Circle Leadership Global Privacy Notice

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 unauthorized access, disclosure, or breach of security affecting Personal Data
• "Personal Data" means any information relating to an identified or identifiable person

Introduction

Circle Leadership Global ("we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Notice explains how we collect, use, and protect personal information gathered through our services, platforms, and interactions with you.

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 program 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, 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:

• Deliver our leadership programs
• Process payments
• Communicate with you
• Screen for potential risks or fraud
• Provide marketing information (with your consent)
• Improve and optimize our website and services
• Generate analytics about customer behavior
• Maintain secure records of our interactions

Client Employee Information

We use employee information provided by our corporate clients to:

• Deliver leadership development programs
• Send program-related communications
• Manage program participation and progress
• Generate anonymized aggregate reports
• Provide access to learning platforms
• Track completion and engagement
• Support program administration

We process this information under data processing agreements with our corporate clients and:

• Only for the duration of the program 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 organization and individual employees

Security Incident Management

We maintain strict procedures for handling security incidents. In the event of unauthorized access or disclosure of personal information, we will:

1. Immediately assess and contain the incident
2. Notify affected individuals and relevant authorities as required by law
3. Investigate and implement preventive measures
4. 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

Kajabi Security

• SSL/TLS encryption
• Secure payment processing
• Regular security updates
• Automated backups
• 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
• Moderation tools for content security

Account Holder Responsibilities

As an Account Holder, you have specific responsibilities when providing us with personal information about others:

1. You must ensure you have appropriate consent to share personal information
2. You must inform us if consent is withdrawn
3. You are responsible for maintaining accurate information
4. You must notify us immediately of any security incidents
5. You must use our platforms securely and in compliance with our policies

Your Privacy Rights

You have the right to:

1. Access your personal information
2. Request corrections to your data
3. Request deletion of your data
4. Opt out of marketing communications
5. Request data portability
6. Restrict processing
7. Object to processing

Data Retention

We retain your information:

• For the duration of our service relationship
• As required by law
• As needed for business purposes
• Until you request deletion

We maintain your personal information for as long as necessary to provide our services and fulfill our legal obligations. For active clients and program participants, this typically means retaining information throughout the duration of our service relationship.

Cookies and Tracking

Our websites and platforms use cookies and similar tracking technologies to enhance user experience and analyze 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 periodically to reflect changes in our practices or legal requirements. Significant changes will be communicated through our website or direct notification to affected individuals.

Contact Information

For any privacy-related inquiries or to exercise your privacy rights, please contact our Privacy Officer at:

Circle Leadership Global
16 Hastings Place, Buderim QLD 4556 Australia
Email: [email protected]
Version: 2.0
Last Updated: 31st December 2024