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Privacy policy

SATKARMA HUMANITARIAN YOUTH AWAKENING MISSION (SHYAM) 

PRIVACY POLICY

Satkarma Humanitarian Youth Awakening Mission ("SHYAM"respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to who we are and how and why we collect, store, use and share your personal data when you:

·           visit our website at www.gitaclass.org;

·           are on our e-mail mailing list;

·           are on our WhatsApp distribution list;

·           are on our mobile phone text distribution list; and/or

·           attend our events. 

This privacy policy will also tell you about your privacy rights and how the law protects you.

By:

·         using our website;

·         being on our e-mail mailing list;

·         being on our WhatsApp distribution list;

·         being on our mobile phone text message distribution list; and/or

·         by attending our events,

you are agreeing to be bound by this policy in respect of that aforementioned activity or those aforementioned activities (as applicable and as the context permits).

By submitting your personal data to us, you acknowledge that:

·      You have read and understood this privacy policy and consent to us using your personal data as set out in this privacy policy.

·      Your personal data may be transferred and processed by third party service providers in countries inside and outside of the EEA that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this privacy policy.

 

1.    IMPORTANT INFORMATION AND WHO WE ARE

(a) Purpose of this privacy policy

This privacy policy aims to give you information on how SHYAM collects and processes your personal data as a data controller through your:

·         use of our website;

·         being on our e-mail mailing list;

·         being on our WhatsApp distribution list;

·         being on our mobile phone text message distribution list; and/or

·         attendance at our events,

including any data you provide through any of the aforementioned activities.

We do not knowingly collect data relating to children aged 16 or under and are concerned to protect the privacy of children.  If you are aged 16 or under then please get your parent/guardian’s permission before you provide us with your personal data.

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

 

(b) Who we are

SHYAM (collectively referred to as "we", "us" or "our" in this privacy policy) is a non-profit organisation whose address is: Satkarma Humanitarian Youth Awakening Mission (SHYAM), Suite 1835, Kemp House, 152 City Road, London EC1V 2NX, United Kingdom. 

SHYAM has been established to practice and promote spiritual, educational, humanitarian, political, recreational and community related activities.

SHYAM is the controller and responsible for your personal data provided to us.

 

(c) Third-party links

Our website, our e-mails, our Whatsapp messages or our mobile phone text messages 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. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, our Whatsapp messages or our mobile phone text messages, we encourage you to read the privacy policy of every website you visit.

 

2.    THE DATA WE COLLECT ABOUT YOU

In this policy, "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).

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

·      Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title and gender.

·      Contact Data includes address, email address and telephone numbers.

·      Work Data includes your job title, employer and organisation to which you belong.

·      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, other technology on the devices you use to access our website, our e-mails, our WhatsApp messages or our text messages, and information obtained from automatic data collection tools including when you open our e-mails, WhatsApp messages or text messages, which website pages you visit and which links you click in our e-mails, WhatsApp messages and text messages.

·      Profile Data includes your username and password, your interests, preferences, feedback and survey responses.

·      Usage Data includes information about how you use our website or read our e-mails.

·      Communications Data includes your communication preferences.

The personal data provided allows us to carry out our activities and confirm your identity. 

On registration on our e-mail mailing list, our WhatsApp distribution list or our mobile phone text message distribution list, your information is stored in our separate SHYAM e-mail, WhatsApp or mobile phone text message subscriber databases that are only accessible by the governing committee of SHYAM.

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

We 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 we collect any information about criminal convictions and offences.

3.    HOW IS YOUR PERSONAL DATA COLLECTED

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

·      Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, WhatsApp message, text message, e-mail or otherwise. This includes personal data you provide when you:

·         subscribe to our e-mails, WhatsApp messages and/or mobile phone text messages;

·         request e-mails, WhatsApp messages and/or mobile phone text messages to be sent to you; 

·         register for or attend any of our events;

·         apply for a volunteering opportunity with us;

·         enter a competition or survey with us; or

·         get in touch with us through the post, e-mail, social media, telephone, WhatsApp, text message or in person.

·      Automated technologies or interactions. As you interact with our website or read our e-mails, WhatsApp messages or text messages, we may automatically collect Technical Data about your equipment, browsing, viewing or clicking actions and patterns. We may collect this personal data by using cookies, server logs and/or other similar technologies. Please see our cookie policy for further details.

·      Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources being Technical Data from the following parties:

·           analytics providers such as Google based inside or outside the EU;

·           search information providers such as Google based inside or outside the EU; or

·           social media, media and messaging service providers such as Facebook, LinkedIn, Twitter, Instagram, YouTube and WhatsApp.

4.    HOW WE USE YOUR PERSONAL DATA

(a) Use of your personal data

We will only use your personal data when the law allows us to.  We will therefore only use your personal information:

·      where we need to perform the contract we are about to enter into or have entered into with you;

·      where we need to comply with a legal or regulatory obligation;

·      if you have given your consent (where necessary) to such use or the organisation you work for has obtained your consent (where necessary) to share your information with us; or

·      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. 

Legitimate interest means the interest of our organisation in:

·         conducting and managing our organisation to enable us to give you the best not-for-profit service and the best and most secure experience;

·         identifying ways to grow our not-for-profit organisation;

·         keeping our records updated;

·         studying how subscribers use our not-for-profit services and what they think of our not-for-profit services including through feedback;

·         defining types of subscribers for our not-for-profit services;

·         promoting, improving and developing our not-for-profit services;

·         informing our marketing strategy;

·         keeping our website updated and relevant; or

·         proving administration and IT services and network security.

We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting info@gitaclass.org.

If you register to receive communications from us, your data is used by and in support of our activities.  These include:

·      Sending you SHYAM updates, e-mails, WhatsApp messages, mobile phone text messages and/or newsletters relating to various spiritual, educational, humanitarian, political, recreational and community related activities, appeals or causes where SHYAM and its speakers, volunteers and members are involved or are to be involved.

·      Inviting you to SHYAM events, activities and classes.

·      Inviting you to join or support our social media accounts and messaging service broadcasts.

·      Sending you details of the benefits of being a member or subscriber of SHYAM.

·      Inviting you to campaign for or to participate in various spiritual, educational, humanitarian, political, recreational and community related activities, appeals or causes.

·      Administrative purposes for example to administer an event you have registered for or attended.

Communications to you will be sent by e-mail, WhatsApp message or mobile phone text message according to the preferences expressed by you about the types of communications you would like to receive.

You can ask us or third parties to stop sending you communications at any time by following the opt-out links on any e-mail, WhatsApp message or mobile phone text message sent to you or by contacting info@gitaclass.org at any time. We will always respect a request by you to stop processing your personal data.  In addition, your statutory rights are set out below.

(b) Purposes for which we will use your personal data

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

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact info@gitaclass.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To manage our relationship with you which will include:

 

(a) Notifying you about changes to our privacy policy

 

(b) Asking you for feedback

(a) Identity

(b) Contact

(c) Profile

(d) Communications

(a) Necessary to comply with a legal obligation

 

(b) Necessary for our legitimate interests (to keep our records updated, to study how subscribers use our not-for-profit services and what they think of our not-for-profit services, improving our not-for-profit services and identifying ways to grow our organisation)

 

(c) If you have given your consent or the organisation you work for has obtained your consent to share your information with us

To enable you to partake in a competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Communications

(a) Necessary for our legitimate interests (to study how subscribers use our not-for-profit services, to develop them and grow our organisation)

 

(b) If you have given your consent or the organisation you work for has obtained your consent to share your information with us

To administer and protect our organisation and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our organisation, provision of administration and IT services and network security)

 

(b) Necessary to comply with a legal obligation

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

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Communications

(f) Technical

Necessary for our legitimate interests (to study how subscribers use our not-for-profit services, to develop them, to grow our organisation and to inform our marketing strategy)

To use data analytics to improve our website, not-for-profit services, marketing, subscriber/visitor relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of subscribers for our not-for-profit services, to keep our website updated and relevant, to develop our organisation and to inform our marketing strategy)

To make suggestions and recommendations to you about not-for-profit services and events that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(a) Necessary for our legitimate interests (to develop our not-for-profit services and grow our organisation)

 

(b) If you have given your consent or the organisation you work for has obtained your consent to share your information with us

To invite you to take part in events, activities, seminars or similar events, and to manage your participation in them

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Communications

(f) Technical

(a) Necessary for our legitimate interests (to  ensure our records are up-to-date, promote our not-for-profit services, receive feedback, develop our not-for-profit services and grow our organisation)

 

(b) If you have given your consent or the organisation you work for has obtained your consent to share your information with us

To send you communications by e-mail, WhatApp messages or mobile phone text messages

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Communications

(f) Technical

(a) Necessary for our legitimate interests (to develop our not-for-profit services and grow our organisation)

 

(b) If you have given your consent or the organisation you work for has obtained your consent to share your information with us

 

 

(c) Cookies and other tracking technologies


We may use first party and third party cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) to identify you and your interests, to remember your preferences, and to track your use of our websites. We also use Cookies and Other Tracking Technologies to control access to certain content on our website, to protect the website, and to process any requests that you make of us.

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 our website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.

(d) Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact info@gitaclass.org at any time

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

Please note that we 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

We only allow our third party service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our 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 our instructions.

Your data will not otherwise be passed to external organisations other than for the purpose of making specified benefits of SHYAM’s activities and not-for-profit services available to you. However, we may use third party processors to conduct research, process data or maintain our website, broadcasts, content or other services.

We will also use your personal information to create anonymous member statistics, from which you cannot be identified.

SHYAM may use social media, media, messaging service, web designing, web hosting, event management, ticketing or e-mail marketing sites and applications such as Facebook, LinkedIn, Twitter, Instagram, YouTube, WhatsApp, Eventbrite, MailChimp and GoDaddy.  The data we are given access to by such providers and services will vary but will always be in line with the terms of that particular provider of service. If you use these services or the products of these services, you should review their privacy policy for more information on how they deal with your personal information.

6.    INTERNATIONAL TRANSFERS

Information may be held at SHYAM or third party parties used by SHYAM for our activities, projects and services as described in section 5 above (Disclosures of your personal data).  These third parties include:

·      service providers acting as processors who provide IT and administration services;

·      professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services; or

·      HM Revenue & Customs, regulators and other authorities based who require reporting of processing activities in certain circumstances.

Some of these external third parties are based outside the European Economic Area ("EEA") so their processing of your personal data will involve a transfer of data outside the EEA.

Our e-mail newsletter platform, MailChimp is located in the USA, and is fully compliant with data protection laws of the USA. The European Commission has made an “adequacy decision” with respect to the data protection laws of the USA, provided that the company is part of the EU-US Privacy Shield. Read MailChimp’s privacy policy by clicking here.

Whenever we transfer your personal data out of the EEA, we will do this in accordance with applicable data protection laws, will take appropriate safeguards in order to ensure its integrity and protection, and will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

·      We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

·      Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

·      Where we use providers based in the USA, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact info@gitaclass.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.    DATA SECURITY

We 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, we limit access to your personal data to the governing team of SHYAM, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We 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 we are legally required to do so.

Unfortunately the transmission of information using the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted online or through the website.  Any transmission is at your own risk.  Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access.

8.    DATA RETENTION

We see being a member of SHYAM as a lifelong relationship.  Generally, SHYAM will look to retain your personal data until you ask us to remove it from our records.  We will routinely remind you of your right to have us remove your personal data.

If you decide that you no longer wish to receive communications from SHYAM please be aware that we still need to retain a minimal amount of personal data so that we can keep a record that you have asked us not to contact you or to the extent required or otherwise permitted by law.

In some circumstances you can ask us to delete your data (see "request erasure" in Section 9 below for further information).

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.    YOUR LEGAL RIGHTS

(a) The rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  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 we hold about you and to check that we are lawfully processing it.

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

·      Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we 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 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we 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 us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

·      Request the transfer of your personal data to you or to a third party. We 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 us to use or where we used the information to perform a contract with you.

·      Withdraw consent at any time where we are 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, we may not be able to provide certain not-for-profit services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact info@gitaclass.org.  We may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of data.

(b) 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, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

(c) What we may need from you

We may need to request specific information from you to help us 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. We may also contact you to ask you for further information in relation to your request to speed up our response.

(d) Time limit to respond

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

10. HOW TO COMPLAIN

We hope that we can resolve any query you may raise about our use of your information. You may also have the right to lodge a complaint in relation to our processing of your personal data with a local supervisory authority. We will provide you with details of your relevant regulator upon request. We would appreciate the chance to deal with your concerns before this so please contact us in the first instance.

11.   CHANGES TO THE PRIVACY POLICY

This privacy policy was last updated on 23 May 2018.  We may make minor changes to this privacy policy to reflect changing legal requirements or our processing practices.  When we make these changes we will publish the updated notice on our website.  If we make significant changes, we will take additional steps to inform you of these.

12.   YOUR DUTY TO INFORM US OF CHANGES

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

13.   HOW TO CONTACT US

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Our contact details are as follows:

·         Our full name: Satkarma Humanitarian Youth Awakening Mission (SHYAM).

·         Our e-mail address: info@gitaclass.org.

·         Our postal address:  Satkarma Humanitarian Youth Awakening Mission (SHYAM), Suite 1835, Kemp House, 152 City Road, London EC1V 2NX, United Kingdom.