Privacy Policy

 

1. General

This privacy policy sets out how Ammrita Online uses and protects any information that you give Ammrita Online when you use this website.

Ammrita Online is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

Ammrita Online may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 24th May, 2018.

2. European Union General Data Protection Regulation (GDPR)

The EU General Data Protection Regulation (GDPR) replaces the Data Protection Directive 95/46/EC and was designed to harmonize data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organizations across the region approach data privacy.

The key articles of the GDPR, as well as information on its business impact, can be found on the dedicated site. The GDPR becomes law in Europe on the 25th May, 2018

The GDPR is laid out in 11 Chapters, the relevant ones to you are :-

  • Chapter 2 – Principles

  • Chapter 3 – Your Rights (Rights of the Data Subject) 

Note that third party services that we integrate to (Constant Contact) may directly provide GDPR opt-in details on forms that they embed on our website when collecting information that they need. You should check these third party Policies and Conditions where these appear before providing your information to them.

3. GDPR Chapter 2: Principles

This chapter covers some basic things about the GDPR that you should know and that we need to adhere to.

3.1. Scope

The GDPR covers the protection of EU citizens regardless of where this data is stored or processed, Even a website outside the EU, if it is intending to process data for EU citizens, must conform to the GDPR regulations.

3.2. Principles 

In protecting EU citizens data the GDPR looks to the following principles regarding your data :-

“Data is specified, explicit and legitimate”. When we ask you for your data we are required to tell you what it is for in terms that specify exactly what it is we need, why we need it and that when we explain this it is written out in clear and understandable terms. 

The 5 main principles the GDPR adds are as follows:

  • Data Minimisation

  • Accuracy

  • Storage Limitation

  • Integrity and Confidentiality

  • Accountability

3.3. Lawfulness of Processing

This article essentially lays out that we have to ask you for your consent to process your data, that the processes we’re going to put that data through is relevant to our activity of providing the services we have for you and that there’s a real need for the data collection in order for us to proceed.

3.4. Conditions for Consent

There are 3 main parts to it as follows :-

  • We are required to … “demonstrate that the data subject has consented to processing of his or her personal data”. You have to actively agree to us processing your data

  • Any form we present to you requires to be … “clearly distinguishable from the other matters, in an intelligible and easily accessible form, using clear and plain language”. This is pretty straight forward and any requests we ask of you should be too!

  • This is the important one you should know about. You … “will have the right to withdraw his or her consent at any time. It will be as easy to withdraw as to give consent”. This should make all of that a whole lot easier to do

3.5. Conditions Applicable to Child’s Consent

There are very specific GDPR rules governing data capture for children. At this point and going forward we’re not going to ask for any data from children. As such this means that only adults, who can give their data willingly, will be allowed access to our site. You must be 16 years old or over to access our site.

3.6. Processing Special Categories

The “Special Categories” cover data which reveals any of the following :-

  • racial or ethnic origin

  • political opinions

  • religious or philosophical beliefs

  • trade union membership

  • genetic or biometric data concerning health

  • details of sex life or sexual orientation

We won’t be asking you for any of the above

4. GDPR Chapter 3: Your Rights (Rights of the Data Subject)

This chapter covers your rights under the GDPR. We’ll highlight the bits that we are required to and bits we think you should know

4.1. Transparent Information, Communication and Modalities

The GDPR allows you to request information about your data from us. It lays out regulations on what we are required to do when fulfilling this. Where you ask us we are required to provide :-

  • data “in a concise, transparent, intelligible and easily accessible form, using clear and plain language”

  • data “orally” where we’ve previously identified you 

  • information on “any action taken on a request”. We need to keep you informed

  • the information “free of charge”. It’s free unless your request is deemed to be excessive

So you can ask us what you need to know and we should reply in a fair and honest way without trying to hide behind legalese. 

4.2. Information to be Provided

Here’s what we need to tell you when we ask you directly for any of your information :-

  • contact details of the controller

    • Data Controller c/o Ammrita, Online Services, Scotland

  • contact details of the data protection officer

    • At the moment we’re not required to have one but you can use the details above in the meantime

  • the purposes of the processing

    • we need your contact details to inform you of content changes within our website. We send your email address to Constant Contact for this. No card payment details are ever stored by us

  • the legitimate interests pursued by the controller 

    • email communication

  • the recipients or categories of recipients of the personal data

    • We make use of the following services internally – local Mail Server, Paypal (Payment Gateway), Google Analytics (Site activity).

  • if we “intend to transfer personal data to a third country or international organisation”

    • Other than the companies we’ve mentioned above we won’t share or sell your information to anyone

We are also required to tell you :-

  • the period for which the personal data will be stored

    • If you register with us your contact details will be held on record for a period of up to one year.  We will remove all registered users with us who have not signed up with us at the end of every year.  User who have signed up with us will have their records kept for the duration of their membership with us. At the end of every year we will check the activity of our signed up members and any member who has been inactive for more than one year will be removed.  We will attempt to contact you before we do so.

  • that you have the right to 

    • request access

    • rectification or erasure of personal data 

    • restriction of processing

    • object to processing

    • data portability

    • withdraw consent at any time

    • lodge a complaint with a supervisory authority

  • whether 

    • the provision of personal data is a “statutory or contractual requirement, or a requirement necessary to enter into a contract”

      • you are not required to enter into a contract, legal or otherwise, with Ammrita. In order for you to register with us we require to be able to contact you and to identify that it is you that is logging in (and not someone else).  At no time do you enter into a contract (legal or otherwise) with us 

    • you are “obliged to provide the personal data and of the possible consequences of failure to provide such data”

      • No, you’re not obliged to provide the data to us.  It will, however, be impossible for us to provide our newsletter or answers to queries.  All other content you'll still be able to see

  • the “existence of automated decision-making, including profiling”

    • We use Google Analytics as described above. This helps us align the information we provide to our site members to reflect what they are interested in. We do not use an automated decision-making. Our Payment Gateway (PayPal) may use automated decision-making in their processes to determine your ability to pay for any items of this site you wish to purchase from us.  Please see PayPal's privacy policy for their statement on this.

4.3. Right to Rectification

Where there are omissions in the data we hold you have the following two rights :-

  • “inaccurate data corrected”

  • “incomplete personal data completed”

If you see any data we hold on you falls into one of the categories above then do let us know and we’ll be happy to address this for you

4.4. Right to be Forgotten

You’re right to have your data removed from our systems. We can do this where :-

  • “Retention of personal data is no longer necessary” for the processing we told you we would carry out on it

  • you specifically :-

    • “withdraw consent” – see above

    • “object to processing” – see above

  • your data has been “unlawfully processed“

  • your data has to be “erased as part of a legal obligation”

Note that as data stored by Google Analytics is deliberately obscured (obfuscated), and as such can’t be used to identify you, Google will not be able to remove any previously suppled data that your activity on our site contributed to.

4.5. Right to Restriction

We’ve covered some of this before but GDPR details more specific information here in Article 18. Under this article you have the right to request restriction of processing where :-

  • “data accuracy is contested” 

  • you oppose the “erasure [of data] and request restriction instead” 

  • we “no longer need the data for intended purpose” 

  • you “object to being processed by automated decision making”. Note that we don’t do any automatic decision making

We’ll store your data when you request us to restrict it and will tell you if this restriction is going to be lifted if restriction has be previously requested for legal reasons

4.6. Right to Object 

There’s a couple of specific clauses we’re obliged to tell you about. Here they are.

  • You have the right to object to processing of personal data for “direct marketing including profiling related to direct marketing” 

  • Where you object your “personal data will no longer be processed for direct marketing” 

  • You will be told of your “right to object to processing”. Please consider us doing that here

5.0. Further Points (non-GDPR)

Use of personal information

We will use your personal information necessary for us to provide our services to you. We do not share any information with unrelated third parties nor do we collect or retain any information other than as required for the provision of our products or services. Information collected will be stored securely and securely destroyed if it is no longer required by Ammrita Online.

Security of information

Personal information collected by our website is stored in secure operating environments that are not available to the public. Ammrita will protect your personal information no matter where we process or store your data.

Changes to our policy

From time to time, it may be necessary for us to review and revise this policy. We reserve the right to change our policy at any time and, should this occur, the amendment will be posted on our website. We encourage you to check this policy periodically to ensure it conforms to your requirements.

07804062019

©2018 AMMRITA