Website Privacy Policy

This Privacy Policy applies to all personal information collected by Sovier Agency (we, us or our) via the website located at sovier.com.au (Website).

1 What information do we collect?

The kind of Personal Information that we collect from you will depend on how you use the Website. The Personal Information which we collect and hold about you may include:

Your name, email address, postal address, phone number, date of birth, payment and billing details, and information about your use of our Website, including browsing behaviour, IP address, and device information collected through cookies and similar technologies. We may also collect information you voluntarily provide when contacting us, subscribing to our newsletter, or creating an account.

2 Types of information

The Privacy Act 1988 (Cth) (Privacy Act) defines types of information, including Personal Information and Sensitive Information.

Personal Information means information or an opinion about an identified individual or an individual who is reasonably identifiable:

1. whether the information or opinion is true or not; and
2. whether the information or opinion is recorded in a material form or not.

If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as "Personal Information" and will not be subject to this privacy policy.

Sensitive Information is defined in the Privacy Act as including information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive Information will be used by us only:

1. for the primary purpose for which it was obtained;
2. for a secondary purpose that is directly related to the primary purpose; and
3. with your consent or where required or authorised by law.

3 How we collect your Personal Information

1. We may collect Personal Information from you whenever you input such information into the Website, related app or provide it to us in any other way.
2. We may also collect cookies from your computer which enable us to tell when you use the Website and also to help customise your Website experience. As a general rule, however, it is not possible to identify you personally from our use of cookies.
3. We generally don't collect Sensitive Information, but when we do, we will comply with the preceding paragraph.
4. Where reasonable and practicable we collect your Personal Information from you only. However, sometimes we may be given information from a third party. In cases like this we will take steps to make you aware of the information that was provided by a third party.

4 Purpose of collection

1. We collect Personal Information to provide you with the best service experience possible on the Website and keep in touch with you about developments in our business.
2. We customarily only disclose Personal Information to our service providers who assist us in operating the Website. Your Personal Information may also be exposed from time to time to maintenance and support personnel acting in the normal course of their duties.
3. By using our Website, you consent to the receipt of direct marketing material. We will only use your Personal Information for this purpose if we have collected such information direct from you, and if it is material of a type which you would reasonably expect to receive from us. We do not use Sensitive Personal Information in direct marketing activity. Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature, such as an unsubscribe button link.
4. We will only send you direct marketing communications where you have provided explicit opt-in consent for each category of communication (including email, SMS, and push notifications). You may manage your marketing preferences at any time through your account settings or by contacting us directly, and we will honour all opt-out or unsubscribe requests within 5 business days of receipt.

5 Security, access and correction

1. We store your Personal Information in a way that reasonably protects it from unauthorised access, misuse, modification or disclosure. When we no longer require your Personal Information for the purpose for which we obtained it, we will take reasonable steps to destroy and anonymise or de-identify it. Most of the Personal Information that is stored in our client files and records will be kept for a maximum of 7 years to fulfil our record keeping obligations.
2. The Australian Privacy Principles:
   1. permit you to obtain access to the Personal Information we hold about you in certain circumstances (Australian Privacy Principle 12); and
   2. allow you to correct inaccurate Personal Information subject to certain exceptions (Australian Privacy Principle 13).
3. Where you would like to obtain such access, please contact us in writing on the contact details set out at the bottom of this privacy policy.
4. We retain Personal Information in accordance with the following category-specific periods: (1) client engagement records: 7 years post-service completion; (2) marketing consent documentation: indefinitely for regulatory compliance proof; (3) analytics and cookie data: 14 months; (4) transactional records: 7 years for tax compliance obligations. Destruction of Personal Information is carried out via secure deletion protocols documented in our Data Security Policy, with annual audits conducted to verify compliance with these retention schedules.

6 Complaint procedure

If you have a complaint concerning the manner in which we maintain the privacy of your Personal Information, please contact us on the contact details set out at the bottom of this policy. All complaints will be considered by MJ Carreno and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.

7 Overseas transfer

We use third-party service providers, some of which store and process Personal Information outside Australia, including in the United States. These include Google (analytics and email), Klaviyo (email marketing), Formspree (form submissions), Stripe (payments) and Hostinger (hosting).

By providing your Personal Information to us, you consent to it being disclosed to and processed by these providers in those locations. These recipients are not required to comply with the Australian Privacy Principles, and we will not be liable for mishandling of your information by an overseas recipient in those circumstances.

8 How to contact us about privacy

If you have any queries, or if you seek access to your Personal Information, or if you have a complaint about our privacy practices, you can contact us at mj@sovier.com.au.

9 Data breach notification

If we become aware of a data breach that is likely to result in serious harm to any affected individual, we will:

1. notify affected individuals without unreasonable delay (within 7 days where practicable), including details of what information was compromised, likely consequences, and steps we are taking;
2. notify the Office of the Australian Information Commissioner (OAIC) where serious harm is likely; and
3. maintain a breach register documenting all incidents, affected individuals, notifications issued, and resolution steps taken.

Notifications will be sent via email to the address we hold on file, or by other means if email is unavailable.