PRIVACY POLICY
1.0 Introduction
Gabriella Mindfulness (the “Organisation” or “we”) is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you, in accordance with the General Data Protection Regulation (GDPR). It applies to all prospective, new and continuing clients and business contacts of the Organisation (“Clients” or “you”).
The Organisation is a “data controller” and a “data processor”. This means that we are responsible for deciding how we hold and use personal information about you and that we process personal information about you on behalf of third parties. We are required under data protection legislation to notify you of the information contained in this privacy notice.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
2.0 Your Personal Information
2.1 What do we hold?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data)
We may collect, process, store, and use the following (non-exhaustive) categories or potential categories of personal information about you:
Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
Date of birth
Nationality
Gender
Next of Kin details
Any physical or learning disabilities or special dietary requirements.
2.2 How do we collect it?
We collect personal information about you directly from you, usually upon registering for one of our events.
We may require to collect additional personal information in the course of providing services throughout the period of our business relationship with you.
2.3 How do we use it?
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
We may also use your personal information in the following situations:
1. Where we need to protect your interests (or someone else’s interests).
2. Where it is needed in the public interest or for official purposes.
2.4 When will we use your personal information?
We need or may need all the categories of information in the list above primarily to allow us to perform our contract with you. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.
2.5 If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you.
2.6 Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain why we are making this request. Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.
3.0 Data Sharing
We may have to share your data with third parties, including third-party service providers.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may require to transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
3.1 Why might we share your personal information with third parties?
We will share your personal information with third parties where required for the purposes of any transaction on your behalf or by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
3.2 Which third-party service providers process your personal information?
“Third parties” includes third-party service providers (including contractors and designated agents). We envisage your personal information may require to be shared with the following third parties:
The Organisation’s professional advisers and/or regulatory bodies
3.3 How secure is my information with third parties
All the above third parties are required to take appropriate security measures to protect your personal information in line with prevailing legislation regarding data protection.
4.0 Data Security
We have put in place measures to protect the security of your information. Details of these measures are contained in our data protection policy.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
5.0 Data Retention
5.1 How long will we use/hold your personal information?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a Client we will retain and securely destroy your personal information in accordance with our data retention policy, taking into account applicable laws and regulations.
6.0 Rights of Access, Correction, Erasure & Restriction
6.1 Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
• Request the restriction of processing of your personal information. This allows you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Processing Officer, in writing.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
7.0 Right to Withdraw Consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Processing Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
8.0 Data Processing Officer
We have appointed a Data Processing Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Processing Officer by email at gfitterer@gmail.com. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
9.0 Cookies
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. For further information about cookies please visit http://www.aboutcookies.org or http://www.allaboutcookies.org.
You can remove existing cookies or/and set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.
We use cookies to ensure that we give you the best experience on our website. If you continue to use this site we will assume that you are happy with it.
10.0 Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will make a new privacy notice available when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.