Privacy policy

1. About this policy

This policy explains what personal information Business on Pointe collects, why it is collected, who it is shared with, how it is protected, and how you can access, correct or complain about it.

It applies to businessonpointe.com, every enquiry and onboarding form operated by Business on Pointe, our free resources, and all client work delivered under any Business on Pointe package.

Business on Pointe is a sole operator consultancy. "We", "us", "I" and "my" all mean Ciara Siobhan Philippa trading as Business on Pointe. There is no team, no agency, and no third party staff with access to your information.

2. Where we stand under the Privacy Act

Business on Pointe turns over less than $3 million a year and does not trade in personal information, so the small business exemption in section 6D of the Privacy Act 1988 (Cth) currently applies to us.

We handle your information in line with the Australian Privacy Principles regardless, because that is the standard you should expect. If our situation changes, this policy changes with it.

3. What we collect

About you: name, email address, phone number, preferred way of being contacted, and your studio's location.

About your studio: studio name, studio location, website or Instagram handle, styles taught, class types, how long you have been operating, and other associated business information to perform Business on Pointe services.

From working together: notes from calls, the briefs and reports we produce for you, and whether our emails to you were delivered, opened or clicked.

Automatically: your IP address and browser type, captured by our website host and form relay for security.

Most of the above is information about a business, not a person. Where your studio is a sole trader and you are identifiable from it, we treat it as personal information.

3.1 What we do not collect

We do not ask for and do not want:

• Sensitive information as defined in the Privacy Act 1988, including health information, racial or ethnic origin, sexual orientation, religious or political beliefs, or criminal record
• Government identifiers such as tax file numbers, driver licence numbers or passport numbers
• Payment card numbers or bank account details through any web form
• Information about your students as individuals

If you are a studio owner, please do not send us student lists, student health information, injury records, incident reports or membership databases. If you send us information of this kind we will tell you, and we will securely delete it unless you have a specific reason for us to hold it that we have both agreed to in writing.

3.2 Dealing with us anonymously

You can browse businessonpointe.com and read our free resources without telling us who you are. Where it is practical, you can also make a general enquiry using only a first name or a pseudonym. We will need your real name and contact details once we are delivering a paid service, issuing an invoice, or where the law requires it, because we cannot do those things anonymously.

4. How and why we collect information

Why we collect it. To answer your enquiry, book a call, deliver the service you bought, send you our free resources if you asked for them, write a strategy brief that is actually about your studio, invoice you, and keep the records tax law requires.

How we collect it. We collect personal information:

• Directly from you through forms you have completed
• Directly from you by email, phone, video call or during a strategy session
• From you when you provide access to a Google Business Profile, social account or analytics account so we can perform work for you
• Automatically, as described in the "What we collect" section above
• Occasionally from a public source such as your studio website or public social profile, when we are preparing a proposal or an audit you have asked for

If someone refers you to us and gives us your contact details, we will only use them to contact you once, we will tell you who referred you, and we will delete your details if you are not interested.

We do not sell, rent or trade personal information. We do not disclose your information to other studios unless the information is already publicly available or has been voluntarily shared.

5. Cookies and analytics

Our website uses cookies and similar technologies, web analytics, and the Meta Pixel to understand how visitors use the site and to measure and improve our marketing.

• Strictly necessary cookies keep the site secure and make our forms work. These are always on.
• Analytics tell us, in aggregate, which pages are visited and how people move through the site, so we can improve it.
• The Meta Pixel and advertising cookies let us measure our advertising and show relevant content to people who have visited the site.

Where the law requires your consent for non-essential cookies, we ask for it through our cookie banner before those cookies are set, and you can change your choice at any time. You can also block or delete cookies in your browser settings, though some parts of the site may not work as well.

Some of these analytics and advertising providers are based overseas and may process your information outside Australia. See "Who we share it with" below.

Our forms also save your partly finished answers in your own browser so you do not lose them. That data stays on your device until you submit the form, and clearing your browser data for our site removes it.

6. Direct marketing

You will only receive our free resources and marketing emails if you asked for them, by submitting a form or by agreeing to receive them as part of a package.

Every marketing email we send identifies Business on Pointe as the sender, includes our contact details, and includes a working unsubscribe link. Unsubscribing takes effect immediately and always within five working days, as required by the Spam Act 2003.

Unsubscribing from our free resources does not stop service emails about work we are actively doing for you. If you want those to stop as well, you are ending the engagement, and you can say so by email.

You can also unsubscribe by emailing home@businessonpointe.com with "unsubscribe" in the subject line.

7. Who we share it with

We use a small number of providers, and each gets only what it needs.

Your information is therefore held outside Australia, mainly in the EU. We choose providers with published contractual data protection terms, but once information sits overseas, Australian law may not be enforceable against that provider.

We may also disclose personal information:

• To our accountant or bookkeeper for invoicing and tax
• To a professional adviser where we need legal advice
• Where required or authorised by law, including to a court, tribunal or regulator
• Where you have given us permission

If you would rather your information was not held overseas, tell us before you submit a form. We can take an enquiry by email or phone.

8. How we use AI

We use AI tools to help draft content ideas, briefs, wording and research. Information about your studio, such as your styles, class types, capacity and marketing challenges, may go into an AI tool as part of that.

A person always decides. Nothing about your quote, your acceptance into a package or what you are offered is decided by a computer. Every recommendation and assessment is reviewed by Ciara before it reaches you. Where we select the tools, we turn off using your information to train AI models.

9. Security and data breaches

All form submissions travel over HTTPS. No API keys or passwords are publicly available. Accounts use unique passwords and multi factor authentication where available, and access is limited to one person.

No system is completely secure. If we become aware of unauthorised access to, unauthorised disclosure of, or loss of personal information we hold, we will:

1. Contain the breach and assess what information was involved.
2. Assess within 30 days whether the breach is likely to result in serious harm.
3. Notify you directly, and notify the Office of the Australian Information Commissioner, if serious harm is likely.
4. Tell you what happened, what information was involved, and what you should do about it.

We will do this whether or not the Notifiable Data Breaches scheme legally binds us at the time.

If you think your information has been compromised, email home@businessonpointe.com straight away.

10. How long we keep it

We keep personal information only for as long as we have a reason to, and we delete it when you ask us to unless the law says we must keep it.

In practice that means enquiries that never become clients are cleared out periodically, unsubscribe records are kept so we can honour your opt out, and financial records are held for seven years because the Australian Taxation Office requires it. Any access you gave us to your accounts is removed when the engagement ends.

11. Accessing and correcting your information

You can ask us at any time to:

• Tell you what personal information we hold about you
• Give you a copy of it
• Correct anything that is wrong or out of date
• Delete it

Email home@businessonpointe.com. We will respond within 30 days. There is no charge for a reasonable request. If a request is repeated or unusually large, we will tell you what it would cost before doing anything.

We will need to confirm you are who you say you are before we release information. Usually that means replying from the email address we hold.

There are limited situations where we may refuse. These include where releasing the information would unreasonably affect another person's privacy, where the request is frivolous, or where the law requires us to keep the record. If we refuse, we will tell you why in writing and how to complain.

12. Complaints

Email home@businessonpointe.com with "Privacy complaint" in the subject line. We will acknowledge within 5 working days and respond properly within 30 days.

If that does not resolve it, you can contact the Office of the Australian Information Commissioner at oaic.gov.au, on 1300 363 992, or at GPO Box 5218, Sydney NSW 2001. Because the small business exemption currently applies to us, the OAIC may decline to investigate on jurisdictional grounds. That does not change our commitment to sort it out with you.

13. Other law that applies to us

The following apply to Business on Pointe now:

14. If you are in the United Kingdom or the European Economic Area

If you are located in the UK or the EEA, the UK GDPR or EU GDPR may apply to our handling of your personal information regardless of our position under Australian law.

Controller. Ciara Siobhan Philippa trading as Business on Pointe, contactable at home@businessonpointe.com.

Lawful bases we rely on:

• Consent, for our free resources and other marketing email. You can withdraw consent at any time by unsubscribing, without affecting the lawfulness of what we did before you withdrew it.
• Performance of a contract, for delivering a service you have purchased.
• Legitimate interests, for responding to an enquiry you initiated, keeping business records, and securing our systems.
• Legal obligation, for tax and financial records.

Your rights. You have the right to request access to your personal data, correction, erasure, restriction of processing, portability, and to object to processing based on legitimate interests. You also have the right to lodge a complaint with your local supervisory authority, or with the UK Information Commissioner's Office at ico.org.uk.

Transfers. Your data will be transferred to and stored in Australia. Australia does not currently hold an EU adequacy decision. We rely on your explicit consent, or on the necessity of the transfer to perform a contract with you, as the basis for that transfer.

No EU representative. Business on Pointe does not currently have an establishment or representative in the EU or the UK. We handle a very small volume of UK and EEA data. If that changes we will appoint a representative and update this section.

15. Additional items

Children. We sell to adult studio owners. Our forms are not for anyone under 18 and we do not knowingly collect children's information. If your studio teaches children, we still do not need anything about individual students.

Other websites. We link to studio sites, social platforms and news sources. This policy does not cover them. Read their privacy policies before giving them information.

Changes. We will update this policy when our practices change, when the law changes, or when we add a service or a provider. The version number and effective date at the top of this document will change with it. Material changes affecting how we use information we already hold will be notified to free resource subscribers and current clients by email before they take effect.

Change log

16. Contact us

Business on Pointe Ciara Siobhan Philippa ABN: 46 479 571 451 Email: home@businessonpointe.com Web: businessonpointe.com

We are a one person business. Email is the fastest way to reach us and the only way to make a formal privacy request.

If you would like this policy in another format, email us and we will provide it.