information in a number of different formats, including software programs (located both onsite and offsite, including in the cloud), databases, filing systems and in offsite backup storage. She Serves currently uses hosting services provided by third parties, including Circle, ClickFunnels, Stripe, ActiveCampaign, Kajabi, Squarespace and Baremetrics.
9.2 She Serves is committed to ensuring that the information you provide is secure and we take all reasonable steps to protect your personal information from loss, unauthorised access, modification, disclosure or misuse. However, we cannot ensure the security of any information that you transmit to us over the internet and you do so at your own risk.
10 Disclosure of personal information outside Australia
10.1 We may disclose your personal information to overseas recipients. For the purposes of storing and backing up data, we are likely to disclose your personal information to overseas recipients in the United States and/or the United Kingdom.
10.2 If we disclose your personal information to an overseas recipient, we will take reasonable steps before disclosure to ensure that the overseas recipient will not breach relevant data protection legislation.
11 Privacy Rights for non-Australian visitors
11.1 She Serves recognizes that if you are accessing our website and services from the UK and/or an EU country, you may have additional legal rights under relevant consumer protection laws in those jurisdictions. To meet these requirements, we have the following additional provisions and notices, which only apply to visitors who are resident in either the UK or an EU jurisdiction where She Serves is controller and responsible for your personal information under the relevant laws being either General Data Protection Regulation ((EU) 2016/679) (UK GDPR) and/or the Data Protection Act 2018 (DPA 2018) as appropriate, collectively Data Protection Laws.
11.1.1 Our purpose for processing your personal information is as set out in clause 5.1 of this Privacy Policy;
11.1.2 Personal information, or personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data);
11.1.3 She Serves do not actively collect special category data (as defined in Data Protection Law) other than as specified under clause 4 of this Privacy Policy;
11.1.4 She Serves relies on lawful bases under Data Protection Law to process your personal information. Typically, the lawful basis replied upon by She Serves to process your personal information with be legitimate interests or performance of a contract, as set out below. However, note that we may process your personal information under more than one lawful ground depending on the specific purpose for which we are using your information. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate:
Purpose/Activity under clause 5.1: to provide you with information about our products and services, including information of a marketing nature
Type of data: Contact information provided on the site
Lawful basis for processing including basis of legitimate interest: In anticipation of entering into a contract with you for our services, and our legitimate business interests in promoting our services
Purpose/Activity under clause 5.1: to send you information about special offers, publications and newsletters
Type of data: Contact information provided on the site
Lawful basis for processing including basis of legitimate interest: Our legitimate business interests in promoting our services
Purpose/Activity under clause 5.1: to verify your identity
Type of data: We may check with third party websites to confirm your identification, or payment method
Lawful basis for processing including basis of legitimate interest: In anticipation of entering into a contract with you for our services and to manage that contract
Purpose/Activity under clause 5.1: to provide you with the products and services you request
Type of data: User names and registration data to access the site and other information you provide to us
Lawful basis for processing including basis of legitimate interest: In anticipation of entering into a contract with you for our services and to manage that contract, and for our legitimate business interests in supporting our relationship with you.
Purpose/Activity under clause 5.1: to facilitate your entry and participation in competitions, promotions and offers
Type of data: Information you provide to us as part of that application
Lawful basis for processing including basis of legitimate interest: In anticipation of entering into a contract with you for our services and to manage that contract, and for our legitimate business interests in supporting our relationship with you.
Purpose/Activity under clause 5.1: to process employment applications
Type of data: Information you provide to us as part of that application
Lawful basis for processing including basis of legitimate interest:In anticipation of entering into a contract with you for our services and to manage that contract, and for our legitimate business interests in supporting our relationship with you.
Purpose/Activity under clause 5.1: to improve and manage our business, products and services
Type of data: Content from all interaction with you, and from monitoring cookies and similar technology
Lawful basis for processing including basis of legitimate interest:In anticipation of entering into a contract with you for our services and to manage that contract, and for our legitimate business interests in supporting our relationship with you and promoting our services.
Purpose/Activity under clause 5.1: to customise your experience when using our websites, apps, products and services
Type of data: Data from cookies and similar technologies, and your responses to questions we may ask
Lawful basis for processing including basis of legitimate interest:for our legitimate business interests in developing and promoting our services.
Purpose/Activity under clause 5.1: to address and answer any enquiries or questions that you might have
Type of data: Information that you provide to us
Lawful basis for processing including basis of legitimate interest: to manage our contract or relationship with you and for our legitimate business interests in supporting the development and promotion of our services.
Purpose/Activity under clause 5.1: to protect or defend our legal position.
Type of data: Any personal data which is collected and recorded by us
11.1.5 You acknowledge that we will store and process personal information in Australia and may transfer your personal information other recipients located outside the United Kingdom and/or the EU identified in this Privacy Policy. Many of our external third parties are based outside the United Kingdom so their processing of your personal data will involve a transfer of data outside the United Kingdom. Whenever we transfer your personal information out of the United Kingdom, we ensure a similar degree of protection is afforded to it by either ensuring there is an adequacy finding or we may use specific contracts approved for use in the United Kingdom which give personal data the same protection it has in the United Kingdom.
11.1.6 Please contact us on the details in clause 17 of this Privacy Policy if you want further information on the specific mechanism used by us when transferring your personal information out of the United Kingdom.
11.1.7 Under certain circumstances, you have rights under Data Protection Law in relation to your personal information, which may include: right to rectification, right to withdraw consent to processing (where this is the sole lawful basis for processing) right to make a subject access request, right to object to automated processing, right to erasure. These rights are qualified, and their application depends on specific circumstances.
11.1.8 More information about your rights under Data Protection Law is available on the website of the Information Commissioner: https://ico.org.uk/global/privacy-notice/your-data-protection-rights/ or other supervisory authorities.
11.1.9 If you wish to exercise any of your rights under Data Protection Law please contact us on the details in clause 17 of this Privacy Policy. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues, which can be contacted at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
12 Access to your personal information
At any time, you may request access to personal information about you that She Serves holds by contacting us using the details below. We will process your request within a reasonable time. We will generally give you access to your personal information, and if we do not we will take reasonable steps to meet your needs (for example by letting you know generally the kind of information we hold about you). We will also give you the reasons why your request has been refused and advise you on avenues to make a complaint.
13 Correction of your personal information
You should notify us if there are any changes to your personal information. You may ask us at any time to correct personal information we hold about you by contacting us using the details below.
14 Complaints
Please notify us if you have any complaints relating to She Serve’s handling of your personal information. We will investigate all complaints and respond to you within a reasonable time and in accordance with our legal obligations.
15 Changes to this policy
15.1 This policy was last updated on March 29, 2023.
15.2 She Serves may amend this policy by publishing a revised policy on our website. Any changes will be effective as of the date they are published.
16 Other websites and apps
Our websites, apps and social media pages may contain links to other websites or apps (including social media platforms) of interest. Please note that we do not have any control over those websites or apps. We are not responsible for the protection and privacy of any information which you provide whilst visiting such websites or apps and such websites or apps are not governed by this privacy policy. You should exercise caution and look at the privacy policy applicable to the website or app in question.
17 Contact details and further information
17.1 If you have any questions in relation to privacy or you wish to access or correct your personal information, please contact us by email at hello@sheserves.com
17.2 For further information about privacy issues see the Office of the Australian Information Commissioner’s website at www.oaic.gov.au, or as otherwise directed under this Privacy Policy