Effective date: 1 April 2020
myyodaa Limited (“myyodaa”, “We”, “Our” or “Us” and their connotations) operates a website (myyodaa.com) and a mobile based application called “myyodaa” (together “Platform”) which is engaged exclusively in the service of facilitating users who wish to conduct/avail live interactive yoga and/or meditation classes.
Our Platform is primarily for yoga and meditation teachers who have enlisted their services on the Platform and individuals wishing to avail their services and any other services that myyodaa may provide access to through the Platform (“User”, “You” or “Your”).
“Personal Information” refers to any information about an identifiable individual.
This policy does not limit or exclude any of Your rights under applicable privacy and data protection laws, including the New Zealand Privacy Act 1993 and the General Data Protection Regulation of the European Union (“GDPR”), if applicable. For further information on the New Zealand Privacy Act 1993, see www.privacy.org.nz. For further information on the GDPR, see https://ec.europa.eu/info/law/law-topic/data-protection_en.
2. Personal Information We Collect and use
In order to provide Services, We require certain User Personal Information and may obtain the same through User-provided data or automatic data collection.
We collect Personal Information directly from You which includes, but is not limited to, (i) name, e-mail ID, photograph, location, financial information and other contact information and (ii) gender and other demographics.
We also collect certain Personal Information either when You provide it using the Platform or Services and/or automatically as You navigate through the Platform (which may include usage details, IP address, device ID and type, Your browser type and language, the operating system used by the device, access times, and information collected through cookies, web beacons and other tracking technologies). You agree that We may use such information to do internal research on Our Users' demographics to better understand, protect and serve Our Users and to improve the Platform and Our Services.
We collect video and audio footage of the classes provided on the Platform from both Students and Teachers and hold this for a period of 72 hours from the end of the class. We delete all footage after this period.
3. Purpose of Collection
We collect Personal Information only necessary for the following purposes:
To create and maintain Your account;
To enable You to avail of Our Services, and ensure efficient customer care experience and develop new features;
To dispatch transaction-related communications such as welcome letters, class confirmations and payment information;
To notify the necessary information related to the Platform and Services and Your account on the Platform from time to time;
To maintain records and provide You with an efficient, safe and customised experience while using the Platform;
To investigate and respond to Your complaints in relation to classes You have provided or participated in on the Platform (as the case may be). The video and audio footage We collect of the classes is used solely for this purpose;
To analyse overall trends to helps Us improve the Platform and Services;
To furnish Your information to service partners and providers only to the extent necessary for delivering the relevant services;
Verify Your identity and prevent fraud or other unauthorised or illegal activity;
To comply with applicable laws, rules, and regulations;
We may use Your email address to explain what information We are collecting, how We plan to use it, and how You can revoke consent or request at any time that We remove the account and delete any Personal Information collected from You.
We reserve the right to use or disclose Your Personal Information in response to any statutory or legal requirements. We will use and disclose Your Personal Information if We believe You will harm the property or rights of the Platform, its owners, or those of the Platform’s other users. Finally, We will use or disclose Your Personal Information if We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person or property, violations of the Platform’s other policies, or as otherwise required by law when responding to subpoenas, court orders and other legal processes.
You agree that We may use Personal Information about You to improve Our marketing and promotional efforts, to analyse site usage, improve the Platform's content and service offerings, and customise the Platform's content, layout, and Services. These uses improve the Platform and better tailor it to meet Your needs, so as to provide You with an efficient, safe and customised experience while using the Platform.
We may use Your Personal Information to market Our services and products to You, including contacting You electronically (e.g. by text or email for this purpose). "Opt out" and "unsubscribe" instructions will accompany any such communications.
4. Lawful basis for processing Personal Information
Our lawful basis for processing Personal Information that We collect, use and disclose depends on the Personal Information collected and the context in which We collect it.
Generally, We collect Personal Information from You where We have Your consent, where processing is necessary for the performance of a contract to which You are party or in order to take steps at Your request prior to entering into a contract, or where processing is necessary for the purposes of Our legitimate interests (except where such interests are overridden by Your interests or fundamental rights and freedoms).
Where We process Personal Information based on Your consent, You may withdraw Your consent at any time.
Despite the above, We may process Your Personal Information where such processing is necessary for compliance with applicable laws.
If You have any question about the legal basis on which We process Personal Information or need further information, please contact Us at email@example.com.
We use data collection devices such as "cookies" on certain pages of the Platform to help analyse Our website flow, measure promotional effectiveness, and promote trust and safety. Cookies are small files placed on Your hard drive that assist Us in providing Our Services. We offer certain features that are only available using a cookie. Cookies can also help Us provide information that is targeted to Your interests.
We use Google Analytics to collect information about visitors to Our website. Google Analytics collects information related to Your device, browser, IP address, network location, and website activities to measure and report statistics about Your interactions on Our website. We use this information to help Us manage the performance and design of Our website and to improve Our website.
You can control and/or delete cookies as You wish. You can delete all cookies that are already on Your computer and You can set most browsers to prevent them from being placed. However, if You do this, You may have to manually adjust some preferences every time You visit Our website and attempt use Our services, You may not be able to access certain parts of Our website or Services, and some functionalities may not work.
You can find out more information about cookies and how to change Your browser cookie settings at www.aboutcookies.org.uk.
You may opt out of targeted advertising at http://www.youronlinechoices.eu/. You can learn more about interest-based advertising and opt out of interest-based advertising from participating online advertising companies at the following links.
Network Advertising Initiative – http://optout.networkadvertising.org/
Digital Advertising Alliance – http://optout.aboutads.info/
Digital Advertising Alliance EU – http://www.youronlinechoices.com
DAA AppChoices page – http://www.aboutads.info/appchoices
Please note that opting out of interest-based advertising does not mean You will no longer be served advertising. You will continue to receive generic ads.
6. Data Security
We always strive to keep Your Personal Information safe. We take many safety measures, including:
The security of Your Personal Information is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Information, We cannot guarantee its absolute security.
Safety in the operating environment: We store Your Personal Information in a safe operating environment and it can only be accessed by employees, representatives and service providers on a need-to-use basis. We comply with current accepted industry standards (SSL, etc.) and the law to protect Your Personal Information.
Your account is protected by a password for Your privacy and security. You need to prevent unauthorised access to Your account and Personal Information by selecting and protecting Your password appropriately and limiting access to Your computer or device and browser by signing off after You have finished accessing Your account.
7. Links to other Sites
Advertising may be based on Your user profile in order to provide personalized advertisements and it may come from affiliate advertising networks.
8. Accessing and correcting Your Personal Information
Subject to certain grounds for refusal set out in the New Zealand Privacy Act 1993, You have the right to access Your readily retrievable Personal Information that We hold and to request a correction to Your Personal Information. Before You exercise this right, We will need evidence to confirm that You are the individual to whom the Personal Information relates.
In respect of a request for correction, if We think the correction is reasonable and We are reasonably able to change the Personal Information, We will make the correction. If We do not make the correction, We will take reasonable steps to note on the Personal Information that You requested the correction.
If You want to exercise either of the above rights, email Us at firstname.lastname@example.org. Your email should provide evidence of who You are and set out the details of Your request (e.g. the Personal Information, or the correction, that You are requesting).
9. Compliance with Data Protection Regulations
If You are a resident of the European Economic Area (“EEA”), You have certain data protection rights. myyodaa aims to take reasonable steps to allow You to correct, amend, delete or limit the use of Your Personal Information.
Under the GDPR, the transfer of personal information to a country outside the EEA may take place where the European Commission has decided that the country ensures an adequate level of protection. In the absence of an adequacy decision, We may transfer Personal Information if other appropriate safeguards are in place.
Where We transfer Personal Information outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data, or to a third party where approved transfer mechanisms are in place to protect Your Personal Information (e.g. to organisations in the United States under the EU-U.S. Privacy Shield framework or by entering into the European Commission’s Standard Contractual Clauses).
Some of the Personal Information We collect is processed in New Zealand. New Zealand is recognised by the European Commission as a country that has an adequate level of data protection and We rely on this decision in transferring Personal Information to New Zealand.
If You wish to be informed about what Personal Information We hold about You and if You want it to be removed from Our systems, please contact Us at email@example.com
10. Rights of the EEA Data Subjects
In addition to the rights to access and correct Your personal information, if You are a resident of the EEA, You have the following data protection rights.
The right to access, update or delete the information We have on You. Whenever made possible, You can access, update or request deletion of Your Personal Information directly within Your account settings section. If You are unable to perform these actions Yourself, please contact Us to assist You. If We have shared Your personal data with any third party, We will take reasonable steps to inform those third parties that they must delete Your Personal Information.
The right of rectification. You have the right to have Your information rectified if that information is inaccurate or incomplete. We will take reasonable steps to ensure inaccurate Personal Information is rectified. If We have shared Your Personal Information with any third party, We will tell them about the rectification where possible.
The right to object. You have the right to object to Our processing of Your Personal Information.
The right of restriction. You have the right to request that We restrict or block the processing of Your Personal Information. If We have shared Your Personal Information with any third party, We will tell them about this request where possible.
The right to data portability. You have the right to be provided with a copy of the information We have on You in a structured, machine-readable and commonly used format to enable data portability to another data controller (as that term is defined in the GDPR). Where technically feasible, and at Your request, We will transmit Your personal information directly to another data controller
The right to withdraw consent. You also have the right to withdraw Your consent at any time where myyodaa relied on Your consent to process Your Personal Information.
The rights related to automated decision-making, including profiling. You have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning You or similarly significantly affects You, except where such automated decision-making is necessary for entering into, or the performance of, a contract with You, is authorised by applicable laws or is based on Your explicit consent. We do not undertake automated individual decision-making.
Where Personal Information is processed for the purposes of direct marketing, You have the right to object to such processing, including profiling related to direct marketing.
Please note that We may ask You to verify Your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Information. For more information, please contact Your local data protection authority in the EEA.
11. Sharing of Personal Information
We may share Your Personal Information with third party service providers (called ‘processors’) to perform certain processing activities on Our behalf, such as parties involved in hosting and enabling Our Services. Please note that We will not share Your Personal Information with third parties allowing them to Use this information for their own purposes unless You have given explicit consent thereto. Categories of third party processors are:
We may use third-party service providers to monitor and analyze the use of Our Service
Online and Behavioral Marketing
Payment Processing and Discounting
We may provide paid products and/or services within the Services. In that case, We use third-party services for payment processing (e.g. payment processors).
Any other Trusted Service Providers
We may use any other trusted service providers to improve the services provided to You.
To avoid doubt, other than what We have set out above, We do not provide or sell Your Personal Information to third parties.
13. Contact Details
Please contact us at firstname.lastname@example.org