Data Processing Privacy Policy (Spiritual Master Free Spirit Ltd)
This Privacy Policy describes how your personal information is collected, used, and shared when you visit the website, use the website or make a purchase from this website, as required by EU GDPR 2018 and the UK DPA 2018 (Data Protection) regulations
GDPR and Brexit
From the ICO page, the EU GDPR 2018 is an EU Regulation and it no longer applies to the UK (unless you are an EU customer of Spiritual Master Free Spirit Ltd) in which case EU customers can use the GDPR procedure as you would be defined as a customer/client or website user of a UK business processing information about an EU data subject.
For UK customers the original Data Protection Act 2018 (UK DPA 2018) applies.
Under that act you have similar rights and you have the right to find out what information an organisation stores about you.
Should you submit a GDPR request as a UK citizen, the UK DPA 2018 will apply.
In practice the process is similar, in that you have rights of access, and exemptions also apply as per the GDPR.
To avoid confusion – when you make a legitimate data subject access request, you as a data subject will be informed which regulations apply to you which will depend on your ordinary country of permanent residence.
California Consumer Privacy Act (CCPA)
Spiritual Master Free Spirit Ltd respects the data privacy rights of all customers / clients and website users worldwide including in the United States – however – the California Consumer Privacy Act (CCPA) – by way of its legal definition regarding businesses overseas – does not apply to Spiritual Master Free Spirit Ltd – as the business does not buy, sell and share the personal information of 50,000 or more California consumers – and gross revenues of the business do not exceed USD $25million.
Spiritual Master Free Spirit Ltd does not buy and sell the personal information of any California (or other US residents, or indeed any residents in any country) and the personal data of US clients (and indeed the personal data about clients, customers and website users outside the EU and the UK) is processed primarily to provide the website access and/or the customer and client service requested. In rare instances other legal justifications for processing data may apply.
COOKIES
This website uses essential cookies to ensure the smooth functioning of the website and to display content such as embedded You Tube videos and private membership discourse content, by clicking OK in the simple consent box you agree. Regular visitors will find when the box reappears once a month they will need to renew the consent.
This consent can be revoked at any time by simply clearing your browser cookies.
EU ePrivacy Regulations 2021 (ePR Compliance with Cookies Consent)
This website has been tested for compliance with the regulations regarding the use of cookies and online tracking in relation to the EU ePrivacy Regulations. The website is compliant with the regulations with regard to prior consent on the use of other than strictly necessary cookies (ePR) and compliant with the requirement to obtain prior consent from users to process personal data (GDPR).
CONTACT FORM DATA
This website collects data (the name and email address supplied, plus any message) from visitors who submit a contact form submission and the data provided is simply used to assist in customer service inquiries.
By submitting information through the contact forms on the website by way of ticking the check-box underneath all contact forms marked EU GDPR 2018 / DPA 2018 (Data Processing) Consent you agree that your name and email along with any other information submitted (the message text) is used for data processing purposes in order to process the inquiry and communicate with you.
Visitors agree that geo-location data and IP addresses are saved from contact form submissions, store orders or website visitors. Such data is automatically and routinely purged from the database every 7 days unless a retention exemption applies.
Email addresses submitted via the contact form will never be added to any newsletter, or used in any other way other than to respond to the query or to fulfil any order that might be agreed per email later.
This website does not collect names or emails for any marketing purposes, nor are email addresses and names shared, sold or distributed to third parties under any circumstances, unless in the rare event a “legal justification exemption” applies.
Once a contact form message has been received and dealt with, the data will be deleted unless a retention exemption applies.
In instances where a response is not required and a retention exemption does not apply, the data will be deleted immediately.
PERSONAL INFORMATION PROCESSING
When you make a request to make a purchase through the Site or place an order in the webstore – certain information necessary to create an invoice and to fulfil the order is required, including your name, billing address, shipping address, email address (and a phone number for delivery purposes).
This information is referred to as “Order Information.”
This information is not used in any other way than is required to fulfil the order and to deliver the products ordered.
Spiritual Master Free Spirit Ltd does not share, distribute or sell any customer data to any third party, nor does it collect or use customer/contact form data for any purpose other than to fulfil orders, maintain customer service and respond to queries.
Customer details are confidential and are kept only to the degree it is necessary to fulfil the order.
CUSTOMER ID VERIFICATION
Customers submitting orders for products and/or services will be required to verify their identities before invoicing to ensure customs clearance, for accounting and taxation purposes of Spiritual Master Free Spirit Ltd, to ensure shipping to the correct address and to prevent fraud. Customers will be required to supply scans of government issued ID, proof of address (dated within the last 3 months) and provide a verifiable telephone number and email address. Such information is safeguarded under the provisions of the GDPR.
Those who fail ID verification will not be able to purchase products or services from Spiritual Master Free Spirit Ltd.
PRIVATE MEMBERSHIP DISCOURSE AREA – DATA PROCESSING
Paid up clientele with access to private discourses understand that their email address and other data necessary to provide the service are used to provide the access to the private membership area.
This data is secure, safeguarded and not available to others, email addresses of private members may be used by Spiritual Master Free Spirit Ltd to send them necessary updates with regard to use of the service.
Members agree that geo-location data and IP addresses are saved by a WordPress Statistics Plugin which records logins to the private membership area and the data is purged from the database every 7 days, to access privately you can also use a VPN.
Members that no longer wish to have access to the material or wish to delete their membership account at any time can submit a request via the contact form and your account and all associated data will be deleted.
WEBSITE VISITORS (DATA PROCESSING FOR ANALYTICS PURPOSES)
Visits to the website are stored by a WordPress Statistics Plugin, this analytical data including country, IP address and pages viewed, is used to research and understand website visitor behaviour as well as to prevent nuisance and spam webform submissions, and to prevent fraudulent orders (GDPR legitimate processing citing the detection and prevention of fraud).
Such data is purged from the database every 7 days – except where legal justifications would preside over the right to deletion (for example if a particular IP address (or a group of IP addresses) is (or appears to be based on the preponderance of the evidence) behind repeated attempts at filing fraudulent orders, spamming the contact forms or behind the submission of malicious website form submissions – in which case that data will be saved for legal reference.
HOW IS YOUR PERSONAL INFORMATION USED?
Spiritual Master Free Spirit Ltd will use the Order Information supplied to fulfil any orders placed through the Site or via subsequent email interactions (including arranging for shipping, and providing you with invoices and/or order confirmations) and/or to provide digital access to the Private Membership Area for Discourses.
Additionally, this Order Information is used to:
Communicate with you (about the progress of an order, or to confirm receipt of delivery, or to invoice for products ordered or to share important information regarding digital access to study materials.
This information is respected and not shared for any other purpose.
SHARING YOUR PERSONAL INFORMATION
Personal Information or Order Information is not shared with third parties under any circumstances, unless absolutely required by law.
Customer information is confidential and the security of information is taken very seriously.
Spiritual Master Free Spirit Ltd does not send unsolicited newsletters, nor uses personal or order information in any way other than is necessary to supply the products ordered to the customer or to maintain any contract with a Client that may be created by way of placing an order or agreeing a mentoring program of any kind and/or to provide digital access to the Private Membership Discourse Viewing area.
Unnecessary data is deleted by default, including information from old contact form submissions.
CUSTOMER CONTACT
Email addresses of customers (who have ordered a product) may be saved in order to provide important announcements and updates in the future with regard to discourse access or similar. If you do not wish to receive these updates (which are rare), you can request not to receive them and that request will be honoured.
Business Calls (Recording Policy)
Business telephone calls may be recorded to assist in the provision of high quality customer and client service, such recordings will only be used as far as necessary to assist in that process, after which recordings would be erased.
YOUR RIGHTS
If you are a EU resident, under the provisions of the recent GDPR regulations, you have the right to access personal information held about you and to ask that your personal information be corrected, updated, or deleted.
No charge is made for such a request – in GDPR terms – known as a Subject Access Request.
If you would like to exercise this right, please use the contact form.
If data is held about you, information about the data held will be shared with you, free of charge and within 30 days as per the EU GDPR 2018 Data Regulations (unless any of the GDPR exemptions apply)
The data will be provided in digital form (scanned PDFs) to the email address used to request the data access.
Please note that it may be necessary to confirm your identity in order to ensure the safety of personal information and to ensure the data requester is who they say they are, for example a scan of a drivers licence or passport and/or a proof of address that matches the data on your government issued ID – such as a utility bill dated within the last 3 months.
Any such ID given to confirm your identity to facilitate a Data Disclosure Request / Subject Access Request will be immediately and permanently deleted after your identity is confirmed.
If data is not held about you (in many cases old customer data and contact form submissions are deleted by default anyway) that fact will be confirmed with you, within the 30 day time limit for responding to Data Requests.
DATA ANONYMIZATION AND RETENTION PROCEDURES
When you place an order through the Site, Spiritual Master Free Spirit Ltd will maintain your Personal and Order Information for the records and to assist in continuing to provide access to digital study material – unless and until you ask to delete this information.
Spiritual Master Free Spirit Ltd retains the minimum amount of data necessary to further ensure a strong level of customer/client confidentiality and to ensure the safety of personal data
Note that for taxation purposes customer invoices may be kept on file for some time (a 6 year retention period)
Personally identifiable data is anonymized from such invoice data 1 year after the tax year to which the invoice from Spiritual Master Free Spirit Ltd relates, in the unlikely event of any dispute, data and information may be kept for longer for legal reasons, if such justifications take precedence over the right of anonymization/deletion.
Once data is deemed unnecessary to retain further, it will be deleted automatically by default.
In the same vein repeat customers may be asked for their information again to fulfil a subsequent order.
RETENTION PERIOD
The maximum retention period for customer and client data is 6 years after which such records are then permanently deleted.
CHANGES
Spiritual Master Free Spirit Ltd may update this privacy policy from time to time in order to reflect, for example, changes to practices or for other operational, legal or regulatory reasons.
RIGHT TO COMPLAIN
In the event of any GDPR or DPA 2018 related dispute, if the concerns are not remedied by way of using the GDPR or the Data Protection Act 2018 (DPA 2018) Data Subject Access Request Procedure outlined above, the data subject has the unequivocal right to take the matter to the Data Protection Authority.
The relevant GDPR regulatory body being the Information Commissioners Office, United Kingdom with whom Spiritual Master Free Spirit Ltd is formally registered as a data controller as required by the ICO. Registration number: ZB131914
PRIVACY QUESTIONS / DATA REQUESTS / DELETION REQUESTS / CONTACT
For more information about the privacy practices or for clarification on how customer data is used, or to access your data under the provisions of the GDPR, please use the contact form.
Spiritual Master Free Spirit Ltd™ UK Limited Company. Companies House Registration Number 12696854 Registered Office – Lytchett House, 13 Freeland Park, Poole, BH16 6FA, UK Business Email Address admin@spiritualmasterfreespirit.com