Harlow is committed to complying with the General Data Protection Regulation and the Data Protection Act 2018.  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 an individualised experience. 

This policy is to help you understand: 

  • how and why Harlow collects information from you
  • who Harlow shares your information with, why and on what basis
  • what your rights are

If we make changes to this policy we will update you on our website and by sending you an email notification. You will be deemed to have accepted the terms of the Privacy Policy on your first use of Harlow following the alterations.  

Should you have any questions about this policy please write to us at bookings@harlow.london

This policy was last updated on the 28th of May 2019. 

Definitions and Interpretation 

In this Policy, the following terms shall have the following meanings: 

Our Locations - Includes Online channels: https://harlow.london 11 Lambton Place W11

Our Site - Refers to www.harlow.london

 

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”); 

When do we collect your personal data? 

  • When you create an account at Harlow
  • When you book a service a Harlow 
  • When you engage with us on social media
  • When you contact us by any means with queries, complaints or to send us your CV for a job application
  • When you enter prize draws or competitions
  • When you choose to complete any feedback requests or surveys we send you
  • When you’ve given a third party permission to share with us the information they hold about you
  • When you use the centre which has CCTV systems operated for the security of both guests, members, team and the general public. 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 bhuti, 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 sign up as a member.
  • Consent – where you agree to us using your information in this way e.g. for storing your payment card details.
  • Legitimate Interests – this means the interests of Harlow 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, confidential health information (for your security, we’ll also keep an encrypted record of your login password)  Fulfilling a contract We need this information as a in order to process your orders and bookings
  Consent Contacting with you via email or text regarding relevant information, bhuti news, events, and offers. 
Email/mobile  Legitimate Interests Notifying you about alterations to our services, such as changes to pricing and schedules, updates to our environmental policy or new services Contacting you to request feedback and undertake guest satisfaction surveys 
  Fulfilling a contract  Sending you payment invoices by email 
Date of Birth  Legitimate interest  For health and safety reasons under 13s cannot practice yoga, (unless in a child specific class), Between the ages of 14 and 16 you can practice if accompanied by an adult
Gender 
How you heard about bhuti 
Legitimate interest  Enhancing bhuti’s offering Developing products and services, that best serve our community and using relevant channels to communicate this with them. 
Your location  Legitimate interest  To understand from where our guests and members are coming from so we can best serve our community  
Your photo  Legitimate interest  This helps us ensure that we can recognise you as a guest or member so we can welcome you accordingly and also keep your account private to you. 
Payment card number, expiry date and billing address Consent (we will only store these details if you ask us to)  For ease of payment and recurring membership fees. 
A record of your purchases and bookings  Legitimate Interests  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 guest contact efficiently  
Details of your interactions with us .e.g , we may collect notes from our conversations/consultations with you, details of any complaints or comments you make, and how and when you contact us.  Legitimate Interests  To ensure we best serve you offering the correct advice relevant to your current situation and that we improve our products and services. 
Health information and emergency contact   Legitimate interests  To enable us to assess your suitability for the services and safeguard your health. For instructors to be aware of any injuries and that we can contact someone in an emergency 
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 site. 

 

 

 

Third party services and how we share your data 
We contract with third parties to supply products and services to you on Our behalf. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority. 

We use the following third party data processors who 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. 

Acuity   – we use Acuity online for web scheduling, registration, order processing and online payments 

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 

Where do we store your data? 
Your data will be stored in the UK with all  Acuity & Mailchimp Online data . 

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.

Your rights 
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 a bhuti or Mind Body account 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
  • your debt has been sold to a third party within the last three years or one year for deceased customers
  • 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 be@bhuti.co 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. 

Our use of cookies 
Cookies are small encrypted text files that are stored on your device by a website. We use cookies to enhance your shopping experience and to analyse our traffic. We don’t store personal information in the cookies we create, but personal information that we store about you may be linked to the information stored in and obtained from cookies. 

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.