Last Update: May 21, 2018
POLICY STATEMENT
Path Retreats takes data privacy very seriously. We recognise the importance of protecting and respecting your personal data. This Privacy Policy describes the information we collect, how we use that information, to whom we pass the information, your rights and key contact information.
In order for you to participate in one of our programs or retreats, we need to collect certain personal information about you. Our aim is not to be intrusive, and we won’t ask you unnecessary questions. Any information we receive about you will be subject to strict controls to minimise the risk of misuse, including unauthorised access to, or disclosure of, your personal data.
Please read this notice carefully, together with our “Terms and Conditions to Agreement and Process Ground Rules” and any other documents referred to in it. Here we set out the basis on which any information we collect about you or from you, or that you provide to us, will be processed by us and other parties so that you can participate in one of our programs or retreats. Path Retreats is a trading name of POL Global Foundation Ltd (“our”, “us” and “we”), and we commit to using your information only in accordance with the terms of this Privacy Policy.
For the purposes of this Privacy Policy, the term “information” means any confidential and/or personal data or other information related to users of Path Retreats Services – including, but not limited to, corporate and individual customers and their connected parties.
By visiting this website, our partners’ websites, or providing your personal information to one of our employees, for example by telephone or e-mail, you accept and expressly consent to our use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy.
This includes consenting to the processing of any sensitive personal information you provide, as described below in Section 2. It also includes information you provide when you browse our social media sites or website, request to be added to our newsletter database, request more information, schedule a call with one of our Retreat Advisors, request a quote, participate in one of our programs, retreats, or volunteer events, enter a competition, promotion or submit a survey, donate to our Love in Action Foundation or Scholarship Fund, and when you contact us for other reasons.
If you have concerns about any of the terms of this Privacy Policy, please contact us at [email protected] so that we can provide further information.
A special note about children
Children are not eligible to use Path Retreats Services. We respectfully ask that minors (persons under the age of 18) do not submit any information to us or use Path Retreats Services.
Information you provide to us
You may provide us with information when you browse our social media sites or website, request to be added to our newsletter database, request more information, schedule a call with one of our Retreat Advisors, request a quote, apply for or participate in one of our programs, retreats, or volunteer events, enter a competition, promotion or submit a survey, donate to our Love in Action Foundation or Scholarship Fund, and when you contact us for other reasons.
Initial information & Information we may collect from you
When we communicate
When you communicate with us for customer service or other purposes, including by phone, e-mail or using other methods, we retain that information and our responses to you.
When we speak to you by telephone, Skype, Zoom or WhatsApp, through the Schedule a Call with a Retreat Advisor option, we collect your name, e-mail, Skype Name, and phone number.
Information we collect when you use our website
When you use the Path Retreats website we collect information about the device you are using, such as your IP Address, Browser type, Settings, Plugins and Plugin Settings, Device Type, Operating System, IMEI Number, MAC Address, Wired or Wireless Connection, Mobile or fixed-line phone carrier or network. When you are using our site we collect Google Analytics Metrics, Behavioural Information such as mouse-overs, clicks, cursor patterns, and site movements. When you arrive at or leave our website we collect to/from URLs, click-throughs from paid advertisements, search engines or links on partner websites.
We place 1st party cookies, 3rd party cookies, web beacons and similar tracking technologies. The cookies we place are persistent and can be blocked by adjusting your browser settings.
Information about 3rd Parties
If it is necessary for you to provide personal information about other individuals in the course of dealing with us, for example emergency contact names or phone numbers, you should do so only where you are authorised by those individuals.
Privacy policy notification to 3rd parties
Although the information on 3rd parties is stored for a certain period of time in compliance with applicable law, we will not use it to market to 3rd party.
Additionally, these 3rd parties have the same rights to access and correct information about themselves as registered users of Path Retreats Services. You should bring this Privacy Policy to their attention at the earliest opportunity so they aware of how their information will be processed by us and aware of their rights in relation to that information.
Information about you from other sources
In some cases we use 3rd party services to collect your information, such as:
When you pay for your workshop through PayPal, or donate to our Love in Action Foundation or Scholarship Fund, your financial data is captured as described above. We otherwise do not collect information about you from other sources, except in the rare situation where you may leave a retreat early, the course leader or facilitator may provide you, and Path Retreats, with a recommendation for follow-up work.
Our primary purpose in collecting your information is to provide you with a safe, therapeutic, meaningful, and customised retreat experience. We use this information to determine the suitability of the workshop for you. We appreciate the sensitivity of this information and will ensure it is kept secure and only used and disclosed when required to individuals who need to, including the workshop organiser, the organiser or facilitator conducting your pre-workshop interview, and the workshop leaders and facilitators. By submitting your information to Path Retreats and using Path Retreats Services you agree that we may use your information for the following purposes:
Fulfilling your requests
We will use your information to process your registration, ensure the workshop is a good fit for you at the time of your application, and so that we can provide you with the best retreat experience possible based on your individual needs. We ask whether or not you have any criminal convictions, as that will help us determine the suitability of the retreat for both you, and for the other people on the retreat. We use the photographs to identify you, for example, when you arrive at the retreat centre, and it helps make registration move more quickly and smoothly.
Communication and customer service
We communicate with our users on a regular basis via e-mail to provide requested services, including:
If you opt in to our database, we use your e-mail to:
We communicate with our users via phone, Skype, Zoom or WhatsApp to provide these two requested services:
If you do not wish to receive our service communications in a particular way, please contact us to advise us of your preferred communication method.
Marketing
We also use your e-mail address to send you other types of communications that you can control, including newsletters, after-workshop recommendations, customer surveys and special promotions. These communications are to:
You can choose whether to receive some, all or none of these communications and the methods by which you receive them by updating your preferences on our newsletter portal, or by e-mailing us and requesting an amendment of your preferences. One of our administrators will respond to your request in person, usually within 2 business days.
Device information
We will use this information to improve and streamline our website design to offer a better user experience and product to the customer and a more effective conversion of prospects.
Location information / IP (Internet Protocol) address:
We will use information about your location, derived from your IP address to:
Third party information
We will use anonymised third-party information collected from Google Analytics to:
Questionnaires, surveys, and competitions
From time to time we may offer you optional questionnaires, surveys and competitions. If you choose to answer these questionnaires, surveys or competitions, we may use your information to:
Post-workshop survey feedback will be shared with your Path of Love leaders and facilitators, as well as our office staff, to help us understand how people experience our workshops (from the beginning of the registration process to our aftercare), to study the effectiveness of our workshops, and to make improvements where recommended and needed.
You will be given notice of how the information will be used prior to your participation in the survey, questionnaire or competition.
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site and to provide interest-based advertising. You may adjust the settings on your browser to refuse cookies but some of the services on our website may not work if you do so. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.
To support our business and provide services to you
Path Retreats works with third-party service providers who provide important functions that allow us to review and understand website visitor behaviour, safely and securely store the data you send us and pre-workshop interview notes, send newsletters and communications (only upon opt-in), and administrate your registration in our workshops.
By accepting this Privacy Policy and ordering services from Path Retreats, you expressly consent to the transfer of your data to those third parties for the purposes listed.
Credit card associations and legal process
We may also disclose necessary information in response to the requirements of credit card associations or a civil or criminal legal process.
We may disclose or share your information in order to enforce or apply the “Terms and Conditions to Agreement and Process Ground Rules” and other agreements between you and us, or to investigate potential breaches to protect the rights, property, or safety of Path Retreats, our customers, or others. This includes exchanging information with other companies and organisations and, if required, to obtain professional advice.
Where required by law
We may disclose necessary information to the police and other law enforcement agencies where we are legally compelled and/or permitted to do so.
Mergers and acquisitions
As with any business, it is possible that in the future Path Retreats could buy, merge with, or be acquired by, another company. We may disclose your information to the prospective seller or buyer of such business or assets, along with its professional advisers. If Path Retreats or a substantial proportion of its assets are acquired by a third party, information held by us about our customers will be one of the transferred assets, and such successor company would continue to be bound by this Privacy Policy unless and until it is amended.
Affiliates
If you are referred to us by a third party, either via our affiliate network or other promotion, depending on the arrangement we may notify them when you click through to our site, fill out an application, or attend one of our workshops.
Third party websites
Our site may, from time to time, contain links to the websites of our business partners, advertisers and affiliates. Please note that these websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any information to third party websites.
Path Retreats is committed to adequately protecting your information regardless of where the data resides and to providing appropriate protection for your information where such data is transferred outside of the EEA.
The information that we collect from you may be transferred to, and stored in, a country outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for our suppliers. These staff may be engaged in the fulfilment of your request, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
The laws in some countries may not provide as much legal protection for your information as in the EEA. In these circumstances, our policy to protect your data is to rely on findings of adequacy by the European Commission (for countries in scope of those findings), the EU-US Privacy Shield (for transfers to the USA) or standard contractual clauses adopted by the European Commission or the UK Information Commissioner (for all other countries).
Each time you visit our website, opt-in to our newsletters or apply for one of our retreats, Path Retreats may transfer the data to Google Analytics, our website hosting provider, AWeber or Salesforce, who may have data processing locations outside the EEA, in order to review and understand website visitor behaviour, safely and securely store registration form data and pre-workshop interview notes, send newsletters and communications (only with opt-in), and administrate your registration in our workshops.
By submitting your information and making use of Path Retreats Services, you agree to such transfers, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.
We are obliged by law to retain your data for 7 years after it is submitted. In some circumstances, such as an enquiry from a law enforcement agency, we may have to hold it longer. We may also retain information if required to protect our interests, for example in case of litigation. When data falls outside those retention periods we will take steps to delete it from our system. Where you have asked us not to contact you, we will retain that information on a ‘do not contact’ list to reduce the risk of us contacting you in the future.
Path Retreats has security measures in place designed to prevent data loss, to preserve data integrity, and to control access to the data. Only authorised employees of Path Retreats and our business partners processing data on our behalf have access to your personal data. All Path Retreats employees who have access to your personal data are required to comply with our privacy policy. All business partners are requested by Path Retreats to ensure that any of their employees who have access to your personal data have signed non-disclosure agreements. Contracts with business partners acting as data processors for Path Retreats involving personal data require an adequate level of security and require that personal data is processed only as instructed by Path Retreats.
We will do our best to protect your information, however we cannot guarantee the security of information you send to us by e-mail or other non-secure electronic methods; any such transmission is at your own risk. Once we have received your information, we will use protective procedures and security features to try to prevent unauthorised access.
System security and monitoring
Our server is protected with an SSL certificate. Where we use hosted services (such as Salesforce, AWeber, and our website hosting provider) we rely on their integrated security measures and you can read their security policies for added reassurance.
Password security
To control access to our virtual board, each person is required to input a username and password. To help us protect your information, you are advised to do the following:
Customer responsibilities
We keep our security technology up-to-date to protect your information, but we do not have control over the devices you use to access Path Retreats Services.
It is your responsibility to safeguard your online information and transactions by taking all reasonable measures which may include the following:
You have the following rights:
To ask us to correct any information we hold about you if it is incorrect.
Whilst we endeavour at all times to keep your information accurate, we welcome your corrections. You can correct your profile at any time by e-mailing us, and we will respond to you within 2 business days.
To ask us to erase your information if we no longer have any reason to hold it, also known as the ‘right to be forgotten’.
Our Data Retention Policy (see section 7) explains the circumstances when we can or are obliged to retain information, however outside of those periods we will delete your information in line with our data retention policy and on request. We will maintain a record that you made an erasure request to reduce the likelihood of us contacting you in the future but we will use that information for no other purpose.
To ask us to return to you information you provided to us, also known as ‘data portability’.
You can ask us to send you in electronic format the information you provided to us under consent, or for the performance of a contract between us.
To ask us not to process your information where you previously gave consent or where we are exercising our legitimate interest.
If you make a request for us to stop processing your information, we will investigate to see if there is a compelling reason for processing to continue and will discuss the conclusion of the investigation with you.
You cannot object to processing which is a legal obligation or where we must process your information to satisfy a contract to which you are a party. If you previously gave consent and we processed your data on the basis of that consent, you cannot object to that past processing, however you can ask us to stop processing it in the future.
To ask not to be subjected to automated decision making and profiling.
Path Retreats puts the human factor at the heart of our customer service. We don’t carry out any profiling or other automated decision making.
To ask for a copy of the information we hold about you.
We will endeavour to respond to your request within 30 days, however at time of high demand we may need 90 days to compile a full response.
To ask us not to process your information for marketing purposes.
You can do this by checking or unchecking certain boxes on the forms we use to collect your information, or by clicking on the ‘unsubscribe’ link(s) at the foot of every marketing or promotional e-mail, or by contacting us at [email protected]
You may exercise any of the above rights by contacting us at [email protected]
The Data Controller
The Data Controller is POL Global Foundation Limited, Registered Office Bank House, 66 High Street, Dawley, Telford, England, TF4 2HD, Company Number 09259449.
Contacting us with questions or requests
If you would like to exercise your right to access your information or have any questions about this Privacy Policy, Path Retreats’ information practices, or your dealings with Path Retreats, you can contact us via [email protected] or [email protected], or by writing to us at POL Global Foundation Ltd., Bank House, 66 High Street, Dawley, Telford, England, TF4 2HD, Company Number 09259449.
Complaints to us
If you believe that we have breached a privacy law with which we should comply, please send an e-mail to [email protected]. We aim to respond in a reasonable time, normally within 30 days. Our Business Manager will look after your complaint and will give you additional information about how it will be managed. To read more about our Complaint Procedure, please view our Quality Standards here.
Complaints to the UK Information Commissioner
You have the right to complain to the UK Information Commissioner’s Office if you believe we have not handled your request in an appropriate manner. For information on contacting the Information Commissioner please see their website.
We may amend this Privacy Policy at any time, as new features are added to Path Retreats services or as we incorporate suggestions from our customers. Any changes we may make will be posted on the Path Retreats website, so please check back frequently.
Your continued use of our website and Path Retreats services after a posting of a new version of this Policy will constitute your acceptance of, and agreement to, any changes. If you disagree with the terms of this Privacy Policy, please contact our Business Manager at [email protected].
Schedule a call with one of our Retreat Advisors to learn more about the Path of Love 7-Day Retreat.
This link will take you to an external site, where you can share your contact information (such as e-mail and/or Skype Name, etc.) and schedule an informal chat with one of our Retreat Advisors.
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