LOVE YOGA ANATOMY LTD 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.
LOVE YOGA ANATOMY LTD may 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 20th May 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 harmonise data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organisations 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 process your data in regards to the collection of emails for the newsletters (Mailpoet) and the payment for digital products (Stripe and Paypal) may directly provide GDPR opt-in details on forms that embeded on our website when collecting information that is required. 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 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
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 :
- 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 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
Stuart Girling 10 The Excelsior London Road Brighton BN18QX
- contact details of the data protection officer
At the moment we’re not required to have one (we’re too small a company) 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. We also hold your username and email address so we can identify you as having registered as a member of this site. The email address is required so we can contact you when your subscription with us is about to expire. Any card details you supply us are sent directly (and stored) with the third party processor. So this is PayPal or Stripe, the two payment gateways we use. Please see their sites for details of their GDPR policies. We only have transaction identifiers on this site. No card payment details are ever stored by us
- the legitimate interests pursued by the controller
We use Google Analytics (data held by Google) to track which pages receive regular visits. This helps us work out what members 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 individualaly 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 – Paypal and Stripe (Payment Gateways), 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
We will only keep your data while it is required for you to access services (on line courses) that you have purchased and/or while you choose to be included in our newsletters.
that you have the right to
- request access ie that you can see the data we have on you.
Please instruct us of your wishes through the contact form
rectification or erasure of personal data ie that you want your data changed or deleted entirely. Please instruct us of your wishes through the contact form or if you don’t want to be on the newsletter just unsubscribe.
- restriction of processing this covers the situation where you or another party (say a local authority) require 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.
Please instruct us of your wishes through the contact form.
- 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.
Please instruct us of your wishes through the contact form
- 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.
Please instruct us of your wishes through the contact form
- 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. We’re hopefully this will never happen.
- whether the provision of personal data is a “statutory or contractual requirement, or a requirement necessary to enter into a contract”
No contract is entered into when you view free information on this site. If you undertake to register and pay for a course on this site you pay for the entire period of your course at which point access to the paid for material on the site will be available to you. Most of the courses on this site are not restrained to a time frame so you can continue to access the material for as long as you require and we continue to be able to provide the content.
- 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 accessing the content. If you do not provide us with your details when you register for a membership of this site you will not be granted access to the paid for content as it will be impossible for us to identify you and determine which material you should have access to. Free material will always be available to you.
- 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. Our payment gateways (PayPall and Stripe) may do this in order to ascertain your ability to pay for any subscriptions you undertake with us. Please see their Privacy Policies for information on this.
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 use through the contact form and we will expidite the correction of any inaccuracies.
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”
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 payment details (Paypal and Stripe) or Marketing information (Constant Contact). At this time these 3 companies have still to produce their GDPR policy for us to review. We’re assuming we’ll be able to ask them all to remove data that we’ve previously supplied to them (in may ways they ask you directly for this information, it’s just that their forms are appearing embedded on our website). We have to assume they will be responsible under GDPR to conform to article
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.
Please contact us through the contact form should you require this service
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 through the contact form.
4.6. Right to Object
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
To object to your data being stored or processed please contact us through the contact form.
5. What We Collect
We may collect the following information:
- Name and other registration details (id, password etc)
- Email Address
- Payment Type
- Courses Enrolled In
- Course progression
- A copy of any direct communication with us
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:
- Internal record keeping.
- We may use the information to improve our products and services.
- We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided but only if you have opted in to one of our newsletters.
- We may use the information to customise the website according to your interests.
- We may need to contact you if there are any changes to the way you can access material or courses. Or if there have been any problems with the site that you should know about.
Note that 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 ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
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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. We only use this information for statistical analysis purposes and then the data is removed from the system.
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, other than the data you choose to share with us.
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.
Note that GDPR now provides you rights to withdraw or object to the processing of your data. Please see the GDPR sections above for more information
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 such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question
Note that 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