Adatkezelési tájékoztató - Agykontroll Nagy-Britannia


1		Introduction
	1.1	Mindfulness Education CIC takes your privacy very seriously. This policy contains important information about what to expect when we collect personal information about you and how we will use your personal data. Please read this policy carefully to understand our views and practices regarding your personal data.
	1.2	Mindfulness Education CIC registered office is Prospero House, 46 – 48 Rothesay Road, Luton, LU1 1QZ. Mindfulness Education CIC is trading as The Silva Method in Great Britain (aka Silva-GB)
	1.3	This policy applies to information we collect about:
		1.3.1	people who attend our Silva-GB events, seminars and buy tickets online or by contacting us on telephone or email or via any of our Silva-GB licensed instructors
		1.3.2	people who sign up for our Silva-GB news alerts and updates
		1.3.4	visitors to our website www.silvamethod.uk.com
	1.4	For the purpose of Data Protection legislation (which term includes, but is not limited to, the Data Protection Act 2018 and the General Data Protection Regulation (EU 2016/679)), the data controller is Mindfulness Education CIC. In relation to all your personal data that we hold, we will observe our obligations under the Data Protection legislation and the Data Protection Principles.
2		The information we collect about you
	2.1	When you attend our Silva-GB events, seminars, buying tickets online, telephone, email or a Silva-GB licenced Instructor, we may collect the following personal information from you:
		2.1.1	name and job title
		2.1.2	postal address, email address and telephone number
		2.1.3	your gender and age
		2.1.4	other information relevant to client surveys and/or applicable for seminar attendance or personal coaching
	2.3	We undertake to keep information about you confidential and in a way which does not enable you to be identified from the information displayed on our site, or otherwise published into the public domain.
	2.4	If you notify us by e-mail or other written communication that any of the information which we hold about you is incorrect or misleading, we will take prompt action to correct or amend the information. You may do this by sending an e-mail to better@silvamethod.uk.com.
3		How we will use the information about you
	3.1	When using the various sections of our website or when instructing us to act for you, you may be given the opportunity to provide certain defined personal information to Mindfulness Education CIC for processing when you opt into certain services. The relevant information will then be processed by us to communicate with you on any matters relating to the service to which the information relates as outlined below (and at all times in accordance with this privacy policy).:
		3.1.1	if collected through our online or offline ticket selling facilities, for the purpose of attending our seminars or other events
		3.1.2	if collected through the Sign Up / Register section of our website when you sign up to our newsletters.
		3.1.3	if collected through Silva-GB Scholarship Application Form in the website, for the purpose of communicating with you about your application
		3.1.4	if collected through the Silva-GB Feedback Form in the website, for the purpose of communicating with you about your submitted feedback
		3.1.5	if collected through the Student Testimonial Form in the website
		3.1.6	if collected through email or our website for the purpose of communicating with you about your submitted query or comment
	3.2	If you agree for us to do so, we may also contact you about other products and services we think may be of interest to you.
	3.3	We are never going to sell or give your personal data to any third parties.
	3.4	We may also use aggregate anonymous information and statistics for the purposes of monitoring website usage in order to help us to develop our website and our services.
	3.5	We occasionally run events and promotional activities jointly with other trusted professional parties. While we do not share our contact database with them, nor with other guests to our events, if you are attending the event and have not specifically requested otherwise, your name may be included in an attendee list which is shared with our co-hosts and with other guests.
	3.6	We may from time to time appoint service providers, such as IT, advertising and marketing professionals, printers and other such parties, to provide services to us (“data processors”). This may involve disclosing your personal data to them to enable it to be processed for a purpose which is consistent with this privacy policy. We will ensure that any appointments of data processors on our behalf will comply with the Data Protection legislation.
	3.7	We may in certain circumstances be forced to disclose information by the government or other law enforcement agencies or in connection with the investigation of unlawful activities. These circumstances are therefore exceptions to our policy of maintaining the privacy and confidentiality of your personal information, but we will only make such disclosures if, and to the minimum extent, required by law.
	3.8	If our business is sold, transferred or merged with another business, your details may be disclosed (upon suitable conditions as to confidentiality) to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
	3.9	Except as explained above, we will not disclose your personal data to any third parties for any other purpose.
	3.10	Where we process your data for direct marketing purposes, you can change your communication preferences at any time, in such circumstances you should use the facilities on the website or you can contact better@silvamethod.uk.com.
	3.11	We never have access to your credit or debit card information (therefore cannot store it either), when you are using your card to pay for any of our services. Your card information is collected and is visible only by a payment-gateway online service (e.g. Stripe, PayPal, AmazonPay, etc. whichever is used for a particular type of payment). We will ensure that such appointments of payment processors on our behalf will comply with the Data Protection legislation.
4		IP addresses
	4.1	We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and internal analysis. This will be used for statistical purposes, to analyse our users’ browsing actions and patterns, and is not intended to be used to identify any individual.
5		Marketing
	5.1	If you have provided your consent we may also wish to provide you with information about special features of our website or any other service we think may be of interest to you. If you have agreed to us providing you with marketing information and change your mind, you can always opt out at any time by using the facilities on the website or you can email better@silvamethod.uk.com.
6		Cookies and other information-gathering technologies
	6.1	Our website uses cookies. Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information.
	6.2	We use analytics cookies to collect information on how visitors interact with our website and to enable us to maintain and develop it. The data gathered, which includes details of the number of visitors to the site and the pages they access, is in anonymous form. It will not be used to identify individual users.
7		How we protect your information
	7.1	We store all information you provide to us on our secure servers. Unfortunately, the transmission of information via 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 to our site or via e-mail; any such transmission is undertaken at your own risk. Appropriate measures can be agreed to limit this risk, but we accept no responsibility for any unlawful interception or other access to your data that occurs outside of the systems over which we have control. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
8		Access to your information and updating and correcting your information
	8.1	You have the right to request a copy of the information that we hold about you. If you consider that any of that information ought to be corrected or erased, or if you wish to object to the processing of any data that we hold about about, you can also request this. If you would like to exercise any of these rights, please send an email to better@silvamethod.uk.com. Your rights can be exercised in accordance with the Data Protection legislation. Any repetitive or excessive access requests may be subject to a fee to meet our costs in providing you with details of the information we hold about you. For the protection of our clients’ information, we may require evidence of your identity before allowing you to exercise any of the above rights. We may in some instance be prohibited by law from allowing you to exercise those rights fully, and in some circumstances may not be able to inform you about the nature of that prohibition.
	8.2	We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to Mindfulness Education CIC changes, for example if you change your email address or name, please let us know the correct details by using the facilities on the website or sending an email to better@silvamethod.uk.com. You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.
9		Lawful conditions for processing
	9.1	A range of lawful conditions may exist for our processing of your data. These are set out in an addendum to this privacy notice, below.
10		Changes to Privacy policy
	10.1	We keep our Privacy policy under regular review. If we change our Privacy policy we will post the changes on this page, and place notices on other pages of the website, so that you may be aware of the information we collect and how we use it at all times. This Privacy policy was last updated on 24 May 2018.
11		How to contact Mindfulness Education CIC
	11.1	We welcome your views about our website and our Privacy policy. If you would like to contact us with any queries or comments please send an email to better@silvamethod.uk.com.
12		Links to other websites
	12.1	Our website contains links to other websites. This Privacy policy applies only to this website so when you access links to other websites you should read their own privacy policies.

ADDENDUM – THE LAWFUL CONDITIONS FOR PROCESSING DATA

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest

Buying a ticket for one of our seminars/events or personal coaching service	(a) Name, email address, postal details of your main residence (country, town and postcode) – Part of Identity and Contact details (b) year of birth – Part of Identity (c) mobile number – Part of Contact details (d) job-title, gender (e) Course and subject interests – Part of Marketing preferences, info (f) Where you found out about us, our courses – Part of Marketing info (g) payment details (amount, date, course/event-id the transaction is for, Payment-gateway transaction-ID, but not any card-details)	(a & b) Necessary to create a unique identifier for you, to be able to issue a world-wide course certificate that has international entitlements for you (a & c) Necessary to keep contact with you before and after the event (e.g. sending you your booking confirmation, notifying of any last-minute changes, post-course support) (b) Necessary to check your entitlement to courses as each course type has age-limits (d & e & f) To be able to target our advise and training appropriately to your gender and area/expertise of your work. Some of our workshops are gender and work-specific. (a) To be able to target identify your approximate geographical location for notifying you about courses/events in your area. (g) Necessary to send you your booking confirmation and be able to maintain a class-register for each event; to be able to maintain our company’s Financial Accounts (g) Payment-gateway transaction-ID is necessary to verify payment and manage refunds when applicable (a – g) Necessary to generate and maintain course attendance history in order to identify attendants’ repeat privilegies identify attendants’ advance course entitlements better target upcoming course notifications to yopu To our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Sign Up / Register section of our website when you sign up to our newsletters	(a) Name, email address, postal details of your main residence (country, town and postcode) – Part of Identity and Contact details (b) year of birth – Part of Identity (c) job-title, gender (d) Course and subject interests – Part of Marketing preferences, info (e) mobile number – Part of Contact details	(a to d) Necessary to be able to target our notifications of events appropriately to your gender, age, area/expertise of your work geographical location. (e) Necessary as a backup-notification channel, when emails bounce (likely changed) and need replacement. Notifying the client via SMS-text message that his/her email does not work any more.

Silva-GB Scholarship Application Form in the website	(a) Identity, contact details (b) Your reasons and circumstance for requiring financial assistance (c) Your specific interest in our foundation course	(a) Necessary to be able to communicate with you and create a unique identifier for you as a client in our system (b) To assess your request for financial assistance (c) To assess your if our foundation course is suitable for your interest/goals

Silva-GB Feedback Form in the website	(a) Identity, contact details (optional) (b) Your feedback on our course/service (b) Option for you to allow publishing all or part of your feedback	(a) Necessary to be able to discuss your feedback with you, should you provide this detail (b) Your feedback will be used to improve our courses/products/services to you (c) You may allow us to publish all or part of your feedback (with or without your name)

Student Testimonial Form in the website	(a) Identity, contact details (b) Your testimonial, your experience related to our courses/services (any combination of tex, photos, video-clip) (b) Option for you to allow publishing your testimonial	(a) Necessary to be able to discuss your testimonial (b) Your testimonial will be used to improve our courses/products/services to you (c) You may allow us to publish your testimonial (with or without your name)

To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy; (a) Notifying you about upcoming events; (a) Sending you newsletters, relevant to our courses, services (b) Asking you to leave a review or take a survey or provide a testimonial	Identity, contact details, and marketing info	(a) Performance of our service to you (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a competition or complete a survey	Identity, contact details and marketing preferences	(a) Performance of our service to you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity, contact details and technical data such as IP address	(a) Necessary for our legitimate interests (for running our 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

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity, contact details, technical data such as IP address, marketing preferences	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical data such as IP address	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services or legal developments that may be of interest to you	Identity, contact details, usage data and marketing preferences	Necessary for our legitimate interests (to develop our products/services and grow our business)