Privacy Notice
This Privacy Notice describes how we collect and use personal information about you when you use arunatherapy.thinkific.com to take part in our online courses, in accordance with the Data Protection (Jersey) Law 2018 (DPJL).
Aruna Therapy is the "Data Controller". This means that we are responsible for deciding how we hold and use personal information.
We are required under data protection legislation to notify you of the information contained in this Privacy Notice.
Aruna Therapy is registered with the Jersey Office of the Information Commissioner – Registration No. 61545.
We will comply with data protection law. This says that the personal information we hold about you must be:-
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
We will also only transfer your information when it is safe to do so, when it is necessary to do so and your information is protected in the same way that we protect it.
Aruna Therapy is accountable to you and the Authorities to not only show compliance with the data protection laws but also to demonstrate how we are compliant.
The Data Protection Lead (“DPL”)
We have appointed a DPL 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 DPL at [email protected]
You have the right to make a complaint at any time to the Jersey Office of the Information Commissioner, the supervisory authority in Jersey for data protection issues.
Contact details for these is outlined at the bottom of this Privacy Notice.
The Kind of Information We Hold About You
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).
To explain this to you, we will when necessary list our different services when we collect or use different information about you.
How Is Your Personal Information Collected?
We collect personal information about you when you contact us to inquire about our services, create an account to complete our online course, email you marketing information when you have agreed for us to do so, forms and surveys you complete, or provide use with your information for another specific purpose.
What information do we collect about you?
Contact use about our services.
- Records of email correspondence
- Name and contact details
Create an Account on arunatherapy.thinkific.com to complete an online course.
- Name
- Contact details (telephone number and email address)
- Course progress
- Billing address
Complete a Survey from us
- Details collected from user account (as above)
- May contain sensitive information of the user such as their health status (all survey fields are optional to complete)
Discussion forum
- Name
- Record of communication
Mentor sessions
- Names of those attending
- Notes from the sessions
What Special Category Data we collect about you?
We collect what is called Special Category data we will always have either a clear legal basis to process this or your explicit consent. If we rely on your explicit consent, you can withdraw this at any time by contacting our DPL at [email protected]
Special Category data is any information relating to your health, gender, race, sexual orientation, sex life, genetic or biometric data etc.
An example of this processing would be information you provide to us when you complete surveys provided when you take part in our online course. This information is then stored very safely in our computer system on for as long as we need from its original purpose.
How We Will Use Information About You?
We will only use your personal information when the law allows us to, this is called a legal basis (highlighted in bold) for processing your information (data).
Most commonly, we will use your personal information in the following circumstances:
Where we need to comply with a legal obligation.
Where you have entered into a contract with us to provide you with a service. This would be when you create an account to complete an online course and provide feedback, and when you complete one our Survey’s.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
Where you have given you consent to contact you for a specific purpose. This may be when you sign up to our course you have the option to accept marketing communications from us.
In an emergency and it is in your vital interest that we share your information, when we have it recorded.
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 the legal basis which allows us to do so.
Data Sharing
We may on occasions pass your Personal Information to organisation outside of Aruna Therapy exclusively to process on our behalf, these organisations are called Third Parties.
Aruna Therapy requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice.
We do not pass on information gained from your engagement with us without a clear legal basis for doing so. However, Aruna Therapy may disclose your Personal Information to meet legal obligations, regulations, or valid governmental request such as a Police request.
Data collected from you when you create a user account on thinkific.com to complete an online course created by Aruna Therapy is held on the thinkific.com platform. Aruna Therapy use thinkific.com as their website and online course builder. Access controls are in place for user accounts and personal data provided by the user. For more information about how thinkific.com use this information please visit https://www.thinkific.com/privacy-policy/
We use Mailchimp as our marketing platform. Security measures and access controls are in place to protect the personal data of the user. For more information about how Mailchimp.com use this information please visit https://mailchimp.com/legal/privacy/
We use Calendly so you can easily make bookings with us when you wish to discuss our course before purchase. Security measures and access controls are in place to protect your personal data. For more information about how calendly.com use this information please visit https://calendly.com/pages/privacy
It may also be processed by companies operating outside the EEA who work for us or for one of our service providers.
If we do this, we ensure that your privacy rights are respected in line with this Policy and the same protection is given to your personal information as laid down by the DPJL.
Data Security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, altered or disclosed, or accessed in an unauthorised way,. In addition, we limit access to your personal information to those Colleagues, Agents, Contractors and other third parties on a need to know basis.
They will only process your personal information on our strict instructions and they are subject to a duty of confidentiality.
Details of these measures may be obtained from our Data Protection Lead (DPL).
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.
Data Retention
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 requirements.
You can request our Data Retention Schedule from our DPL if required.
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.
It is important that the personal information we hold about you is accurate and current.
Please keep us informed if your personal information changes during your relationship with us.
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. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables 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 or request that we transfer a copy of your personal information to another party, please contact our DPL at [email protected]
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.
How to request your Information and what we may need from you
Please use the Data Subject Access request form, available here. This form will guide you through the information we require from you and who to send the form to. If you have any questions about this process or any of your rights, please contact our DPL at [email protected].
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.
We will respond to your request within 4 weeks after and upon satisfactory verification of your identity.
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 DPL at [email protected].
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.
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice 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 or requesting you to confirm the accuracy of the information we hold on you.
Complaints
We would like the chance to resolve any complaints you have about the way we process your information; however, you do have the right to complain to the Jersey Office of the Information Commissioner about how we have used your personal data.
Upon receipt of a Complaint about one of the products or services we offer it may be required that we share your data and the subject of the complain with a supplier or producer of the product or service you have complained about. This is part of the investigation into your complaint and we can assure you that your data will be protected as well as it is outlined in the notice.
If you do not want your data shared with a supplier or producer of the product or service you want to complain about, please inform the member of staff taking your Complaint, or email our DPL at [email protected]
The details for each of these contacts are:
Aruna Therapy – Data Protection Lead
Suite 18, Bourne House, Francis Street, St Helier, Jersey, JE2 4QE
Telephone 07797 766264 or email [email protected]
Office of the Information Commissioner – Jersey
2nd Floor, 5 Castle St, St Helier, Jersey JE2 3BT
Telephone +44 (0) 1534 716530 or Email: [email protected]