Shuniya Kundalini Yoga Data Protection Policy and Privacy Notice
Last updated: 9 May 2018
Data Protection Officer: Japjeet Rajbir Kaur Khalsa (dr. Nele Bemong)
Tel: +44 (0)7588030313
Introduction: GDPR and Patanjali’s 8 Limbs of Yoga
The new GDPR (General Data Protection Regulations) legislation that is entering into force on 25 May 2018 and in which Europe lays down – much needed – rules for companies on how to deal with clients’ data, is very much in line with yogic principles. It actually gives us as yoga teachers an excellent opportunity to deepen our practice of Patanjali’s 8 limbs of yoga, specifically the Yamas which are 5 guidelines for moral/ethical social behaviour towards others. Moreover it introduces these Yamas to wider society. As yogis, we very much welcome this movement!
In short, companies are now obliged to learn how they can make sure that the data they hold on clients/customers is serving those persons the data belong to (and not in first instance the company), and how they can make sure no inconvenience or risk is caused to clients and customers (which is in line with the yogic concept of Ahimsa or non-violence, not causing harm). Companies are asked to be clear, transparent, open and honest as to how they got hold of customers’ data (in line with the yogic concept of Satya or truthfulness). Companies can only take what is freely given to them with consent (in line with Asteva or not stealing, not taking anything that does not belong to you), and they always have to have a lawful justification for keeping and using the data they have collected, not holding onto them for any longer than lawfully required (Aparigraha or non-accumulation).
I would like to report in all transparency what kind of data Shuniya Kundalini Yoga keeps; how these data are stored, and how long they are stored for.
Cookies and IP Addresses Collected by this Website
We may store information about you using cookies (these are files which are sent by us to your computer or other access device) which we can access when you visit our site in future. We may also collect your device’s IP address as part of the basic functioning of this website. We do this to allow the website to function properly and to collect anonymous information about how this website is used, through Google Analytics.
Should you wish to stop using cookies or control their use on your browser, you can simply refer to your browser’s settings for cookies. More information on how to do that can be found on the website All About Cookies (https://www.aboutcookies.org/how-to-control-cookies/) or on the Information Commissioner’s website (https://ico.org.uk/for-the-public/online/cookies/).
Please do note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.
Links to Other Websites
Shuniya Kundalini Yoga can in no way be held responsible for the practices employed by websites linked to or from Shuniya Kundalini Yoga (in the Useful Links page or anywhere on our site), nor the information or content contained in them. Please remember that when you use a link to go from www.shuniya-yoga.org to another website, our Privacy Notice is no longer in effect. Your browsing and interaction on any other website (including those that have a link on our website) is subject to that website’s own policies. Please read through those policies before proceeding.
Personal Client Data: What Data Are Collected and Kept, How Are they Stored, and How Long Are they Stored for?
Certain personal data are collected by Shuniya Kundalini Yoga at the time of booking of any service. This is for the purposes of meeting Insurance Company criteria as well as for your health and safety during your yoga practice, massage, consultation or regarding any products you order from us. Health information is also used to tailor sessions to suit your individual needs.
All information gathered by Shuniya Kundalini Yoga during the booking process or provided by a client at any other point in time is treated as confidential and will not be shared with a third party. Two exceptions to sharing information are made:
- Emergency Contact information is collected solely for use in an emergency, should Shuniya Kundalini Yoga need to contact your next of kin or give this information to the emergency services.
- If a cover teacher covers a class in my absence, I share important health information and emergency contact details with them.
You may update or correct your account information, alter any of your data, review how they are used or request their return to you at any time by contacting me via email or phone (contact details are provided at the top of the page).
You may, of course, decline to submit personally identifiable information to Shuniya Kundalini Yoga, in which case Shuniya Kundalini Yoga may not be able to provide certain services to you.
Below I report in all transparency what kind of data Shuniya Kundalini Yoga keeps; how these data are stored, and how long they are stored for.
Shuniya Kundalini Yoga keeps:
- a register of all classes taught with mention of who participated (first and last name), what kriya and meditation we practiced in that class, and how much each person paid (as I use a pricing structure with different pricings). For every workshop and retreat that is taught, Shuniya Kundalini Yoga keeps a register of who attended (and which days, if not all), what we practiced, and how much everyone paid (with date of bank transfer). A similar register is also kept for private classes, consultations and massages (with date of treatment, class or consultation, what we did, and how much you paid and how). These registers are stored in password-secured folders in a secure cloud and backed-up on an external hard-drive kept in a locked metal security box in a safe place.
- an intake health form for all people who have booked into a class (also for those who didn’t turn up for the class they booked for, if they filled out the form), workshop or retreat. This form contains: contact details (name, address, phone number & email, emergency contact), personal information (date of birth, history of practicing (kundalini) yoga, specific class interests) as well as health information and medical details (history of injuries, illnesses, pregnancies, ….; the use of prescribed or recreational drugs, …). If you’ve filled out this form on paper only and NOT emailed it over but handed it over in class, the paper form will be stored in a locked metal security box in a safe place, so as to protect it from theft or fire. If you have filled out this form by hand or on the computer and have emailed it to Shuniya Kundalini Yoga, it will be stored in a password-protected folder in a secure cloud environment and backed-up on a hard-drive kept in a locked metal security box in a safe place.
- For the order of any homemade Sikhs(‘) Nurturing Nature orders, we collect your name and surname, address if the products needs to be parcelled to you, and any relevant health information (allergies to certain products, carrier oils, essential oils). These data are again securely stored in a password-protected folder in a secure cloud environment and backed-up on a hard-drive kept in a locked metal security box in a safe place.
- Emails or messages via Facebook Messenger or Whatsapp that you have sent in the past and that contained any kind of data are also treated with concern for your privacy: the original messages and emails are deleted after the relevant content has been copied and securely stored in the same way as described above.
Length of time data are kept for:
As per lawful obligation (insurance company and tax stipulations), data will be kept for 7 years after a client has used a service (class, massage, consultation, …) for the last time. For minors, all data legally need to be kept for 7 years after they would attain majority (so 7 years after the day they would turn 18).
At any point in time you have the right to request your data back or to be forgotten. In these cases I have a legal obligation to keep some of your data (for tax and insurance obligations), but any other data can then be returned to you or shredded.
How I Use Your Contact Details (Email Address and Phone Number)
On the intake form that you are sent at the time of booking, you will be asked to provide your contact details and sign a disclaimer. In doing so, you are agreeing to your email and phone number being used by Shuniya Kundalini Yoga to inform you of class changes, waiting list spaces becoming available, and service updates directly relating to the service you have booked. I will also use your contact details to check in with you if you have verbally or in any written way registered for a class, workshop or other service but not made a booking payment yet, so that I can confirm participant numbers for a class or workshop, or timings for appointments.
You of course have the right to decline to submit your email and/or phone number, which in some cases may mean that I am not be able to:
- provide certain services to you
- contact you in the event of last-minute class changes or cancellations
- inform you if a waiting list place has become available.
Class bookings themselves can always be made by you either via email or via phone call or text message.
Changes to Our Privacy Notice & How We Notify You
Shuniya Kundalini Yoga may update its Privacy Notice from time to time, and so you should ideally review this Notice periodically. When we change the notice in a material way, we will update the ‘last modified’ date at the top of this Privacy Notice. Any changes to this Privacy Notice are effective as soon as they are posted on this page. If you have any questions about this Privacy Notice, the practices of this website, or your dealings with this website, please contact our Data Protection Officer (contact details can be found at the top of this page).
If there is a change to Shuniya Kundalini Yoga’s Privacy Notices or to how we use your data, we shall contact you via email notice, written or hard copy notice, or through conspicuous posting of the notice on our social media channels and newsletters. We reserve the right to determine the form and means of providing these notifications to you. Please be aware that you may have opted out of certain means of notification as described in this Privacy Notice (e.g. newsletters) or might not be checking our social media channels. You can however always find the latest version of our Privacy Notice on this webpage.
If at any time you feel that there is an issue with the way Shuniya Kundalini Yoga handles your data then you can contact the ICO (Information Commissioner’s Office) via https://ico.org.uk/concerns/.
Data Protection Law means that you as a customer or client have extensive rights regarding the collection, storage and use of your data.
Under the GDPR (General Data Protection Regulation) you have the following rights as an individual regarding your data:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
If you would like to find out more about these rights, or if you would like to report a breach of them, then you can contact the ICO (Information Commissioners Office): https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ or call their helpline on 0303 123 1113 (UK). Further contact details for the ICO can be found here: https://ico.org.uk/global/contact-us/helpline/