PRIVACY POLICY

Modification Date: 10 September, 2019

Effective Date: 5th May, 2019

Hi. SerpWolf here. Just like you, I care about the use of my personal information online, so it is only fair I provide you with insight into the privacy practices employed here at SmartPassiveIncome.com. Particular areas of the world now require different privacy disclosures, so please read the entire policy to make sure you understand our practices fully.

I. If You are Located In the EU

A. What Personal Data Do I Collect From You?

Personal data is information that can be used to identify you such as your name, IP address, and email address. As a business, I collect personal data from you in a number of ways including:

(1.) Opt-In To Email newsletters: Your name and address.

(2.) Waiting Lists: Your name and address.

(3.) Transactional: You name, email address, billing information and payment source.

(4.) Submitting Questions: Your name, email address, and question.

(5.) Training Lessons: Your name and email address.

B. What Is The Purpose of Processing Your Personal Data?

I collect the information above for the following purposes.

(1.) Opt-In To Email Newsletters: To provide you with information on the topics I write about and lessons I teach and to ask for questions for upcoming webinars.

(2.) Waiting List: To let you know when a course or service opens or is closing.

(3.) Transaction: To process a purchase you make with me.

(4.) Submitting Questions: To answer questions you might have for me.

(5.) Lessons: To send you lessons you are interested in.

C. What Legal Basis Do I Have For Collecting and Processing Your Information?

Websites must have a legal basis for collecting information from individuals. 

(1.) Opt-In To Email Course: I will ask for your consent first.

(2.) Waiting List:  I will ask for your consent first.

(3.) Transaction: I will collect your information as part of a legal contractual transaction.

(4.) Submitting Questions: I have a legitimate interest in providing a response to your questions and need to use your data to do so. I will not use the data for other purposes.

(5.) Lessons:  I will ask for your consent first.

“Legitimate interests” for processing your personal information exist where you submit the information with an expectation that it will be processed and there is no undue impact on you.

D. Who Has Access To The Data I Collect?

I process and access the data I collect from you. However, I use third parties to assist me with processing your personal data including the following categories of recipients:

  • Financial transaction processors (processing your payments)
  • Customer service communication platform
  • Contest and survey platform
  • Email communication manager
  • Marketing funnel providers
  • Website management services
  • Website design and programming services

These third parties have signed contract with me in which they are prohibited from utilising, sharing or retaining your personal data for any purpose other than we dictate.

E. Cookies and Similar Technologies

This site uses cookies and similar technologies to track particular aspects of you and other people who visit me. This tracking is done to provide me with information on how people move about the site, what is of interest to them and what is not, how me marketing is performing, and incidental items such as what percentage of users access the site from a personal computer versus a mobile phone. You may block most cookies by adjusting your browser settings as well as responding to the cookie consent notice that appears when you visit this site. 

F. How Long Do I Keep Your Data?

I keep your personal data for different periods of time depending on the reason it was gathered in the first place.

(1.) Opt-In To Email Newsletter: 24 months

(2.) Waiting List: 24 months

(3.) Transaction: Four years for tax audit purposes.

(4.) Submitting Questions: Five years

(5.) Lessons: 26 months

If a legal claim arises involving your data, I will store and disclose that data until the matter has resolved.

G. Your Right To Ask For Corrections, Erasure, And Export Of Your Data

You have the right to control your personal data. Specifically, you have the following rights:

  • The right to be informed: I am informing you now with this policy.
  • The right of access: I’ll provide you with the data I have about you.
  • The right to rectification: Request I fix incorrect data about you.
  • The right to erasure: Request I erase certain data about you.
  • The right to restrict processing: Ask me to restrict certain type of processing of your personal information.
  • The right to data portability: Ask me to provide your personal data we have for export.
  • The right to object: Object to how I use your data.
  • Rights in relation to automated decision making and profiling: I don’t profile you, but keep in mind you have this right with other sites.

H. Your Right To Withdraw Consent

Although this is mentioned above, I want to emphasize that wherever I’ve asked for your consent to collect or process your personal data, you have the right to withdraw that consent. If you receive email messages from me, you can use the “unsubscribe” link in each message to withdraw consent and stop the mailings. 

I. Do I Transfer Your Data To Third Countries?

No and Yes. I’m located in Australia but some of the third party marketing platforms are located in the United States. I have no business operating in the European geo location.

J. Privacy Concerns, Contacting me, Complaints.

You can contact me at admin@serpwolf.xyz with your request with any questions or requests you have about these policies or your personal data. 

Data Controller

Representative: SerpWolf

Serpwolf.xyz

II. For All Visitors Regardless of Location

A. Privacy Policy Modifications and Updates.

I may update and modify this Privacy Policy at any time. In doing so, I will post a notice on the site 30 days before the change goes into effect and forward an email message to you should I have an email address for you.

B. Legal Disclosures of Personal Information.

I may process, store, and disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to (1) conform to the edicts of the law or comply with legal process served on us, (2) protect and defend my rights or property or (3) act under exigent circumstances to protect the safety of the public or users of the site.

C. Public Comments.

You may leave comments on posts. Please remember that any information you provide is not private. The information can be viewed by anyone online including family, friends, the media, investigators, and potential employers conducting background checks.

D. Third Party Websites.

I link to other sites, but please keep in mind that I do not control the privacy policies of those sites. Make sure to review the policies of any such sites before providing your personal information.

E. Sale of Business

Should I sell this site, your personal information that has been collected will be an asset transferred to the new owner.

If you have any questions about this Privacy Policy, please contact me.

.