Circle Leadership Global Privacy Notice
Ninety Million Pty Ltd operates Circle Leadership Global and its associated website at https://www.circleleadershipglobal.com/ (hereafter referred to as the "Service"). Your privacy is critically important to us. This Privacy Notice explains how we collect, use, and protect personal information gathered through our services, platforms, and interactions with you. By using the Service, you agree to the collection and use of information in accordance with this policy.
Definitions
The following terms have specific meanings in this Privacy Notice:
- "Account Holder" means the primary account holder who has entered into our Master Services Agreement
- "Users" means all registered users of our services, including client employees and administrators
- "Data Protection Laws" means applicable privacy legislation including the Privacy Act 1988 (Cth, Australia), the General Data Protection Regulation (EU), and other applicable privacy laws
- "Security Incident" means any unauthorised access, disclosure, or breach of security affecting Personal Data
- "Personal Data" means any information relating to an identified or identifiable person
Introduction
This notice applies to all personal information processed through:
- Our website (www.circleleadershipglobal.com)
- Our Kajabi learning management platform
- Our Microsoft Office 365 environment
- Our Circle.so community platform
- Offline interactions and client delivery
Legal Framework
We operate under and comply with multiple data protection and privacy laws. Our privacy framework is designed to meet the requirements of applicable legislation while helping our clients comply with their own privacy obligations. We regularly review and update our practices to maintain compliance with evolving privacy regulations.
Personal Information Collection and Processing
Types of Information We Collect
We collect and process personal information necessary for delivering our services. This includes contact details such as your name and email address, professional information, and program participation data. We process this information as both a data controller and, in some cases, as a joint controller with our clients.
When working with corporate clients, we collect employee data including work email addresses, job titles, and program participation records. This processing is governed by our agreements with clients and applicable data protection laws.
Platform-Specific Data Collection
Our services operate through three main platforms:
Microsoft Office 365 serves as our primary business communication platform. We protect all communications and documents with enterprise-grade security features including Azure Active Directory authentication and advanced threat protection.
Through Kajabi, we deliver and track learning progress, maintaining strict data security through SSL encryption and secure access controls.
Our Circle.so community platform facilitates secure member interactions, with all data protected by AWS infrastructure security and comprehensive privacy controls.
Use of Your Information
Individual Client Information
We use your personal information to:
- Provide and maintain our Service, including delivery of our leadership programs
- Process payments
- Communicate with you and notify you about changes to our Service
- Allow you to participate in interactive features of our Service
- Provide customer support
- Screen for potential risks or fraud, and detect, prevent and address technical issues
- Provide marketing information (with your consent)
- Improve and optimise our website and services through analytics and usage monitoring
- Maintain secure records of our interactions
Client Employee Information
We use employee information provided by our corporate clients to:
- Deliver leadership development processes
- Send process-related communications
- Manage process participation and progress
- Generate anonymised aggregate reports
- Provide access to learning platforms
- Track completion and engagement
- Support process administration
We process this information under data processing agreements with our corporate clients and:
- Only for the duration of the engaement plus any agreed retention period
- In accordance with client-specific data handling requirements
- With strict access controls and security measures
- Never for direct marketing without explicit permission from both the client organisation and individual employees
International Transfer of Data
Your information, including Personal Data, may be transferred to and maintained on systems located outside of your state, province, country, or other governmental jurisdiction where data protection laws may differ from those of your jurisdiction. We do not transfer Personal Data to third-party entities except as required to deliver our services, such as for payment processing purposes, and we take reasonable steps to ensure your data is treated securely and in accordance with this Privacy Notice wherever it is processed.
Security Incident Management
We maintain strict procedures for handling security incidents. In the event of unauthorised access or disclosure of personal information, we will:
- Immediately assess and contain the incident
- Notify affected individuals and relevant authorities as required by law
- Investigate and implement preventive measures
- Document the incident and our response
Data Security
Our commitment to data security is implemented through our primary platforms:
Microsoft Office 365 Security: Azure Active Directory authentication, multi-factor authentication, Advanced Threat Protection, Data Loss Prevention policies, email encryption, automated backups, and ISO 27001 compliance.
Kajabi Security: SSL/TLS encryption, secure payment processing, regular security updates, automated backups, and access controls.
Circle.so Security: AWS infrastructure security, SSL/TLS encryption, regular security updates, access control and user permissions, secure authentication, data backup and recovery, privacy-focused community controls, and moderation tools for content security.
While we strive to use commercially acceptable means to protect your Personal Data, no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee its absolute security.
Children's Privacy
Our Service does not specifically target anyone under the age of 18 ("Children"). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us so we can take appropriate action.
Account Holder Responsibilities
As an Account Holder, you have specific responsibilities when providing us with personal information about others:
- You must ensure you have appropriate consent to share personal information
- You must inform us if consent is withdrawn
- You are responsible for maintaining accurate information
- You must notify us immediately of any security incidents
- You must use our platforms securely and in compliance with our policies
Your Privacy Rights
You have the right to:
- Access and receive a copy of the personal information we hold about you
- Request corrections to any inaccurate data
- Request deletion of your data
- Opt out of marketing communications
- Request data portability
- Restrict processing
- Object to processing
To exercise these rights, or to be informed about what Personal Data we hold about you, please contact us at [email protected].
Data Retention
We maintain your personal information for as long as necessary to provide our services and fulfil our legal obligations. For active clients and program participants, this typically means retaining information throughout the duration of our service relationship, as required by law, as needed for legitimate business purposes, or until you request deletion.
Cookies and Tracking
Our websites and platforms use cookies and similar tracking technologies to enhance user experience and analyse service usage. These technologies are essential for platform functionality and help us improve our services through analytics and performance monitoring. Marketing-related cookies are only used with your consent, and you can manage your cookie preferences through your browser settings.
Changes to This Notice
We may update this Privacy Notice from time to time to reflect changes in our practices or legal requirements. We will notify you of any changes by posting the new Privacy Notice on this page, and for significant changes, via email and/or a prominent notice on our Service prior to the change becoming effective. The "Last Updated" date will be revised accordingly.
Contact Us
If you have any questions about this Privacy Notice, or wish to make a complaint or exercise your privacy rights, please contact us:
- By email: [email protected]
- By visiting: https://www.circleleadershipglobal.com/contact
- By mail: 22 Corella St. Forest Glen, Qld 4556 Australia
Version: 3.0
Last Updated: 30 June 2026
