We respect and value the privacy of everyone who visits our websites, www.sourcemedicine.org.uk and www.sourcesound.org (“Our Sites”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of Our Sites;|
2. Information About Us
Our Sites are owned and operated by Source Medicine, a company limited by guarantee registered in England, under company number 10085231.
Registered address: Bowden House, Totnes, TQ9 7PW, UK.
Data Protection Officer: Leilani van Koten, MB, ChB.
Email address: firstname.lastname@example.org and email@example.com.
Postal address: Bowden House, Totnes, TQ9 7PW, UK.
3. What Does This Policy Cover?
4. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
6. What Data Do You Collect and How?
We collect data concerning health (personal data related to the physical and mental health of a natural person) and personal data relating to children.
We do not collect any data relating to criminal convictions and/or offences.
|Data Collected||How We Collect the Data||Why Do We Need the Data|
|Identity Information including first and last name, date of birth, place of birth, place of current residence, gender, language your mother spoke during her pregnancy.||Data is obtained from you, by questionnaire.||This is needed for personalization of each Source Resonance.|
|Contact information including address, email address.||Data is obtained from you, by questionnaire.||We use this data for communication and in case we want to check out how you are doing on the programme.|
|Emotional/mental health information, including the feeling of accepting oneself, in general.||Data is obtained from you, by questionnaire.||You can use this as a reference point for the beginning of the program.|
|Payment information including card details such as bank account number and cardholder name.||Data is obtained from you, via Stripe or PayPal.||For processing online transactions as a condition for enrolment into our programs, trainings and usage of Source Resonances.|
|Profile information including preferences, interests, login details, purchase history.||Data is obtained automatically by cookies.||Automatically obtained data.|
|Technical information including IP address, browser type and version, operating system.||Data is obtained automatically by cookies.||Automatically obtained data.|
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and our lawful bases for doing so:
|What We Do||What Data We Use||Our Lawful Basis|
|Registering you on Our Sites.||First and last name, email address.||Consent.|
|Providing and managing your Account.||Profile information including preferences, interests, login details, purchase history.||Consent.|
|Providing and managing your access to Our Sites.||Technical information including IP address, browser type and version, operating system.||Consent.|
|Personalising Source Resonances to be provided to you through Our Sites.||Identity Information including first and last name, date of birth, place of birth, place of current residence, gender, language your mother spoke during her pregnancy.||Consent.|
|Administering our business.||Contact information including address, email address.||Consent.|
|Supplying our products and services to you.||Contact information including address, email address.||Consent.|
|Managing payments for our products and services.||Payment information including card details such as bank account number and cardholder name.||Consent.|
|Communicating with you.||Contact information including address, email address.||Consent.|
|Supplying you with information by email and post that you have opted-in-to (you may opt-out at any time by unsubscribing).||Contact information including address, email address.||Consent.|
We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We will only use your personal data for the purposes for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purposes and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purposes for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
|Type of Data||How Long We Keep It|
|Identity Information including first and last name, date of birth, place of birth, place of current residence, gender, language your mother spoke during her pregnancy.||3 months after personalization of last Source Resonance.|
|Contact information including address, email address.||For as long as you are subscribed to Our mailing list.|
|Emotional/mental health information, including the feeling of accepting oneself, in general.||In anonymised form we will keep this 10 years after the end of the program, as this will serve us a basis for doing a feasibility study of the Self-acceptance programme.|
|Payment information including card details such as bank account number and cardholder name.||10 years after the last payment is done.|
|Profile information including preferences, interests, login details, purchase history.||Up to 1 year, depending on the exact cookie.|
|Technical information including IP address, browser type and version, operating system.||Up to 1 year, depending on the exact cookie.|
9. How and Where Do You Store or Transfer My Personal Data?
We will only store your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
10. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
- In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Sites, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us, which you may do by unsubscribing using the links provided in our emails and by managing your Account.
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
You may access certain areas of Our Sites without providing any personal data at all. However, to use all features and functions available on Our Sites you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within two weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of Leilani van Koten, MB, ChB.
Email address: firstname.lastname@example.org and email@example.com.
Postal address: Bowden House, Totnes, TQ9 7PW, UK.