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
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 firstname.lastname@example.org with your request with any questions or requests you have about these policies or your personal data.
II. For All Visitors Regardless of Location
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.