Privacy Policy — Meditation with Rhodope

INTRODUCTION

Welcome to Meditation with Rhodope’s privacy policy.

Meditation with Rhodope respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how I look after your personal data when you visit my website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO I AM

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how I collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to my newsletter.

This website is not intended for children and I do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy I may provide on specific occasions when I am collecting or processing personal data about you so that you are fully aware of how and why I am using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

Rhodope Kostalas is the controller and responsible for your personal data (collectively referred to as “me”, “I” or “my” in this privacy policy).

CONTACT DETAILS

If you have any questions about this privacy policy or my privacy practices, please contact me via email at meditationwithrhodope@gmail.com.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). I would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact me in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM ME OF CHANGES

I keep the privacy policy under regular review.

It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party websites and am not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy policy of every website you visit.

2. THE DATA I COLLECT 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).

I may collect, use, store and transfer different kinds of personal data about you which I have grouped together as follows:

• Identity Data includes first name, last name, marital status, title, date of birth and gender.

• Contact Data includes email address and telephone numbers.

• Transaction Data includes details about payments to and from you and other details of services you have purchased from me.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

• Profile Data includes your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use my website and services.

• Marketing and Communications Data includes your preferences in receiving marketing from me and my third parties and your communication preferences.

I also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, I may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if I combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, I treat the combined data as personal data which will be used in accordance with this privacy policy.

I do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do I collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where I need to collect personal data by law, or under the terms of a contract I have with you, and you fail to provide that data when requested, I may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, I may have to cancel a service you have with me but I will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

I use different methods to collect data from and about you including through:

• Direct interactions. You may give me your Identity and Contact Data by filling in forms or by corresponding with me by post, phone, email or otherwise. This includes personal data you provide when you:

• subscribe to my service or publications;

• request marketing to be sent to you; or

• give me feedback or contact me.

• Automated technologies or interactions. As you interact with my website, I will automatically collect Technical Data about your equipment, browsing actions and patterns. I collect this personal data by using cookies and other similar technologies. Please see the cookie policy below for further details.

• Third parties or publicly available sources. I will receive personal data about you from various third parties [as set out below:

• Technical Data from analytics providers such as Google based outside the UK; and

• Contact and Transaction Data from providers of technical and delivery services such as PayPal, Acuity Scheduling and MailChimp based outside the UK.

4. HOW I USE YOUR PERSONAL DATA

I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:

• Where I need to perform the contract I am about to enter into or have entered into with you.

• Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where I need to comply with a legal obligation.

To find out more about the types of lawful basis that I will rely on to process your personal data, please see the glossary below.

Generally, I do not rely on consent as a legal basis for processing your personal data although I will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting me.

PURPOSES FOR WHICH I WILL USE YOUR PERSONAL DATA

I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.

Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which I am using your data. Please contact me if you need details about the specific legal ground I am relying on to process your personal data where more than one ground has been set out below.

Purpose/Activity

To register you as a new customer

Type of Data

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest

Performance of a contract with you

Purpose/Activity

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to me

Type of Data

(a) Identity

(b) Contact

(d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary for my legitimate interests (to recover debts due to me)

Purpose/Activity

To manage our relationship which will include:

(a) Notifying you about changes to my terms or privacy policy

(b) Asking you to leave a review or take a survey

Type of Data

(a) Identity

(b) Contact

(d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

Purpose/Activity

To enable you to partake in a prize draw, competition or complete a survey

Type of Data

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary for my legitimate interests (to study how customers use my services, to develop them and grow my business)

Purpose/Activity

To administer and protect my business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of Data

(a) Identity

(b) Contact

Lawful basis for processing including basis of legitimate interest

(a) Necessary for my legitimate interests (for running my business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

Purpose/Activity

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising I serve to you

Type of Data

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

Lawful basis for processing including basis of legitimate interest

Necessary for my legitimate interests (to study how customers use my services, to develop them, to grow my business and to inform my marketing strategy)

Purpose/Activity

To use data analytics to improve my website, products/services, marketing, customer relationships and experiences

Type of Data

(a) Technical

(b) Usage

Lawful basis for processing including basis of legitimate interest

Necessary for my legitimate interests (to define types of customers for my products and services, to keep my website updated and relevant, to develop my business and to inform my marketing strategy)

Purpose/Activity

To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of Data

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

Necessary for my legitimate interests (to develop my services and grow my business)

MARKETING

I strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM ME

I may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what I think you may want or need, or what may be of interest to you. This is how I decide which services and offers may be relevant for you (I call this marketing).

You will receive marketing communications from me if you have requested information from me or purchased services from me and you have not opted out of receiving that marketing.

OPTING OUT

You can ask me or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting me at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to me as a result of a service purchase, service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies I use, please see the Cookie Policy below.

CHANGE OF PURPOSE

I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact me.

If I need to use your personal data for an unrelated purpose, I will notify you and I will explain the legal basis which allows me to do so.

Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

I may share your personal data with External Third Parties (defined in the Glossary below) for the purposes set out in the table above.

I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow my third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with my instructions.

6. INTERNATIONAL TRANSFERS

I do not transfer your personal data outside the UK.

7. DATA SECURITY

I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, I limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on my instructions and they are subject to a duty of confidentiality.

I have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where I am legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

I will only retain your personal data for as long as reasonably necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. I may retain your personal data for a longer period in the event of a complaint or if I reasonably believe there is a prospect of litigation in respect to my relationship with you.

To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask me to delete your data: see Your Legal Rights below for further information.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please contact me.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I could refuse to comply with your request in these circumstances.

WHAT I MAY NEED FROM YOU

I may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up my response.

TIME LIMIT TO RESPOND

I try to respond to all legitimate requests within one month. Occasionally it could take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of my business in conducting and managing my business to enable me to give you the best service and the best and most secure experience. I make sure I consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for my legitimate interests. I do not use your personal data for activities where my interests are overridden by the impact on you (unless I have your consent or are otherwise required or permitted to by law). You can obtain further information about how I assess my legitimate interests against any potential impact on you in respect of specific activities by contacting me.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that I am subject to.

EXTERNAL THIRD PARTIES

• Service providers based in the United Kingdom who provide IT and system administration services.

• Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities based in the United Kingdom.

• MailChimp, based outside the United Kingdom, who provide email services.

• PayPal, based outside the United Kingdom, in order to receive payments for my services.

• Acuity Scheduling, based outside the United Kingdom, in order to process appointments and bookings for my services

YOUR LEGAL RIGHTS

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data I hold about you and to check that I am lawfully processing it.

• Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to me.

• Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where I am 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios:

• If you want me to establish the data’s accuracy.

• Where my use of the data is unlawful but you do not want me to erase it.

• Where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims.

• You have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for me to use or where I used the information to perform a contract with you.

• Withdraw consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain to you. I will advise you if this is the case at the time you withdraw your consent.

COOKIE POLICY

My website uses cookies to distinguish you from other users of my website. This helps me to provide you with a good experience when you browse my website and also allows me to improve my site.

A cookie is a small file of letters and numbers that I store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

I use the following cookies:

· Strictly necessary cookies. These are cookies that are required for the operation of my website. They include, for example, cookies that enable you to log into secure areas of my website or make use of e-billing services.

· Analytical or performance cookies. These allow me to recognise and count the number of visitors and to see how visitors move around my website when they are using it. This helps me to improve the way my website works, for example, by ensuring that users are finding what they are looking for easily.

· Functionality cookies. These are used to recognise you when you return to my website. This enables me to personalise my content for you, greet you by name and remember your preferences (for example, your choice of language or region).

· Social media cookies. These cookies work together with social media plug-ins. For example, when I embed photos, video and other content from social media websites, the embedded pages contain cookies from these websites. Similarly, if you choose to share my content on social media, a cookie may be set by the service you have chosen to share content through.

Please note that the following third parties may also use cookies, over which I have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies such as Google Analytics, Facebook and Instagram.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of my website.

Except for essential cookies, all cookies will expire after 6 years of inactivity of your account.

If you have any questions about my cookie policy, please contact meditationwithrhodope@gmail.com.

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