Privacy Policy
VERSION: 17th September, 2022
ABOUT US:
Think Emerald LTD is a United Kingdom based company that operates under https://www.think-emerald.com/ providing holistic courses, events and one-one sessions.
This is the privacy notice of Think Emerald LTD In this document, “we”, “our”, or “us” refer to Think Emerald LTD
We are committed to providing quality services to you and this Privacy Policy outlines our ongoing obligations to you in respect of how we manage your Personal Data.
This Policy describes the kind of information we collect, the purposes for which we use the information and how we may share this information. We appreciate your trust in us.
We have adopted the laws of the United States of America, Brazil, Australia, New Zealand, United Kingdom, Europe and abide by the General Data Privacy Regulations (“GDPR”) to provide a high standard to our client’s personal data and privacy (the “Data Acts”). The Data Acts govern the way that we collect, use, disclose, store, secure and dispose of your Personal Data. A copy of the Data Acts for each country may be seen below:
The Personal Data Protection and Electronic Documents Act, SC 2000, c5 (federal, Canada); the Personal Data Protection Act (Alberta, Canada); the Personal Data Protection Act (British Columbia, Canada); all applicable United States federal and state privacy laws, including, but not limited to, the California Online Privacy Protection Act
Brazilian General Data Protection Law
General Data Protection Regulations
And any other applicable privacy legislation (collectively the “Data Acts”).
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 can confirm all platforms are GDPR compliant.
THE PURPOSE OF THIS POLICY:
In the course of providing you with our services, we will collect and process information that is commonly known as Personal Data.
This Policy describes how we collect, use, share, retain and safeguard Personal Data.
This Policy sets out your individual rights; we explain these later in the Policy but in summary, these rights 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 or where we provide you with paper based forms for completion or we complete a form in conjunction with you.
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 or other more sensitive data such as credit or debit card details.
We are legally required to comply with specific data processing requirements for Personal Data.
WHAT PERSONAL DATA IS COLLECTED BY US?
As a provider of holistic courses, events and 1:1 services, we will process the following categories of data:
• Personal data such as an individual’s full name, email, telephone number and after a purchase of course event or 1:1 service, debit or credit card details will be stored.
• Special categories of personal data such as health and details on historic injuries or illnesses (physical and physiological), image (still or moving), voice, and aspects of your health that may affect your participation or our provision of services to you.
CONFERENCE STYLE LIVE CLASS:
• If your microphone and camera are on during the live class your personal data of the image (still or moving), voice and likeness will be captured in a live virtual class and presented to those in the group. We may record live classes and workshops whether in-person or online that capture your image (moving or still), likeness and voice during the recording. You have the right to inform us at any time that you do not wish to be recorded and we will edit you from the footage, or not record you. If via an online platform you can turn off your microphone or camera to not be captured. Recordings that contain your personal data may be used for marketing purposes anywhere in the world, commercial sale and distribution.
If you object to the collection, sharing and use of your personal data we may be unable to provide you with our services.
We may record your communications with us when contacting our team. We may collect information about your visits to us to help us personalise your experience with us. By providing this information to us you are consenting to our use in the manner set out in this policy.
We do not knowingly accept information or attendance of anyone under the age of 18 years old.
If you are under 18 years of age you will need your parent or guardian to agree to this Privacy Policy and terms for you. They are responsible to ensure that you fully understand what you are sharing with us and why.
OUR SERVICES
We will 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. By providing this information to us you are consenting to our use in the manner set out in this Policy.
Our primary purpose for collecting and processing this Personal Data about you is to provide and administer our services to you, our clients and marketing. If you object to the collection, sharing and use of your personal data we may be unable to provide you with our services.
We use third-party software to securely store your data to perform specific functions to support our services. Third-party software providers include; MailChimp, Acuity Scheduling, Squarespace and Circle.so. Third-party suppliers have access to personal information needed to perform their functions but may not use it for other purposes. Their privacy policy is linked below as to how they handle data as part of the service we use.
Mailchimp: https://www.intuit.com/privacy/statement/
Acuity Scheduling operated by Squarespace: https://www.squarespace.com/privacy
Circle.so: EU - https://app.circle.so/eu-privacy
Circle.so US/Rest of World - https://app.circle.so/privacy
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.
Live online classes may be recorded both as audio alone and audio-visual files by our delivery provider Zoom. Booking via Zoom requires your name and email to register for online sessions and then captures, and stores your image, likeness and voice in the recordings on the private computer of the course facilitator. There is no cloud backup of these recordings. The files are password protected.
Please contact us at info@think-emerald.com if you wish any of your personal data to be amended or removed in such recordings or turn off your camera and microphone in the live online sessions.
We do not sell or pass your personal information onto third parties.
DURATION PERIOD
We may store videos and audio files for longer where relevant for commercial distribution and sale, service provision, business development, marketing and advertising of our services.
YOUR RIGHTS
You have a legal right to withdraw consent to your personal data being captured or held in any live class recordings. Please contact Tessa Blackman to request the recordings or images of you in recorded live classes to be edited out of the entire recording.
CLIENT NOTES AND CLASSES
We take and keep notes online that contain personal information that may include Sensitive information during your appointments. We store this written information in google documents. This document is protected by our google account password. These documents will not be shared, passed or sold to any third party.
BOOKINGS
We use Acuity Scheduling to manage our client bookings. This software requires you to complete the following information for your account: First name, Last name, email address and phone number. You may update the details in Acuity Scheduling at any time by emailing us.
PAYMENT ONLINE
If you pay using an online transaction such as a credit or debit card we use Stripe for verification. These third-party payment facilitators are PCI DSS v 3.2.1 compliant to ensure your financial data is secure and we can never access your full payment details.
THIRD-PARTY PROCESSORS
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.
DATA MANAGEMENT
We use the following third-party providers for our service to you. Their privacy policy is linked within as to how they handle data as part of the service we use. With all of the below suppliers you can ask us to review your stored data to ensure that it is accurate and best serves you.
Client records are not stored as paper documentation, however, a digital version is stored with Google Docs, clients are not identified by full name and proper care is taken to anonymise any and all individuals. Google provides a minimum security level to protect your Personal Data. We may keep your records on remote digital devices that are password protected.
• Communications with us via email are stored in our account with Google.
• To schedule appointments, we use Acuity by Squarepsace. You can opt out of this and manage your data in this system at any point by logging into the booking confirmation email.
• Payments for our services can use third party payment facilitators Stripe. Stripe is PCI DSS v 3.2.1 compliant to ensure your financial data is secure and we can never access your full payment details.
• Marketing from us may include:
- Instagram is used by us. If you follow, like and interact with our social media account then your comments may be public depending on your personal privacy settings within that social media platform. 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.
- We may conduct surveys using third parties to collect information in the survey to get an idea of the market. You do not have to participate, and you can choose to complete your name and email address or leave it anonymous.
- Our mailing list service provider MailChimp ensures that we only send emails to those who want to hear from us. We email on occasion with content relating to our services. You can unsubscribe at any time by clicking on the unsubscribe button in the emails sent.
• Our website is hosted by Squarespace. While using our website, we may ask you to provide us with certain personally identifiable information that might be collected through our website provider Squarespace. This includes a collection of your unique online electronic identifier; this is commonly known as an IP address, browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages and other statistics. Think Emerald uses cookies to provide the website and ensure the necessary function of our services. To learn more about the cookies on our website, please read our Cookie Policy here.
LINKS TO OTHER WEBSITES
Our services may include links to third party websites. When you click on this link you have left our website and services. We do not have control over what cookies or beacons or other technology these sites may use to track activity into their website, and do not have control over what data they may collect or their privacy policy. Use of their websites and clicking on those links is at your sole risk. We are not responsible for the protection and privacy of any information that you provide whilst visiting such sites and these sites are not governed by this Privacy Policy. We suggest that you read their privacy statement before using the website.
We do not provide any personally identifiable customer information to these sites.
DISCLOSURE OF PERSONAL 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 authorised 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.
This includes fraud protection, but not selling, sharing or otherwise disclosing personally identifiable information from clients for commercial purposes in a way that is contrary to this Privacy Policy.
SECURITY OF PERSONAL DATA
Your Personal Data is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure. We do this abiding by the Data Acts as stated above.
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. However, most of the Personal Data is or will be stored in client files which will be kept by us for the Duration Period.
DURATION PERIOD
If you have received Services with us we will store your data for seven years from your last appointment or purchase with us (“Duration Period”), as required by our insurers for any potential claims.
ACCESS TO YOUR PERSONAL DATA
You may request a copy of all data that we store about you at no cost at info@think-emerald.com. In order 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 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.
Your rights in such a request include:
1. Right to access
2. Right to rectification of errors
3. Right to deletion (may be limited)
4. Right to object to processing
5. Right to restrict processing
6. Right to withdraw consent
7. Right to object to marketing
8. Right to complain to relevant data protection authority
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.
INTERNATIONAL DATA TRANSFERS
Our services are available internationally. We control and manage Personal Data in England, UK. We may transfer data outside of the UK to our suppliers to provide the service to you. We ensure that their service meets the minimum requirements set out in the Privacy Laws. You can request to learn more about what data and which services may have access to your Personal Data.
We transfer your data outside the European Economic Area/ home country to fulfil our services to you. We do so in accordance with this Privacy Policy and to comply with Data Acts.
Any third parties used outside of Europe/ Country to help our administration of your data are required to safeguard your personal data through the use of appropriate technical and organisation data security measures and are prohibited from disclosing or sharing your data with other third parties without our prior authorisation, or unless as required by law. Please contact us here: info@think-emerald.com for further information on the measures undertaken to safeguard your data.
POLICY UPDATES
We reserve the right to update and amend this Privacy Policy at any time, effective upon posting an updated version on the Website. We will publish such updates on our website and may email notifications to you. Continued use of the Website after any such changes shall constitute your consent to such changes.
PRIVACY POLICY COMPLAINTS AND ENQUIRIES
If you have any queries or complaints about our Privacy Policy please contact us at:
Tessa Blackman at info@think-emerald.com
Should you have a complaint about the way that we have handled your Personal Data, you may submit this to the Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/ or call their helpline at 0303 123 1113.