Privacy Policy

This privacy policy relates to how Relax Me Online Australia Pty. Ltd. ("JS", “we”, “our” or “us”) collects and handles your personal information and applies to your use of our services, whether you are making an enquiry regarding our services or engaging us to provide our services on the Platform (we will refer these as the “Services”). It also applies to your use of our website located at jasonstephenson.net and your use of our Facebook page located at https://www.facebook.com/JasonStephensonMeditation, Facebook group located at https://www.facebook.com/groups/JSLoveandCompassion, our YouTube pages located at https://www.youtube.com/channel/UCqPYhcdFgrlUXiGmPRAej1w], https://www.youtube.com/channel/UCnj31fpPRsSJLchEKMEChrw, https://www.youtube.com/channel/UCKqP5dghQMua9l6ZfZi9V3A, our Instagram page located at https://www.instagram.com/jasonstephensonmeditation/, our LinkedIn page located at https://www.linkedin.com/in/jason-stephenson-884a33149/, our Pinterest page located at https://www.pinterest.com.au/jasonstephensonmeditation/, our Tik Tok page located at https://vm.tiktok.com/J1HQFFb/ and any other social media sites of ours from time to time (we’ll refer to them together as the “Websites”) and your use of our associated application (if any) (the “App”) (the Websites and App hereinafter collectively known as the “Platform”).

We are committed to protecting the privacy of all our clients. The Privacy Act (1988) (Cth) (Privacy Act) and the Australian Privacy Principles (Privacy Principles) set out in Schedule 1 of the Privacy Act, govern the collection, storage, use, and disclosure of information by which individuals may be identified. Further, to the extent applicable, we comply with EU General Data Protection Regulation 2016/679 (GDPR) and the California Consumer Privacy Act (CCPA).

We may update the privacy policy from time to time at our sole discretion. Any variations become effective on posting the updated privacy policy and we shall have no obligation to provide you with individual notice of such changes. Your continued use of the Services following the publication of any amended privacy policy shall signify your acceptance of that amended privacy policy, except where we are otherwise obliged by law to seek your direct consent.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING OUR SERVICES. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES.

WHAT INFORMATION DO WE COLLECT?

This privacy policy covers all information collected via your use of the Services and the Platform, as well as information supplied to us in person, by phone, by writing (including email) or in any other way. The information we collect can be broken down into the following types:

“Personal Information” means information that can be used to personally identify you such as your name, residential address, email address, contact number and payment details. We do not collect or process the Personal Information of anyone under the age of 18 without the consent of their parent or guardian and otherwise in accordance with our Terms.

“Usage Information” means anonymous aggregate data that is automatically collected through your use of our Platform. This includes information that identifies your device, your operating system, your IP address and dates and times that you access and use the Platform. This information is used for statistical analysis to help us to improve the Services to the benefit of all users.

The GDPR recognises that Usage Information, whilst for the most part anonymous, can be cumulatively used to directly or indirectly identify you. Usage Information that can be used to identify you in any way, together with your Personal Information, shall collectively be referred to in this privacy policy as “Personal Data”.

HOW DO WE COLLECT YOUR INFORMATION

Personal Information is collected directly from you when you:

make an account for our services

If you choose to register and create an account with us in order to access our Services, we require you to provide your full legal name, location, email address and credit card details (for the purposes of charging you the agreed fees for the Services). We need this information to create an account for you so that you can access the Services, we can correspond with you about delivery of the Services and so that you pay for the Services. If you do not provide these details, we cannot provide the Services.

If you do not provide these details we may be limited in how we can perform the Services.

contact us via our website, email, telephone or otherwise;
access, browse, use, follow, like, comment or otherwise interact with our Platform;
sign up to our mailing list: from time to time we may offer you the opportunity to subscribe to emails, newsletters or other direct marketing communications about our products and services. We will request your full name and a valid email address in order to sign you up to such lists.

It is your choice to provide Personal Information to us. Wherever it is lawful and practicable, you have the option not to identify yourself when interacting with us. Please be aware that it may be necessary for us to collect your Personal Information to enable us to provide the Services to you. As such, if you do not wish to provide your Personal Information, we may not be able to provide the Services to you in a fully operational form or at all.

COOKIES

We may collect anonymous Usage Information on our Platform through Google Analytics, Facebook Ad Analytics and other user/data analytics sites/programs from time to time, which utilises cookies, pixel tags and other tracking technologies (collectively “Cookies”). Cookies are small packets of data that are downloaded onto your device when you access a website. Cookies hold specific information that helps a website ‘remember’ your actions and preferences over time. These are the types of Cookies that we may use to operate our Services:

Strictly Necessary Cookies – these Cookies are essential to making sure the Platform works correctly, and record information that allows you to move around the Websites and navigate their features.

Performance Cookies – these Cookies collect information about how you use the Platform, such as how often you access the Platform and if you encounter any errors.

Functionality Cookies – these Cookies allow our Platform to remember the choices you make to provide a more personalised experience.

Targeting or Advertising Cookies – these Cookies deliver targeted advertising to you based on your interests and use of the Platform.

Cookies can stay on your device temporarily (Session Cookies) or until you manually delete them (Persistent Cookies).

HOW DO WE USE YOUR INFORMATION

Legimate purposes that you agree we may use your Personal Data for include but are not limited to the following:

to respond to requests or correspondence submitted by you;
to provide the Services;
to improve and develop the Services;
to inform you of Services which may be of interest to you;
to process your payment for any Services;
to improve the functioning of the Platform;
to prevent, detect and investigate potential illegal activities, security breaches and fraud.

For the avoidance of doubt, we will only use your Personal Data for purposes that you would reasonably expect us to use your Personal Data for in connection with providing the Services to you, or where we are required by law to collect your Personal Data. We will not sell, rent, or licence your email address or any of your Personal Data.

WHO WE DISCLOSE YOUR INFORMATION TO

You agree and consent that we may disclose your Personal Data to:

employees, service providers and contractors of JS;
authorities, including police and regulators if JS is required to do so by law.

We may use de-identified wellbeing survey data, other survey data and data regarding use of our Platform for purposes including research and analysis, case studies, marketing and improving and continuing to develop our Services.

For the avoidance of doubt, all employees, consultants, contractors and agents of ours are bound by Australian privacy laws.

You can withdraw your consent for us to share your Personal Data with third parties at any time by emailing us at support@jasonstephenson.net, but please note that withdrawal of such consents may affect your ability to access and use the Services.

YOUR RIGHTS TO YOUR INFORMATION

In accordance with the GDPR, we acknowledge the right of EU citizens to:

have their data erased that is no longer being used for a legitimate purpose;

request a copy of all Personal Data held about you by us in a readable format; and
request restricted processing of your Personal Data whilst any complaints or concerns are being resolved.

To erase, request a copy of or restrict processing of your Personal Data, please email us at support@jasonstephenson.net.

Upon your written request we will provide you with a copy of your Personal Data that we hold unless:

we reasonably believe that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety;
giving access would have an unreasonable impact on the privacy of other individuals;
your request for access is frivolous or vexatious;
the information relates to existing or anticipated legal proceedings between us and you, and would not be accessible by the process of discovery in those proceedings;
giving access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
giving access would be unlawful;
denying access is required or authorised by or under an Australian law or a court/tribunal order;
we have reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to our functions or activities has been, is being or may be engaged in and giving you access would be likely to prejudice the taking of appropriate action in relation to those matters;
giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
giving access would reveal evaluative information generated within the entity in connection with a commercially sensitive decision-making process.

ACCESSING, REVIEWING AND CHANGING YOUR INFORMATION

We cannot modify your Personal Information without your instruction. You can update your details with us at any time by emailing us at support@jasonstephenson.net. You acknowledge that it is your responsibility to maintain the truth, accuracy, and completeness of your information at all times and your failure to do so may inhibit our ability to provide the Services. We shall have no liability to you or any third party arising from your failure to keep your information up to date.

DIRECT MARKETING

For the purposes of this privacy policy, “Direct Marketing” is the promotion of goods and services directly to you including through emails, phone calls, sms, push notifications and the post.

How we use your Personal Data for Direct Marketing is tightly controlled by the Privacy Act. We will follow those laws to ensure you only receive direct marketing in circumstances where you are expecting to. Under the Privacy Act we may use your Personal Data for the purposes of Direct Marketing if:

we collected the information directly from you; and
you would reasonably expect us to use or disclose your Personal Data for the purpose of direct marketing.

As set out above, we may use your Personal Data to provide you with information regarding our Services and your Usage Information to provide you with customised recommendations regarding use of our Platform (either by email, sms or through the Platform).

Unless it would be impracticable or unreasonable, we need your consent when:

collecting your Personal Data from a third party for the purpose of Direct Marketing; or
you would not reasonably expect to receive the Direct Marketing.

If at any time you want to know who provided us with your Personal Data, then please send a request to us at support@jasonstephgenson.net. We will provide the details of that third party within a reasonable time and without charge.

We recognise your right under the Spam Act 2003 (Cth) and the GDPR to opt out from Direct Marketing, and as such these consents can be modified at any time by emailing us at support@jasonstephenson.net or clicking unsubscribe on any Direct Marketing communications. We will always provide a simple means for you to “opt-out” from receiving direct marketing, which typically involves an “opt-out” or “unsubscribe” link on emails, a check box on the collection notice or through a pop-up on your screen when you provide personal information on our Website or via the App.

We will not use or disclose your Personal Data for the purposes of Direct Marketing material if you have previously told us not to.

If at any time in the future you do not want us (or one of our service providers) to send you Direct Marketing material or you wish to cancel a previous consent, please inform us by contacting us at support@jasonstephenson.net. We will affect the change in a reasonable time and without charge.

SECURITY

We protect your Personal Data through technical security measures i.e. firewalls, encryption that limit the risk of loss, disclosure, or unauthorised access. No security measures are, however, 100% secure so we cannot guarantee the security of your information or data at any time. To the extent permitted by law, we accept no liability for any breach of security, or direct hacking of our security measures, or any unintentional disclosure, loss or misuse of any information or data or for the actions of any third parties that may obtain any information or data.

Notwithstanding the above, we acknowledge our obligation to report any data breach that is likely to risk the rights and freedoms of natural persons to the Australian Information Commissioner and, where our data breach involves the information of EU citizens, report to the European Data Protection Supervisor. We will also inform you, where possible, if your data has been breached in circumstances where it poses a risk of serious harm or your rights and freedoms.

We also train all staff or contractors who may have access to your Personal Data about this privacy policy and our obligations under the Privacy Act, Privacy Principles and GDPR. For more information on our internal policies, email us at support@jasonstephenson.net.

THIRD PARTY LINKS

Please note that this privacy policy does not cover the information practices of third party websites which may be linked to our Platform. Notwithstanding our encouragement for third parties to adopt similar privacy policies as ours, we are not responsible for their collection and use of your Personal Data. Please refer to the privacy policies and statements of the relevant third party website to obtain information regarding their information collection, use and disclosure policies.

OVERSEAS DISCLOSURE

We may, in the course of providing the Services to you, transfer your Personal Data to overseas countries that are deemed by the EU Commission as having an ‘adequate’ level of Personal Data protection. Where we transfer data to a third party in a country where no adequacy decision has been made, we warrant that any person or entity handling your data in those countries are bound under contract to meet the requirements of the Privacy Act, Privacy Principles and GDPR.

For the avoidance of doubt, we may transfer any data to an overseas third party with your express or implied consent, and the above condition only applies in the case of a data transfer or transmission to our related business entities in other countries.

CONTACT

Thank you for taking the time to read our privacy policy. If you have any questions regarding our privacy policy, you can reach our privacy officer at jaime@jasonstephenson.net.

If you are not satisfied with our handling of your Personal Data, or have any other concern over our privacy policy, then you may lodge a formal complaint with the Office of the Australian Information Commissioner (for more information, please see www.oaic.gov.au) or with the European Data Protection Supervisor (for more information, please see https://edps.europa.eu).