This privacy notice sets out how SeasonalYoga.net uses and protects any information that you give SeasonalYoga.net when you use this website.
SeasonalYoga.net is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
SeasonalYoga.netmay change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 16th May, 2018.
2. European Union General Data Protection Regulation (GDPR)
The EU General Data Protection Regulation (GDPR) replaces the Data Protection Directive 95/46/EC and was designed to harmonize data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organizations across the region approach data privacy.
The key articles of the GDPR, as well as information on its business impact, can be found on the dedicated site by clicking here (opens in new window). The GPPR becomes law in Europe on the 25th May, 2018
The GDPR is laid out in 11 Chapters, the relevant ones to you are :-
- Chapter 2 – Principles (Articles 5-9)
- Chapter 3 – Your Rights (Rights of the Data Subject) (Articles 12-23)
Note that third party services that we integrate to (Constant Contact) may directly provide GDPR opt-in details on forms that they embed on our website when collecting information that they need. You should check these third party Policies and Conditions where these appear before providing your information to them.
3. GDPR Chapter 2: Principles
This chapter covers some basic things about the GDPR that you should know and that we need to adhere to.
3.1. Scope (GDPR Article 3)
The GDPR covers the protection of EU citizens regardless of where this data is stored or processed, Even a website outside the EU, if it is intending to process data for EU citizens, must conform to the GDPR regulations.
3.2. Principles (GDPR Article 5)
In protecting EU citizens data the GDPR looks to the following principles regarding your data :-
“Data is specified, explicit and legitimate”. When we ask you for your data we are required to tell you what it is for in terms that specify exactly what it is we need, why we need it and that when we explain this it is written out in clear and understandable terms.
The 5 main principles the GDPR adds are as follows:
- Data Minimisation
- the data we ask you to provide us should only be relevant to what we need it for
- the data is to be “accurate”. For example, if you change your address, you move home, and you tell us this then we are required by law to update our records where we have them to reflect this change
- Storage Limitation
- your data should be with us for no longer than is necessary for us to process it. We are no longer allowed to maintain your records indefinitely (unless we are required to do so by State law). This is a risk limitation strategy introduced to protect your data from potentially falling in to the wrong hands.
- Integrity and Confidentiality
- Any processing we do on your data must be of a lawful nature and we must prevent against “accidental loss, destruction or damage”. Your data is exactly that – your data! And as such we should treat it with the same respect as if we were dealing with you yourself.
- Essentially this means that we as an organisation need to be able to show that we have in place processes that adhere to the above earlier 4 principles.
3.3. Lawfulness of Processing (GDPR Article 6)
This article essentially lays out that we have to ask you for your consent to process your data, that the processes we’re going to put that data through is relevant to our activity of providing the services we have for you and that there’s a real need for the data collection in order for us to proceed.
3.4. Conditions for Consent (GDPR Article 7)
This is one of the more important articles that you should be aware of. There are 3 main parts to it as follows :-
- We are required to … “demonstrate that the data subject has consented to processing of his or her personal data”. So no more opt-out check boxes. You have to actively agree to us processing your data
- Any form we present to you requires to be … “clearly distinguishable from the other matters, in an intelligible and easily accessible form, using clear and plain language”. This is pretty straight forward and any requests we ask of you should be too!
- This is the important one you should know about. You … “will have the right to withdraw [your] consent at any time. It will be as easy to withdraw as to give consent”.
3.5. Conditions Applicable to Child’s Consent (GDPR Article 8)
There are very specific GDPR rules governing data capture for children. At this point and going forward we’re not going to ask for any children data. As such this means that only adults, who can give their data willingly, will be allowed access to our site. You’ll see a checkbox asking you to confirm this on sign-up. The GDPR lays out that a child is “below the age of 16 years”. So you must be 16 years old or over to access our site.
3.6. Processing Special Categories (GDPR Article 9)
The “Special Categories” cover data which reveals any of the following :-
- racial or ethnic origin
- political opinions
- religious or philosophical beliefs
- trade union membership
- genetic or biometric data concerning health
- details of sex life or sexual orientation
We must have your consent before acquiring any of the above types of data. There’s exceptions to this but essentially we won’t be asking you for any of the above anyway. If someone does ask you for any of the above we suggest you ask them “Why?”
4. GDPR Chapter 3: Your Rights (Rights of the Data Subject)
This chapter covers your rights under the GDPR. We’ll highlight the bits that we are required to and bits we think you should know
4.1. Transparent Information, Communication and Modalities (GDPR Article 12)
The GDPR allows you to request information about your data from us. It lays out regulations on what we are required to do when fulfilling this. Where you ask us we are required to provide :-
- data “in a concise, transparent, intelligible and easily accessible form, using clear and plain language”
- data “orally” where we’ve previously identified you
- information on “any action taken on a request”. We need to keep you informed
- the information “free of charge”. It’s free unless your request is deemed to be excessive
So you can ask us what you need to know and we should reply in a fair and honest way without trying to hide behind legalese.
4.2. Information to be Provided (GDPR Article 13)
Here’s what we need to tell you when we ask you directly for any of your information :-
- contact details of the controller
- GDPR Data Controller, c/o Seasonal Yoga, McCormick Business Centre, 46 Darnley Street, Pollokshields, Glasgow, G41 2SE, Scotland
- contact details of the data protection officer
- At the moment we’re not required to have one but you can use the details above in the meantime
- the purposes of the processing
- we need your contact details to inform you of content changes within our website. We send your email address to Constant Contact for this. No card payment details are ever stored by us
- the legitimate interests pursued by the controller
- we’re genuinely interested in growing our website to make the information and experience you have here as good as possible. In order to do that we need to track what things work and what don’t. We use Google Analytics (data held by Google) to track which pages receive regular visits. This helps us work out what vistors of our site are interested in so we can provide more of this to you. One note on Analytics. Google aggregates data and the lowest level of granularity we can ever get to is down to the City level. The data they present can never be used to individuals identify you. It may tells us how many people have visited us from London, say
- the recipients or categories of recipients of the personal data
- We make use of the following services internally – Constant Contact (Email Marketing), Google Analytics (Site activity).
- if we “intend to transfer personal data to a third country or international organisation”
- Other than the companies we’ve mentioned above we won’t share or sell your information to anyone
We are also required to tell you :-
- the period for which the personal data will be stored
- Your contact details will be held on record for the duration of any training course you sign up for, start and complete. If you withdraw from a course before it's completion we will remove your records (unless we are required to keep this information for legal reasons). If you are requesting information about out courses we will keep hold of your records for the period of any communication between us.
- that you have the right to
- request access
- ie that you can see the data we have on you.
- rectification or erasure of personal data
- ie that you want your data changed or deleted entirely
- restriction of processing
- this covers the situation where you or another party (say the Police) require us to stop processing your data but request that it is not deleted. For example, the Police may ask us to prevent you from further accessing the site but require us to keep you data as is whilst they perform any investigation. We’re legally obliged to do as they request
- object to processing
- this covers the ‘right to be forgotten’. For example, say you become married and your change in circumstances now also impacts your willingness to continue to allow us to process your information (you may not wish us to process your new details). This right allows you to change or remove your consent previously given to us.
- data portability
- if you request information from us we’re obliged to give it to you in a machine readable format (encrypted). You may also request us to send this information to a supervising authority of your choosing.
- withdraw consent at any time
- we’ve covered this above but if you change your mind about your consent at any time jus let us know and we’ll be happy to address that for you
- lodge a complaint with a supervisory authority
- if we fail to act on our best interest, or provide you with the information you are requesting you can of course take recourse elsewhere.
- request access
- the provision of personal data is a “statutory or contractual requirement, or a requirement necessary to enter into a contract”
- you are not required to enter into a contract, legal or otherwise, with SeasonalYoga.net. At this time we only offer a simple 'Contact Us' and 'Download PDF Brochure' both of which only require us to be able to contact you to answer your request and deliver the brochure to you. If you register and are accepted on to one of our training courses a contact will be given to your for the payment of the course. You will need to complete an application form prior to commencing the course
- you are “obliged to provide the personal data and of the possible consequences of failure to provide such data”
- No, you’re not obliged to provide the data to us, it just makes our and your life easier when it comes to answering your request
- the provision of personal data is a “statutory or contractual requirement, or a requirement necessary to enter into a contract”
- the “existence of automated decision-making, including profiling”
- We use Google Analytics as described above. This helps us align the information we provide to our site members to reflect what they are interested in. We do not use an automated decision-making.
4.3. Right to Rectification (GDPR Article 16)
Where there are omissions in the data we hold you have the following two rights (Art 16.4) :-
- “inaccurate data corrected”
- “incomplete personal data completed”
If you see any data we hold on you falls into one of the categories above then do let us know and we’ll be happy to address this for you
4.4. Right to be Forgotten (GDPR Article 17)
Article 17 calls this ‘Erasure” – you’re right to have your data removed from our systems. We can do this where :-
- “Retention of personal data is no longer necessary” for the processing we told you we would carry out on it
- you specifically :-
- “withdraw consent” – see above
- “object to processing” – see above
- your data has been “unlawfully processed“
- your data has to be “erased as part of a legal obligation”
Do note that removing your data may not be entirely possible where data is held on our behalf with a third party. We’re thinking here specifically of your Marketing information (Mail Chimp / Constant Contact). Note that as data stored by Google Analytics is deliberately obscured (obfuscated), and as such can’t be used to identify you, Google will not be able to remove any previously suppled data that your activity on our site contributed to.
4.5. Right to Restriction (GDPR Article 18)
We’ve covered some of this before but GDPR details more specific information here in Article 18. Under this article you have the right to request restriction of processing where :-
- “data accuracy is contested”
- you oppose the “erasure [of data] and request restriction instead”
- we “no longer need the data for intended purpose”
- you “object to being processed by automated decision making”). Note that we don’t do any automatic decision making
We’ll store your data when you request us to restrict it and will tell you if this restriction is going to be lifted if restriction has be previously requested for legal reasons
4.6. Right to Object (GDPR Article 21)
There’s a couple of specific clauses we’re obliged to tell you about. Here they are.
- You have the right to object to processing of personal data for “direct marketing including profiling related to direct marketing”
- Where you object your “personal data will no longer be processed for direct marketing”
- You will be told of your “right to object to processing”. Please consider us doing that here
5.0. Further Points (non-GDPR)
Use of personal information
We will use your personal information necessary for us to provide our services to you. We do not share any information with unrelated third parties nor do we collect or retain any information other than as required for the provision of our products or services. Information collected will be stored securely and securely destroyed if it is no longer required by Seasonal Yoga.
Where we engage third party contractors (e.g. teachers and therapists) to perform services for us, those third party contractors may be required to handle your personal information. Under these circumstances, those third party contractors must safeguard this information and must only use it for the purposes for which it was supplied, although we are not responsible for ensuring this. Other than the above, we will not disclose your personal information without your consent unless disclosure is either necessary to prevent a threat to life or health, authorised or required by law, reasonably necessary to enforce the law or necessary to investigate a suspected unlawful activity.
Seasonal yoga makes use of third party software to manage bookings, such as MindBody Online
Security of information
Personal information collected by Seasonal Yoga and our website is stored in secure operating environments that are not available to the public. Seasonal Yoga will protect your personal information no matter where we process or store your data.
Changes to our policy
From time to time, it may be necessary for us to review and revise this policy. We reserve the right to change our policy at any time and, should this occur, the amendment will be posted on our website. We encourage you to check this policy periodically to ensure it conforms to your requirements.