The purpose of this policy
Your personal data is protected by law and we want you to know your individual rights, which include your right to know what data is held about you, how this data is processed and how you can place restrictions on the use of your data.
This Policy applies when you may share personal data in contact with us via our website, online forms, email, social media accounts, the telephone, when writing to us directly, providing photographic or video content, or where we provide you with paper based forms for completion or we complete a form in conjunction with you.
To provide a high standard to our client’s personal data and privacy, we aim to comply with the General Data Protection Regulation (EU) or (“GDPR); any other applicable privacy legislation (collectively the “Data Acts”). The Data Acts govern the way that we collect, use, disclose, store, secure and dispose of your Personal Data.
We are the controller of any personal data gathered by your use of our website and services. Where we use third parties to process your data, we have a contract with these third parties for the provision of these services.
A data ‘controller’ means the individual or organization which, alone or jointly with others, determines the purposes and means of the processing of personal data.
A data ‘processor’ means the individual or organization which processes personal data on behalf of the controller.
What is personal data? Personal Data is information relating to an identified or identifiable natural person. Examples include an individual’s name, age, address, date of birth, gender and contact details.
Sensitive Personal Data may contain information which is known as special categories of personal data. This may be information relating to and not limited to, an individual’s health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and biometric data, or data relating to sexual orientation. We are legally required to comply with specific data processing requirements for Personal and Sensitive Data.
What personal data do we collect about you? As a provider of Golden Quantum Attunement, Spinal Attunement, Golden Transformational Journey/From Nigredo to Rubedo and Fusion De-Armouring Services, we will process the following categories of data:
(a) Personal Data, such as:
Date of birth
Contact details including address, email, telephone, next of kin name and telephone
(b) Sensitive Personal Data:
Current health and details of historic health states, injuries or illnesses (physical and psychological)
Photographs, audio and visual
Aspects of your health that may be required for, or affect your participation or our provision of services to you
If you object to the collection, sharing and use of your personal data we may be unable to provide you with our services.
Sensitive Data will be used by us only:
For the primary use for which is was obtained
For a secondary purpose that is directly related to the primary purpose
With your consent, or where required or authorized by law
We are committed to securely storing and handling your sensitive information.
Only Kaja Pogacar have access to sensitive material
Some sensitive information may be stored securely online, or in the cloud through Google Drive
You may choose not to provide us with your sensitive information. However, if you choose not to be completely honest with us, we may not be able to provide you with the services that you request. We do not sell or pass your personal information onto third parties.
Recording Sessions online or in-person: We may record your communications with us. This may be for instances such as playback to you, in consultation for professional development, or for teaching or demonstration purposes. This will only ever be conducted if discussed with you prior, and only with your express permission. If permission is given, you may rescind this permission at any time.
We may collect information about your visits to us to help us personalize your experience with us. By providing this information to us you are consenting our use in the manner set out in this policy.
Why do we collect your personal data? We use this information to:
respond to your enquiries
provide you with relevant news and updates about our services
improve our websites and the services we provide
We will only collect your personal information:
with your full awareness and consent, such as when you email us, tick a checkbox or fill in a form to provide us with information
if we need it to provide you with information or services that you request
for necessary administrative processes if you become our client
if we believe that we can demonstrate a legitimate interest in using your data for marketing purposes, although we will always give you a choice to opt out
We will also collect your Personal Data where you request information about our services, via our website, provide information in communications with us via in person, telephone, texts, social media, events, promotions, campaigns, from cookies and third parties. We may collect information about your visits to us to help us personalize your experience with us. We may also ask for feedback from our sessions and may use your feedback for publication on our website and social media. By providing this information to us you are consenting our use in the manner set out in this Policy.
When we collect Personal Data we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it. Please ask if you do not understand. If you object to the collection, sharing and use of your personal data we may be unable to provide you with our services.
Third Party Suppliers: Where reasonable and practicable to do so, we will collect your Personal Data only from you. However, in some circumstances we may be provided with information by third parties. We may use third party suppliers for management of specific services e.g. payment processing, and they may store some of your Personal Data to provide such service to you. In such a case, we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party or that you can access your account to check this information directly yourself.
We do not sell or pass your personal information onto third parties.
Client Notes and Sessions: We take and keep notes on paper and online that contain Personal Data and may include Sensitive Data during your appointments. We may also take photographs and video recordings of our sessions. These are scanned and stored in Google Drive to ensure that it is safe and secure.
Payments Online: If you pay an online transaction such as credit card we use Stripe. These third-party payment facilitators are compliant to ensure your financial data is secure and we can never access your full payment details. You can learn more about Stripe security measures here.
Marketing: We may promote our services to you using the information you provide to us, including email or text. If you wish to receive promotional offers, please opt in by completing the form on our website, or by emailing email@example.com to request to be added.
Mailing List: If you opt in to receive our emails, SMS, social media you will receive a monthly email with updates and offers from us. You can unsubscribe from this at any time from within one of these emails or contacting us at firstname.lastname@example.org.
Social Media: If you follow us on any social media platforms, your privacy settings in your social media account control what you share with others. Please check this if you are concerned about your privacy on any social media platform. Please let us know if you do not wish to be tagged in any of our posts.
Photos / Videos of Sessions: Where appropriate, during our sessions, on retreats, and in other services we may take photographs and/or videos of you which may be used on social media and for the marketing of our services. Please contact us at any time should you wish to change or amend any posts on social media by us or be removed from recordings.
Quotes for Services: If you contact us for a quote or request services we provide, we consider ourselves as having a legitimate business interest to provide you with further information about our services. You may request that we stop this at any time via email at email@example.com.
Development: We will also use your Personal Data to manage your account, perform statistical analysis on the data we collect, for business forecasting purposes, and to develop new and market existing services.
Data retention / Disclosure of data: We may release personal data where we believe that it is appropriate in a number of circumstances, including the following:
Third parties where you consent to the use or disclosure;
Where required or authorized by law;
To enforce or apply our agreements with you;
To protect the rights, property or safety of us, our clients or others; and
With your consent following specific notice or request from us.
Videos of Clients: We may store videos and audio files for longer where relevant for business development, marketing and advertising of our services. These may also be used in instances such as playback to you, in consultation for professional development, or for teaching or demonstration purposes.
Security of Personal Data: Your Personal Data is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure. We use commercially reasonable efforts to protect it from unauthorized access or disclosure. However, we are not insurers of the security of your Personal Information. Accordingly, we assume no liability for any disclosure of data due to errors in transmission, unauthorized third party access or other acts of third parties, or acts or omissions beyond our reasonable control.
Duration period: If you have received services with us we will store your data as long as it is required by law. When your Personal Data is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Data.
Your rights: We want you to know you have legal rights about your personal data. You grant use of your data under the contract and terms herein through your active conduct and use of our services. At any time, you have the right to know what personal data relates to you that is held by us, for what purpose, how it is collected and used, with whom it is shared, where it is located, to object to its processing, to have the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing.
You may request the following at any time about your data held by us with regards to the services that we provide:
The right to be informed about the personal data being processed
The right to rectification of your personal data
The right to erasure of your personal data
The right to restrict processing of your personal data
The right to data portability (to receive an electronic copy of your personal data)
The right to object to the processing of your personal data
The right to access your personal data
You can also request the deletion of their personal data, but this may be denied on the exception for the establishment, exercise or defense of legal claims. Please see the Information Commissioners Office in Europe here for guidance on this exception. In accordance with the General Data Protection Regulations (“GDPR), you may request a copy of all data that we store about you at no cost at firstname.lastname@example.org. To protect your Personal Data, we may require identification from you before releasing the requested information. Repeated, unfounded or excessive requests may be challenged by us. There are some limited circumstances that may limit the information that we can provide to you in a request, for example, public interest, law enforcement, legal and or health related matters. Please also bear in mind that we rely on third parties for some of your information in the flow of data. It may take us the full calendar month permitted to provide a full response to your request.
Maintaining the Quality of your Personal Data: It is important to us that your Personal Data is up to date. We will take reasonable steps to make sure that your Personal Data is accurate, complete and up to date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
Notification of Breach: If we have reason to suspect that a serious data breach has occurred and that this may result in harm or loss to you, we will immediately assess the situation and take appropriate remedial action. If we still believe that you are at risk, we will notify the Office of the Information Commissioner and either notify you directly, or if that is not possible, publicize a notification of the breach on this website.
Version date: 24th July 2023
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