Política de privacidad

Last updated: May 2019

Welcome to www. DharmaSun.org (the “Platform”). The Platform is provided and controlled by Ka-Nying Shedrub Ling Development Trust (“we” or “us”). We are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. By accessing or using our website, services, applications, products and content (that include but are not limited to the Platform) (collectively, the “Services”), you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it. If you do not agree with this policy in general or any part of it, you should not use our Services. Capitalized terms that are not defined in this policy have the meaning given to them in the Terms of Service.

Our representative in the EU and also for the rest of the world is Michael Eisenbach and our contact details are: Lainzerstrasse 105, 1130 Vienna, Austria.

If you have any questions about how we use your personal data or about data protection in general, please contact privacy@dharmasun.org.

SUMMARY
What information do we collect about you?

We process information when you create an account and use the Platform, including your name, country, email address, language selection, and content you create. We also collect technical and behavioural information about your use of the Platform.

How will we use the information about you?

We use your information to fulfil and enforce our service contract with you, to improve and administer the Platform and allow you to use its functionalities. We also use your information to, among other things, send you newsletters or other promotional materials.

Who do we share your information with?

We share your data with our third party service providers we rely on to help us provide you with the Platform. These providers include cloud storage providers, hosting service providers, analytics providers, newsletter provider and other IT service providers. We may also share your information with law enforcement agencies, public authorities or government bodies as required by law.

Your Rights

You may have rights in relation to your information.

How long do we keep hold of your information?

We retain your information for as long as it is necessary to fulfil (1) our contractual obligations and rights in relation to the information involved, (2) our legal obligation(s) under applicable law(s) and regulations to retain data for a certain period of time, taking into account statute of limitations under applicable law(s); (3) our legitimate business purposes; (4) and to conduct a defence in relation to disputes or potential disputes.

How will we notify you of any changes?

We will generally notify all users of any material changes to this policy, through a notice on our Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of the Services after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.

1. The types of personal data we use
We may collect and use the following information about you:

– Information you give us. You give us information about you when you register for and/or use the Platform, including your name, country, email address, as well as your language selection. In addition, this category will include your PayPal or other third-party payment channel account where required for the purpose of making or receiving payments. It also includes user-generated content, photographs and other content that you choose to broadcast on our Platform, such as your user avatar.

– Technical Information we collect about you. We automatically collect certain information from you when you use the Platform, including your IP address, Cookies (as defined below), and user agent.

– Behavioural information we collect about you. We also collect information regarding your use of the Services, e.g. your course registration and completion records, your study progress, and your comments posted on the Forum or any other user-generated content that you generate through and broadcast on our Platform. In addition, we link your contact or subscriber information with your activity on our Platform across all your devices using your email log-in details.

2. Cookies
We use cookies and other similar technologies (e.g. pixels etc.) (“Cookies”) to enhance your experience using the Platform. Cookies are used to indirectly collect information, including personal data, from you. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

We use the following Cookies

– Strictly necessary Cookies. These are Cookies that are required for the operation of the Platform. They include, for example, Cookies that enable you to log into secure areas of the Platform.

– Functionality Cookies. These Cookies are used to recognise you when you return to the Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). These Cookies support the log-in function in the Platform for a 90 day period.

– Analytics Cookies. Analytics Cookies are statistical audience measuring systems that our analytics providers use to help us measure which web pages you click on and how you use the Platform (see below for more details).

If for any reason you do not wish to take advantage of Cookies, you can disable Cookies by changing the settings on your browser. However, if you do so, this will affect your enjoyment of the Platform and we will no longer be able to offer to you personalised content. Unless you opt out of Cookies, we will assume you consent to the use of Cookies.
“Do-not-track” signals are preferences that users can set on their web browser to limit how their activity is tracked across third-party websites or online services. The Platform does not respond to «do-not-track» signals in your web browser.

 

Analytics information

On our Platform, we use third-party analytics tools to help us measure traffic and usage trends for the Services. Traffic refers to the different data flows surrounding activities of the users on the Services. These tools, for example, collect information sent by your device or our Services, including the pages you visit, add-ons, and other information that assists us in improving the Service. The information will be used to report and evaluate your activities and patterns as a user of the Platform to provide services in accordance with these activities.

Our third party analytics tool is Google Analytics provided by Google, Inc (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). Google Analytics uses Cookies, small text files containing a string of alphanumeric characters and which are stored on your computer. Google will use this information including your truncated IP address to assemble statistics on the use of our Service or to provide other related services as described above. For further information on how Google Analytics collects and processes information about you and information on how to opt out from Google’s collection of information from you, please click here. You can also find further information in the Google Analytics Terms of Service & Privacy.

We further use «Facebook Pixel» of Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA («Facebook»). This tool is used for advertising purposes in order to reveal if you have seen our advertisement on Facebook. If you do not want Facebook to collect the described information about you, you can opt-out of Facebook’s use of cookies and Facebook Pixels here.

 

3. How we use your personal data
We will use the information we collect about you in the following ways:

– In accordance with, and to perform our contract with you, we will use your information to:

– – give you access to specific programs on the Platform;

– – notify you about new content on the Platform and upcoming events that may be of interest to you;- notify you about changes to our service;

– –  provide you with user support;

– –  enforce our terms, conditions and policies;

– – receive payments from you and/or make payments to you in accordance with the Terms of Services through a third party payment channel such as Paypal; or

– –  communicate with you.

– As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our products and organisation, we will use your information to:

– –  Improve and develop the Platform and to ensure content from the Platform is presented in the most effective manner for you and your device and conduct product development;

– –  administer the Platform (i.e. to improve our Website and services to you) and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes (i.e. to guarantee the website’s stability and security) and to solicit your feedback;

– –  allow you to participate in interactive features of the Platform, i.e., the Forum, when you choose to do so;

– –  keep the Platform safe and secure;

– –  to provide you with services based on the language settings you have chosen, such as programs, events, and other content that is related to the language settings;

 

4. How we share your personal data

We will share your personal data and other information with the following selected third parties:

– cloud storage providers to store the information you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you;

– IT service providers who we use to for a range of services including IT support, and a newsletter service provider which is registered in Belgium;

– Analytics and search engine providers that assist us in the optimisation and improvement of the Platform; and

– our data centre and the servers of our host provider, which is registered in Germany.

We will also share your information with our affiliate, Rangjung Yeshe Gomde Scotland, a charity registered in Scotland (SC040361), only for our internal business purposes.

Where we transfer your personal data to countries outside the EEA, we do so under the Commission’s model contracts for the transfer of personal data to third countries (i.e. standard contractual clauses) pursuant to 2004/915/EC or 2010/87/EU (as appropriate) For a copy of these Standard Contractual Clauses, please contact us at privacy@dharmasun.org.

We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if such use is reasonably necessary to:

– comply with legal obligation, process or request;

– enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;

– detect, prevent or otherwise address security, fraud or technical issues; or

– protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

 

5. Where we store your personal data

The personal data that we collect from you will be transferred to, and stored at the servers of our host provider, which is a company registered in Germany, with the only exception of user avatar (if you choose to upload one). The user avatar may be transferred to, and stored at our cloud storage, a destination outside of your country and the European Economic Area («EEA«). Further information regarding the transfer of data outside of the EEA is available. Please contact us at privacy@dharmasun.org if you have any questions.

6. Your Rights

In certain circumstances you have the right to access the personal data that we hold about you and to correct, update, or request deletion your personal data. Prior to the fulfilment of your request concerning your personal data, we will ask you to verify your identity before we can act upon your request.

You have the following rights:

– The right to require free of charge (i) confirmation of whether we process your personal data and (ii) access to a copy of the personal data retained;

– The right to request proper rectification, removal or restriction of your personal data;

– Where processing of your personal data is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the personal data concerning you in a structured, commonly used and machine-readable format or to have your personal data transmitted directly to another company, where technically feasible (data portability);

– Where the processing of your personal data is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question;

– The right not to be subject to any automatic individual decisions which produces legal effects on you or similarly significantly affects you; and

– The right to take legal actions in relation to any breach of your rights regarding the processing of the personal data, as well as to lodge complaints before the competent data protection regulators.

As far as we process your personal data on the basis of our legitimate interests, you can object to processing at any time. You can find a detailed description of our processing activities and the legal basis in the sections above. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your personal data and decide whether to adjust the processing accordingly.

Please send an e-mail to us if you would like to exercise any of your rights privacy@dharmasun.org.

 

7. The security of your personal data

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

 

8. How long we keep your personal data

We use the following criteria to determine the period for which we will keep your personal data:

– our contractual obligations and rights in relation to the information involved;

– legal obligation(s) under applicable law(s) to retain data for a certain period of time; and

– disputes or potential disputes.

After you have terminated your use of our Services, we can store your information in an aggregated and anonymised format. Notwithstanding the foregoing, we can also retain any personal data as reasonably necessary to comply with our legal obligations, allow us to resolve and litigate disputes, and to enforce our agreements.

 

9. Information relating to children

The Platform is not directed at children under the age of 18. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at privacy@dharmasun.org.

 

10. Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at privacy@dharmasun.org and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority or follow the Dispute Process.

 

11. Changes

We will generally notify all users of any material changes to this policy, through a notice on our Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of the Services after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.

 

12. Contact

Questions, comments and requests regarding this policy should be addressed to privacy@dharmasun.org.