Introduction

This website, sagacityrising.com, is owned and operated by Mya Joseph of By Design Solutions Pty Ltd T/A Sagacity Rising, ACN: 609 364 070.

This document sets out my Privacy Policy. It describes how I collect and manage your personal information when you interact with this site. I take this responsibility very seriously. If you have any questions or concerns about how your personal information is being handled, please do not hesitate to contact me.

I am committed to complying with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).

I understand that visitors from the EU (European Union) may access this site, so I also aim to comply with the General Data Protection Regulations (GDPR).

Contact Details

Mya Joseph

Sagacity Rising

Email: support@sagacityrising.com

Personal Information

If you engage with me via this website, I may ask to collect the following kinds of personal information from you, including:

  • First Name
  • Last Name
  • Email address
  • Location (country/region you live in)
  • Activity on my website
  • Activity on my mailing list
  • Payment details (via third party apps like Paypal or Stripe)
  • Your opinion about future topics, products or services that may interest you

Collection and Use

I may collect your personal information by various means including:

  • opt-in forms on this website
  • newsletter subscription (ConvertKit)
  • sign up for webinar / seminar / events
  • website interactions – cookies, IP address, analytics
  • surveys
  • provided verbally or written by you in meetings, events – online or in person
  • social media – like Facebook, Twitter, Instagram, LinkedIn
  • if you join my community on Mighty Network
  • messenger services – like Facebook Messenger, WhatsApp
  • when you email or contact me
  • text message via mobile phone interactions
  • onboarding forms, questionnaires and contracts if you become a client
  • invoicing (Xero)
  • online booking services (Acuity Scheduling)
  • referrals from third parties

I use this information to:

  • provide you with relevant news and updates about my services
  • improve this website and the services I provide
  • respond to your enquiries

I will only collect your personal information:

  • with your full awareness and consent, such as when you email me, tick a checkbox or fill in a form to provide me with information
  • if I need it to provide you with information or services that you request
  • if I am legally required to collect it
  • for necessary administrative processes if you become my client
  • if I believe that I can demonstrate a legitimate interest in using your data for marketing purposes, although I will always give you a choice to opt out

Sensitive Information

I understand that some personal information is particularly sensitive.

If you decide to become a client, I may ask you to provide me with sensitive information. The types of sensitive information that I collect, and the securing, storing and handling of this sensitive information is set out in detail in my client service contracts. If you have any questions, please feel free to contact me: support@sagacityrising.com.

I will only collect sensitive information by the means specified above and for these specified purposes:

  • When you become a client, you will be sent on-boarding forms, contracts or similar, requesting any sensitive information that I require to start working with you, and explaining how it will be handled.
  • As a client you may reveal sensitive information to me, either written or verbally, which will be collected and managed in accordance with the contracts I have signed with you.
  • My purpose in collecting this information is always to provide the most effective services to you as a client.

Professional Considerations

As a member of the ICF (International Coaching Federation) I am governed by their code of ethics, which can be reviewed here: https://coachfederation.org/code-of-ethics

Section 4 highlights specifics around my obligations on Privacy and Confidentiality.

Use of Personal Information

Reasons why I may disclose your personal information include:

  • to provide you with the services you have requested
  • to carry out your instructions
  • to send you products that you have purchased
  • when using sub-contractors or other third parties to deliver services requested

In order to do this, I may share some relevant personal information – on a strictly need to know basis – with:

  • my website provider (WordPress)
  • my email marketing provider (ConvertKit)
  • my appointment scheduling service (Acuity Scheduling)
  • my accounting software (Xero)
  • the programs I use for webinars and online communication (Skype or Zoom)
  • my online membership community provider (Mighty Networks)
  • Australia Post or courier companies if sending physical items that you have requested

Legal Disclosure

I will also disclose your information if required by law to do so or in circumstances permitted by the Privacy Act – for example, where I have reasonable grounds to suspect that unlawful activity or misconduct of a serious nature that relates to my functions or activities has been, is being or may be engaged in, and in response to a subpoena, discovery request or a court order.

If you have any concerns regarding the disclosure of your personal information, please do not hesitate to get in touch with me to discuss this personally.

Disclosure Overseas

I will use all reasonable means to protect the confidentiality of your personal information while in my possession or control. I will not knowingly share any of your personal information with any third party other than the service providers who assist me in providing the information and/or services I am providing to you. To the extent that I do share your personal information with a service provider, I only do so if that party has agreed to comply with my privacy standards as described in this Privacy Policy, or if I am satisfied that they have a suitably rigorous privacy policy of their own. However, some of my service providers may be overseas and may not be subject to Australian Privacy Laws or compliant with GDPR. Please contact me if you have any concerns about the potential disclosure of your information.

Security

I take reasonable physical, technical and administrative safeguards to protect your personal information from misuse, interference, loss, and unauthorised access, modification and disclosure.

I do not store information unnecessarily and when I no longer need to retain the information for the purposes of serving you, I dispose of your personal information appropriately.

I manage risks to your personal information by:

  • storing your information on password protected computer/s
  • having 2 Factor Authentication (2FA) on cloud services and on other apps that support it
  • allowing only key personnel to have access to sensitive information
  • providing information to service providers, sub-contractors and third parties on a strictly need-to-know basis
  • conducting yearly audits of my security systems

As mentioned above, your personal information may also be stored with a third-party provider, where it will be managed under their security policies. Here are my current providers:

  • Acuity Scheduling
  • Airtable
  • ConvertKit
  • Dropbox
  • Google Analytics
  • Google Drive
  • Microsoft Outlook
  • Mighty Networks
  • OneDrive
  • Paypal
  • Skype
  • Stripe
  • WordPress
  • Xero
  • Zoom

From time to time I may combine information provided by you with information gathered from these providers. If you do not wish this to occur, please contact me.

Access to Information

You can contact me to access, correct or update your personal information at any time. I will endeavour to make your information available to you within 30 days, unless I am subject to a confidentiality obligation, or some other restriction on giving access to the information which permits me to refuse you access under the Privacy Act, and I believe there is a valid reason for doing so.

Please contact me at support@sagacityrising.com.

Complaints

If a breach of this Privacy Policy occurs, you may contact me by sending an email outlining your concerns to me at support@sagacityrising.com. I shall communicate with you in the intention of seeking a win/win resolution for any dispute through negotiation and discussion.

If you are not satisfied with my response to your complaint you may seek a review by contacting:

  • a mediator that is appointed by agreement between both parties
  • the Office of the Australian Information Commissioner using the information available at http://www.oaic.gov.au/privacy/privacy-complaints
  • the ICF (International Coaching Federation) should the issue pertain to coaching services rendered by me

Notification of Change

I may change my Privacy Policy from time to time, at my sole discretion. I encourage visitors to frequently check this page for any changes to my Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.

Notification of Breach

If I have reason to suspect that a serious data breach has occurred and that this may result in harm or loss to you, I will immediately assess the situation and take appropriate remedial action. If I still believe that you are at risk, I will notify the Office of the Information Commissioner and either contact you directly, or if that is not possible, publicise a notification of the breach on this website.