Shine Om Limited Privacy Policy & GDPR

 

Privacy Policy & GDPR Provisions

This is the privacy notice of Shine Om Limited In this document, “we”,“our”, or “us” refers to Shine Om Limited.

Introduction

This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.

We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.

We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended.

We undertake to preserve the confidentiality of all information you provide to us.

Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).

The law requires us to tell you about your rights and our obligations to you with regards to the processing and control of your personal data.

We do not share, or sell, or disclose to a third party, any information collected through our website or via the Mindbody Booking System or on the mobile application.

Paying by credit/debit card using the Mindbody Application (Mobile Device) or via the Mindbody Website portal uses the payment clearing system called Paysafe which provides end-to-end payment solutions for businesses and consumers around the world. All payment data is fully secure and safe and processed through Paysafe which is fully PCI compliant.

1.      Information we process because we have a contractual obligation with you

When you create an account on our website or via the Mindbody app, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information including your Name, Address, Email, Birthday and Emergency Contact Details.

We may use it in order to:

•        verify your identity for security purposes

•        provide you with our services

•        sell products to you

•        provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract. If you have contacted us then we will respond with the requested information, product or suggestion.

We never contact you or ‘cold call’.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

All emails go out ‘BCC’ Blind carbon copy.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

Anti-Spam Policy

At Shine Om we love to share information, but we keep our communications to a minimum with a seasonal Newsletter of up to 4 per year with the exception of any important changes or events which we are required to keep you informed of.

We like to keep your inbox clean, no junk e-mails from us! Just good to know news from time to time.

If you subscribe to electronic newsletters or other communications from us on our website or on the Mindbody App you will always have an option to unsubscribe immediately.

2. Information we process With your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website, register with the Mindbody App or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies. Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You may withdraw your consent at any time by instructing us at janet@shineom.me or visit our website www.shineom.me

However, if you do so, you may not be able to use our website or our services further.

Mindbody App

Shine Om is a customer ('data controller' under GDPR terminology) is responsible for ensuring compliance with the key requirements of the GDPR which includes the use of MINDBODY.

Mindbody has made provisions to assist in meeting those requirements where possible and appropriate, such as:

•        Tools and processes to assist our EU customers in honouring individuals' requests, including requests for deletion, data portability, access and rectification. This functionality has been launched within the Mindbody app May 2018.

•        A customised Privacy Policy and Terms & Conditions is now available via the Mindbody App and Website log in.

•        A new preference centre has been launched that provides functionality to opt in and out of communications sent through the MINDBODY software (except for those types of communications that are operationally necessary, such as purchase receipts, forget password notifications, etc.)

See their guides to updating preferences on the website log in portal: Mindbody Consumer Preferences See Screen shots below of how to Opt Out / In on the Mindbody app:

For further information regarding the Mindbody System and its compliance with GDPR, visit their website here:

https://www.mindbodyonline.com/blog/business-advice/news/gdpr-readiness

3. Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.

4. Specific uses of information you provide to us

Information provided on the understanding that it will be shared with a third party, our Shine Om Social Media links allow posts with a view to that information being read for information only.

In posting personal information, it is up to you to satisfy yourself about the privacy level of every person with access to it in the public domain. It is stored within the social media account and we reserve a right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted.

You can make a request by contacting us at janet@shineom.me or visit our website www.shineom.me

5. Complaints regarding content on our website

If you complain about any of the content on our website, we shall investigate your complaint. If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

Freedom of speech is a fundamental right, so we have to make a judgement as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

6. Information relating to your method of payment

At the point of payment, you are transferred to a secure page on the website through the Mindbody App.

Paying by credit/debit card payment is taken via Paysafe which is an end-to-end payment solution and Partner to Mindbody for businesses and consumers around the world.

Payment data is fully secure and safe and processed through Paysafe which is fully PCI compliant which is the world-wide benchmark mandated by the card schemes for the protection of cardholder identity and transaction information.

https://www.mindbodyonline.com/privacy-policy

https://developer.paysafe.com/en/resources-and-support/pci-dss-validation/

No payment details are kept on our website or servers.

 

7. Sending a message to our support team

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business.

We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

8. Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use. If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies in the following ways:

• to track how you use our website

• to record whether you have seen specific messages we display on our website

• to keep you signed in our site

9. Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information such as your geographical location, your Internet service provider and your IP address.  We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

10. Access to your personal information

•        At any time you may review or update personally identifiable information that we hold about you, by signing in to your Mindbody Account via our website – follow the link below:

Log in - Shine Om - Mind Body Account

•        To obtain a copy of any information that is not provided on our website you may send us a request at janet@shineom.me

•        After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

11. Removal of your information

If you wish us to remove personally identifiable information from our website or from the MindBody App or from our mailing lists: you may contact us at janet@shineom.me and www.shineom.me

This may limit the service we can provide to you.

12. Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Other matters

13. Use of site by minors

We do not sell products or provide services for purchase by children, nor do we market to children. If you are under 18, you may use our website only with consent from a parent or guardian.

14. Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

15. How you can complain

If you are not happy with our privacy policy or if have any complaint then you should tell us by email. Our address is janet@shineom.me or write to Shine Om Limited, 2nd Floor, 8 Victoria Street, Douglas, Isle of Man.  If a dispute is not settled then we hope you will agree to attempt to resolve it

by engaging in good faith with us in a process of mediation or arbitration.

16. Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal

information only for as long as required by us:

• to provide you with the services you have requested;

• to comply with other law, including for the period demanded by our tax authorities;

• to support a claim or defence in court.

17. Compliance with the law

Our privacy policy has been compiled so as to comply with the laws of the Isle of Man and UK jurisdiction in which we aim to do business. It is ultimately your choice as to whether you wish to use our website.

18. Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any question regarding our privacy policy, please contact us.

Contact: Janet Bradley, Shine Om Limited, 2nd Floor, 8 Victoria Street, Douglas, Isle of Man. Email: janet@shineom.me Telephone: 07624 434775