Your personal information allows us to provide the products and services you have asked for, as well as enabling us to improve those products and services by understanding your interests and preferences. By understanding what you like (and what you don’t) we are able to personalise your course, show relevant adverts and improve your course.
WHO WE ARE
www.second-nature.co (“we”, “our”, “us”) is the data controller.
LEGAL BASIS FOR USING YOUR INFORMATION
All organisations need a legal reason to use your personal information.
We are conscious of our legal responsibilities as a “data controller” and we shall endeavour to ensure that the personal information we obtain and use will always be held, used, transferred and otherwise processed in accordance with our legal obligations. If we don’t have a reason, we can’t use your personal information. There are a number of legal grounds that enable data processing. It’s quite complicated but below are the most relevant grounds you should be aware of.
1. With your consent (C)
However, if you do so, we may not be able to provide the product or service you have requested. For example, where we want to send you marketing messages by email, we would first ask your permission to opt-in. If you opt-in, you may request to opt-out at any time. We will indicate in the Policy where we rely on consent.
2. To fulfil a contract (A)
We also process your personal information in order to fulfil a contract we have with you. For example, when you book a workshop or online course with us, we will process your information to administer that course.
3. For a legitimate interest (LI)
Sometimes we may use your information to help achieve our business objectives but only where that activity doesn’t negatively affect your rights. For example, we might use your information to analyse occupancy rates of our courses and adjust course rates.
WHAT INFORMATION DO WE COLLECT?
When you interact with our products and services we collect information about you and that particular interaction. Generally this may include:
Your personal details
Contact information, and preferences
Information about your use of our programs, and other services when you work with us
Images of you during our events and retreats. We will always ask you in advance and you can always ask to not be included in these images.
Where you provide information to us about other people, you need to make sure you have their permission to do so.
For example when working together, you may provide us with details about your health and wellness background.
If you do not allow us to process any sensitive personal data, this may mean we are unable to provide all or parts of the services you have signed up for.
WHEN AND HOW WE COLLECT YOUR INFORMATION?
We collect information you provide to us directly and indirectly when interacting with our products and services, including when you book any events or programs with us.
You provide information directly to us
This may include when you:
Register to an online program
Create, use or manage an online account
Visit our website
Fill out our online forms
Buy products from us
Use social media pages
Interact with us in online forums, by email, text, or on social media
Post reviews of your experiences or interaction with us
Complete our market research/customer surveys
Enter competitions or promotions
Requests, complaints and/or disputes
2. You provide information via our websites
HOW WE USE YOUR PERSONAL INFORMATION
The reason we use your information will often be obvious from the way you interact with us. For example, if you registers for a program or coaching with us, we would use that information to administer your service with us. However, our uses of your information may not always be so obvious. You can find out more below. When you provide your information to us, we may use it to:
Use of Personal Information
Legal basis for processing (Where there is more than one, the exact grounds will depend on the activity – Click links to see the section above for an explanation of each)
Provide you with the products and services you have requested, including administering your bookings for sessions, responding to any enquiries, complaints or requests you may have C, LI, A
To manage our relationship with you C, LI, A
Allow you to participate in loyalty programmes C, LI, A
Send you market research surveys C, LI
Tailor our service to your preferences, where you tell us about them C, LI,A
Make decisions about what direct marketing to show you based on how you have interacted with us LI
Improve our products and services online and offline, including our websites LI, A
Allow you to interact with us online and offline, in forums, on social media and elsewhere C, LI, A
Monitor the use of our products and services and content LI, LO
Send you product or service related communications, service messages C, LI, A, LO
Send you direct marketing, where you have consented C, LI,
Allow social sharing functionality C, LI, A
Facilitate payments C, LI, A, LO
Investigate and respond to disputes C, LI, LO
(C) With your consent
(A) To fulfil a contract
We also process your personal information in order to fulfil a contract we have with you. For example, when you book a program/course with us, we will process your information to administer that program/course.
(LI) For a legitimate interest
Sometimes we may use your information to help achieve our business objectives but only where that activity doesn’t negatively affect your rights. For example, we might use your information to analyse success rates of the program and re-adjust the curriculum.
(LO) To comply with legal obligations
Further Information on how we use your information. We sometimes use your information for reasons that we think you might want a bit more detail on, so to help we have added more information to these below. There may be situations where we need to use your information to comply with legal obligations.
In addition to sending you information about the products and services you use (product communications) and in-life communications while you work with us, where we have your permission we may send you direct marketing communications about our products, services, events and offers.
Direct marketing communications may be sent by email, telephone, SMS and MMS, through social media (such as Whatsapp, Instagram, Twitter, and Facebook).
We may send you direct marketing while you have an ongoing relationship with us and for a reasonable time after you have used one of our products or services.
You will be able to opt-out of direct marketing by following the instructions in the communications you receive or changing your device settings.
Product related communications and in-life updates
We may use your information to send you newsletters, articles, support, and other in-life communications (about your course), and triggered communications where you make changes to your account or other information about products and services you have signed up for.
For example, we may send you email or text messages about an upcoming event with us in order to help you plan your visit and give you the best event experience possible. You’ll be able to opt-out of these.
Service communications will be sent to you regarding products and services you interact with. These are important messages relating to the products and services we provide to you.
ANALYSIS AND PRODUCT DEVELOPMENT
We may use your information to improve the products and services we offer. For example, we may look at the preferences our clients have to offer other clients comparable opportunities.
PROTECTION OF PERSONAL DATA
www.second-nature.co strive to protect the privacy of the information that you share with us. We have undertaken reasonable efforts to implement security measures designed to protect all data we collect against unauthorised access. We utilise the industry standard security measures available through your browser, so that it is unlikely that your information can be read as it travels over the Internet.
Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, although we strive to protect your information, we cannot ensure or warrant the security of the information that you submit to us via the Site and you do so at your own risk. We also implement measures to protect your personal information off-line.
We do not hold any of your payment information. That is done by PayPal or the other services you use to make your payment. All we see is the amount and date of the payment, which we need for our accounting processes.
DISCLOSURES REQUIRED BY LAW
Your information will be disclosed where we are obliged by law to do so. We may also disclose your information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, such as fraud.
We do not transfer or share your information.
ACCESS AND CONTROL
Updating your information
If you have an online account with us, please ensure that the information you provide (e.g. any contact information) is correct and that you review and update it regularly. Alternatively, you can tell us that your information has changed and we will update it for you.
Controlling direct marketing
A customer may allow www.second-nature.co to provide them with information about products and services that www.second-nature.co. www.second-nature.co will only do this where a customer has agreed to receive such information. You agree to receive marketing information:
From www.second-nature.co about our products and services by choosing not to opt-out on your registration form for a www.second-nature.co website or service.
From www.second-nature.co about similar products and services where you provide your details in the course of purchase or negotiations for the purchase of a product or service.
Controlling other communications
You can control the communications you receive from us, such as product related communications, by following the instructions in any relevant communication.
RIGHTS IN RELATION TO YOUR INFORMATION
Under GDPR, you may have the right to object, erase, or restrict our processing of your information – for example, where we process your personal information because this is in our legitimate interests, you may object to this. We will carefully consider your request as there may be circumstances which require us to, or allow us to, continue processing your data.
The request must be in writing and must contain the following:
Your name and postal address.
Details of your request.
Any details which may help us locate the information which is the subject of your request, for example:
Booking information and dates.
You must also provide:
Your signature and the date of the request.
If you are applying on behalf of another person then signed authority from the individual or the organisation is required.
Please send your request to:
Personal information from Children
We do not provide services to children, nor do we market to children. We do not knowingly collect personally identifiable information from children under 18 without permission from a parent or guardian. If you are a parent or legal guardians and think that your child under 18 has given us information, you can contact us at email@example.com
GDPR – The fees to access the personal data
We must provide a copy of the requested information free of charge. However, we can charge the requestor a ‘reasonable fee’ when a request is manifestly unfounded, mischievous, vexatious, specious or excessive, particularly if it is repetitive.
We may also charge a reasonable fee to comply with requests for further copies of the same information. This does not mean that we can charge for all subsequent access requests.
The fee will be based on the administrative cost of providing the information.
Complaining to the regulator
If you have any comments, concerns or complaints about our usage of your information we would ask that you contact us first, so that we can try and resolve any matter. However, where we are unable to assist, you are able to complain to the Information Commissioner’s Office in the United Kingdom or the data protection regulator in your country of residence, who will be able to liaise with the UK Information Commissioner in the UK.
Retention of your information
We will retain your information for as long as necessary for the uses set out in this Policy or while there is a legitimate business reason for doing so. We will destroy your personal information as early as practicable and in a way that the information may not be restored or reconstructed. If you ask us to delete your information before this time, we may not be able to do so for technical, legal, regulatory or contractual constraints. For example, where you wish to be suppressed from direct marketing, we would need to retain your information for this purpose.
Where you ask for your account to be closed, we will do this as soon as possible subject to any terms and conditions relating to the account. Your information will be retained in order to comply with legal and regulatory obligations as well as for analysis, to prevent fraud, collect any monies owed, and to resolve disputes.
COOKIES AND SIMILAR TECHNOLOGIES
What are cookies?
What cookies do we use?
These make our websites work. They remember what dates you want to study with us, what sort of course you want and that you are logged in to your account. They also allow us to collect information about your use of our websites and apps, enabling us to improve the way they work. Analytics cookies also allow us to see if there are any technical issues on our websites and if you are experiencing any issues using our websites. They also allow us to look at usage statistics and performance.
We use Google Analytics to help us understand how you use our services. For more information on Google Analytics, please visit Google’s website.
What other purposes do cookies and similar technologies are used for:
Allow you access to our websites;
Permit your internet connection to our websites;
Assess content usage;
Provide relevant content;
How to delete cookies?
Deleting your cookie settings is also relatively easy but the process does differ between browsers. Here’s how to delete cookies in the most popular browsers.
You can find this and further information about cookies at http://www.aboutcookies.org
From time to time we may make changes to this Policy. This might be in relation to changes in the law, best practice, changes to the services we provide or collection and use of your personal information. We will always display clearly when the Policy was last updated and where appropriate, notify you of any relevant changes.
If you would like to get in touch with us, please contact firstname.lastname@example.org
This policy was last updated on 24 May 2018