Data Protection Policy

Mindful Equanimity Limited (ME) will to the best of its ability to adhere to the data protection principles of the Data Protection Act (DPA) which came into force on 25 May 2018,
which are:

1. Personal data shall be processed fairly and lawfully.
2. Personal data shall be obtained only for one or more specified and lawful purposes and shall not be further processed in any manner incompatible with that purpose or those purposes.
3. Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.
4. Personal data shall be accurate and, where necessary, kept up to date
5. Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6. Personal data shall be processed in accordance with the rights of data subjects under this Act.
7. Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss
   or destruction of, or damage to, personal data.
8. Personal data shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of
   protection for the rights and freedoms of data subjects in relation to the processing of personal data.

Use of personal data

The records we use that contain personal data are hosted by the following DPA compliant software providers:

• Merchant account provider ‘Stripe’
• Bookings account provider ‘Bookwhen’
• Bank account provider HSBC

Privacy policies for these can be found here:
https://bookwhen.com/privacy

https://stripe.com/en-gb/privacy

How we use your data
These records are used solely for the purposes of administering course attendance and supporting continued engagement with the work of ME. The personal data
typically includes name, address, email address, payment card details (not accessible to Mindful Equanimity employees), courses attended and other engagement
with the work of ME such as being on the mailing list for the purposes of administering attendance on ME courses.

Individual emails to and from the @mindfulequanimity.temp.webaust.com email addresses are hosted by our DPA compliant email provider Google Gmail, for the purposes of
administering attendance on ME courses and supporting continued engagement with the work of the MA, and will be reviewed and if no longer needed for these purposes
will be deleted after a period of 1 year.

Personal data will be shared only with ME employees delivering the courses participated in and only to the extent necessary for administering the attendance of
individuals on ME courses and supporting engagement with the work of the ME.

Personal data will not be shared with third parties.

Collection of data

When an individual’s data is initially collected, eg. via an online booking or through the website the individual will be made aware of the use which will be made
of their information, by using the ‘Privacy Notice’ below and of this data protection policy.

Privacy Notice

The data you provide to Mindful Equanimity Limited will be stored securely and will be used for the purposes of administering your attendance on ME courses
and supporting your continued engagement with the work of ME in accordance with our data protection policy, which can be downloaded from the ME’s website and
is in accordance with the UK Data Protection Act. To support your engagement with us we will contact you from time to time via email with guidance to support your ongoing mindfulness practice, including details of upcoming courses, which may be of interest to you. You can opt out of receiving emails from the ME, at any time, by contacting info@mindfulequanimity.temp.webaust.com.

 Deletion of data

At any time you can request that your records on Google Gmail or Bookwhen to be deleted by contacting info@mindfulequanimity.temp.webaust.com

Records on Google Gmail and Bookwhen will be deleted, where an individual has opted out of email communication and has not done any prerequisite courses
with the ME.  Any paper or electronic copies of documents held by the ME, and which contain personal information, will be destroyed or deleted when a course ends. 
Emails to and from ME course participants or other individuals making enquiries to the ME will be reviewed after a period of 1 year and if no longer necessary for
the purposes will be deleted.  Paper records will be destroyed by shredding or burning.

Right to a copy of information held

On request an individual will be provided with a copy of the information comprising their personal data and held by ME, within 40 days of the request.  
All such requests should be sent via email to info@mindfulequanimity.temp.webaust.com

Information Security

Personal data is hosted by the following data processors, who are compliant with the new Data Protection Act:

• Merchant Provider Stripe, and bank account provider HSBC (accessible by Katherine Gail Pursglove)
• Email provider Google Gmail and document storage provider Google Cloud accessible by Katherine Gail Pursglove
• Bookings provider Bookwhen accessible by Katherine Gail Pursglove

The data security arrangements of these providers have been reviewed to ensure that they meet the requirements of the Data Protection Act.

How ME protects your data
No personal data will be passed to an individual who is not the individual concerned. Personal data passed on to the individual concerned will be sent to their
registered email address only. On receiving or making a phone call ME will establish the identity of the caller before disclosing or amending any of their
personal data, asking for their postcode and details of the most recent course they attended.

ME will ensure that all computers and IT used for processing personal data are password protected and that the password is changed every three months.
Computers will be screen locked or logged out of when employees are away from their desks. Desks will be cleared at the end of each day and any personal
information or other sensitive information securely stored in a locked cabinet. Computer screens should be positioned facing away from windows.

Care will be taken to prevent virus attacks by ensuring computers have virus protection software and undergo regular software updates and care should be
taken when opening email attachments and when visiting new websites.

ME will review information security on an annual basis.

Mindful Equanimity Limited
1 May 2020