Website privacy notice – Michelle Gupta – www.embodyharmony.com
This privacy notice provides you with details of how I collect and process your personal data through your use of my website www.embodyharmony.com including any information you may provide through our site when you purchase a product or service, sign up to receive updates or make an appointment.
By providing us with your data, you warrant to us that you are over 13 years of age.
I am self-employed under my own name Michelle Gupta and the (unlicensed) brand name Embody Harmony and I am responsible for your personal data (referred to as “I”, “me” or “my” in this privacy notice).
My Contact Details
If you are not happy with any aspect of how I collect and use your data, you have the right to complain to the Data Protection Commissioner, Ireland’s supervisory authority for data protection issues https://www.dataprotection.ie/. I would be grateful if you would contact me first if you do have a complaint so that I can try to resolve it for you.
It is very important that the information I hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing me at firstname.lastname@example.org
- WHAT DATA DO I COLLECT ABOUT YOU
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of personal data about you as follows:
- Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
- Contact Data may include your billing address, delivery address, email address and telephone numbers.
- Financial Data may include your bank account and payment card details.
- Transaction Data may include details about payments between us and other details of purchases made by you.
- Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from me and your communication preferences.
I may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where I review your Usage Data to work out the percentage of website users using a specific feature of our site. If I link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
I do not collect any Sensitive Data about you. Sensitive Data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. I do not collect any information about criminal convictions and offences.
Where I am required to collect personal data by law, or under the terms of the contract between us and you do not provide me with that data when requested, I may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide me with the requested data, I may have to cancel a product or service you have ordered but if I do, I will notify you at the time.
- HOW I COLLECT YOUR PERSONAL DATA
I collect data about you through a variety of different methods including:
- Direct interactions: You may provide data by filling in forms on my site (or otherwise) or by communicating with me by post, phone, email or otherwise, including when you:
- attend an appointment for a therapy
- attend a class, workshop, event or retreat
- order my products or services
- create an account on my site
- subscribe to my service, updates or publications
- request resources or marketing be sent to you
- enter a competition, prize draw, promotion or survey
- give me feedback or service reviews.
- Third parties or publicly available sources:
- Analytics providers such as Google based outside the EU
- Search information providers based inside the EU
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as Stripe/Paypal]
- Identity and Contact Data from publicly available sources and the Electoral Register based inside the EU
- Where you have given me your name and email address either on a handwritten list or consultation form at, for example, an event, class or appointment, or have handed me your business card
- HOW I USE YOUR PERSONAL DATA
I will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where I need to perform the contract between us
- Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where I need to comply with a legal or regulatory obligation
Generally, I do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing me at email@example.com
Purposes for processing your personal data
Set out below is a description of the ways I intend to use your personal data and the legal grounds on which I will process such data. I have also explained what my legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email me at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you as a new customer||(a) Identity(b) Contact
|Performance of a contract with you|
|To process and deliver your order including:(a) Manage payments, fees and charges
(b) Collect and recover money owed to me
|(a) Identity(b) Contact
(e) Marketing and Communications
|(a) Performance of a contract with you(b) Necessary for my legitimate interests to recover debts owed to us
(b) Asking you to leave a review or take a survey
|(a) Identity(b) Contact
(d) Marketing and Communications
|(a) Performance of a contract with you(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep my records updated and to study how customers use y products/services
(d) As per the terms and conditions of my personal and professional liability insurance as a teacher and holistic therapies practicioner
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity(b) Contact
(e) Marketing and Communications
|(a) Performance of a contract with you(b) Necessary for my legitimate interests to study how customers use my products/services, to develop them and grow my business
|To administer and protect my business and my site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity(b) Contact
|(a) Necessary for my legitimate interests for running my business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re-organisation (b) Necessary to comply with a legal obligation
|To deliver relevant content and advertisements to you and measure and understand the effectiveness of my advertising||(a) Identity(b) Contact
(e) Marketing and Communications
|Necessary for my legitimate interests to study how customers use my products/services, to develop them, to grow my business and to inform our marketing strategy|
|To use data analytics to improve my website, products/services, marketing, customer relationships and experiences||(a) Technical(b) Usage
|Necessary for my legitimate interests to define types of customers for my products and services, to keep my site updated and relevant, to develop my business and to inform my marketing strategy|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity(b) Contact
|Necessary for my legitimate interests to develop my products/services and grow our business|
You will receive marketing communications from me if you have:
- requested information from me or purchased goods or services from me; or
- if you provided me with your details when you entered a competition or registered for a promotion or free resources; and
- in each case, you have not opted out of receiving that marketing
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to me as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
I will only use your personal data for the purposes for which we collected it, unless I reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email me at email@example.com
If I need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
- DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
- Other companies in our group who provide IT and system administration services and undertake leadership reporting.
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Revenue & Customs, regulators and other authorities based in Ireland and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Companies who provide competitions for my websites. You will be given an opt in option to enable us to do this.
- Third parties to whom I sell, transfer, or merge parts of my business or our assets.
I require all third parties to whom I transfer your data to respect the security of your personal data and to treat it in accordance with the law. I only allow such third parties to process your personal data for specified purposes and in accordance with my instructions.
I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, I limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on my instructions and they are subject to a duty of confidentiality.
I have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. DATA RETENTION
I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, insurance or reporting requirements.
To determine the appropriate retention period for personal data, I consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.
By law I have to keep basic information about my customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask me to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case I may use this information indefinitely without further notice to you.
8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email me at firstname.lastname@example.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.
I may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up our response.
I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.
9. THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.