LAST UPDATED: June 1, 2018

Life Creation Inc., dba DHARMI® Method (the “Company”) is concerned about privacy issues and wants you to be familiar with how it collects, uses and discloses your Personal Information. This policy covers the Company websites (the “Websites“) and Services (as defined below) and is applicable to the Company. This Privacy Policy informs you as to how the Company looks after your Personal Information and tells you about your privacy rights and how the law protects you. By providing Personal Information to us, you agree to the terms and conditions of this Privacy Policy.

Important Information

This Privacy Policy aims to give you information on how the Company collects and processes your Personal Information through your use of its Websites and Services, including any data you may provide through the Websites when you sign up to the Company’s newsletter, make a reservation or take part in an event.

The Company’s Services do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing your Personal Information so that you are fully aware of how and why we are using your Personal Information. This Privacy Policy supplements the other notices we may provide to you and is not intended to override them.

Controller

The Company is the controller and is responsible for your Personal Information.

Contact Us

Full name of legal entity: Life Creation Inc.
Email address: info@dharmi.com
Tel: +1 786.529.5588

We would appreciate the chance to deal with your concerns before you approach the ICO so please do contact us in the first instance at info@dharmi.com.
Though, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
PERSONAL INFORMATION

Personal Information We Collect

Personal Information” is information that identifies you as an individual or relates to an identifiable person, including:

  • Identity Data which includes: first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data which includes billing address, delivery address, email address and telephone numbers.
  • Financial Data which includes payment card details.
  • Transaction Data which includes details about payments to and from you and other details of products and services you have purchased from us.
  • Profile Data which includes your username and password, profile picture, reservations, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data which includes information about how you use our Websites, products and Services (as defined below).
  • Marketing and Communications Data which includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Third Parties

We may use a third-party payment service to process payments made through the Services.  It is our policy to only share Personal Information with contractors, service providers and other third parties who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.  If you wish to make a payment through the Services, your Personal Information may be collected by such third party and not by us and will be subject to the third party’s privacy policy, rather than this Privacy Policy.  We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Information.

We may also disclose your Personal Information to a third party when you ask us to do so or when we believe it is required by law.

If you submit any Personal Information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

How We Collect Personal Information

This Privacy Policy describes our practices in connection with Personal Information that we collect through the Websites operated by us from which you are accessing this Privacy Policy, through the software applications made available by us for use on, or through, computers and mobile devices, through HTML-formatted email messages that we send to you that link to this Privacy Policy.

We may collect Personal Information through the services we may collect Personal Information through the Services, sign-up or opt-in as a subscriber to DHARMI Method programs and experiences.

How We Use Personal Information

We will only use or disclose your Personal Information when the law allows us to. Most commonly, we use or disclose your Personal Information in the following circumstances:

  • where we need to perform the contract we are about to enter into or have entered into with you;
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
  • where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your Personal Information, other than in relation to sending direct communications to you via email or text message. You have the right to withdraw consent to email campaigns and other form of communication at any time by contacting us at info@dharmi.com

Please note that if, in the event we rely on your consent to process your Personal Information, you withdraw your consent we may no longer be able to provide you with: (a) updates and promotions; (b) the best user experience possible to our Services; (c) the best customer experience.

We have set out below a description of all the ways in which we plan to use your Personal Information:

  • to respond to your inquiries and fulfill your requests, such as to send you inspirational messages, news and updates;
  • to send administrative information to you, such as information regarding the Services and changes to our terms, conditions and policies;
  • to complete and fulfill your booking or other purchase, including, for example, to process your payment, communicate with you regarding your purchase and provide you with related customer service;
  • to send you marketing communications that we believe may be of interest to you;
  • to contact you with respect to any membership and/or billing inquires;
  • to personalize your experience on the Services by presenting products and offers tailored to you;
  • to allow you to participate to our programs for your wellbeing;

How We Disclose Your Personal Information We will only disclose your Personal Information when the law allows us to. Most commonly, we disclose your Personal Information in the following circumstances:

  • to our third party service providers who provide services such as website hosting, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other services. For example, we may use Google Analytics and others to provide analytics;
  • by you, on message boards, chat, profile pages, blogs and other services to which you are able to post information and materials.  Please note that any information you post or disclose through these services will become public and may be available to other users of the Services and to the general public.  We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Services;
  • to your friends associated with your social media account, to other users of the Services and to your social media account provider, in connection with your social sharing activity, such as if you connect your social media account to your Services account or log into your Services account from your social media account. By connecting your Services account and your social media account, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s own privacy policy.  If you do not want your Personal Information shared in this way, do not connect your social media account with your Services account, and do not participate in social sharing on the Services.
  • as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, and/or that of you or others.

OTHER INFORMATION

How We May Collect Other Information / Online Tracking

We may collect Other Information in a variety of ways, including:

  • Through your browser or device:  Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using.  We use this information to ensure that the Services function properly.
  • Using cookies: Cookies are pieces of information stored directly on the computer that you are using.  They allow us to collect information such as browser type, time spent on the Services, pages visited, your location, language preferences and anonymous traffic data.  We use the information for such purposes as security, to facilitate navigation, to display information more effectively, to personalize your experience, to understand how the Services are used, to improve the Services and to assist us with resolving questions regarding them.  Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services.  We may also use cookies to track responses to our online advertisements.
  • http://www.networkadvertising.org/choices/.We use Google Analytics, which uses cookies and other, similar technologies to collect information about use of the Services and reports website trends, without identifying individual visitors.  You can learn about Google’s practices and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

How We May Use and Disclose other information

We may use and disclose other information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat other information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.

We may combine other information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

CHOICES AND ACCESS

Your choices regarding our use of your Personal Information

You may opt out from receiving electronic communications from us.  If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out of receiving them by following the instructions contained in each such message.

We will try to comply with your request as soon as reasonably practicable. If you opt-out, we may still send you important administrative messages, from which you cannot opt-out.

How you can access, change or suppress your Personal Information

If you would like to review, correct, update, suppress or delete Personal Information that you have provided to us, contact us at the address below.  In your request, please make clear what Personal Information you would like to have changed, whether you would like to have the Personal Information you have provided to us suppressed from our database, or otherwise let us know what limitations you would like to put on our use of the Personal Information you have provided us.  For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.  There may also be residual information that will remain within our databases and other records and which will not be removed.

RETENTION PERIOD

We will retain your Personal Information for the period necessary to provide the Services. Processing is therefore necessary for the purposes of our legitimate interest, unless a longer retention period is required or permitted by law.

YOUR LEGAL RIGHTS

You have rights under data protection laws in relation to your Personal Information: You have the right to:

  • Request access to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

In respect of exercising your rights, please note:

No fee usually required. 

You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy.  The “LAST UPDATED” legend at the top of this page indicates when this Privacy Policy was last revised.  If there are any material changes to this Privacy Policy or our information practices change in the future, we will notify you by posting the changes to the Website. Any changes will become effective when we post the revised Privacy Policy on the Services.  Your use of the Services following these changes means that you accept the revised Privacy Policy.