Pri­va­cy Pol­i­cy

Pri­va­cy Pol­i­cy

 

1. INTRODUCTION

This pri­va­cy notice pro­vides you with details of how we col­lect and process your per­son­al data through your use of our site www.speakmoreclearly.com.

By pro­vid­ing us with your data, you war­rant to us that you are over 13 years of age.

speakmoreclearly.com is the data con­troller and we are respon­si­ble for your per­son­al data (referred to as “we”, “us” or “our” in this pri­va­cy notice).

Our full details are:

Esther Bruhl and Asso­ciates Pty/Ltd Trad­ing as speakmoreclearly.com

Email address: Esther.bruhl@speakmoreclearly.com

Postal address: Unit 7/ 112-134 Hall St, Bon­di Beach. 2026  Syd­ney. Aus­tralia

It is very impor­tant that the infor­ma­tion we hold about you is accu­rate and up to date. Please let us know if at any time your per­son­al infor­ma­tion changes by email­ing us at info@speakmoreclearly.com 

2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

Per­son­al data means any infor­ma­tion capa­ble of iden­ti­fy­ing an indi­vid­ual. It does not include anonymized data. 

We may process the fol­low­ing cat­e­gories of per­son­al data about you: 

  • Com­mu­ni­ca­tion Data that includes any com­mu­ni­ca­tion that you send to us whether that be through the con­tact form on our web­site, through email, text, social media mes­sag­ing, social media post­ing or any oth­er com­mu­ni­ca­tion that you send us. We process this data for the pur­pos­es of com­mu­ni­cat­ing with you, for record keep­ing and for the estab­lish­ment, pur­suance or defense of legal claims. Our law­ful ground for this pro­cess­ing is our legit­i­mate inter­ests which in this case are to reply to com­mu­ni­ca­tions sent to us, to keep records and to estab­lish, pur­sue or defend legal claims.
  • Cus­tomer Data that includes data relat­ing to any pur­chas­es of goods and/or ser­vices such as your name, title, billing address, deliv­ery address email address, phone num­ber, con­tact details, pur­chase details and your card details. We process this data to sup­ply the goods and/or ser­vices you have pur­chased and to keep records of such trans­ac­tions. Our law­ful ground for this pro­cess­ing is the per­for­mance of a con­tract between you and us and/or tak­ing steps at your request to enter into such a con­tract.
  • User Data that includes data about how you use our web­site and any online ser­vices togeth­er with any data that you post for pub­li­ca­tion on our web­site or through oth­er online ser­vices. We process this data to oper­ate our web­site and ensure rel­e­vant con­tent is pro­vid­ed to you, to ensure the secu­ri­ty of our web­site, to main­tain back­ups of our web­site and/or data­bas­es and to enable pub­li­ca­tion and admin­is­tra­tion of our web­site, oth­er online ser­vices, and busi­ness. Our law­ful ground for this pro­cess­ing is our legit­i­mate inter­ests which in this case are to enable us to prop­er­ly admin­is­ter our web­site and our busi­ness.
  • Tech­ni­cal Data that includes data about your use of our web­site and online ser­vices such as your IP address, your login data, details about your brows­er, length of vis­it to pages on our web­site, page views and nav­i­ga­tion paths, details about the num­ber of times you use our web­site, time zone set­tings and oth­er tech­nol­o­gy on the devices you use to access our web­site. The source of this data is from our ana­lyt­ics track­ing sys­tem. We process this data to ana­lyze your use of our web­site and oth­er online ser­vices, to admin­is­ter and pro­tect our busi­ness and web­site, to deliv­er rel­e­vant web­site con­tent and adver­tise­ments to you and to under­stand the effec­tive­ness of our adver­tis­ing. Our law­ful ground for this pro­cess­ing is our legit­i­mate inter­ests which in this case are to enable us to prop­er­ly admin­is­ter our web­site and our busi­ness and to grow our busi­ness and to decide our mar­ket­ing strat­e­gy. 
  • Mar­ket­ing Data that includes data about your pref­er­ences in receiv­ing mar­ket­ing from us and our third par­ties and your com­mu­ni­ca­tion pref­er­ences. We process this data to enable you to par­take in our pro­mo­tions such as com­pe­ti­tions, prize draws and free give-aways, to deliv­er rel­e­vant web­site con­tent and adver­tise­ments to you and mea­sure or under­stand the effec­tive­ness of this adver­tis­ing. Our law­ful ground for this pro­cess­ing is our legit­i­mate inter­ests which in this case are to study how cus­tomers use our products/services, to devel­op them, to grow our busi­ness and to decide our mar­ket­ing strat­e­gy.
  • We may use Cus­tomer Data, User Data, Tech­ni­cal Data and Mar­ket­ing Data to deliv­er rel­e­vant web­site con­tent and adver­tise­ments to you (includ­ing Face­book adverts or oth­er dis­play adver­tise­ments) and to mea­sure or under­stand the effec­tive­ness of the adver­tis­ing we serve you. Our law­ful ground for this pro­cess­ing is legit­i­mate inter­ests which is to grow our busi­ness. We may also use such data to send oth­er mar­ket­ing com­mu­ni­ca­tions to you. Our law­ful ground for this pro­cess­ing is either con­sent or legit­i­mate inter­ests (name­ly to grow our busi­ness).

Sen­si­tive Data 

We need to col­lect the fol­low­ing sen­si­tive data about you in order to deliv­er services/product to you:

  • your eth­nic­i­ty
  • your native or back­ground lan­guage.

Where we are required to col­lect per­son­al data by law, or under the terms of the con­tract between us and you do not pro­vide us with that data when request­ed, we may not be able to per­form the con­tract (for exam­ple, to deliv­er goods or ser­vices to you). If you don’t pro­vide us with the request­ed data, we may have to can­cel a prod­uct or ser­vice you have ordered but if we do, we will noti­fy you at the time. 

We will only use your per­son­al data for a pur­pose it was col­lect­ed for or a rea­son­ably com­pat­i­ble pur­pose if nec­es­sary. For more infor­ma­tion on this please email us at info@speakmoreclearly.com. In case we need to use your details for an unre­lat­ed new pur­pose we will let you know and explain the legal grounds for pro­cess­ing. 

We may process your per­son­al data with­out your knowl­edge or con­sent where this is required or per­mit­ted by law.

We do not car­ry out auto­mat­ed deci­sion mak­ing or any type of auto­mat­ed pro­fil­ing. 

3. HOW WE COLLECT YOUR PERSONAL DATA

We may col­lect data about you by you pro­vid­ing the data direct­ly to us (for exam­ple by fill­ing in forms on our site or by send­ing us emails). We may auto­mat­i­cal­ly col­lect cer­tain data from you as you use our web­site by using cook­ies and sim­i­lar tech­nolo­gies. Please see our cook­ie pol­i­cy for more details about this 

We may receive data from third par­ties such as ana­lyt­ics providers such as Google based out­side the EU, adver­tis­ing net­works such as Face­book-based out­side the EU, such as search infor­ma­tion providers such as Google based out­side the EU, providers of tech­ni­cal, pay­ment and deliv­ery ser­vices, such as data bro­kers or aggre­ga­tors.

We may also receive data from pub­licly avail­able sources such as Com­pa­nies House and the Elec­toral Reg­is­ter based inside the EU.

4. MARKETING COMMUNICATIONS  

Our law­ful ground of pro­cess­ing your per­son­al data to send you mar­ket­ing com­mu­ni­ca­tions is either your con­sent or our legit­i­mate inter­ests (name­ly to grow our busi­ness). 

Under the Pri­va­cy and Elec­tron­ic Com­mu­ni­ca­tions Reg­u­la­tions, we may send you mar­ket­ing com­mu­ni­ca­tions from us if (i) you made a pur­chase or asked for infor­ma­tion from us about our goods or ser­vices or (ii) you agreed to receive mar­ket­ing com­mu­ni­ca­tions and in each case you have not opt­ed out of receiv­ing such com­mu­ni­ca­tions since. Under these reg­u­la­tions, if you are a lim­it­ed com­pa­ny, we may send you mar­ket­ing emails with­out your con­sent. How­ev­er, you can still opt out of receiv­ing mar­ket­ing emails from us at any time.   

Before we share your per­son­al data with any third par­ty for their own mar­ket­ing pur­pos­es we will get your express con­sent. 

You can ask us or third par­ties to stop send­ing you mar­ket­ing mes­sages at any time by click­ing on the ‘man­age your sub­scrip­tion link’ in our mar­ket­ing emails OR by email­ing info@speakmoreclearly.com at any time. 

If you opt out of receiv­ing mar­ket­ing com­mu­ni­ca­tions this opt-out does not apply to per­son­al data pro­vid­ed as a result of oth­er trans­ac­tions, such as pur­chas­es, war­ran­ty reg­is­tra­tions etc.  

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your per­son­al data with the par­ties set out below: 

  • Ser­vice providers who pro­vide IT and sys­tem admin­is­tra­tion ser­vices.
  • Pro­fes­sion­al advis­ers includ­ing lawyers, bankers, audi­tors and insur­ers
  • Gov­ern­ment bod­ies that require us to report pro­cess­ing activ­i­ties.
  • Secure pay­ment pro­cess­ing sys­tems
  • Third par­ties to whom we sell, trans­fer, or merge parts of our busi­ness or our assets.

We require all third par­ties to whom we trans­fer your data to respect the secu­ri­ty of your per­son­al data and to treat it in accor­dance with the law. We only allow such third par­ties to process your per­son­al data for spec­i­fied pur­pos­es and in accor­dance with our instruc­tions. 

6. INTERNATIONAL TRANSFERS

We share your per­son­al data with­in our group of com­pa­nies which involves trans­fer­ring your data out­side the Euro­pean Eco­nom­ic Area. 

We are sub­ject to the pro­vi­sions of the Gen­er­al Data Pro­tec­tion Reg­u­la­tions that pro­tect your per­son­al data. Where we trans­fer your data to third par­ties out­side of the EEA, we will ensure that cer­tain safe­guards are in place to ensure a sim­i­lar degree of secu­ri­ty for your per­son­al data. As such: 

  • We may trans­fer your per­son­al data to coun­tries that the Euro­pean Com­mis­sion have approved as pro­vid­ing an ade­quate lev­el of pro­tec­tion for per­son­al data by; or
  • If we use US-based providers that are part of EU-US Pri­va­cy Shield, we may trans­fer data to them, as they have equiv­a­lent safe­guards in place; or
  • Where we use cer­tain ser­vice providers who are estab­lished out­side of the EEA, we may use spe­cif­ic con­tracts or codes of con­duct or cer­ti­fi­ca­tion mech­a­nisms approved by the Euro­pean Com­mis­sion which give per­son­al data the same pro­tec­tion it has in Europe.

If none of the above safe­guards is avail­able, we may request your explic­it con­sent to the spe­cif­ic trans­fer. You will have the right to with­draw this con­sent at any time. 

7. DATA SECURITY

We have put in place secu­ri­ty mea­sures to pre­vent your per­son­al data from being acci­den­tal­ly lost, used, altered, dis­closed, or accessed with­out autho­riza­tion. We also allow access to your per­son­al data only to those employ­ees and part­ners who have a busi­ness need to know such data. They will only process your per­son­al data on our instruc­tions and they must keep it con­fi­den­tial. 

We have pro­ce­dures in place to deal with any sus­pect­ed per­son­al data breach and will noti­fy you and any applic­a­ble reg­u­la­tor of a breach if we are legal­ly required to. 

8. DATA RETENTION

We will only retain your per­son­al data for as long as nec­es­sary to ful­fill the pur­pos­es we col­lect­ed it for, includ­ing for the pur­pos­es of sat­is­fy­ing any legal, account­ing, or report­ing require­ments.

When decid­ing what the cor­rect time is to keep the data for we look at its amount, nature and sen­si­tiv­i­ty, poten­tial risk of harm from unau­tho­rized use or dis­clo­sure, the pro­cess­ing pur­pos­es, if these can be achieved by oth­er means and legal require­ments. 

For tax pur­pos­es the law requires us to keep basic infor­ma­tion about our cus­tomers (includ­ing Con­tact, Iden­ti­ty, Finan­cial and Trans­ac­tion Data) for six years after they stop being cus­tomers.  

In some cir­cum­stances we may anonymize your per­son­al data for research or sta­tis­ti­cal pur­pos­es in which case we may use this infor­ma­tion indef­i­nite­ly with­out fur­ther notice to you. 

9. YOUR LEGAL RIGHTS

Under data pro­tec­tion laws you have rights in rela­tion to your per­son­al data that include the right to request access, cor­rec­tion, era­sure, restric­tion, trans­fer, to object to pro­cess­ing, to porta­bil­i­ty of data and (where the law­ful ground of pro­cess­ing is con­sent) to with­draw con­sent. 

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exer­cise any of the rights set out above, please email us at info@speakmoreclearly.com.

You will not have to pay a fee to access your per­son­al data (or to exer­cise any of the oth­er rights). How­ev­er, we may charge a rea­son­able fee if your request is clear­ly unfound­ed, repet­i­tive or exces­sive or refuse to com­ply with your request in these cir­cum­stances.  

We may need to request spe­cif­ic infor­ma­tion from you to help us con­firm your iden­ti­ty and ensure your right to access your per­son­al data (or to exer­cise any of your oth­er rights). This is a secu­ri­ty mea­sure to ensure that per­son­al data is not dis­closed to any per­son who has no right to receive it. We may also con­tact you to ask you for fur­ther infor­ma­tion in rela­tion to your request to speed up our response.  

We try to respond to all legit­i­mate requests with­in one month. Occa­sion­al­ly it may take us longer than a month if your request is par­tic­u­lar­ly com­plex or you have made a num­ber of requests. In this case, we will noti­fy you. 

If you are not hap­py with any aspect of how we col­lect and use your data, you have the right to com­plain to the Infor­ma­tion Commissioner’s Office (ICO), the UK super­vi­so­ry author­i­ty for data pro­tec­tion issues (www.ico.org.uk). We should be grate­ful if you would con­tact us first if you do have a com­plaint so that we can try to resolve it for you. 

10. THIRD-PARTY LINKS

This web­site may include links to third-par­ty web­sites, plug-ins and appli­ca­tions. Click­ing on those links or enabling those con­nec­tions may allow third par­ties to col­lect or share data about you. We do not con­trol these third-par­ty web­sites and are not respon­si­ble for their pri­va­cy state­ments. When you leave our web­site, we encour­age you to read the pri­va­cy notice of every web­site you vis­it. 

11. COOKIES

You can set your brows­er to refuse all or some brows­er cook­ies, or to alert you when web­sites set or access cook­ies. If you dis­able or refuse cook­ies, please note that some parts of this web­site may become inac­ces­si­ble or not func­tion prop­er­ly. For more infor­ma­tion about the cook­ies we use, please see