This policy was last updated on 11th of January, 2020.
Pills of Moksha is committed to complying with the General Data Protection Regulation and the Data Protection Act 2018.
We want you to be confident that your personal data is kept safely and securely and to understand how we use it.
We have published this notice to help you understand:
- how and why we collect information from you
- who we share your information with, why and on what basis
- what your rights are
If we make changes to this notice we will update you on our website and by sending you an email notification. You will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
Pills of Moksha (PoM) and Azzurra Nonni is the data controller of the information you provide. Should you have any questions about this policy please write to us at info@pillsofmoksha.com .
Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
| “Our Locations” | Includes: Online channels: https://www.pillsofmoksha.com Offline channels: our premises |
| “Our Site” | Refers to https://www.pillsofmoksha.com |
| “Personal Data” | means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via any of Our Locations. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); |
| “We, Us ,Our” | means Pills of Moksha and Azzurra Nonni |
When do we collect your personal data?
- When you create an account at any of Our Locations
- When you purchase a product at any of Our Locations or apply for concession pricing which requires proof of age, job seekers, student or disabled status.
- When you book a service at any of Our Locations or ask to be added to a waiting list for a service
- When you visit our centres to attend a class/treatment
- When you redeem a gift card at any of Our Locations
- When you contact us by any means with queries, complaints, send us your CV for a job application or complete an application form for one of our workshops or teacher trainings
- When you choose to complete any feedback requests or surveys we send you
- When you’ve given a third party permission to share with us the information they hold about you
What data do we collect and how do we use it?
Depending upon your use of Our Locations, We may collect some or all of the following personal and non-personal data
Data Protection says that we are allowed to collect and use your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons:
- Contract – your personal information is processed in order to fulfil a contractual arrangement e.g. to place an order or book a class/treatment.
- Consent – where you agree to us using your information in this way e.g. including you in a newsletter.
- Legitimate Interests – this means the interests of Pills of Moksha in managing our business to allow us to provide you with the best products and service in the most secure and appropriate way
- Legal Obligation – where there is statutory or other legal requirement to share the information e.g. when we have to share your information for law enforcement purposes.
| What we store | Our Reasons (Legal Basis) | What we use the data for |
| Name, surname, age, email, telephone number. | Fulfilling a contract | We need this information as a minimum in order to process your orders and bookings |
| Email, address and telephone number | Consent (email only) | Supplying you with email Marketing communications that you have opted into to keep you informed of special offers, promotions and new events. |
| Legitimate Interests | 1) Reminders and Schedule Changes: Notifying you of changes to classes/treatments that you’ve already booked such as cancellations or waitlist changes
2) Enhancements to our services: Such as changes to pricing and schedules or new services 3) Satisfaction surveys: In order to improve our service to you we may send you a short satisfaction survey. We may also contact you to discuss feedback or complaints. |
|
| Fulfilling a contract | Sending you payment invoices by email | |
| Gender How you heard about triyoga |
Legitimate interest | Personalising and tailoring your experience. Preparing the therapist for your visit. Developing products and services, that attract and retain customers. Improving customer interaction with our sites. |
| Time and date of your check-ins for any bookings | Legitimate interests | To help us with planning and handling our customer contact efficiently and effectively |
| Details of your interactions with us through Our Locations. For example, we collect notes from our conversations with you, details of any complaints or comments you make, and how and when you contact us. | Legitimate interests | Keeping our records up to date, handling our customer contact efficiently and effectively |
| Health information and emergency contact | Legitimate interests | To enable us to assess your suitability for the services and safeguard your health |
Third party services and how we share your data
We contract with third parties to supply products and services to you on Our behalf. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights,
Our obligations, and the obligations of the third party under the law.
In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
We use the following third party data processors who are based outside the EU, but who are protected by the Privacy Shield, which allows them to store EU data on US soil with the GDPR.
Google, California USA – We may compile statistics about the use of Our Locations using Google Analytics including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law
Zoom – We us Zoom for all our online and live streamed classes, workshops, courses, treatments and trainings. We will send you a unique link for your required booking, which will only be shared with yourself for treatments or with other students for online and live streamed classes, workshops, courses or training. You will be required to have your own personal Zoom account to attend. Zoom ensures your data is secure at all time, for full details please visit the following: Zoom privacy policy.
MailChimp – We may use MailChimp to send communications and store your sign-up/opt-in data for all promotional emails. Your data is stored safely and securely and will not be shared with any third party directly from MailChimp. You can opt-out of these emails at any time by clicking the unsubscribe link at the bottom of every email
Google Recaptcha – This plugin send IP address go Google for captcha verification. Please read Google Privacy Policy.
Where do we store your data?
Your data will be stored in the UK. Data with third party service providers and MailChimp are stored in the US, protected by the Privacy Shield that allows MailChimp to store EU data on US soil with the GDPR.
How long we keep your information
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under ‘What data do we collect and how do we use it’.
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
- we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
- in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
In-centre live streamed classes and workshops
To provide flexibility for all our clients, we may provide a selection of our in-centre classes and workshops via live stream. Full details of each class and workshop that will be live streamed are detailed clearly on our website and/or social media accounts. We will use Zoom for all live streamed classes and workshops, and the unique link will only be shared with fellow clients. The classes and workshops will not be recorded and the camera is located in a place where participants will not be in view. If there is a possibility a student may be in view; we will advise and request permission prior to the class or workshop commencing. Zoom ensures your data is secure at all time, for full details please visit the following: Zoom privacy policy.
Your rights
You have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
right to access – You have the right to request information about the personal data we hold on you at any time.
right to portability – Whenever We process your personal data, by automated means based on your consent or based on an agreement, you have the right to get a copy of your data transferred to you or to another party. This only includes the personal data you have submitted to us.
right to rectification – You have the right to request rectification of your personal data if the information is incorrect, including the right to have incomplete personal data completed.
right to erasure – You have the right to erase any personal data processed by Us at any time except for the following situations:
- you have an ongoing matter with Customer Service
- you have an unsettled debt with Us, regardless of the payment method
- if you are suspected or have misused our services within the last four years
- your debt has been sold to a third party within the last three years or one year for deceased customers
- if you have made any purchase, we will keep your personal data in connection to your transaction for book-keeping purposes
- we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible
- in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
Your right to object to processing based on legitimate interest
You have the right to object to processing of your personal data that is based on Our legitimate interest. We will not continue to process the personal data unless we can demonstrate legitimate grounds for the process which overrides your interest and rights or due to legal claims.
If you have any cause for complaint about Our use of your personal data, please contact Us at info@pillsofmoksha.com in the first instance in order that we can investigate thoroughly. Should you find the response unsatisfactory, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office, by calling 0303 123 1113.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
Our use of cookies
Cookies are small encrypted text files that are stored on your device by a website. We use cookies to enhance your shopping experience and to analyse our traffic. We don’t store personal information in the cookies we create, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
By continuing to browse our site, you consent to our placing cookies on your computer (unless you have chosen to disable them via your browser). Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings but please be aware that Our Site may not work properly if you do so.
The following first party Cookies may be placed on your computer or device:
| Name of Cookie | Purpose | Strictly Necessary |
Third party Cookies may be placed on your computer or device by the following companies however these are not within our control:
- Social Sharing (Facebook, twitter and Google+) uses cookies to allow for customer engagement on social media platforms
- Youtube is used to provide video social media and content
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. If you’d like to learn more about cookies in general and how to manage them please visit aboutcookies.org.
Our Policy on The Brazillian LGPD (Lei Geral de Proteção de Dados)
The Brazillian LGPD (Lei Geral de Proteção de Dados) is a new data privacy law that will apply to businesses (both inside and outside Brazil) that process the personal data of users located in Brazil. The new law is expected to go into effect on 16th August 2020, but ongoing discussions in the Brazilian government may result in a change to the effective date. The LGPD terms will be incorporated into our existing data protection terms, so no action is required to accept the LGPD terms where the existing data protection terms already form part of your account.
Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us via info@pillsofmoksha.com. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from all our servers. For all our Children’s online and in-centre classes we require parental booking. Our Children’s classes will not be live streamed or recorded.
Information about Pills of Moksha and Azzurra Nonni
Our Locations are owned and operated by Azzurra Nonni, whom registered address is Flat 16 Alder Court, 411 Long Lane, London, England,N2 8JQ.