PRIVACY NOTICE
Last updated: July 2022
We are dedicated to safeguarding and preserving your privacy when visiting our site or communicating electronically with us.
This Privacy Notice (“Notice”) provides an explanation about what happens to any Personal Data (“Data”) that you provide to us, or that we collect from you.
By continuing to use our Website and to participate in the treatments, meditation, breathwork events, workshops, programs and/or courses offered by us (“Services”), you agree to our Terms and Conditions (“Terms”) and this Privacy Notice for the collection and processing of your Personal Data.
This Privacy Notice sets out our use of any and all data collected by us in relation to your use of our website, https://allinsync.co.uk (“Website”). The Website is operated by All In Sync represented by Anupa Panjabi, a certified Reiki Master and NLP practitioner (“All In Sync”, “we”, “us”, “our”, “ourselves”).
For the purposes of processing your Personal Data, we are the Data Controller (as defined under Article 4 of the EU and UK General Data Protection Regulation 2016/679 (“GDPR”). Personal Data (“Data”) shall have the meaning given to it under Article 4 of the GDPR 2016/679, and which is more particularly defined in this Privacy Notice below.
This Privacy Notice should be read in conjunction with our disclaimers and general terms. We may amend or update this Notice from time to time and will publish revised versions on this Website. We reserve the right to alter and make changes to this Notice at our sole discretion and we therefore request all users to regularly refer to our Privacy Notice for updates and variations.
The contents of this Privacy Notice are as below:
- Who is the person responsible for the management of your Personal Data?
- What Personal Data do we need/receive?
- What are the sources of collection of Personal Data?
- How do we use your Personal Data?
- Children’s Privacy
- What are the Lawful Bases for processing your Personal Data?
- Who may use your information?
- Social Media
- How do we store and transfer Your Personal Data?
- For how long do we store your Personal Data?
- Use of Cookies
- Marketing Communications
- Change in Terms of Privacy
- Third party Links
- Payments
- Access to Information
- Erasure of your Information
- Other Rights
- Contacting Us
- Complaints
Who is the person responsible for the management of your Data?
As a business operating in the United Kingdom, we are registered with the Information Commissioner’s Office (ICO) under registration number ZB350382
The person responsible for data protection is Anupa Panjabi. For any queries relating to the management of your Personal Data please do not hesitate to send us an email at anupa@allinsync.co.uk
What Personal Data do we need/receive?
“Personal Data” has been defined under the GDPR (EU and UK) as “any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.”
Any references to “Personal Data” in this Notice therefore means information about living individuals, which, alone or in conjunction with other information held by us is capable of identifying them. The GDPR 2016/679, the UK GDPR, The Data Protection Act 2018 and any other national implementing legislation relating to data protection in the UK, regulate our use of your Personal Data (collectively “Applicable Data Protection Law”).
In order to provide our Services or for the purposes of conducting our business we may need the following Data from the individuals we are dealing with (“you”, “yours”, “yourself/yourselves”).
We have tried to cover categories of Data that we generally require while providing Services to our clients or for the purposes of operating our business. However, this is not an exhaustive list.
- Your name
- Your physical and electronic addresses
- Your phone number
- If you are a company, the company registration number and registered office address
- For the purposes of making payments or any other transactions, bank details
- For employment purposes, National Insurance number
- Details of your visits to our Website and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data
- Any other information that you provide by filling out forms on our Website, such as when you register for information or make a purchase
- Your medical history
- Any health or medical conditions that you may be suffering from
- Any prescribed or non-prescribed medication that you are taking
- Any allergies that you may have
- Lifestyle related information
- Any other information provided to us when you communicate with us for any reason
- Your social media account details if you follow us on or communicate with us via social media
Sources of Personal Data
We may obtain Personal Data from you when you contact us or get in touch with us via our Website or when you, or your organisation correspond with us through any means of communication. This includes Personal Data you provide to us when you:
- Contact us with a question or query via email at anupa@allinsync.co.uk, telephone or fill out our online form to book a treatment (“Appointment Form”)
- Book a discovery call with us or ask us to provide our Services to you
- Ask us to collaborate with you on any assignment
- Contact us or authorise anyone to contact us for the purposes of our Services
- Contact us to provide us your services or goods
- Correspond with us to submit any complaints that you may have
- Correspond with us to address any complaints we may have raised
- Register for a seminar, networking, or social event where information is shared between fellow members
- Register to receive updates and newsletters from us
- Attend events and provide our staff with your personal information, business cards or contact details
- Deal with us when we are providing services to our clients (which maybe you, your dependent, your organisation or a third party)
- Submit identity documents directly to us or to third party agencies commissioned by us to collect your Data for the purposes of carrying out identity checks and due diligence (We shall continue to remain the Data Controller for any information submitted to third-parties in connection with your dealings with us)
- Contact us for the purposes of employment or apprenticeships
- Connect with us on social media platforms or join groups created and administered by us on social media
We may also collect and retain Personal Data
- Obtained from public sources about you or your organisation, which includes all information available on your website, the Companies House, or other online sources accessible through Search Engine Optimisation searches
- Obtained from third parties, that may include our clients, professional regulators, public bodies, and other entities, including providers of analysis, screening and database services who have a right to disclose this information to us and
- Relating to whether our contacts read electronic correspondence from us or click on links we send them.
How do we use Your Information
The information that we collect and store relating to you is primarily used to enable us to provide our Services to you. In addition, we may use the information for the following purposes:
- To provide you with information requested from us, relating to our Services. To provide information on other products or services which we feel may be of interest to you, where you have consented to receive such information.
- To meet our contractual commitments to you such as the delivery of our Services to you.
iii. To notify you about any changes to our Website, such as improvements, or changes to our Services
- To carry out research, including market research, statistical research on site traffic, sales and other commercial information to assist us in improving the Services we provide to you and to improve our Website
- For internal use such as governance, quality control and monitoring purposes
- If you are an existing customer, we may contact you with information about products and Services similar to those which were the subject of a previous sale to you.
vii. To send you newsletters and other promotional material if you have opted-in.
viii. To connect with you on social media, if you have requested to connect with us and, once connected, to provide you with information and updates about us and our Services on social media.
By completing our “Appointment Form”, you consent to us using your Personal Data as detailed above, including the use of your Personal Data for the purposes of sending you newsletters, updates and other promotional material.
Children’s Privacy
We do not knowingly collect or process Data from anyone under the age of 13 (thirteen) years old (“Child”/ “Children”). Our Services and Site Content are not directed at minors, i.e., persons below the age of 18 [eighteen] years, especially children below the age of 13 [thirteen] years.
If you are a parent or guardian and you are aware that your Child has provided us with Personal Data without your consent, please contact us. Unless contacted by a parent or legal guardian, we have no way of knowing that Personal Data was submitted by a Child without parental consent. As a parent/legal guardian you understand that that the onus of controlling your Child’s Personal Data lies on you. If we become aware, after notification by a parent/legal guardian or the Children themselves, that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.
What are the Lawful bases for processing your Personal Data?
The following are the lawful bases for us processing your Personal Data:
Article 6.1 (a) of the GDPR 2016/679- Consent
In order to avail of our Services, you consent to us obtaining and processing your Personal Data. While dealing with you we may issue terms and conditions (“Terms of Business”) or execute a contract outlining the terms and conditions of our engagement with you. The Terms of Service/contract along with this Notice set out the purposes for which your Personal Data may be obtained and processed by us. By accepting our Terms of Service or by using our Website or by executing a contract with us and by continuing to deal with us you confirm that you have consented to us collecting and processing your Personal Data in accordance with our Terms and this Privacy Notice.
By expressly opting in to receive our newsletters and promotional material, you consent to us using your email address for the said purposes, in which case the lawful basis for us using your Personal Data is your consent as outlined in Article 6.1 (a) of the GDPR 2016/679.
Article 6.1 (b) of the GDPR 2016/679- Contractual necessity
One of the grounds for obtaining and processing your Personal Data is so that we can perform our Services in line with the Terms of Service mutually agreed to by us.
Article 6.1 (c) of the GDPR 2016/679- Compliance with legal obligations
We may have to collect Personal Data in order to comply with certain legislative and regulatory requirements relating to client due diligence. Consequently, we may process your Data to carry out identity checks and maintain records of customer due diligence.
We may employ third party service providers for the purposes of carrying out client identity checks, or for processing your Data for the purposes of due diligence. However, we remain the Data Controllers.
Article 6.1 (f) of the GDPR 2016/679 – Legitimate interests
In circumstances where you are a client or an employee of All In Sync we may have to process your Personal Data to promote and pursue legitimate interests of the public and/or our organisation, and/or yours as our client or employee, particularly where we need to access your health or medical records to ensure that the Services being provided to you will not aggravate any existing medical or health conditions.
In terms of promotional material, if you unsubscribe from our mailing list or revoke your consent to receive our newsletters and promotional material, corresponding Data will be removed from our mailing list and will no longer be processed for these purposes. Including your email address in our blocking list is effected in order to safeguard our legitimate interests under Article 6.1 (f) of the GDPR 2016/679. Our legitimate interests lie in not sending you any e-mails in the future.
* However, you can object to us processing your Personal Data, on any of these bases at any time and, if you do so, we will stop processing the Personal Data unless we can show compelling legitimate grounds which override your rights and interests such as, without limitation your own health and safety or the health and safety of any other person(s), or the legitimate interest of our organisation and/or the public or we need the Data to establish, exercise or defend legal claims – see “Your rights” below.
Who may use your information?
We are committed to keeping your e-mail address confidential. We do not sell, rent, or lease the subscription lists to third parties.
We may disclose your Personal Data:
- to enforce our policies, to comply with our legal obligations (such as if we are required to disclose your Personal Data under a court order, legal requirement and/or regulatory requirement) or in the interests of security, public interest, or law enforcement in any country where we have entities or affiliates. For example, we may respond to a request by a law enforcement agency or regulatory or governmental authority. We may also disclose Data in connection with actual or proposed litigation, or to protect our property, security, people and other rights or interests
- We may share your Personal Data with our employees, independent contractors, consultants, partners and/or third parties who help deliver our services to you. Examples include hosting our web servers, analysing data, providing marketing and administration assistance, and providing customer service. These companies will have access to your personal information as necessary to perform their functions, but they may not use that Data for any other purpose. Our contracts with all third parties processing our clients’ Personal Data shall outline their obligations relating to data protection.
- While booking a treatment or session online you may have to enter your payment details. Please note that we do not store your payment details, and these are only used by the payment gateway to help facilitate the payment transaction in question.
- We may share aggregated anonymised data with third parties in order to monitor our Services and to ensure consistent quality and safety relating to the Services provided to clients.
Social Media
Please remember that when you share information publicly on the Website or on social media platforms, for example a comment on a blog post or within social media groups, it may be indexable by search engines, including Google, which may mean that the information is made public.
When you participate in conversations on social media your Personal Data is visible to members of the concerned social media group and to the public in general. Please note that you participate in social media related activities at your sole discretion, and we shall not be liable for the access and use of your Personal Data by third parties, via social media, including circumstances, where third parties contact you or initiate a conversation with you, on social media or otherwise, as a result of your information made available to them via our social media groups or any activity you participate in through our social media platforms or by connecting with us on social media.
Also please note you may be tracked by Facebook, Google or Instagram cookies if you access our profile via these social media platforms. The links to their respective privacy policies have been provided below:
Facebook- Privacy Policy
Instagram-Privacy Policy
Google- Privacy Policy
How do we Store and transfer Your Personal Data?
All Personal Data collected by All In Sync is stored in a secure manner compliant with the GDPR.
Your Personal Data may also be stored on servers that may not be located in the United Kingdom and/or the European Economic Area (the EEA). For example our servers may be located in the United States of America.
Consequently when you use our Website to purchase our Services or opt in to receive promotional material your Personal Data may be processed by servers located in the United States of America, with less strict privacy laws and the associated risk of your Personal Data being easily accessible in the United States of America.
Should you not wish your Personal Data to be processed in the United States of America you must not:
- Opt-in to receive promotional material from us
- Purchase Services via our Website, and/or pay via the Website
A purchase by you of Services using our Website and/or using any of the above-mentioned payment platforms shall constitute your consent to your Personal Data being processed in the United States of America.
We may also transfer Data that we collect from you to locations within and outside of the United Kingdom but within the European Economic Area for processing and storing. Also, it may be processed by staff or independent contractors operating within the European Economic Area who work for us.
By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all reasonable steps to make sure that your Data is treated securely and in agreement with this Privacy Notice.
Emails– all our inbound and outbound email communications are TSL (Transport Security Layer) encrypted, which is an industry standard for all encryption.
Security of Personal Data– The transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of Data sent to us electronically and transmission of such Data is therefore entirely at your own risk. Where we have given you (or where you have chosen) a password so that you can access certain parts of our site, you are responsible for keeping this password confidential.
For how long do we store your Personal Data?
Our policy is that we retain your Personal Data for as long as it is necessary for the purposes set out in this Notice, or as is required by applicable law. All of the Personal Data is disposed of securely to ensure compliance with Applicable Data Protection Law.
Use of Cookies
On occasion, we may gather information about your computer for our Services and to provide statistical information regarding the use of our Website.
Such information will not identify you personally as it is statistical data about our visitors and their use of our site. This statistical data does not identify any personal details whatsoever.
Similarly to the above, we may gather information about your general internet use by using a cookie file.
A cookie is a small text file. Where used, these cookies are downloaded to your computer automatically, typically somewhere within your browser settings files. They help us to improve our Website and your experience of it.
Examples of Cookies we use:
Session Cookies. We use Session Cookies to operate our service. Session Cookies are temporary cookies, as they store information about your current session and then are erased when your browser is closed.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.
Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyse our service.
All computers have the ability to decline cookies. Our Website will display a pop-up to remind you that when you access our Website we will place cookies on your device to improve your experience of our Website. We will also give you the option to consent or opt-out of cookies. You can opt-out of cookies by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular parts of our Website.
We have presence on social media, such as (without limitation) Facebook, Instagram and Google. Your access of our profile via these social media platforms may result in you and your activities being tracked by the cookies placed by these social media platforms.
For more information on Cookie Consent you may also want to visit the UK Information Commissioner’s webpage on cookies: https://ico.org.uk/for-organisations/guide-to-pecr/guidance-on-the-use-of-cookies-and-similar-technologies/
Google Analytics:
In order to optimise our service we may apply Google Analytics and our own statistical analyses.
Google Analytics is a web analysis service provided by Google, which is used for purposes of market research and ensuring that the service meets user requirements. Google Analytics uses “cookies”, which are placed on your computer to make it possible to analyse how you make use of the service. The information generated by the cookies about your use of the service (including your pseudonymised IP address) is as a rule transmitted to and stored by Google on servers in the United States . Google uses this information in order to evaluate your use of the service and to create reports on activities for the operator of the service. Google may also transmit this information to third parties if this is prescribed by law, or if third parties process the data on behalf of Google. On no account will Google connect your IP address with other Google data. At https://tools.google.com/dlpage/gaoptout?hl=en-GB you can, with effect for the future, opt out of the recording and saving of your Data at any time. The saving of cookies makes it possible to analyse user behaviour and activate interest-based advertising.
Marketing communications
If you have given permission, we may contact you about any of the following:
- Client and purchase information
- Occasional information about our Services, products and offers
- Updates about All In Sync
- Newsletters (if you have opted-in to receiving them)
- New blog posts
In compliance with Applicable Data Protection Law, all emails sent by us will clearly state who the email is from and will provide clear information on how to contact the sender. In addition, all marketing email messages will also contain concise information on how to remove yourself from our mailing list should you wish to, so that you receive no further email communication from us.
We are committed to keeping your information confidential. We will use your email address solely to provide timely information about us and our services and we will maintain the information you send via email in accordance with Applicable Data Protection Law.
Change in Terms of Privacy
We reserve the right to alter our privacy policies. Any changes to the Notice will be posted on this page. This Website is controlled and operated by All In Sync from its offices within the United Kingdom. We make no representations that materials, information, or content available on or through this Website are appropriate or available for use in other locations, and access to them from territories where, accessing such materials, information, or content is illegal is prohibited. Those who choose to access this Website from other locations do so on their own volition and are responsible for compliance with applicable local laws.
Third Party Links
You might find links to third party websites on our Website. These websites should have their own privacy policies which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.
Payments
In order to enable our consumers to purchase our Services, we use third-party services for payment processing (for example, payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their respective Privacy Policies. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
Access to Information
The GDPR and The Data Protection Act 1998 give you the right to access the information that we hold about you. We will provide the information that we hold on you free of charge as long as this information hasn’t been provided to you already. If the information is a copy of information already provided or is excessive then an administration cost of £10 will be charged. Should you wish to receive details that we hold about you please contact us using the contact details below. You will need to provide suitable evidence that you are the person that the information pertains to before we will release it. Information will be provided to you within one month of receipt of request.
Erasure of your information
If you are no longer a client with us then you have a right to erasure of your information. Once we have received your request for erasure we will ensure all Personal Data we hold on you is erased within one month of the receipt of the request, unless we are required to retain your information under a legal requirement.
Other rights
Under the Data Protection Act you have the following rights in relation to your own Personal Data:
- to prevent us using your Data for direct marketing
- to have (in certain circumstances) inaccurate Personal Data corrected, blocked, or destroyed
- to access a copy of your Personal Data that is undergoing processing (“subject access rights”)
- to object to automated decisions. We do not, however, use automated decision making
- Data portability, which allows you to get and use your Personal Data for different purposes
- the right to withdraw consent and/or to object to us continuing to process your Personal Data and
- a right to object to processing that is likely to cause or is causing damage or distress.
If you want to (1) tell us to stop using your Data for direct marketing or withdraw consent from us processing your Personal Data for any of the purposes mentioned in this Notice (2) exercise your subject access rights; (3) tell us about inaccurate Personal Data you think we hold on you; or (4) object to a use you believe we’re making of your Data which is causing, or is likely to cause damage or distress, please contact our Data Protection Manager or write to us at this address:
Anupa Panjabi
All In Sync
Contacting Us
We welcome any queries, comments or requests you may have regarding this Privacy Notice. Please do not hesitate to contact us at anupa@allinsync.co.uk
Complaints
If you are unhappy with the way we are processing your Personal Data you can submit a complaint by writing to our Data Protection Manager at anupa@allinsync.co.uk
You are also entitled to make a complaint at the Information Commissioner’s Office https://ico.org.uk/make-a-complaint/
The ICO’s address is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk