This Privacy Policy explains how Knickerbox Industries Pty Ltd (ABN 41 162 351 484), trading as Integrated Sex Therapy and Lauren Muratore (we, us or our), collects, holds, uses and discloses your personal information.
It applies to our websites at integratedsextherapy.com.au and laurenmuratore.com (Websites), and to our coaching programs, digital products and other services (Services).
We are committed to protecting your privacy. We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Where they apply to you, we also handle information consistently with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the UK GDPR. If you are in the United States, additional information that applies to you is set out in section 15.
This Privacy Policy is effective from [insert date].
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The personal information we collect
We may collect the following kinds of personal information:
- your name and contact details, such as your email address, phone number and postal address;
- booking and scheduling information;
- payment and billing information;
- coaching and intake information, which may include sensitive information about your health, sexual practices and relationships;
- the content of your communications with us, including messages you send through Telegram and by email;
- your marketing preferences and newsletter subscription details; and
- technical information about your use of our Websites, such as your device and browser type, IP address and the pages you view.
We collect personal information only where it is reasonably necessary for our functions and activities.
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Sensitive information
- Some of the information we collect is sensitive information, which is called special category data under the GDPR. It includes information about your health, sexual practices and relationships.
- We collect and handle sensitive information only with your consent and only where it is necessary to provide the Services, or where the law otherwise allows. You give this consent when you accept our Coaching Agreement and when you provide the information to us.
- We take extra care with sensitive information and limit who can access it.
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How we collect your personal information
- We collect personal information directly from you, for example when you make an enquiry, book a session, complete an intake questionnaire, purchase a Service, subscribe to our newsletter, or communicate with us.
- We also collect some information automatically when you use our Websites, through cookies and analytics tools, as described in section 5.
- Where it is reasonable and practicable, we collect personal information directly from you. If we collect your personal information from someone else, we take reasonable steps to tell you.
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Why we collect, hold, use and disclose your personal information
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We collect, hold, use and disclose personal information to:
- provide the Services and manage your bookings, payments and account;
- communicate with you and respond to your enquiries;
- send you marketing and newsletters where you have agreed to receive them;
- improve our Websites and Services; and
- meet our legal obligations.
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If you are in the United Kingdom or the European Union, we rely on the following legal bases under the GDPR:
- the performance of our contract with you;
- your consent, including your explicit consent for sensitive information under Article 9;
- our legitimate interests; and
- compliance with our legal obligations.
- If you do not provide the personal information we ask for, we may not be able to provide the Services.
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We collect, hold, use and disclose personal information to:
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Cookies and website analytics
- Our Websites use cookies and similar technologies to help them work and to understand how they are used.
- We use website analytics tools to understand how visitors use our Websites, and tools to help protect our Websites from spam and abuse. These tools may be provided by third parties and may involve the transfer of information overseas, as described in section 7.
- You can control cookies through your browser settings and, where a cookie banner is shown, through your cookie choices. For more detail, please see our Cookie Notice.
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Who we share your personal information with
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We share personal information with third parties who help us provide the Services, including:
- payment processors;
- booking and scheduling systems;
- website analytics and security providers;
- messaging platforms we use to deliver coaching;
- email and newsletter providers; and
- website hosting providers.
- Our payment processor handles all card payments for us, and we do not store your full card details.
- We may also disclose personal information to our professional advisers, and where we are required or permitted to do so by law.
- We do not sell your personal information.
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We share personal information with third parties who help us provide the Services, including:
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Sending information overseas
- Some of the service providers we use are located, or store information, outside Australia. This means your personal information may be disclosed to, or stored in, countries including the United States and the United Arab Emirates, and other countries where our service providers are located.
- Our website hosting is in Australia, although your information may also be hosted overseas.
- We take reasonable steps to ensure that our service providers, and any overseas recipients, protect your personal information and handle it consistently with the APPs. This usually includes putting appropriate terms in place with the service providers we use.
- Where we transfer personal information from the United Kingdom or the European Union, we also put in place the additional safeguards required under the UK and EU rules, such as standard contractual clauses.
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Direct marketing
- We may send you marketing about our Services where you have agreed to receive it. Every marketing message includes a way to opt out, and we handle marketing consistently with the Spam Act 2003 (Cth).
- You can ask us to stop sending you marketing at any time, by using the unsubscribe link or by contacting us.
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How we store and protect your personal information
- We take reasonable steps to protect your personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.
- No method of transmission or storage is completely secure. In particular, messages you send through Telegram are handled on Telegram’s systems and are only as private as your own use of the app allows.
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How long we keep your personal information
- We keep personal information only for as long as we need it for the purposes described in this Privacy Policy, or for as long as the law requires.
- Because we hold health information, we generally keep coaching and health records for at least seven (7) years after our last contact with you.
- When we no longer need personal information, we take reasonable steps to destroy or de-identify it.
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Your rights and choices
- You may ask us to give you access to, or to correct, the personal information we hold about you.
- If you are in the United Kingdom or the European Union, you also have rights to erasure, to restrict or object to processing, to data portability, and to withdraw your consent. These rights may be limited in some cases.
- To exercise any of these rights, please contact us using the details in section 13.
- If you are not satisfied with how we handle your personal information, you can complain to us, and then to the Office of the Australian Information Commissioner. If you are in the United Kingdom, you can complain to the Information Commissioner’s Office; if you are in the European Union, you can complain to your local data protection authority.
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Data breaches
If a data breach happens that is likely to cause you serious harm, we will notify you and the Office of the Australian Information Commissioner in accordance with the Notifiable Data Breaches scheme. Where the GDPR applies, we will also notify the relevant authority within seventy-two (72) hours where we are required to do so.
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How to contact us
- Lauren Muratore handles privacy enquiries and complaints for our business.
- You can contact us at [insert privacy email] or by writing to Knickerbox Industries Pty Ltd, Level 1, 196 Keilor Road, Essendon North, Victoria 3041, Australia.
- If we are required to appoint a representative in the United Kingdom or the European Union, our representative’s details are: [to be confirmed].
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Children
Our Services are not directed to children under eighteen (18) years of age, and we do not knowingly collect their personal information.
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Additional information for United States residents
[This section is a placeholder and is subject to confirmation with our United States lawyers.]
- If you are a resident of the United States, additional privacy rights may apply to you under the law of your state.
- Depending on where you live, you may have the right to ask us what personal information we collect about you, to access, correct or delete it, and to opt out of the sale or sharing of your personal information. As set out above, we do not sell your personal information.
- To exercise any of these rights, or for more information, please contact us using the details in section 13.
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Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The current version is always available on our Websites, and the effective date appears at the top of this Privacy Policy.