PRIVACY POLICY
Privacy Policy
1. Overview
This Privacy Policy applies to all websites and services owned and operated by SpiritCode Institute PTY LTD (ABN: 61930251867) ("we," "us," "our," or "the Company"), including but not limited to athinabailey.com and authenticenergy.org (collectively referred to as "the Website" or "our Websites"). This policy clearly outlines how we handle your personal information, your privacy rights, and our obligations under applicable laws.
For ease of use, any reference to "we," "us," or "the Company" explicitly refers to SpiritCode Institute PTY LTD and includes our employees, contractors, agents, and affiliates.
2. Acceptance of this Privacy Policy
By accessing or using any of our Websites or services, you explicitly acknowledge, understand, and accept the conditions and practices outlined in this Privacy Policy. Your continued use of our Websites and services constitutes your acceptance of this policy in full.
If you do not agree with the terms of this Privacy Policy, please do not use our Websites or services or provide us with your personal information.
3. Compliance with Australian Privacy Law
We explicitly respect your privacy rights under the Privacy Act 1988 (Cth) ("Privacy Act") and the associated Australian Privacy Principles (APPs). In accordance with these requirements, we manage and protect your personal information lawfully, securely, and transparently.
4. Compliance with the General Data Protection Regulation (GDPR)
We also explicitly uphold and protect your privacy rights if you are based in the European Union (EU) or the European Economic Area (EEA), in full compliance with the General Data Protection Regulation (GDPR). Your specific rights under the GDPR are clearly outlined in detail later in this Privacy Policy.
If you choose not to provide us with your personal information, you have the right to do so. However, this may significantly limit or negatively affect your access to our Websites, products, and services.
5. Contact Information
If you have questions about this Privacy Policy or our practices, please contact our designated Data Protection Officer (DPO) clearly at:
Email: team@spiritcodeinstitute.com
6. What is Personal Information?
In this Privacy Policy, the term “personal information” has the specific meaning provided under both the Privacy Act 1988 (Cth) ("Privacy Act") and the General Data Protection Regulation (GDPR).
Generally, personal information is any data or information relating to you that clearly identifies you, or from which your identity can be reasonably identified. Examples of personal information we collect may explicitly include (but are not limited to):
-
Name
-
Current mailing or residential address
-
Email address
-
Telephone number
-
Age or date of birth
-
Profession or occupation
-
Personal preferences and opinions
-
Any other information specifically requested on our Websites, during communications, or otherwise voluntarily provided by you.
We may also collect and process information that does not personally identify you. This includes anonymised or aggregated data, anonymous responses to surveys, statistical analysis of user behaviour on our Websites, and other non-personal information intended solely for research and analytics purposes.
Your personal information will not be sold, rented, shared, or disclosed in any manner other than as clearly described and permitted in this Privacy Policy.
7. Purpose of Collecting Personal Information
We collect, store, use, and disclose your personal information clearly and explicitly for the following business purposes:
-
To provide and deliver our products, services, courses, and coaching to you.
-
To send communications and information specifically requested by you, including newsletters, product updates, and other relevant content.
-
To promptly respond to your enquiries and provide accurate information, advice, or support regarding our existing and new services.
-
To grant you access to secure, protected, or restricted areas of our Websites, programs, or platforms.
-
To comply fully and transparently with any applicable law, legal obligations, regulatory requirements, lawful court orders, or governmental requests.
-
For internal business record-keeping, compliance, and administrative purposes.
-
For marketing purposes, including sending direct marketing communications (only where you have explicitly consented to receive these communications).
-
To conduct competitions, promotions, giveaways, or provide additional benefits to our clients and community.
-
To conduct market research, business analysis, product improvement, and website optimisation, aiming always to enhance your experience.
Your personal information will not be used or disclosed for purposes other than those clearly outlined in this Privacy Policy without your explicit consent or unless required by law.
8. Methods of Collecting Personal Information
We collect your personal information directly from you wherever possible. This collection happens clearly and explicitly when you:
-
Submit an enquiry or contact form about our services through our Website or by direct communication.
-
Register for an account, membership, or subscription on our Website or platforms.
-
Participate in conversations, consultations, or coaching sessions with our team or representatives.
-
Subscribe explicitly to our mailing lists, newsletters, or other communication channels.
-
Become our client or customer, or purchase, access, and utilise any of our products, programs, or services.
If collecting personal information directly from you is impractical or unreasonable, we may clearly and transparently collect your personal information from trusted third parties or publicly available sources (for example, social media profiles).
9. Consequences of Not Providing Personal Information
You are not legally required to provide your personal information to us. However, clearly be aware that if you choose not to provide the personal information requested by us, the following may explicitly occur:
-
We may not be able to deliver our products or services to you, or not to the expected standard.
-
We may not be able to communicate important information to you, including product updates, new service offers, or exclusive promotions.
- We may be unable to personalise or tailor the content and user experience on our Websites and platforms to your preferences.
10. Security of Your Information
We take all reasonable measures to protect your personal information. However, as our Websites and services operate online, and given the inherent nature of internet-based communication, we cannot fully guarantee the security of information transmitted to us online.
Therefore, you explicitly acknowledge and accept that:
-
Any information, including personal information, transmitted online is done entirely at your own risk.
-
Despite our best efforts to safeguard your data using industry-standard security practices, we cannot warrant that the information you transmit will not be intercepted, accessed, or compromised during online transmission.
We strongly recommend that you take additional personal measures to enhance the security of your information online, including regularly updating passwords and ensuring secure internet connections.
11. Recording of Webinars, Live Videos, and Meetings
Please clearly note that when attending any live forums, meetings, webinars, or live video sessions hosted or authorised by Athina Krol or SpiritCode Institute PTY LTD, recordings of these sessions may take place.
By registering for, attending, or participating in any webinar, live video session, or online event hosted by Athina Krol, SpiritCode Institute PTY LTD, or any approved representative:
-
You explicitly acknowledge and consent that these sessions may be recorded in audio, video, or both formats.
-
You explicitly agree that these recordings may be stored and shared by Athina Krol or SpiritCode Institute PTY LTD with participants, hosts, or other attendees, and used for educational, promotional, or business purposes at the discretion of Athina Krol or SpiritCode Institute PTY LTD.
If you do not wish to be recorded, you explicitly retain the option not to participate and may choose to leave any session at your discretion.
12. Disclosure of Your Personal Information
We may share your personal information with the following parties, but only as required and permitted by this Privacy Policy:
-
Employees, Contractors, and Service Providers:
Including individuals and organisations who support our website and business operations such as web hosting providers, IT administrators, mailing services, couriers, payment processors, customer support providers, data entry services, debt collectors, and professional advisors (accountants, solicitors, consultants).
-
Third-party Suppliers and Partners:
Organisations with whom we have commercial or professional relationships, for purposes related to marketing, promotions, business collaborations, or providing additional services and offerings to you.
-
With Your Consent:
Other organisations or third parties when you have given your clear consent or specifically authorised us to share your personal information.
We take all reasonable steps to ensure these third parties maintain strict standards of privacy and data security, consistent with the terms and protections outlined in this Privacy Policy.
13. Additional Circumstances for Disclosure
In certain situations, we may disclose your personal information without further notice to you, including:
-
To provide products, services, information, or marketing content you have requested or consented to receive;
-
To credit reporting agencies, courts, tribunals, or regulatory authorities if you fail to pay for goods or services you have obtained from us;
-
To courts, tribunals, law enforcement authorities, and regulatory bodies if legally required, or in connection with any actual or anticipated legal proceedings, or to establish, exercise, or defend our legal rights;
-
To third-party agents or subcontractors assisting us in providing our services or marketing communications. This may include parties located or operating outside of Australia.
When your personal information is transferred or stored outside Australia, we take measures to ensure that appropriate safeguards (such as contractual obligations) are in place to protect your information according to applicable privacy standards.
14. Change of Business Ownership
If there is a change in control or ownership of our business, or if there is a sale or transfer of business assets, we reserve the right to transfer, to the extent permitted by law, our user databases. This includes all personal and non-personal information contained within these databases. Such information may be disclosed to potential or actual purchasers or business partners.
We commit to disclosing this information in good faith, taking all reasonable steps to maintain confidentiality, and ensuring the continued protection and privacy of your information as described in this Privacy Policy.
15. Information We Collect Through Your Use of Our Websites
Like many online businesses, we collect certain information automatically about your visits to and use of our Websites. This information is collected through the use of internet cookies, web beacons, and similar tracking technologies, and may include:
-
Your IP address and domain name of your internet service provider;
-
The type and version of browser and operating system you are using;
-
Information about your interactions with our Websites, including pages visited, time spent, and actions taken;
-
Communication and interaction history with our Websites, products, and services.
This data is used to help us improve our Websites, user experience, and services, and is typically collected and analysed in aggregate form that does not personally identify you.
16. Feedback and Surveys
We may occasionally contact you with voluntary surveys, questionnaires, or market research requests to collect your opinions, feedback, or suggestions regarding our products, services, or website. Your participation in such activities is entirely optional.
Any personal information collected through surveys or feedback forms will be protected and handled in accordance with the terms and protections outlined in this Privacy Policy.
17. Personal Information from Third Parties
If we receive your personal information from any third-party source (such as social media platforms, referral services, or other authorised third parties), we will protect and handle it according to this Privacy Policy and applicable privacy laws. We will use such information only for the specific purposes authorised or consented to by you, or as otherwise permitted by law.
18. Your Rights and Control of Your Personal Information
You have the following rights regarding your personal information and can exercise these rights at any time:
Choice and Consent
Providing your personal information to us is entirely optional and voluntary. You can choose not to share certain information; however, please be aware this may affect your access to our products and services. By providing your personal information, you consent to our collection, use, and disclosure as described in this Privacy Policy.
Restriction of Use
You can restrict how your personal information is collected or used. If you have previously consented to direct marketing communications, you can withdraw or limit your consent at any time by contacting us at team@spiritcodeinstitute.com.
Access to Your Information
You may request access to the personal information we hold about you, as permitted under the Privacy Act 1988 (Cth). In certain cases, we may charge an administrative fee to cover our reasonable costs. In specific circumstances outlined in the Privacy Act, we may refuse your request; if we do so, we will clearly provide the reasons for refusal.
Correction of Your Information
If you believe that any personal information we hold about you is inaccurate, incomplete, outdated, irrelevant, or misleading, please promptly inform us at team@spiritcodeinstitute.com. We will take reasonable steps to correct your information and respond to your request within a reasonable timeframe.
Complaints and Concerns
If you believe that we have breached the Australian Privacy Principles or the GDPR, please contact us immediately by email at team@spiritcodeinstitute.com, clearly outlining the details of your concern or complaint. We will promptly investigate and respond in writing, explaining the outcome of our investigation, any actions taken to address the issue, and steps to remedy the breach.
Unsubscribe or Opt-Out
To unsubscribe from our email communications or to opt out of receiving future marketing messages, please contact us at team@spiritcodeinstitute.com, or follow the unsubscribe instructions provided in our emails.
19. Storage and Security
We are committed to protecting your personal information and maintaining its security. To prevent unauthorised access, misuse, interference, loss, or disclosure, we implement suitable physical, electronic, and managerial security procedures designed to safeguard and secure the information we collect from you.
However, because no method of data transmission or storage is completely secure, we cannot guarantee the absolute security of personal information you transmit to or receive from us via the internet. Therefore, any transmission of personal information is undertaken at your own risk.
We take all reasonable steps to ensure your personal information is stored securely and protected from misuse, loss, unauthorised access, modification, or disclosure. Our employees, contractors, and service providers who have access to your personal information are required to maintain strict confidentiality and follow rigorous security standards.
Your personal information may be stored in electronic or physical form. Once your personal information is no longer required, or when we are no longer legally obligated to retain it, we take reasonable steps to destroy or permanently de-identify your information.
20. Cookies & Web Beacons
We may utilise "cookies" on our Websites. Cookies are small text files placed on your computer or device that store preferences and provide us with information on how users interact with our Websites. Cookies by themselves do not directly identify you; however, when you voluntarily provide us with personal information, it may become linked to information stored within a cookie.
We may also use "web beacons" (also known as clear gifs or tracking pixels) on our Websites. Web beacons are small pieces of code embedded into webpages or emails that allow us to monitor user behaviour, count visitors, track responses to marketing campaigns, and understand how visitors interact with specific pages.
You have the ability to accept or decline cookies by adjusting your browser settings; however, declining cookies may limit your ability to fully use our Websites and services.
21. Links to External Websites
Our Websites may contain links to external websites operated by third parties. We have no control over, and assume no responsibility for, the privacy practices, policies, content, or security measures of those third-party websites.
When you access these external websites, your personal information will be governed by their respective privacy policies and terms. We strongly encourage you to read and familiarise yourself with the privacy policies of each external website you visit.
22. Payment Information
When you purchase our products or services, we use third-party payment processors to securely handle your transactions. We do not store, process, or directly collect your payment card details.
Your payment information is provided directly to our trusted third-party payment processors, whose use and management of your personal information is governed by their own privacy policies and terms. These third-party payment processors adhere strictly to the Payment Card Industry Data Security Standard (PCI-DSS), managed by the PCI Security Standards Council, which is a collaborative initiative of major brands such as Visa, Mastercard, American Express, and Discover. The PCI-DSS ensures the secure and confidential handling of payment information.
Our current third-party payment processors include:
-
PayPal
-
Moonclerk
- Kartra
-
Stripe
For detailed information on their privacy practices, we encourage you to review their respective privacy policies directly.
23. Retention of Personal Information
We retain your personal information only for as long as is necessary to fulfill the specific purposes outlined in this Privacy Policy, or as required by applicable legal, regulatory, tax, accounting, or reporting obligations.
In determining the appropriate retention period for your personal information, we carefully consider:
-
The amount, nature, and sensitivity of your personal data;
-
The potential risk of harm from unauthorised use or disclosure of your data;
-
The purposes for which we process your personal data and whether those purposes can be achieved through alternative methods;
-
Applicable legal requirements and mandatory retention periods.
By law, we are required to retain basic customer information (including contact details, identity verification, financial records, and transaction history) for at least five years to comply with Australian tax legislation.
In some circumstances, you may request deletion of your personal data—see the "Your Rights and Control of Your Personal Information" section above for further details.
We may also anonymise your personal information (so it no longer personally identifies you) for purposes such as research, analytics, and statistical analysis. Anonymised data may be used indefinitely without further notice to you.
24. Your GDPR Rights (For Individuals Based in the EU)
If you are located in the European Union (EU), you have specific rights under the General Data Protection Regulation (GDPR) concerning your personal data. These rights include:
-
Right to Be Informed
You have the right to receive clear information about how and why we collect and use your personal data.
-
Right of Access
You can request access to a copy of the personal data we hold about you (also known as a "data subject access request").
-
Right to Rectification
You have the right to request corrections to any inaccurate or incomplete personal data we hold about you.
-
Right to Erasure ("Right to Be Forgotten")
You can request deletion of your personal data in certain circumstances, unless we have an overriding legal obligation to retain it.
-
Right to Restrict Processing
In specific circumstances, you have the right to request that we temporarily stop processing your personal data.
-
Right to Data Portability
You can request that we provide you with a copy of your personal data in a structured, commonly used, and machine-readable format (such as a CSV file), and you have the right to transfer this data to another organisation.
-
Right to Object
You can object to the processing of your personal data in certain circumstances—for example, if you object to direct marketing communications.
-
Rights Related to Automated Decision-Making and Profiling
You have the right to transparency regarding any automated decision-making or profiling processes involving your personal data.
If you wish to exercise any of these rights, please contact us at:
team@spiritcodeinstitute.com
We will respond to your request promptly, in accordance with GDPR requirements.
25. Accessing and Correcting Your Personal Information
You may request access to the personal information we hold about you at any time by contacting us at:
team@spiritcodeinstitute.com
When requested, we will provide access to your personal information through appropriate means (e.g., via email). We may charge a reasonable administrative fee to cover the costs of providing this information. We do not charge for making the request itself or for making corrections to your personal data.
In certain cases, we may refuse your request for access to personal information—for example, if providing access would infringe on the privacy of others or result in a breach of confidentiality. If your request is refused, we will provide you with clear, written reasons for our decision.
If you believe any of your personal information we hold is inaccurate, incomplete, outdated, irrelevant, or misleading, you can request correction or amendment by contacting us. We will assess and respond to your request within a reasonable timeframe. If we do not agree with your correction request, we will clearly note your disagreement alongside your personal information.
26. Withdrawing Your Consent
You have the right to withdraw your consent to this Privacy Policy and our use of your personal data at any time. To withdraw consent and request the deletion of your personal data from our records, please contact our Data Protection Officer at:
team@spiritcodeinstitute.com
Additionally, if you have previously agreed to receive marketing communications and wish to opt-out or unsubscribe, please email us at the address above or use the "unsubscribe" link provided within our email communications.
When contacting us to unsubscribe, please clearly indicate "Unsubscribe" in your email subject line to ensure prompt attention.
27. How to Make a Privacy Complaint
If you believe your privacy has been breached or if you have concerns about how your personal information has been handled by us, please contact us immediately at:
team@spiritcodeinstitute.com
In your message, please clearly outline the details and circumstances of your complaint so we can investigate the issue thoroughly and promptly. We take privacy complaints seriously and will treat your concerns confidentially. Upon receiving your complaint, we will acknowledge receipt and aim to investigate and resolve your complaint within a reasonable timeframe, in accordance with applicable requirements under the Australian Privacy Act and/or GDPR.
28. Contacting Us
If you have any questions, concerns, or feedback regarding this Privacy Policy, our handling of your personal information, or wish to contact our Data Protection Officer directly, please reach us at:
team@spiritcodeinstitute.com
We will treat your inquiries and feedback confidentially and will respond promptly to discuss and resolve your concerns in a timely and effective manner.
29. Children's Privacy
Our services and websites are not intended for individuals under the age of 18 ("Children"). We do not knowingly collect, solicit, or store personally identifiable information from individuals under 18 years old.
If you are a parent or guardian who believes your child has provided us with their personal information without your consent, please contact us immediately at team@spiritcodeinstitute.com. If we become aware that we have collected personal data from minors without proper parental consent, we will take immediate steps to delete this information from our systems.
30. Testimonials
If you voluntarily provide us with a testimonial, you consent to our use of your name and the testimonial content on our websites, marketing materials, and promotional communications. By submitting a testimonial, you grant us the right to publicly display and share the provided testimonial and related details.
31. Comments
Comments or other content submitted to our websites are generally not stored on our servers unless specifically required (e.g., to investigate false positives or spam). If such comments or content are stored temporarily, they will only be retained for the minimal period necessary to effectively manage and improve our services, after which they will be deleted or anonymised.
32. Termination
We reserve the right, at our sole discretion and without prior notice, to cancel or terminate your access to our websites, products, services, or any part thereof at any time. Upon termination, your right to access the affected websites, products, or services will immediately cease.
The restrictions imposed on you regarding content downloaded from our websites, as well as disclaimers, indemnities, and limitations of liability outlined in these Terms of Service and Privacy Policy, will continue to apply even after your access is terminated.
33. Changes to This Privacy Policy
We may update or amend this Privacy Policy periodically at our discretion. Any changes, updates, or additions to the Privacy Policy become effective immediately upon being posted on our website.
Your continued use of our websites and services following any updates or amendments indicates your acceptance of these changes. To stay informed about how we manage and protect your personal information, we encourage you to regularly review this Privacy Policy, especially before providing personal information or using our services.
If you do not agree with any changes made to this Privacy Policy, you should cease using our websites or services and refrain from providing additional personal information.
34. Contact Information
For any questions, notices, or concerns related to this Privacy Policy, please contact us directly at:
SpiritCode Institute PTY LTD
Email: team@spiritcodeinstitute.com
We will respond to your inquiries promptly and confidentially.
35. Data Breach Notification
If we become aware of any unauthorized access, disclosure, or breach of your personal information that poses a serious risk of harm, we will notify you promptly. We will also take all necessary steps to address and resolve the breach in compliance with our obligations under the Australian Privacy Act 1988 (Cth) and the GDPR, including reporting the incident to the relevant data protection authorities if required.
36. International Data Transfers
Your personal information may be transferred to, stored, and processed in countries outside Australia or the European Union, including countries where our data hosting providers and third-party service providers operate. By providing us with your personal information, you consent to the international transfer, storage, and processing of your data. We take all reasonable steps to ensure your data remains secure and protected according to this Privacy Policy and applicable privacy laws.
37. California Residents – CCPA Rights
If you are a resident of California (United States), you have specific rights under the California Consumer Privacy Act (CCPA), including:
-
Right to Know: You have the right to request information about the personal data we have collected, used, disclosed, or sold concerning you.
-
Right to Request Deletion: You have the right to request the deletion of your personal data we hold, subject to certain exceptions.
-
Right to Opt-Out of Sale: We do not sell your personal data; however, you have the right to formally request that your data never be sold.
To exercise any of these rights, please contact us directly at:
team@spiritcodeinstitute.com
38. Analytics and Third-Party Tools
We use third-party analytics tools, such as Google Analytics and Facebook Pixel, to collect anonymous data about your interaction with our website. These tools use cookies and similar technologies to help us understand how users interact with our content, enabling us to improve our website, services, and user experience.
You can opt out of Google Analytics tracking using Google's opt-out tool available here. You can also manage your preferences for Facebook Pixel and similar technologies through your Facebook account's privacy settings.
39. Social Media Integration
Our website may include features, links, or integrations to third-party social media platforms such as Facebook, Instagram, LinkedIn, and YouTube. If you interact with these social media features (e.g., "liking," "sharing," or posting comments), your interactions are governed by the privacy policies of those respective platforms. We encourage you to review each platform’s privacy policies directly for further details.
40. Do Not Track (DNT) Requests
At present, our website does not respond to "Do Not Track" signals sent by your browser or other similar mechanisms. You may manage and disable cookies or other tracking technologies through your browser settings or by using third-party privacy enhancement tools.
41. Cookies Policy
Our websites (athinabailey.com, authenticenergy.org, and any associated sites operated by SpiritCode Institute PTY LTD) use cookies to enhance your browsing experience and deliver personalised content. Cookies are small text files placed on your device to store your preferences, track user behaviour, and gather analytical information.
How We Use Cookies:
We use cookies for the following purposes:
-
Website Functionality: Essential cookies to ensure our websites function correctly.
-
Analytics and Performance: To collect information about how you interact with our websites, allowing us to improve user experience and website performance.
-
Marketing and Advertising: To personalise content and provide targeted marketing based on your browsing history and preferences.
Managing Cookies:
You have the right to accept, decline, or manage cookie preferences directly in your browser settings. However, disabling cookies may impact your ability to use certain features on our websites.
Third-Party Cookies:
We may also utilise cookies provided by trusted third parties such as Google Analytics, Facebook Pixel, and other platforms to track user interactions, measure website performance, and deliver targeted advertising.
By continuing to use our websites, you agree to our use of cookies as described in this policy.
For further information or queries regarding our Cookie Policy, please contact us at team@spiritcodeinstitute.com.