Privacy Policy

1. About this Privacy Policy


Welcome to www.iswara.life (“Site”).

In this Privacy Policy, “we”, “our,” or “us” or “Iswara” means Iswara (ABN 51 880 574 636). Any reference to “you” or “your” means you, as a member (“Member”) or user of our Site for the supply of use of our products and services.

Protecting your personal information is very important to us. When you share your personal information with us, we treat it with care and take our responsibility to protect it seriously. We only use or disclose your personal information for the purpose for which it was collected.

We adhere to the Australian Privacy Principles contained under the Australian Privacy Principles (“APPs”) in the Privacy Act 1988 (Cth), the Privacy Amendment (Notifiable Data Breaches) Act 2017 (NDB) and the EU General Data Protections Regulation (GDPR) (collectively “Privacy Laws”).

This Privacy Policy will give you an understanding of:

(a) the types of personal information we collect;
(b) how and when we collect, use, store, disclose and otherwise handle personal information;
(c) the purposes for which we collect, use, and disclose personal information;
(d) how you may access your personal information;
(e) how to update your personal information;
(f) how you can make a complaint and how we deal with any such complaint; and
(g) how to contact us.

You consent to the collection and use of your personal information as described in this Privacy Policy. If you do not accept our Privacy Policy, please do not access or use our products and services.

You have the right not to provide us with personal information, but if you do not provide your personal information to us, your user experience, the navigation of our Site and the supply of our products and services to you may be affected.

We may update this Privacy Policy from time to time to reflect changes in how we handle Personal Information and to reflect any changes to the Privacy Laws. Updates to this Privacy Policy will be effective upon posting to the Site.

 

2. About Iswara


This Site delivers online modules to its members (“Members”) and the opportunity to browse as well as purchase products and services (“Products and Services”)
 

3. Personal Information

 

Personal information means information about an individual whose identity is apparent or can reasonably be ascertained from that information (“Personal Information”).

Please read this Privacy Policy carefully as it sets out how we collect, store, use and safeguard your Personal Information in relation to the Products and Services that we offer on our Site in compliance with the Privacy Laws.

When you access or use our Site, we may automatically receive, collect, and record Personal Information about you through the Site directly when you:

(a) purchase our Products and Services; or
(b) join our Site as a Member; or
(c) register an interest in relation to our Products or Services.

The Personal Information we collect from you is so that we can supply you with our Products and Services or information about our Products and Services.

By registering for a login account (Account) on our Site, you will be required to accept our Terms and Privacy Policy by clicking the “Join” button. By clicking the “Join” button you agree to our Terms and our Privacy Policy which gives you notice through the User interface as follows:

By Joining, you agree that you’ve read and accept our Terms and Conditions and you consent to our Privacy Policy.

 

4. What Personal Information is collected?


The Personal Information we collect from you may include:

(a) name
(b) address (town/city, state, post code, country)
(c) phone
(d) email
(e) payment data
(f) marketing information including social media networks, and
(i) any other information as specified in the Account interface.

(“Account”)

We may collect additional information from you at other times, including but not limited to, when you provide marketing information, when you provide feedback, when you change your Account or email preference, and when you respond to our surveys and/or promotions, or communicate with our customer support.

We collect, hold, use and disclose your Personal Information for the purpose of:

(a) ongoing services;
(b) communication requests;
(c) contact correspondence;
(d) inquiries, advice and information;
(e) access to protected portals on our Site;
(f) advertising our Site and services;
(g) internal administrative, marketing and planning requirements;
(h) in compiling and reporting stats with all the relevant personal and/or proprietary information de-identified prior to the completion of such statistics; and
(i) to comply with all rules, regulations, laws, lawful and binding determination, decision or direction to a regulator, or in co-operation with any government authority.

When we collect your Personal Information for marketing purposes, it will be in circumstances where you would reasonably expect the data to be used for marketing purposes, and we will always give you a means to “opt out” of any marketing communications.

You also have the option of not providing your Personal Information to us. If you choose to withhold your Personal Information, it may not be possible for us to provide you with our Products or Services or for you to access certain parts of our Site or for us to respond to your query.

You are entirely responsible for the security of your User name and password (“Login Details”) It is important that you keep your Account and Login Details secure. You must not give your Login Details to any other person. You must notify us immediately if you are aware, or believe, that someone other than yourself has access to your Account.

You should also take measures, such as changing your Login Details regularly, so that your Account is secure.
 

5. How we collect your Personal Information


Iswara collects Personal Information from you in a variety of ways, including when you interact with us electronically or in person, through customer support on the phone, when we supply our Products and Services to you, through surveys, when you access our Site or complete online Site forms to purchase our Products or when you register an interest in any of our Products or Services.

You may provide Personal Information to us directly or you may supply it to us digitally when you use our Site or purchase our Products.

We may also receive Personal Information from third parties in connection with the supply of our Products and Services. If we do, we will protect your Personal Information in accordance with this Privacy Policy.
 

6. How we use your Personal Information


We may use the Personal Information collected from you to supply you with our Products and Services and for ongoing sales and support.

We use your Personal Information for marketing purposes to make you aware of new products, services and opportunities available to you.

We may contact you by a variety of measures including, but not limited to telephone, email, SMS, mail or social media sites.

We may send you Site-related emails, mobile-phone push notifications and messages. You can opt out of our mailing list if you select the ‘unsubscribe’ service provided by us in every communication.
 

7. If Iswara can’t collect your Personal Information


If the Personal Information we request is not provided by you, the following may result:

(a) Products and Services created by Iswara may not be delivered to you;
(b) Iswara may be unable to deliver its requested services to, including promotional information or offers; and
(c) we may also be unable to adapt our Site content and experience to your optimum preferences.
 

8. Disclosure of your Personal Information and Third Parties with access to it


We will share your Personal Information where you have given us your consent in accordance with the purposes described in this Privacy Policy.

We may share your Personal Information or disclose your Personal Information to any of our group companies, vendors, service providers, employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Privacy Policy. Personal Information is only supplied to a third party when it is required for the delivery of our Site or Services.

We may share your Personal Information with third-party service providers to help us provide our Website and Services. Our third-party service providers may be located outside of Australia or outside of the EU.

When we disclose your Personal Information to third-party service providers, we do so on the basis that your Personal Information is treated with confidence, and only used for the limited purpose of providing support to our Website, our Products and Services and in manner consistent with this Privacy Policy.

We may from time to time need to disclose Personal Information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.

If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our databases, together with any Personal Information and non-Personal Information contained in those databases.
 

9. International Data Transfers


Subject to and in accordance with the Privacy Laws, your Personal Information may be transferred to affiliates in other countries where we operate. In this event, we will ensure that the recipient of your Personal Information offers an adequate level of privacy protection for your Personal Information.

As part of our obligations under the GDPR, we only transfer the data of individuals residing in the EU to countries outside of the EU with adequate privacy data laws or to a third party where we have approved transfer mechanisms in place to protect your Personal Information, for example, by entering into the European Commission’s Standard Contractual Clauses for data protection for data that is transferred internationally or ensuring the entity is Privacy Shield Certified for data transfer to third parties based in the United States.

If the above safeguards do not apply, we will request your explicit consent to any transfers and you will have the right to withdraw this consent at any time.
 

10. Security of your Personal Information and Data Breach protocol


We are committed to ensuring that the Personal Information you provide to us is secure. We take practical steps to protect your Personal Information from any loss, misuse, alteration, and unauthorised or accidental access or disclosure or destruction in accordance with our security policy.

To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, technical and managerial procedures, such as encryption of Personal Information, to safeguard and secure data and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

These measures include where appropriate or required by law, computer safeguards and secured, Internet firewalls, intrusion detection, anti-virus protection, network monitoring and Transport Layer Security (“TLS”) or similarly encrypted browsers.

A reportable “Data Breach” is a security incident where the integrity of Personal Information is compromised through being destroyed, lost, altered, corrupted, disclosed or accessed by an unauthorised person where it is likely to result in serious harm to any individual affected.

We have procedures and systems in place including a data breach incident response plan, specific data breach policies and procedures and personnel to deal with an actual or suspected “Data Breach” and will notify you and the applicable regulator in accordance with our obligations under the Privacy Laws and NDB.

No method over the transmission or storage system is 100% private and secure. You understand that we do not guarantee or warrant the absolute privacy or security of any information we collect from or about you. If you have any questions about privacy or security, please contact us.

Please report any actual or suspected breaches in relation to the Services or Website for investigation to Iswara by using the contact details provided below.
 

11. Notifiable Data Breach


The security of your data is important to us, but remember no method of transmission over the Internet is 100% private and secure. We do not guarantee or warrant the absolute privacy or security of any data we collect from or about you.

The Internet is an insecure medium and Users should be aware that there are inherent risks transmitting information across the Internet. Information submitted unencrypted via electronic mail or web forms may be at risk of being intercepted, read or modified.

A reportable “Data Breach” is a security incident where the integrity of Personal Information is compromised through being destroyed, lost, altered, corrupted, disclosed or accessed by an unauthorised person where it is likely to result in serious harm to any individual affected.

We have procedures and systems in place including a data breach incident response plan, specific data breach policies and procedures and personnel to deal with an actual or suspected “Data Breach” and will notify you and the applicable regulator in accordance with our obligations under the Privacy Laws and NDB.

Please report to Iswara any actual or suspected data breaches for investigation by using the contact details provided in the Contact Us page of our Site.
 

12. Access to and how you can control your Personal Information


You may request details of Personal Information that we hold about you. If you would like a copy of your Personal Information or believe that your Personal Information is inaccurate, out of date, incomplete, irrelevant, please contact us at our contact details below.
 

13. Legal basis in the European Union (EU) for the collection and processing of your Personal Data


“Personal Data” refers to any information relating to an identifiable natural person who can be identified directly or indirectly (“Data Subject”).

The GDPR applies to the data processing activities of businesses with an establishment in the EU or where the processing activities relate to offering goods or services to individuals in the EU, or monitoring the behaviour of individuals in the EU.

If you live in the EU, the GDPR (General Data Protection Regulation) applies, giving you the rights under the data protection Laws in regards to your personal data. Listed below are your rights:

(a) The right to be informed – we are obliged to inform you how your personal data is used
(b) The right of access – the right to make what’s known as a ‘data subject access request’ for a copy of the personal data we hold on you
(c) The right to rectification – you have a right to have us correct personal data about you that may be erroneous or half-finished
(d) The right to erasure – in certain situations you may ask us to remove the personal data we have on you, unless legally we must keep the specified information
(e) The right to restrict processing – in certain situations you may ask us to suspend processing of personal data
(f) The right to data portability – you may ask us for a copy of your personal data in a commonly used format, i.e. a .csv file
(g) The right to object – you may object to us processing your personal data, i.e. objecting us to process your personal data for direct marketing
(h) Rights in regards to automated decision making and profiling – you have the right for us to be transparent about profiling or other automated decision making

All rights listed above are subject to certain rules around when you can exercise them.

In regards to exercising any rights listed above, please contact us at [email protected]

We may collect and process Personal Data about you in accordance with the GDPR. A “Controller” says how and why personal data is processed and a “Processor” acts on behalf of the Controller by processing the data. Iswara operates both as a Controller and a Processor when controlling or processing the Personal Data of customers and employees.

When you use our Website, we process Personal Data on your behalf as a Data Processor where you are the Data Controller and otherwise to the extent that we are a Data Controller as defined in the GDPR.

The legal basis we rely on to collect and process your Personal Data is based on the following:

(a) Contractual basis. This legal basis applies to the collection or processing of Personal Data in order to fulfil or perform a contract with you, or to which you are a party.
(b) Consensual basis. This applies where you have provided your consent to the collection or processing of Personal Data for a specific purpose (for example, to provide you with marketing updates). You can withdraw your consent at any time by updating your email preferences, opting-out, or by contacting us directly.
(c) Legitimate interests. This applies where we have a legitimate interest to collect or process your Personal Data. For example, it may be to respond to an enquiry about our Services.
(d) Legal obligations. This applies where it is necessary to disclose your Personal Data to comply with a legal obligation.

When we use third-parties to process your Personal Data on our behalf, we ensure that the processing of this Personal Data is confidential, pursuant to our documented instructions and in accordance with the legal basis for the processing.

We only employ third-party data processors that are compliant with the GDPR requirements and that have sufficient security measures in place to protect and safeguard your data.

In the event of a Personal Data breach including any breach of security that leads to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data transmitted, stored or process, we will report the breach to you (where we are required to do so under the GDPR) without undue delay after becoming aware of the breach, and not later than 72 hours after the breach giving you a description of the nature of the breach.
 

14. Data Ownership


As a User of the Site, you own all right, title and interest in the Personal Information that you provide to us (your “Data”). You are solely responsible for the accuracy, quality, legality, integrity, reliability and appropriateness of your Data.

You grant to us a perpetual, worldwide, exclusive, fully paid-up and royalty-free, unlimited, revocable, sub-licensable and transferable licence whilst you are a User of the Site to use, copy, transmit and store your Data in accordance with this Privacy Policy and, where applicable, our Terms.

We and any related entities own all right, title and interest in any data or information that we create, generate, compile, derive, or produce in connection with our Site or the supply of our Products, including data and information that is:

(a) aggregate or raw or statistical data relating to usage, analytics and results of the Site or research relating to the supply of our Products and Services;
(b) for the purpose of optimising delivery, commercialisation and performance of our Site; and
(c) samples and prototypes, conclusions, techniques, know how, methods, and undocumented findings generated in the usual course of our business.

 

15. Use of cookies and similar technologies


When you use, or access our Site or any third-party platform, including third party service providers, such as Google Analytics, third-party payment gateway providers or other third-party advertising and links, there may be cookies and similar technologies that store log files to collect information about your use of the Site.

Cookies are small text files (often including a unique identifier) that can be stored on your computer, tablet or mobile device when you visit a Site. A cookie stores a small amount of data on your device about your visit to a website.

These small files contain information about your browsing activity. Cookies are also used to identify you when you come back to the Site and store details about your use of the Site. They are widely used to make websites work more efficiently, to improve User experience and also to provide information to website operators.

In addition, cookies can be used to analyse traffic and may be used to serve relevant ads to Site visitors through third party services such as Google AdWords.

To understand more about cookies and how they are set, visit www.aboutcookies.org or www.allaboutcookies.org

We may use the following cookies to help the functioning of the Site and to improve User experience:

(a) Strictly necessary cookies: These cookies are necessary for the functioning of the Site and help to improve the efficiency of the Site for Users.
(b) Analytical/performance cookies: These cookies monitor your use of the Site. For example, they collect information about website traffic and use, unique users, unique sessions and store information about users’ sessions and website campaigns.
(c) Targeting/advertising cookies: These cookies help us to provide useful and more targeted advertising.
(d) Preference cookies: These cookies help us to identify Users, so that we remember your preferences on the Site.

You may accept or refuse cookies from our Site or any other website by managing the settings on your browser. You can opt-out from accepting our cookies by editing your browser options, but certain features of our Site will not function if you disable cookies. You can find out how to manage and opt-out from cookies on popular browsers by visiting the specific browser developer’s website.

We may also use web beacons, action tags, and tracking devices to provide analytical and User data that can help us monitor usage and improve the Site.

Non-personal information is information about you or your activities which cannot be used to personally identify you. We may collect non-personal information through your browser, through text files (cookies), applications (e.g. mobile applications), and your IP address. We use non-personal information to compile statistical information about the use of our Sites (or for maintenance purposes) which may include (but is not limited to) recording your server address, your top-level domain name, the date and time of your visit to the Sites, the pages you accessed and downloaded, the previous site you visited and the types of browser you are using.

Any third-party advertisements and links that are provided to you on the Site may also use cookies and other similar technologies to gather your information. When you leave the Site to visit a link or advertisement provided to you via the Site, any information you provide to such advertisements or links, whether voluntarily or involuntarily, will not be governed by this Privacy Policy. You should visit the relevant third-party privacy policy to find out how they use your information.
 

16. Third-Party Services


We use technologies and third-party services that may use cookies, pixels, tags and web beacons (code snippets) on our Site to customise content and advertising, to provide social media features and to analyse traffic to the Site, including about how you use and interact with our Site or when you open or access emails.

We also share information about your use of the Site with our trusted social media, advertising and analytics partners.
 

17. Website Links


Our website provides links to other websites and third party websites, as in social media platform sites. These linked sites are not under our jurisdiction, and we cannot accept responsibility for the behaviour of these companies. We advise you to assess the terms and conditions and privacy policies of any linked website before disclosing any personal information. It is the responsibility of the third party websites to inform you of their own privacy practices.
 

18. Information on Groups and Forums


Information that you provide through chat rooms, webinars, discussion forums will be available to other people, possibly inside or outside Iswara, who have access to the specific content program. Individual forums and chat rooms may have specific rules, guidelines and conditions of use. The opinions of other participants on discussion forums, webinars or chat rooms is that of the participants, and does not reflect the opinions of Iswara.

Please be advised that webinar or meeting hosts can record any session for webinars or forums that you attend. When you choose to sign up or use any aspect of Iswara’s webinar services or other hosts authorized by Iswara, including without limitation by attending any Iswara meeting or webinar, you clearly acknowledge that we may create and store recording for meetings or webinars. At the discretion of Iswara, we may allow these recordings to be available to hosts and other attendees. Remember, you can choose to leave any meeting or webinar on your own accord, if you do not want to be recorded.
 

19. Security


We are committed to ensuring that the Personal Information you provide to us is secure. We have taken reasonable steps to ensure the security of your Personal Information.

We employ appropriate technical, administrative and physical procedures to protect Personal Information from misuse, interference and loss, unauthorised disclosure or alteration.

These measures include where appropriate or required by law, computer safeguards and secured, Internet firewalls, intrusion detection, anti-virus protection, network monitoring and Secure Sockets Layer(“SSL”) or similarly encrypted browsers.

While we take precautions against possible security breaches of our Site and servers, no Site or Internet transmission can be guaranteed to be totally secure. The security of your data is important to us but remember no method of transmission over the Internet is 100% private and secure. We do not guarantee or warrant the absolute privacy or security of any data we collect from or about you.

The Internet is an insecure medium and Users should be aware that there are inherent risks transmitting information across the Internet. Information submitted unencrypted via electronic mail or web forms may be at risk of being intercepted, read or modified.

You acknowledge that we are not responsible for the privacy or security practices of any third-party (including third parties that we are permitted to disclose your Personal Information to in accordance with this Privacy Policy or any applicable laws). The collection and use of your information by such third parties may be subject to separate privacy and security policies.

You also acknowledge that the security of communications sent by electronic means or by post cannot be guaranteed. You provide information to us via the Internet or by post at your own risk. We cannot accept responsibility for misuse or loss of, or unauthorised access to your Personal Information where the security of information is not within our control.

 

20. Direct Marketing and other Services


Information about our services and direct marketing communications may be sent to you, if we believe this will be of interest to you. Through mail, over SMS or email are the communication methods that will be used. We will follow any applicable marketing laws in doing so, including the Spam Act 2003 (Cth). When practical to do so, we will use your preferred mode of communication. Please remember that you are able to opt-out of receiving marketing communications any time by contacting us, or by using the services provided in the marketing communications. In these circumstances, we will remove your name from our mailing list/subscription.

We will never supply other organisations your Personal Information for direct marketing purposes.
 

21. Disclaimer and Limitation of Liability


Your use of our Site is at your own risk. The Site is provided on an “as is” basis.

We will take all reasonable steps to keep your Personal Information secure but to the maximum extent permitted by law, we exclude all liability for the consequences of any unauthorised access to your Personal Information. This includes (but is not limited to) loss or damage you might suffer because of any of the following:

(a) reliance on the completeness, accuracy, suitability or currency of the Site (including third-party material and advertisements);
(b) failure of performance, error, omission, interruption, deletion, defect, delay in operation or transmission, virus or other harmful component, loss of data, communication line failure, unlawful third-party conduct, or theft, destruction, alteration or unauthorised access to records;
(c) accessing any sites or servers maintained by other organisations through links on the Site or any communication from the Site. Links are provided for the convenience of users of the Site only and without responsibility for the content or operation of those sites (unless otherwise stated, linked sites and the services are not endorsed by us and your linking to any such site is at your own risk);
(d) the provision of financial information, the failure to complete (or delay in completing) any transaction, or other loss or damage arising from any e-commerce transacted or attempted to be transacted on the Site.

We do not warrant that the Site will be uninterrupted or free from error or that any defects on the Site will be corrected or that the Site or servers are free of viruses or other harmful conditions or components.

To the extent permitted by law, we disclaim liability, whether based in contract, tort, negligence, strict liability or otherwise, for damages of any kind (including, but not limited to indirect, incidental, consequential, special, punitive or exemplary damages) in any way arising from the functionality, operation or the information provided by the Site including but not limited to damages arising from interruptions of service or delays in operation or transmission even if we are expressly advised of the possibility of such damages.
 

22. Access to and how you can control your Personal Information


You may request details of Personal Information that we hold about you in accordance with the provisions of the Privacy Laws. We give you access to your Personal Information for the purpose of correcting any Personal Information that is inaccurate, incomplete or not up to date.

Please regularly update your records and your Account via our Site. If you would like a copy of your data or believe that your data is inaccurate, out of date, incomplete, irrelevant, please contact us using the contact details provided below.

Please be aware that you may need to provide proof of identity before we can change your records or update your details. We may refuse to provide you with certain information where permitted or required by law.

We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act 1988 (Cth).
 

23. Data Integrity and Retention under the GDPR


We take reasonable steps to ensure that your Personal Data is accurate, complete and kept up to date. You can request Iswara to review, correct or update your Personal Data but we will first ensure that your identity is properly verified and any access rights are authenticated.

We may keep your Personal Data for a period of time that is consistent with the original purpose of us collecting the Personal Data from you. We do not keep your Personal Data for longer than it is necessary for the fulfilment of its purpose.

In regulating the retention period for your Personal Data, we consider the following factors: the amount, type, and overall sensitivity of the Personal Data collected, the potential risk of harm from unapproved use or disclosure of your Personal Data, the reasons for which we process your Personal Data and whether we can meet those purposes through other means, and the appropriate legal requirements.

Under the GDPR, periods of data retention will apply differently for each specific category of data. If you have any questions about the applicable data retention periods, please contact us by using the contact details provided below.

If you request, we will delete or anonymise your Personal Data so that it no longer identifies you unless we are legally allowed or required to maintain certain Personal Data. The removal of any of your Personal Data means that we may not be able to supply you with our Services.

 

24. Access to and how you can control your Personal Data


You may request details of Personal Data that we hold about you in accordance with the provisions of the Privacy Laws. We give you access to your Personal Data for the purpose of correcting or deleting any Personal Data that is inaccurate, incomplete or not up to date.

We store information about our clients by law for five years for Australian tax Law purposes, which includes: Transaction Data, Identity, contact and Financial.

If you would like a copy of your data or believe that your data is inaccurate, out of date, incomplete, irrelevant, please contact us using the contact details provided below.
 

25. Opting-Out


If we use your Personal Information to market and promote our Products and Services, you may notify us at any time that you do not wish to receive marketing or promotional material by contacting us directly or through the “unsubscribe” mechanism in our marketing or promotional emails.
 

26. Law and Jurisdiction


This Privacy Policy is governed by and construed in accordance with Australian law. You irrevocably submit to the jurisdiction of the Courts of Queensland and any court that may hear appeals from any of those courts for determining any dispute concerning this Privacy Policy and waive any right you may have to claim that those courts are an inconvenient forum.
 

27. Complaints


If you think we have breached the Privacy Laws or wish to make a complaint about the way we have handled your Personal Information or other information connected to your Account or if you have any questions or concerns about our collection, use or disclosure of your Personal Information, please contact us using our details provided below.
 

28. Contact Us


You can contact us:

(a) by post at PO Box 235, SAMFORD QLD 4520, Australia
(b) by email at [email protected]

 

© 2019 Iswara. All Rights Reserved.

 

Privacy Policy last updated 24 Aug 2019

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