The Hertford Yoga Shala 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.
The Hertford Yoga Shalamay 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 the 25thMay 2018.
2. EU 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 • Chapter 3 – Your Rights (Rights of the Data Subject) •
Note that third party services that we integrate to 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 privacy policies and terms 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.
The GDPR covers the protection of EU citizens regardless of where this data is stored or processed. No matter where a website is located, if it is intending to process data for EU citizens it must conform to the GDPR regulations.
In protecting EU citizen’s 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 Minimization
• Storage Limitation
• 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 organization 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
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
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”. 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”.
• 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
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
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.
4. GDPR Chapter 3: Your Rights
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
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: -
So you can ask us what you need to know and we should reply in a fair and honest way without trying to dupe you with legalese. That seems pretty reasonable to us.
4.2. Information to be provided
Here’s what we need to tell you when we ask you directly for any of your information: -
• Contact details of the controller
Please email us for this information
• Contact details of the data protection officer
At the moment we are 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 reply to the questions you are asking us. At the moment we’re only running a ‘Contact Us’ form where you fill out your enquiry and send it to us. In order for us to reply we need to have an email address that we can send the reply to.
• The legitimate interests pursued by the controller
We wish to make our services known to those who can benefit from them
• The recipients or categories of recipients of the personal data
We make use of the following services internally;
E-mail services, you will only receive e-mails relevant to your enquiries
• If we “intend to transfer personal data to a third country or international organization”
We won’t share your information with anyone
• We are also required to tell you: -
• The period for which the personal data will be stored
Your contact details will be kept until we have processed your enquiry. If you choose to be added to one of our e-mail lists (currently there is an Ashtanga group list, a foundation course list and a handout group list), your details will be kept until you ask for them to be removed.
That you have the right to
• Data Subject Access requests
• Request access
I.e. that you can see the data we have on you. You can request this from us at any time
I.e. that you want your data changed or deleted entirely.
This covers the situation where you or another party (say a local authority) requires us to stop processing your data but request that it is not deleted. For example, the local authority 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.
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 just let us know and we’ll be happy to address that for you
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. We’re hopefully this will never happen.
The provision of personal data is a “statutory or contractual requirement, or a requirement necessary to enter into a contract”We don’t feel that there is a need for a contract; there is no explicit contract between you and us, you’re simply sending us a request to answer a question or joining our email service.
• You are “obliged to provide the personal data and of the possible consequences of failure to provide such data”. This is not necessary because we do not have a contract
• “Existence of automated decision-making, including profiling.
• 4.3. Right to Rectification
• Where there are omissions in the data we hold you have the following two rights:
• • “Inaccurate data corrected”
• • “Incomplete personal data completed”
• If you see any data we hold on you falls into one of the categories above, and this can’t be corrected with the access you currently have, then please contact us.
4.4. Right to be forgotten
Article 17 calls this ‘Erasure”. No, not the 1980’s pop group – 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
If, prior to us processing your request, you wish to withdraw your consent simply let us know and your data will be immediately deleted.
• 4.5. Right to Restriction
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”
• 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. To request restriction of your data please contact us.
4.6. Right to Object
There are 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. What We Collect
We may collect the following information:
contact information including email address
details regarding your specific question
that you’ve confirmed that you are aged 16 years or older
that you consent to your data being collected and processed as outlined above under GDPR
Note that GDPR requires that we only collect information that is relevant to the processing we are intending to run on the data you provide us. We are also required to have your consent prior to collection of any processing. Please see the GDPR sections above for full information on this
6. What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons;
Notethat GDPR specifically grants you the right to request the right to be forgotten (erasure), the right to object to processing and the right to restriction. We also must provide you with specific details on how long we will hold your details for. Please see the sections on GDPR above for more information on this
We are committed to keeping your data secure. Only authorized people will have access to you data.
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We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website
9. 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 this privacy statement does not govern such sites. You should exercise caution and look at the privacy statement applicable to the website in question
Notethat with the introduction of GDPR you should also check the GDPR policy of any site that you visit as a result of following any links on this website. We strongly advise you not to provide any website any personal information unless you are satisfied that the Privacy Notice and GDPR Policies of the website meets your own requirements
10 Google Analytics
This website uses Google Analytics to help streamline the services we provide to you. We also think it’s important to keep John informed on where the majority of the website traffic is coming from in the hope he might use this information when deciding which places to travel to teach.
The information provided to Google Analytics is normalised in the sense that it can’t be used in any way to identify you. At most Google Analytics can identify you down to the town/city in which you are roughly located. Often this in itself is not entirely accurate as it is often linked to your Internet Provider. Google holds all of this information
The introduction of the provides you more control over your data that we store and on the processing that you give consent to us to perform. This is detailed in the sections that appear above. If there is anything you do not understand or would like to talk to us about please contact us