Aerial Roots 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.
Aerial Roots 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 25/5/2018.
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 Wix/Facebook 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.
3.1. Scope 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.
3.2. Principles 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
• Accuracy 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.
• Accountability 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 Julie Garrioch, dunavon gardens Dunipace• contact details of the data protection oﬃcer • the purposes of the processing , Class registers, class newsletters, workshops and events • the legitimate interests pursued by the controller newsletters, latest events and timetables and changes 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 individuals 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 – google mail and face book messenger • if we “intend to transfer personal data to a third country or international organisation” Seasonal yoga Academy and cover teachers
We are also required to tell you :-
• the period for which the personal data will be stored will be duration of attending class and 1 year later that you have the right to
• request access ie that you can see the data we have on you.by emailing through webpage, message via face book and requesting data • rectiﬁcation or erasure of personal data
ie that you want your data changed or deleted entirely. email address on website or face book messenger • 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. following procedures laid down by Wix.
• 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. send email on site or message via face book • 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. email address on website • 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.
• the provision of personal data is a “statutory or contractual requirement, or a requirement necessary to enter into a contract” such as booking classes or events • you are “obliged to provide the personal data and of the possible consequences of failure to provide such data” we cannot book you in • the “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 via webpage or Face book 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”
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 send email to the address on website. 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 send request via email address on this website.
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 send request to email on this site.
5. What We Collect We may collect the following information:
• details relating to your attendance in class or to our events 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:
• Hold class records for latest information, changes, cancellation of classes/events. • 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.
• From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests
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
7. Security. .Your internet and social media data is held on by password protected technology, paper files are filed and in a locked cabinet.
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