Who we are and what does this policy cover?
It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Your rights” section.
Our Platforms may include links to other websites over which we have no control. Living Ashram is not responsible for the privacy policies or practices of other websites. We may also link to other websites operated by Living Ashram which operate under separate privacy policies. If you access these websites via our Platforms, you should review the privacy policies of those websites so you can understand how they collect, use and share your information.
What information do we collect?
We collect and process personal data about you when you:
- register to join our email list;
- use our Platforms;
- enter into a contract with us;
- give us your comments or make a complaint;
- submit an enquiry or make a request;
- agree to fill out our opt-in survey; or
- interact with us and our Platforms by other means.
The information we collect may include:
- your name and password;
- your email address, company name, job title and phone number;
- your payment, including billing and credit card details, where you make purchases from us;
- your marketing preferences, including any consents you have given us;
- information related to the browser or device you use to access our Platforms;
- areas of the app you access and length of time in each;
- information in any surveys you choose to participate in, including gender, age, job level, working experience, salary band, etc.
What information do we receive from third parties?
Sometimes, we receive information about you from third parties. In particular:
- when you interact with us on social media platforms such as Facebook or Instagram (depending on your privacy preferences on those platforms);
How do we use this information, and what is the legal basis for this use?
- To fulfil a contract, or take steps linked to a contract: this is relevant where you make a purchase from us. This includes:
- taking payments;
- communicating with you; and
- providing customer services;
- As required by Living Ashram to conduct our business and pursue our legitimate interests, in particular:
- to verify your identity;
- to provide products and services you have requested, and respond to any comments or complaints you may send us;
- to monitor use of our Platforms, and use your information to help us monitor, improve and protect our products, content, services and Platforms;
- to use information you provide to personalise our Platforms, products or services for you;
- if you provide a credit or debit card as payment, we also use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud (see data sharing below);
- to monitor customer accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
- to investigate any complaints received from you or from others, about our Platforms or our products or services; and
- in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).
- Where you give us consent:
- we will send you direct marketing in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners;
- we invite all end users to participate in our consent-based surveys to measure the impact of our programme and app; and
- on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
- For purposes which are required by law:
- In response to requests by government or law enforcement authorities conducting an investigation.
Relying on our legitimate interests
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
Who will we share this data with, where and when?
Living Ashram may disclose your personal data to the following categories of recipients (in all cases, only when necessary to fulfil their functions):
- our staff (including employees and external consultants), professional advisors and agents;
- third party service providers which process your personal data on behalf of Living Ashram and who are bound by contractual obligations to keep your personal data confidential and appropriately secure. In particular, we use third party providers of website hosting, backend service provider, analytics, crash reporting, and email marketing.
- government authorities, regulatory agencies and law enforcement officials, if required for the purposes specified above, if mandated by law, or if required for the legal protection of our legitimate interests in compliance with applicable laws;
- if there is a corporate sale, merger, reorganisation, insolvency event or other similar event.
Our office headquarters are based in London, and our main data centre is located in Germany. However, where required to perform our contract with you or for our wider business purposes, the information that we hold about you may be transferred to, and stored at, a destination outside the UK and the EU. It may also be processed by staff operating outside the UK and EU who works for us or for one of our service providers.
Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to using the details set out below.
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred. In the UK, the data protection authority is the Information Commissioner’s Office (ICO) (www.ico.org.uk).
We will aim to respond to all legitimate requests as soon as we reasonably can and in any event within 30 days. If we think that it will take us longer than 30 days, we’ll let you know why and keep you updated. Where you make any requests, we might ask for specific information to confirm your identity as a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. This might include asking for further information in relation to your request to be able to speed up our response.
How to get in touch with us
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at firstname.lastname@example.org, or by writing to Living Ashram™ Ltd., Regina House 124, Finchley Road, London NW3 5JA, UK.
How long will you retain my data?
Where we process registration data, we do this for as long as you are an active user of our Platforms and for 6 years after this.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
Where we process personal data in connection with performing a contract, we keep the data for 6 years from your last interaction with us.
Changes to this Privacy Notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise. Regularly reviewing this page ensures that you are always aware of what information we collect, how we uses it and under what circumstances, if any, we will share it with other parties.