Data and Privacy Policy for Dru websites
Summary
Dru aims to provide you with an excellent experience of safe, secure and inspirational browsing on our websites.
Under the General Data Protection Regulations you have enhanced rights over how your personal data is used, and we aim to fulfil those rights to the highest level.
This document sets out our Privacy Policy in detail. Because it has to be legally effective it is very detailed. So to make things as clear for you as possible we’ve summarised some of the highlights of our approach to protecting your data here.
Of course, our summary is intended to simply be a guide to our full policy and in the event of any conflict of meaning between the summary and full policy below, the full policy document takes precedence. Please let us know if you find any such conflicts! We will be glad to rectify them.
Your data is safe
Our website and our organisation are PCI DSS compliant, reviewed annually. Further, our website server’s security is rated A+ by ssllabs.org, the independent security review system.
We take the safety of your data very seriously and in the event of a security breach that could place your data at risk we will email you as soon as possible.
We do not pass on your data to others
Your privacy is very important to us. We are committed to ensuring that any information you provide to us is secure so we will under no circumstances sell, trade or rent any personal information that you supply to us to any third party. Your personal information may be used with third-party advertisers to create look-alike audiences or to be used for retargeting reminders. Your data will be encrypted and the third-party advertisers will not have direct access to your personal information. It’s perhaps important to note that we do on occasions use outside programmers and webservices to improve the experience of some aspects of our IT infrastructure. Such people and organisations have signed confidentiality agreements.
What we track on our websites
We use cookies to give you a smoother browsing experience. We also track user data anonymously to ensure we give the best possible experience. If you are logged in, our websites may on occasions respond to interests you’ve told us about – such as yoga, meditation, Ayurveda and more – so as to give you the most relevant information and techniques possible. We also track visitation data using tracking sites such as Meta analytics and Google Analytics. Google Analytics may collect information on your browsing history with our website if you have given consent to that within your Google settings.
How we use your data
When you provide your personal data to us, we use it for various purposes in relation to your experience with Dru. We use it to administer your event or course bookings, to manage your online courses, product purchases or memberships with us. We use it to do our best to provide you with information that you will find relevant and useful. As mentioned above, we do not share your data with others.
When we will contact you
We’ll contact you with our regular eNews emails if you have signed up for these or if you are a customer of Dru. These emails provide news, tips, techniques and inspiration from Dru. You can opt-out of them at any time using the links at the footer of these emails, contacting our offices [iikn} or in your account on our website(s).
We’ll contact you by mail, phone, sms or email in relation to events you are booked on with us. We’ll send you payment receipts, administrative information, and ask you for feedback about your experience. You can opt-out of these communications at any time, but if you do, we will be unable to contact you about your bookings.
Similarly, we may contact you in these ways in respect to other purchases you make with us.
If you are a customer, or if you have asked to receive such information, we may contact you by phone or by sms if there are upcoming events or offers that you might be interested in. You can opt out of this at any time by calling our offices, emailing us or editing your preferences in your account with us.
If you want to know what data we store with you, or want it deleted
We are committed to providing you with the data we store about you. If you would like a copy of this, please ask us in writing as described below.
We will also delete your personal information with us if you request this. Please note that we are required by law and insurance to keep records pertaining to customers for up to seven years. If you are such a customer and request your information to be deleted, we will anonymise your data to the extent permitted by law and insurance.
Dru Website privacy notice - the full policy
This website and associated systems is jointly owned by Dru (UK) Ltd and Dru Australia Ltd. For users outside of Australasia, this privacy policy applies. For customers inside Australasia we have a separate policy. Please refer to this. In general, pages that contain '/au/' in their URL apply to Australasia and so have the Australasian privacy policy.
Privacy Notice
This is the privacy notice of Dru (UK) Ltd. In this document, "we", "our", or "us" refer to Dru (UK) Ltd.
Dru (UK) Ltd is a company registered in England and Wales under company number 2273970.
Our registered office is at:
Dru (UK) Ltd, Snowdonia Mountain Lodge, Nant Ffrancon, Bethesda, Bangor, Gwynedd, LL57 3LX, UK.
Email: hello@druworldwide.com
Tel: +44 (0)1248 602900
Introduction
1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
3. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
4. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
6. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
7. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
1. Information we process because we have a contractual obligation with you
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
1.1. verify your identity for security purposes
1.2. sell products to you
1.3. provide you with our services
1.4. provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including [job opportunities and] our products and services, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us [at email address or webpage]. However, if you do so, you may not be able to use our website or our services further.
3. Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of our organisation
- responding to unsolicited communication from you to which we believe you would expect a response
- protecting and asserting the legal rights of any party
- insuring against or obtaining professional advice that is required to manage organisational risk
- protecting your interests where we believe we have a duty to do so
4. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us
5. Information provided on the understanding that it will be shared with a third party
Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.
Examples include:
5.1. posting a message our forum
5.2. tagging an image
5.3. clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks
In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do not specifically use this information except to allow it to be displayed or shared.
We do store it, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at hello@druworldwide.com.
6. Complaints regarding content on our website
Our website is a publishing medium. Anyone may register and then publish information about himself, herself or some other person.
We attempt to moderate user generated content, but we are not always able to do so as soon as that content is published.
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
7. Information relating to your method of payment
We may store information about your debit or credit card or other means of payment when you first provide it to us.
If we store this payment information it is at your request in order to make repeat purchasing of goods and services easier next time you visit our website.
We take the following measures to protect your payment information:
7.1. We immediately send your payment information with full industry standard encryption to our payment gateway providers. We do not retain this information on our servers.
7.2. We do not keep all your payment information so as:
7.2.1 to prevent the possibility of our duplicating a transaction without a new instruction from you;
7.2.2 to prevent any other third party from carrying out a transaction without your consent
7.3. We do not have access to your payment information, although our staff and our system may be able to initiate further payments on your payment information if you request it. Access to this functionality is restricted to authorised staff only.
7.4. If we ask you questions about your payment information, we only show the last four digits of the debit or credit card number, so that you can identify the means of payment to which we refer.
7.5. [Other...]
We automatically delete your payment information [after X days OR when a credit or debit card expires].
8. Information about your direct debit
When you agree to set up a direct debit arrangement, the information you give to us is passed to our own bank for processing according to our instructions. We do keep a copy.
We keep this information only for the duration of the direct debit arrangement.
We are registered under the direct debit guarantee scheme. This provides for the customer's bank to refund disputed payments without question, pending further investigation. Direct debits can only be set up for payments to beneficiaries that are approved originators of direct debits. In order to be approved, these beneficiaries are subjected to careful vetting procedures. Once approved, they are required to give indemnity guarantees through their banks.
9. Job application and employment
If you send us information in connection with a job application, we may keep it for up to [three years] in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for seven years before destroying or deleting it.
10. Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our organisation.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
11. Complaining
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
12. Affiliate and business partner information
This is information given to us by you in your capacity as an affiliate of us or as a business partner.
It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you.
The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and of the terms of our relationship.
We expect any affiliate or partner to agree to reciprocate this policy.
Use of information we collect through automated systems when you visit our website
13. Cookies
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.
When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.
If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.
We use cookies in the following ways:
13.1. to track how you use our website
13.2. to record whether you have seen specific messages we display on our website
13.3. to keep you signed in our site
13.4. to record your answers to surveys and questionnaires on our site while you complete them
13.5. to record the conversation thread during a live chat with our support team
14. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
We also track visitation data using tracking sites such as Meta analytics and Google Analytics. Google Analytics may collect information on your browsing history with our website if you have given consent to that within your Google settings.
15. Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.
Disclosure and sharing of your information
16. Information we obtain from third parties
We are committed to ensuring that any information you provide to us is secure and Dru UK will under no circumstances sell, trade or rent any personal information that you supply to us to any third party.
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. No such information is personally identifiable to you.
Your personal information may be used with third-party advertisers to create look-alike audiences or to be used for retargeting reminders. Your data will be encrypted and the third-party advertisers will not have direct access to your personal information.
17. Third party advertising on our website
On very rare occasions, third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.
They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.
We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.
18. Credit reference
To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
19. Data may be processed outside the European Union
Our websites are hosted in the United Kingdom.
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be processed outside the European Union.
For example, some of the software our website uses may have been developed in the United States of America or in Australia.
We use the following safeguards with respect to data transferred outside the European Union:
19.1. the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union
19.3. we comply with a code of conduct approved by a supervisory authority in the European Union
Access to your own information
20. Access to your personal information
20.1. At any time you may review or update part of the personally identifiable information that we hold about you, by signing in to your account on our website.
20.2. To obtain a copy of any information that is not provided on our website you may send us a request at hello@druworldwide.com.
20.3. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
21. Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact us at hello@druworldwide.com.
This may limit the service we can provide to you.
22. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Other matters
23. Use of site by children
23.1. We do not sell products or provide services for purchase by children, nor do we market to children.
23.2. If you are under 18, you may use our website only with consent from a parent or guardian
23.3. Certain areas of our website are designed for use by children over 15 years of age. These areas include events such as our youth retreats.
23.4. We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.
23.5. Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site marketing they find, wherever they visit.
24. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
25. How you can complain
25.1. If you are not happy with our privacy policy or if have any complaint then you should tell us by email. Our address is hello@druworldwide.com.
25.2. You can find further information about our complaint handling procedure at in our Terms and Conditions of Use.
25.3. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
25.4. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/
26. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
26.1. to provide you with the services you have requested;
26.2. to comply with other law, including for the period demanded by our tax authorities;
26.3. to support a claim or defence in court.
27. Compliance with the law
Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.
However, ultimately it is your choice as to whether you wish to use our website.
28. Review of this privacy policy
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
If you have any question regarding our privacy policy, please contact us.