PRIVACY POLICY

 

Official Adviser Pro Tools Privacy Policy

Modification date: April 29, 2021
Effective date: April 29, 2021

Totally Primal (“us”, “we”, or “our”) owns and operates the https://adviserprotools.com (APT) website (the “Service”,”Site”). With particular areas of the world now requiring specific privacy disclosures, we have decided to make these our standard practice, so please read the entire policy to make sure you fully understand. We have placed simply to read headers into this page to make it easier to find sections to refer back to if you require in the future. By using the Service, you agree to the collection and use of information in accordance with this policy and to the terms of service of this website.

We have adopted the National Privacy Principles (NPPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Federal Privacy Commissioner at www.privacy.gov.au.

We also collect, manage and destroy personal data in accordance with the EU – GDPR provisions for EU residents.

I. If Your Based in the EU

If you are based in the EU please note that we collect, manage and destroy personal data in accordance with the EU – GDPR provisions for EU residents. Details of our management of EU resident data is detailed in the sections below, and is specifically referenced where possible. Additionally, please note that your information may be transferred outside of Europe, including to Australia, Canada and the United States.

II. How Adviser Pro Tools (APT) Manages Your Privacy

A. What Personal Data Do We Collect From You?

While using our Service, we may collect certain personally identifiable information such as your name and email address, your IP address, time zone and web browser, that can be used to contact or identify you (“Personal Data”).

As a business, we collect personal data from you in a number of ways including:
(1.) Opt-in To Email Courses: Your name and email address
(2.) Waiting Lists: Your name and email address
(3.) Transactions: Your name, email address, phone number, billing information and payment source.
(4.) Lessons: Your name and email address.
(5.) Join The Membership site: Your name and email address
(6.) Opt-in to email newsletter: Your name and email address
(7.) Join APT Book Club: Your name and email address
(8.) Leaving Reviews: Your name and email address

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

We collect this information for the following purposes:

(1.) Opt-in To Email Courses: To provide you with information about the course you wish to join and the topics being discussed or taught.
(2.) Waiting Lists: To let you know when the course, service or product opens or is closing.
(3.) Transactions: To process a purchase you make with us, send email confirmations & invoices, notify you of one time offers that are still available. (‘Order Information’)
(4.) Lessons: To send you the lessons you are interested in.
(5.) Join The Membership site: To send you messages regarding new tools and scripts added to the site, services being offered or special offers being provided to members.
(6.) Opt-in to email newsletter: To provide you with information about listings on the site, blog posts on the site, free and paid offers and updates from social and other media.
(7.) Join APT Book Club: To send you messages regarding books the APT Team have read and reviewed.
(8.) Leaving Reviews: To legitimise the reviews of listings and products for our other members

C. How Do We Use Your Personal Information

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations).

Additionally, we use this Order Information to:
– Communicate with you;
– Screen our orders for potential risk or fraud; and
– When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

D. What Information Do We Collect From You Browsing Our Site

When you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”. This tracking is done to provide us with information on how you move about the site, what is of interest to you and what is not, how our marketing is performing and incidental items such as what percentage of users access the site from a personal computer versus a mobile phone.

We collect Device Information using the following technologies:
(1.) “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
(2.) “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
(3.) “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

BEHAVIORAL MARKETING

Web beacons and cookies can also provide information to assist us with advertising and retargeting campaigns, one way for us to find people who are interested in the services we provide. We use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

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. To learn more about this technology, please visit our Cookie Policy.

Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as “Order Information.”

Offline Purchases and Optin. We may process orders for you offline using a point of sale device or facilitate an offline enrolment, optin, subscription of event signup. In each of these cases we may collect personal data from you which is then transferred into our online systems.

DO NOT TRACK SIGNALS

Please note that we do not currently honour the “Do Not Track” signals issued from your browser or third party sources.

METHOD OF OBTAIN LEGAL CONTENT FOR COLLECTING INFORMATION

Our legal basis for each of the ways we collect information from you is detailed below. Please note where consent forms the basis, you can withdraw consent at any time by contacting Chris Ball or opting out of any email message using the “unsubscribe” link.

Below are our legitimate business reasons for collecting your information:
(1.) Opt-in To Email Courses: We ask for your consent.
(2.) Waiting Lists: We ask for your consent.
(3.) Transactions: We collect your information as part of the legal contract that takes place during the transaction.
(4.) Lessons: We ask for your consent.
(5.) Join The Membership site: We ask for your consent.
(6.) Opt-in to email newsletter: We ask for your consent.
(7.) Join APT Book Club: We ask for your consent.
(9.) Leaving a Review: We ask for your consent.

D. Who Has Access To The Data We Collect?

We process and access the data we collect from you. However, we do use third parties to assist us with processing your personal data including the following types of providers:

Financial transaction processors (payment processes) e.g Paypal or Stripe.
Customer service communication platforms
Contest & survey platforms
Email service providers e.g. mailchimp
Facebook Messenger service providers e.g. ManyChat
Website messaging services e.g. PushCrew or Drift
Marketing funnel providers
Website management services
Website design and programming services

These third parties all have contractual agreements with us which prohibit them from utilising, sharing or retaining your personal data for any other purpose than the purpose we dictate.

THIRD PARTY COUNTRIES

We are located in Australia and as such us a number of offshore providers in the United States, Canada and the United Kingdom to collect and store some of your data.

E. How Long Do We Keep Your Data?

We keep your personal data for varying periods of time depending on the reason was initially collected.

Transaction: Seven years for Australian Tax purposes.
Site Membership: Seven years after closing account.
Lessons, courses, waiting lists, book lists and the like will be maintained for a minimum of 24 months after you cancel the service or unsubscribe. Should you wish to activate a service again, you can provide consent to the service, as detailed above, and your existing service can be reactivated. After the 24 month period, the previous service history may not be recoverable.

Should a legal claim arise involving your data, we will store and disclose that data until the matter has resolved.

F. Your Right to Ask for Correction, Erasure and Export Of Your Data?

In accordance with the EU GDPR provisions you have the right, if you are an EU resident, to control your personal data. Specifically you have the rights to:

Be informed: This privacy policy, cookie policy, terms of services and end user agreement are informing you now.
Access: We’ll provide you with the data we have about you
Rectification: You can request that we fix incorrect data about you
Deletion: You can request we erase certain data about you
Restrict Processing: Ask us to restrict a certain type of processing of your personal information
Data Portability: You can request us to provide data we have for export.
Object: Object how we use your data

To exercise any of these rights please contact Chris Ball at [email protected] with your request.

We keep your personal data for varying periods of time depending on the reason was initially collected, as detailed above.

G. Your Right to Withdraw Consent.

As mentioned above that wherever we have asked for your consent to collect or process your personal data, you have the right to withdraw that consent. If you receive an email message, facebook message or website push notification from us, you can use the appropriate method to unsubscribe from that service and withdraw you consent. This may include clicking ‘Unsubscribe’ in the bottom of the email, typing ‘stop’ in a facebook message to us, following the steps on the pushcrew website to turn of our push notifications in your browser. Alternatively, you can contact Chris Ball at [email protected] with your request.

H. Privacy Concerns Complaints and Contacting Us.

You can contact Claire Ball at [email protected] with your request or question you have about these policies or your personal data. If, after contacting us, you feel your privacy issue has not been resolved, as an EU resident you have the right to file a complaint with a Supervisory Authority such as the Data Protection Commissioner of Ireland. Alternatively, non EU resident can contact the Australian Federal Privacy Commissioner via www.privacy.com.au

Data Controller
Representative: Chris Ball
Adviserprotools.com
PO Box 464 Bull Creek
Western Australia 6149

I. Privacy Policy Updates and Modifications.

We may update or modify this Privacy Policy at any time. When doing so, we will post a notice on the site and inform you of the date the changes/modification come into effect. We urge you to review these changes when they occur.

J. Legal Disclosure of Personal Information.

We 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 our rights or property or (3) act under exigent circumstances to protect the safety of the public or users of the site. Adviserprotools.com operates under the legal jurisdiction of Australian Federal Law and Western Australia State Law.

K. DMCA Disclosures.

We comply with the Digital Millennium Copyright Act of 1998. As part of the compliance process, we may be required to disclose whatever information we have for you to a copyright holder who has submitted a complaint to us.

L. Public Comments.

You may leave comments on forum 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. In addition if you leave a comment on our site you may opt-in to saving your name, email address and website in cookies.

These are for your convenience so that you do not have to fill in your details again when you leave another comment.

M. Uploading Media Files

If you upload images to the website for a review, listing or blog, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website could download and extract any location data from images on the website.

N. Third Party Websites

We link to numerous other sites and businesses. Please keep in mind that we do not control the privacy policies of those sites. Make sure to review the policies of any such sites before providing your personal information.

O. Children’s Privacy

This website is not intended to collect the information of any minor under the age of 18 years. If your minor child has provided us with personally identifiable information, you may request the deletion of that information from our records. Contact us to make this request at [email protected]

P. Sale of the Website or Business

Should we sell this site, or the business, your personal information will be an asset transferred to the new owner.
If you have any questions about this Privacy Policy, please contact us at
Adviserprotools.com
[email protected]