Last Updated: September 7. 2023
In this privacy policy (“Privacy Policy”), Natural Wakefulness Center (“Natural Wakefulness Center,” “NWC,” “we,” “us,” and/or “our”) describes the types of information we collect from and about you when you use our services, whether accessed via computer, mobile device, other technology, or in person (collectively, “Services”), including:
We also describe how that information may be used, with whom it may be shared, and how you can reach us to get answers to questions you may have about our privacy practices. Finally, we also set forth certain legal rights you may have, subject to applicable law, and how you can exercise them.
Please read this policy carefully. By using the Services you (a) acknowledge that you understand and agree to the terms of this policy; and (b) consent to our collection, use and disclosure of information about you, including information that may be considered Personal Information (see below for the definition). In addition, please review our Terms of Service (available at http://www.lochkelly.org/terms-of-service), which governs your use of the Services and any content you submit to the Services (the “Terms of Service”).
If you still have any questions or concerns, please contact us at [email protected].
For purposes of this Privacy Policy, when we say “Personal Information” we mean information that specifically identifies an individual (such as a name, address, telephone number, mobile number, email address, or photograph), as well as any non-public information about that individual that is directly linked to any of the foregoing. Personal Information includes “personal data” as defined by the European Union’s General Data Protection Regulation (“GDPR”) and “personal information” as defined by the California Consumer Privacy Act (“CCPA”).
Personal Information does not include “Aggregate Information”, which is data we collect about the use of the Services or about a group or category of services or users from which individual identities or other Personal Information has been removed. Aggregate Information does not, by itself, permit the identification of individual persons.
Information You Provide to Us Directly
We collect information that you voluntarily provide in the following ways.
Information Collected When You Request a Trial or Sign In to the Mindful Glimpses App. When you request a free trial or sign in to the Apps for the first time, we require that you provide us with your email address, Apple ID, or Google ID which we use to send you a code to sign into the app. We may also ask about your interests and/or experiences, including without limitation your interest in the Apps, past meditation experience and the time of day and frequency with which you meditate.
Information Collected When You Set Up an Account and Populate Your Profile. If you create an NWC account, we give you the option to populate your profile with certain personal information (such as first and last name, the city in which you reside, and a mobile phone number). You will be required to provide your first and last name to set up an Account, but where other information is requested and indicated as optional (for example, phone number), your provision of such information is entirely voluntary and is simply offered as a way to personalize your account.
Information Collected When You Purchase a Subscription or Other Products Or Services. If you choose to subscribe to the Mindful Glimpses app, you will be required to provide your payment card information, which can include your name, card number, expiration date, security code, and billing address. If you subscribe from within our Apps, your payment card information will be collected and stored by the third-party app store you use. If you subscribe through our Website, or you make purchases of other products or services through our Website, your payment card information will be collected and stored by our third-party payment processor.
Information Collected When You Use Certain App Features. From time to time, we may offer features that require that we request additional permissions to certain aspects of your mobile device. No information will be collected unless you explicitly agree to these permissions and you can change the permissions you grant at any time using your device settings.
Information Collected When You Sign Up to Receive Newsletters or Other Email Communications from Us, Subscribe to Our Blog, or Complete a Survey. When you engage in one of these activities, we may collect your name, email address, and any additional information you choose to provide to us as part of that request (such as information about your satisfaction with our Services in response to a survey). The information you provide is used to deliver the Services you requested. We may also track your participation in any of these activities for the purpose of understanding our customers and improving our Services (such as tracking which online events you participate in to understand which events are popular).
Information Collected When You Participate in Online Events. From time to time, we may offer online events (“Online Events”, together with In-Person Events (as defined below), “Events”). If you sign up for or register for an Online Event, we may collect information about you, including your name, billing information, and email address . To enable these Online Events, we may stream video and audio feed of interactions between participants as well as the contents of any communications enabled by integrated chat functions within the third-party services, such as Zoom, which we may use to provide the Online Events. This could include collecting your image, voice, movements, physical environment, and any other information provided during the Online Event. Occasionally, we may record Online Events and make those recordings accessible to other Mindful Glimpses users and/or users of our Services. Please refer to the Event specific terms as set forth in the Terms of Service for further information on participating in and recording of Events.
Information Collected When You Participate in In-Person Events. From time to time, we may offer in-person events (“In-Person Events”). If you register for an In-Person Event, we may collect information about you, including your name, phone number, and address. We may also require you to submit answers to application questions, including question(s) about your meditation experience. Occasionally, we may record events and make those recordings accessible to other Mindful Glimpses users and/or users of our Services. Please refer to the Event specific terms as set forth in the Terms of Service for further information on participating in and recording of Events.
Information Collected When You Email Us to Ask a Question or Request Customer Service, or When You Communicate with Us Via a Third-Party Social Media Platform. When you contact us by email; through our branded social media accounts; or by telephone, SMS, or physical mail, we may collect your name, email address, phone number, physical address, and the contents of your communication which can include any information you choose to provide. We strictly use that information to provide the service or support you have requested.
Information Collected When You Share Our Services. Our Services allow you to share our Services with another person. In these cases, we will use the recipient’s email address solely to deliver the necessary information or invitation.
Information We Collect by Automated Means
We also collect certain information automatically via “cookies” and other “web-beacons” (also known as internet tags, pixel tags, tracking beacons and clear GIFs) as you navigate our Services or interact with our communications. Please see our Cookies and Other Tracking Technologies section below to learn more about what these are and how they work.
The information we collect automatically can include the following:
Information We Collect from Other Sources
We may also obtain Personal Information from other sources. For instance, we may collect Personal Information about you from:
Payment Processors. In general, when you purchase a subscription from NWC, your payment card information is provided directly to our third-party payment processor and NWC does not collect or store that information. However, we may receive limited information about your payment card such as the last four digits of your card, the country of issuance, and the expiration date.
Another Mindful Glimpses User. We may collect Personal Information from another Mindful Glimpses user if that user provides us with your email address in order to share our Services with you.
Third-Party App Stores. We may receive certain transaction information from third-party app stores such as Apple’s App Store and Google’s Play Store when you use those platforms to install our App or purchase a subscription. For instance, when you make a purchase or cancellation, we collect information about the transaction, such as the date and time of the transaction, the price paid, and the expiration date for the subscription or free trial.
Service Providers. We may also receive Personal Information from our service providers, including companies that assist with analytics, data processing and management, and other services we may use to personalize your Service experience.
We may combine the information we collect about you from these various sources. If a combination of information that we collect identifies you as an individual, we will treat the combined information as Personal Information.
We use the information described above to do the following:
We and trusted third parties use cookies and similar technologies on the website to collect and process Personal Information.
Cookies
What is are Cookies? A “cookie” is a small text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. We, and our third-party service providers, use cookies in order to do things such as recognize you when you return to our website, save your preferences (including your preferences regarding cookie handling), understand which sections and features of our Services you find most interesting, ensure our Services are working properly, and prevent fraud. We use both “session cookies” (which expire when you close your browser) and “persistent cookies” (which stay on your computer until you delete them or until they expire).
What types of Cookies are there?
Strictly necessary cookies. These cookies are essential to the functioning of a site, enabling you to move around the site and allowing the site to provide the services that you ask for. For example, a strictly necessary cookie might be used to log into secure areas of a site or to recognise the region you are in, thereby allowing the site operator to tailor the site accordingly. Strictly necessary cookies do not gather any information that could be used for marketing purposes and they do not retain information beyond the end of your visit.
Analytical/performance cookies. These cookies collect information about how visitors use a website. They allow the site operator to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps the site operator to improve the way the website works, for example, by ensuring that users are finding what they are looking for easily. All information collected by these cookies is aggregated and therefore cannot be used to identify individual visitors. The information is only used to improve how a website works.
Functionality cookies. These cookies allow a website to remember choices that a user makes and provide enhanced, more personalised features. For example, such cookies enable you to stay signed into the website and recognise you when you arrive. The information these cookies collect may be anonymised and they cannot track browsing activity on other websites.
Targeting cookies. These cookies record users’ visits to a website, the pages they have visited and the links they have followed. They are also used to ensure that users are presented with adverts, which are relevant to their interests, to limit the number of times a particular advert is displayed and to help measure the effectiveness of an advertising campaign. The information is often shared with other organisations, such as advertisers.
Managing Cookies: Enabling and Disabling
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website or the Services may become inaccessible or not function properly. Each browser is different, so check the ‘Help’ menu of your particular browser (or your mobile phone’s handset manual) to learn how to change your cookie preferences. You can also manually delete previously stored cookies at any time.
Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
Other Technologies
Certain pages on the Services may contain “web beacons” (also known as Internet tags, pixel tags, tracking beacons and clear GIFs). A web beacon is a transparent graphic image placed on a web page or in an email, which indicates that a page or email has been viewed or that an email has been forwarded. In addition, a web beacon allows third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the third party. A web beacon may also tell your browser to get content from another server.
Analytics and Advertising.
NWC also uses third-party analytics and advertising tools to measure traffic and usage trends on our Services and to serve advertisements on our behalf across the internet. These companies may use a cookie or an action tag to to tailor the advertisements you see on this website and other sites, to track your response to their advertisement, to determine whether advertising has been served and to measure the effectiveness of their advertising. These tools assist us in improving our Site and help us better understand which ads bring users to our Services. For more information about interest-based ads or to opt out of having your web browsing information used for interest-based advertising purposes, please visit https://www.aboutads.info/choices or https://www.youronlinechoices.eu.
We may share information about you with certain third parties in the following circumstances:
Companies under Common Control. We may share information between and among any current or future parents, subsidiaries, affiliates, and other companies under common control and ownership with NWC.
Third Parties Providing Services on Our Behalf. In order to carry out your requests, to make various features, services, and materials available to you through the Services, and to respond to your inquiries, we may share your Personal Information with third parties that perform functions on our behalf, such as companies or individuals that host or operate our Services, analyze data, or provide customer service.
Advertisers. We may allow advertisers and associated third parties to collect and use information they need to confirm that their ads are properly served and to measure the success of their campaigns on websites and apps. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-NWC related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. If you prefer that we do not share your personal data with third-party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 7 below.
Other Third-Party Systems, Such as the Apple Health App and Google Fit. If you choose to connect the Mindful Glimpses App to third-party systems such as Apple’s Health app or Google Fit, we will supply certain information, such as the amount of time you spend on mindfulness activities using our app to your Health app or Google Fit database. Please note that we only share information to and do not read any information from these databases. Before you tell us to share your information with another system, we encourage you to review the applicable privacy policy and terms of use for that system as any information you instruct us to share will become subject to those policies and we are not responsible for safeguarding any information stored within those systems.
Business Transfers. We may share Personal Information with another company in connection with or during negotiations of any merger, acquisition, financing, re-organization, bankruptcy, sale of all or a portion of our assets, or transition of services to another provider.
Legal Disclosure. We may transfer and disclose information, including your Personal Information, to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Service or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our Services, or the public.
Consent. We may share Personal Information with third parties with your consent and at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide that information. For instance, if you participate in an Online Event that we record and make available via our Services, we will ask for your consent to capture your image in connection with the recording and share it with other Mindful Glimpses users.
We may also share non-Personal Information, such as aggregate user statistics, demographic information, and usage information which cannot reasonably be used to identify you, for various purposes including compliance with various reporting obligations and for business or marketing purposes.
The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to use or disclose your Personal Information. To the extent those laws apply, our legal grounds are as follows:
Legitimate Interest. In most cases, we handle Personal Information on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
Legal Compliance. We need to use and disclose Personal Information in certain ways to comply with our legal obligations.
To Honor Our Contractual Commitments to an Individual. Some of our processing of Personal Information is to meet our contractual obligations to the individual to whom the Personal Information pertains.
Consent. Where required by law, and in some other cases, we handle Personal Information on the basis of implied or express consent. For instance, in relation to direct marketing, we will obtain and rely on your consent in relation to the processing concerned.
You have a variety of rights and choices related to our use of your Personal Information.
Opting Out of Email Marketing. You can opt out of receiving our promotional emails at any time by following the instructions included in those emails. Please be aware that it may take up to 10 days for us to process your request, and you may continue receiving promotional communications from us during that period. If you opt out of receiving such communications, please be aware that we may continue to send you non-promotional emails (such as emails related to our business relationship or emails about changes to our legal terms).
Restricting Cookies/Do Not Track. Our Services are not currently designed to respond to web browser “do not track” signals. However, you can configure most browsers to reject cookies or to notify you when you are sent a cookie, giving you a chance to decide whether or not to accept it. You can consult the help section of your browser to find out how to do this. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. In the event that a universally accepted standard emerges on how organizations should respond to “do not track” signals, we will assess and provide an appropriate response to those signals.
Limiting Information in Your Profile. You can control the information we collect about you by limiting the information you provide through your profile.
Accessing, Updating, or Deleting Your Information. If you would like to access, update, or delete Personal Information you have provided you may do so by emailing us at [email protected]. Please note that if you choose to close your account, we may keep certain Personal Information as necessary to comply with our legal obligations or for legitimate business purposes, such as to resolve disputes or enforce our agreements. We may also keep cached archived copies of Personal Information for a certain period of time.
Disabling Push Notifications. With your consent, we may share push notifications or alerts to your mobile device. We use push notifications to inform you of important updates and to send you meditation reminders. You can manage or deactivate these notifications at any time by turning off the notifications setting in the app or by disabling notifications through the device settings on your mobile device. If you choose not to receive push notification, you will still receive in-app notifications in the “Notifications” section of the app.
Limiting Device Permissions. With your consent, we may access your mobile device’s camera, microphone, or storage features. However, we will never import any photos or audio files other than those you explicitly choose to share. At any time, you can turn off these features using the device settings of your mobile device.
Data Requests. Certain privacy laws, including the GDPR, UK GDPR, and the CCPA provide users with rights related to their Personal Information. Depending on your location, you may be eligible for a number of rights with respect to your information.
If you are in the EU or the UK, you also have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the EU where you are habitually resident where we are based or where an alleged infringement of data protection law has taken place.
The CCPA provides California residents with the following additional rights:
Limiting use of, or deleting, your Personal Information may affect features and uses that rely on that information. However, we will not discriminate against you for exercising any of your rights, including otherwise denying you goods or services, providing you with a different level or quality of services, or charging you different prices or rates for services.
We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. Before responding to your request, we may require that you provide us with additional information to confirm your identity. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government-issued identification. We may verify the authenticity of the request directly with you. You also have the right to lodge a complaint with the authorities applicable to your situation. However, we invite you to contact us with any concern, as we would be happy to try to resolve it directly.
Notice of Collection: In addition to the rights and choices described above, the CCPA requires disclosure of the categories of Personal Information collected over the past 12 months. While this information is covered in greater detail in Section 2, “Information Collected on Our Services” above, the categories of Personal Information that we have collected – as described by the CCPA – are:
Business or Commercial Purpose for Collecting and Using Personal Information. We collect each category of Personal Information listed above for the business or commercial purposes described in Section 3, “How We Use the Information Collected” above.
Categories of Sources of Personal Information. We collect each category of Personal Information listed above directly from you, through automatic data collection means, or through the third-party sources described in Section 2, “Information Collected on Our Services” above.
Categories of Personal Information Disclosed. In the preceding 12 months, we have disclosed the categories of Personal Information listed above in the circumstances described in Section 4, “What Personal Information Do We Share with Third Parties” above.
Shine the Light. California Civil Code § 1798.83, also known as the “Shine The Light” law, permits California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Information in the immediately preceding calendar year. NWC does not share Personal Information with third parties for their direct marketing purposes.
We may provide links to third-party websites, services, and applications that we do not own or operate. This Privacy Policy does not apply to the privacy practices of those third parties. The fact that we link to a website, service, or application is not an endorsement, authorization, or representation of our affiliation with that third party. We encourage you to review the privacy policies of any third-party service before providing any Personal Information to or through them.
We maintain generally accepted administrative, technical, and physical safeguards to help protect against loss, misuse or unauthorized access, disclosure, alteration, or destruction of your Personal Information. However, there is always some risk involved in transmitting information over the internet and storing information electronically. Please note that NWC cannot and does not guarantee absolute security.
We only keep your Personal Information for so long as reasonably necessary for the purposes described in this Privacy Policy, as required by law, or as necessary to resolve disputes and enforce our rights and agreements. To dispose of Personal Information, we may anonymize it, delete it, or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.
Personal Information we collect may be stored and processed for the purposes set out in this Privacy Policy in the United States where we are based or in any country where we have operations or where we engage vendors or service providers. To the extent permitted by law, by using the Services, or providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to, those in the country where you reside.
Our Services are directed at adults and we do not knowingly collect Personal Information from children. If you are a parent or legal guardian and think your child under 13 (or a higher age threshold where applicable) has given us Personal Information without your consent, please contact us at [email protected].
We may change this Privacy Policy from time to time to reflect changes in our practices or in the law. If we make changes to this policy, we will post the updated Privacy Policy on our website and indicate when it was last revised. You are advised to review this policy periodically to stay informed of our practices. If we make material changes, we may provide you with additional notice, such as posting a statement on our homepage or sending you an email notification, if we have your email address on file. Your continued use of the Services after the revised Privacy Policy has become effective indicates that you have read, understood, and agreed to the current version of this Privacy Policy, to the extent permitted by law.
If you have any questions about our Privacy Policy or how we protect your Personal Information, please contact us at [email protected] or you may write to us at:
Natural Wakefulness Center
P.O. Box 122
Stone Ridge, NY 12484
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