Viveka Gardens Privacy and Cookie Policy
Re-written 1.5.18
1 Introduction
1.1 This Policy
This policy has been re-written having researched the requirements of the General Data Protection Regulation, May 25 2018. Viveka Gardens, in the spirit of yoga and ethical living, respects the Regulation and is keen to abide by the qualities of transparency, accountability and demonstrability that the legislation encourages. We have studied the 8 Individual Rights under GDPR (section 4.4), and a range of documents to produce this policy. Our aims with this Policy are to engender your trust and uphold VG’s reputation.
1.2 Your Privacy
Viveka Gardens is committed to ensuring that your privacy is protected. We have limited the amount of personal data that we collect to that which is strictly necessary. We treat your information as sensitive. When you provide information by which you might be identified, you can be assured it will only be used in accordance with this privacy statement.
1.3 Scope
This Privacy and Cookie Policy sets out how Viveka Gardens uses and protects the data you give Viveka Gardens:
- when you use this website
- when you give your data via Googledocs for the purposes of registering for workshops, courses, retreats and other events
- when you sign up to the newsletter either via the website or directly via the newsletter email marketing platform (Mailchimp)
- when you give your email address and it is stored in Outlook
1.4 Third Party platforms
Please be aware that when you give your information to third party platforms such as Google, Mailchimp, Outlook, Facebook, Instagram or Twitter, you acknowledge that it will be transferred to them for processing in accordance with their terms and conditions.
1.4.1 Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement.
1.5 Policy updates
Further updates to this page will be notified to newsletter subscribers. Otherwise you can check this page from time to time to ensure that you are happy with any changes. If we would like to use the information in a different way than to what you have already consented, we will contact you to arrange new consent. However, this is not anticipated.
2. Your information
See the table below for what data is collected, why we collect it, the legal basis for processing it, how to opt-out, and the data lifecycle.
2.1 Data Processing
Your data may be processed under a legal basis. See the table below. For instance, participants’ data for a particular workshop may be put into a table and printed for a workshop for safety reasons. The main form of processing is in Mailchimp, where it may be ‘segmented’ to enhance the services we provide and benefit students and visitors at VG according to location and interests. International processing: Viveka Gardens operates solely in the UK and so cross-border processing is not relevant.
| Website | Googledocs | Mailchimp | Outlook | |
| Data collected | Contact form:
First name Last name Email address Message content Cookies: See section below
|
First name
Last name Email address Postcode Health information Phone number(s) Emergency contact name, email, phone number |
First name
Last name Email address Postcode Interests in types of yoga activity
|
First name
Last name Email address Message content
|
| Purpose | Contact
|
Contact
Safety Insurance requirement |
Contact
|
Contact
Inform students of special circumstances for imminent classes or events |
| Processing legal basis | n/a | Legal obligation (safety, insurance)
Contractual (payment, terms and conditions) Vital interests (life or death) Public interest (in case of legal action) |
Legitimate interest
(tailor newsletters to your locality and interests) |
n/a |
| How to opt out | Not use website | Use the contact form to request deletion of your entry | Use the contact form to request deletion or unsubscribe using the link at the bottom of the newsletter | Use the contact form to request deletion from address book |
| Data lifecycle | 3 months | 7 years | 2 years | 2 years |
2.2 Cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree on your first visit to the website, we collect necessary cookies that make a website usable by enabling basic functions like page navigation and access to secure areas of the website. They will record your IP address. The website cannot function properly without these cookies. You are asked for consent to use cookies on your first visit to the website. These are the cookies that are collected and as you can see they expire within the session:
2.2.1 Cookie popup
We use an app called Ginger-cookie for the cookie pop up, visible on your first visit to the website. It will remember you for a year unless you clear your cookie cache sooner.
2.2.3 Statistics cookies
To simplify matters and eliminate anonymous statistics cookies, google analytics was unlinked from the website on 30.4.18. Thus traffic log cookies to identify which pages you look at are no longer used
3. Security
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. In line with GDPR, a data breach would be reported to the ICO (Information Commissioner’s Office).
4. Your rights
4.1 Subject Access Request
You have the right to request what information is held. Please write c/o the contact page and we will get back to you within two weeks if not within 24 hours.
4.2 Third Parties
We will not give, sell, distribute or lease your personal information to third parties.
4.3 Paper data
Data may be downloaded and printed from googledocs to make a table of participants in an event. This will be kept covered and then destroyed after the event. At the moment no other printing of data is anticipated.
4.4 Individual Rights under GDPR
The GDPR provides the following rights for individuals and this is how Viveka Gardens believes we have respected them in these ways:
1 The right to be informed
Through this Privacy Policy and any forms you may fill in, we have provided transparency over how data are collected, stored, protected and processed.
2 The right of access
You can contact us to access your data. This Privacy Policy explains how your data are used. Any forms you may fill in summarise the info and refer you to this document.
3 The right to rectification
You may contact us to correct any information, or edit your own Mailchimp data via the link at the bottom of the newsletter. It is also possible to edit your googledoc info.
4 The right to be deleted
We will remove your data on request unless there is any compelling reason to retain it (eg legal).
5 The right to restrict processing
We will honour your request not to process your data for specific purposes
6 The right to data portability
We can provide copies of your data in a portable format.
7 The right to object
We will comply with requests to stop automated decision making and profiling (but this is not something we do currently anyway)
8 The right to stop processing
We allow your data to be stored but not processed on request.
Contact Fiona Law if you wish to be in touch about your data.