This policy was last updated on 4th of October, 2020.
We are committed to complying with the General Data Protection Regulation and the Data Protection Act 2018. Looking after the personal information you share with us is very important, and we want you to be confident that your personal data is kept safely and securely and to understand how we use it to offer you a better and more personalised experience.
We have published this notice to help you understand:
- How and why We collect information from you
- Who We share your information with, why and on what basis
- What your rights are
Silence Speaks Ltd is the data controller of the information you provide. Should you have any questions about this policy please write to us at firstname.lastname@example.org
Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
Online channels: https://www.silencespeaks.co.uk and the Silence Speaks appointment booking portal at https://live.vcita.com/site/luis.melendezjr
|“Our Site”||Refers to https://www,silencespeaks.co.uk|
|“Client Portal”||Refers to a Silence Speaks website client portal required to access and/or use certain areas and features of Our Locations|
|“Personal Data”||Means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via any of Our Locations. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);|
|“We, Us ,Our”||Means Silence Speaks (UK) Limited, registered in England under company number 06182067, whose registered address is 5 Dukes Piece, Buckingham, MK18 7DA, United Kingdom.|
When do we collect your personal data?
- When you book a service at any of Our Locations or ask to be added to a waiting list for a service
- When you create an account at any of Our Locations
- When you purchase a product at any of Our Locations or apply for concession pricing which requires proof of age, job seekers, student or disabled status.
- When you visit our centres to attend a workshop
- When you redeem a gift card at any of Our Locations
- When you engage with us on social media
- When you enter prize draws or competitions
- When you choose to complete any feedback requests or surveys we send you
- When you use our premises which may have CCTV systems operated for the security of both customers and Partners. These systems may record your image during your visit
What data do we collect and how do we use it?
Depending upon your use of Our Locations, We may collect some or all of the following personal and non-personal data
Data Protection says that we are allowed to collect and use your personal data only where we have a proper reason to do so. The law says we must have one or more of these reasons:
- Contract – your personal information is processed in order to fulfil a contractual arrangement e.g. to place an order or book a class.
- Consent – where you agree to us using your information in this way e.g. for storing your details in relation to provision of services
- Legitimate Interests – this means the interests of Silence Speaks Ltd in managing our business to allow us to provide you with the best products and service in the most secure and appropriate way
- Legal Obligation – where there is statutory or other legal requirement to share the information e.g. when we have to share your information for law enforcement purposes.
|What we store||Our Reasons (Legal Basis)||What we use the data for|
|Name, date of birth, email, telephone number, For your security, we’ll also keep an encrypted record of your login password.||Fulfilling a contract||We need this information as a minimum in order to process your appointments and bookings|
|Email, address and telephone number||Consent (email only)||Supplying you with email Marketing communications that you have opted into to keep you informed of special offers, promotions and new events.|
|Legitimate Interests||1) Reminders and Schedule Changes: Notifying you of changes to classes that you’ve already booked such as cancellations, teacher substitutes, style changes or waitlist changes.2) Enhancements to our services: Such as changes to pricing and schedules or new services
3) Satisfaction surveys: In order to improve our service to you we’ll send you a short satisfaction survey after the sooner of your third visit or 30 days after your first visit. We’ll also send you a short satisfaction survey if you cancel a membership with us. These emails are sent by a third party called Email Octopus and Vcita and you can opt-out of these emails at any time by clicking the unsubscribe link at the bottom of any email.
We may also contact you to discuss feedback or complaints.
|Fulfilling a contract||Sending you payment invoices by email|
|Date of Birth||Legitimate interest||For health and safety reasons under 14s cannot practice yoga, (unless in a child specific class), Between the ages of 14 and 16 you can practice if accompanied by an adult|
How you heard about Silence Speaks
|Legitimate interest||Personalising and tailoring your experience with Silence Speaks. Developing products and services, that attract and retain customers. Improving customer interaction with our sites.|
|Preferred Silence Speaks location||Legitimate interest||To personalise your experience when using our online Locations|
|Your photo||Legitimate interest||This helps us ensure that your pre-paid class passes are not being used fraudulently by someone else|
|Payment card number, expiry date and billing address||Consent (we will only store these details if you ask us to)|
|If you purchase one of our services or make a booking: your purchased / booked services, receipts||Fulfilling a contract||We also use information about services bought and volumes, to help us with planning, demand forecasting, management information and research|
|Time and date of your check-ins for any bookings||Legitimate interests||To help us with planning and handling our customer contact efficiently and effectively|
|Details of your interactions with us through Our Locations. For example, we collect notes from our conversations with you, details of any complaints or comments you make, and how and when you contact us.||Legitimate interests||Keeping our records up to date, handling our customer contact efficiently and effectively|
|Health information (we only request this when you register interest to book a service)||Legitimate interests||To enable us to assess your suitability for the services and safeguard your health|
|Details of your visits to our websites or apps, including IP address, web browser and version, operating system, and which website referred you to ours.||Legitimate interests||Improving customer experience and interaction with our sites.|
Third party services and how we share your data
We use the following third party data processors, many of which are based outside the EU, but who are protected by the Privacy Shield, which allows them to store EU data on US soil with the GDPR.
- Google, California USA – We may compile statistics about the use of Our Locations using Google Analytics 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. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law. If you want to opt out, please download and install the add-on for your web browser. The Google Analytics opt-out add-on is designed to be compatible with Chrome, Internet Explorer 11, Safari, Firefox and Opera. In order to function, the opt-out add-on must be able to load and execute properly on your browser. For Internet Explorer, third-party cookies must be enabled. Learn more about the opt out and how to properly install the browser add-on here.
Where do we store your data?
All Silence Speaks client data is held in our offices in the UK, both in print and electronic format stored on our computer systems. In addition, data held with third party service providers, Vcita and Google are stored in the US, protected by the Privacy Shield that allows to store EU data on US soil with the GDPR.
How long we keep your information
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under ‘What data do we collect and how do we use it’.
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
- we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
- in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
Live streaming client sessions only
You have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
right to access – You have the right to request information about the personal data we hold on you at any time.
right to portability – Whenever We process your personal data, by automated means based on your consent or based on an agreement, you have the right to get a copy of your data transferred to you or to another party. This only includes the personal data you have submitted to us.
right to rectification – You have the right to request rectification of your personal data if the information is incorrect, including the right to have incomplete personal data completed. If you have Silence Speaks Client Portal, you can edit your personal data under your account and membership pages.
right to erasure – You have the right to erase any personal data processed by Us at any time except for the following situations:
- you have an ongoing matter with Customer Service
- you have an unsettled debt with Us, regardless of the payment method
- if you are suspected or have misused our services within the last four years
- if you have made any purchase, we will keep your personal data in connection to your transaction for book-keeping purposes
- we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible
- in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
Your right to object to processing based on legitimate interest
You have the right to object to processing of your personal data that is based on Our legitimate interest. We will not continue to process the personal data unless we can demonstrate legitimate grounds for the process which overrides your interest and rights or due to legal claims.
If you have any cause for complaint about Our use of your personal data, please contact Us at email@example.com in the first instance in order that we can investigate thoroughly. Should you find the response unsatisfactory, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office, by calling 0303 123 1113.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
By continuing to browse our site, you consent to our placing cookies on your computer (unless you have chosen to disable them via your browser). Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings but please be aware that Our Site may not work properly if you do so.
The following first party Cookies may be placed on your computer or device:Third party Cookies may be placed on your computer or device by the following companies however these are not within our control:
- Doubleclick is used for placing adverts and marketing on third party websites
- Youtube is used to provide video social media and content
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. If you’d like to learn more about cookies in general and how to manage them please visit aboutcookies.org.
Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Our Policy on The Brazillian LGPD (Lei Geral de Proteção de Dados)
The Brazillian LGPD (Lei Geral de Proteção de Dados) is a new data privacy law that will apply to businesses (both inside and outside Brazil) that process the personal data of users located in Brazil. The new law is expected to go into effect on 16th August 2020, but ongoing discussions in the Brazilian government may result in a change to the effective date. The LGPD terms will be incorporated into our existing data protection terms, so no action is required to accept the LGPD terms where the existing data protection terms already form part of your account.
|_ga||This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site’s analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.||2 years||Analytics|
|_gid||This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the wbsite is doing. The data collected including the number visitors, the source where they have come from, and the pages viisted in an anonymous form.||1 day||Analytics|
|_gat||This cookies is installed by Google Universal Analytics to throttle the request rate to limit the colllection of data on high traffic sites.||1 minute||Performance|
|____vcita_session||This cookie is installed by Vcita which is the CRM platform used for managing booking appointments and Client Portal.||1 month||CRM|
We require parental booking and consent for any/all services relating to minors and children with the same security
Information about Silence Speaks Ltd
Our Locations are owned and operated by Silence Speaks Ltd, a limited company registered in England under company number 06182067, whose registered address is 5 Dukes Piece, Buckingham, Bucks, MK18 7DA