PRIVACY AND COOKIES POLICY
Updated: November 18, 2024
Introduction
Puti Meditation College (Canada) Ltd. (“Company” / “we” / “our” / “us”) respects your privacy and is committed to protecting your personal data. This Privacy and Cookies Policy will inform you as to how we look after your personal data when you visit our Site: https://www.PutiCollege.com (the “Site”) (regardless of where you visit it from), any associated mobile application, application programming interfaces, products, other services, and content including text, graphics, videos and images offered by Puti Meditation College (Canada) Ltd., Bodhi Tree Productions Ltd., Taiwan Shan Porsche Co. Ltd., Ba Bao Wisdom Sdn. Bhd., and GrandMaster JinBodhi through the Site and associated mobile application or application programming interfaces (collectively, the “Services”) and will tell you about your privacy rights and how the law protects you.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information where we have your consent, where we need to perform the contract we have entered into with you, where we need to comply with a legal obligation or 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.
Throughout this Privacy and Cookies Policy, terms “you” and “your” refer to an adult user, as well as Child or Teenager (defined below) user as supervised by their parent or guardian.
1. IMPORTANT INFORMATION AND WHO WE ARE
1.1 Purpose of this Privacy and Cookies Policy
This Privacy and Cookies Policy (together with the Terms of Use and the Sales Terms) sets out the basis on which any personal data we collect from you when you interact with us or that is provided by you through your use of the Site and the Services. If you do not consent to our use or collection of your personal information, please do not use this Site or the Services.
It is important that you read this Privacy and Cookies Policy together with any other privacy and cookies policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data.
1.2 Our data privacy officer
We have appointed a data privacy officer who is responsible for overseeing questions in relation to this Privacy and Cookies Policy. If you have any questions about this Privacy and Cookies Policy, including any requests to exercise Your Legal Rights, please contact the data privacy officer by email at privacy@puticollege.com.
1.3 Third-party Links
The Site and associated mobile application, application programming interfaces may include links to third-party sites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party sites and we are not responsible for their privacy statements. When you leave our Site or associated mobile application, application programming interfaces, we encourage you to read the privacy and cookies policies of every site you visit.
2. THE DATA WE COLLECT ABOUT YOU
2.1 The Types of Information We Collect
In this Privacy and Cookies Policy, “personal data”, or “personal information”, means information that can identify an individual or information about an identifiable individual. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name and last name (including name in foreign language i.e. Chinese name), Bodhi Dharma Name (if applicable), date of birth, verification photograph, image or likeness, username or similar identifier, title, and company details.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from through our Site (including classes, class credits, subscriptions).
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Site.
- Profile Data includes your username and password, your interests and preferences, languages spoken, place of residency, highest level of education, highest academic certificates, employment history, volunteer work experience, reason for attending the classes and goals, Bodhi Meditation Programs Attended, daily meditation time, feedback and survey responses.
- Usage Data includes information about how you use our Site, the Services, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences, topics of interests.
- Course Data is collected only when you subscribe for the Services and includes classes, assignments and quizzes you have started and completed, class purchases and credits, subscriptions, course certificates, your exchanges with instructors, teaching assistants, and other students, and answers to questions, and other items submitted to satisfy class requirements.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not and cannot not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site or Service feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy and Cookies Policy.
Generally we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, with your consent, when you enroll in higher level classes, we will collect limited information about your health and fitness levels to assess what classes are appropriate for you.
2.2 If You Fail To Provide Personal Data
Where we need to collect personal data by law, or under the terms and conditions of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel an order you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED
We may collect your personal information through: (i) direct communication when you fill our forms or correspond with us by post, phone, email or otherwise; (ii) as you interact with our Site, we will automatically collect technical data about your equipment, browsing actions and patterns; (iii) we may receive your personal information from various third parties including analytics providers, advertising networks, search information providers, providers of technical, payment and delivery services, other publically available sources.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data for the following purposes:
- To perform the contract we are about to enter into or have entered into with you, or provide you with goods, Service or information.
- 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.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal information although we will get your consent before sending direct marketing communications to you via email.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact privacy@puticollege.com.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity |
Type of Data |
Lawful basis for processing including basis of legitimate interest |
To register you as a new user of the Site and the Services with the Same Sign-On account, and provide you with updates regarding your account |
Identity Contact Profile |
Performance of a contract with you* *Shared with third-party service providers and other Bodhi Meditation Centers for verification purposes and enable access to the services |
To enable you to browse the products and services on the Site and associated mobile application, application programming interfaces |
Technical Usage |
Necessary for our legitimate interests (to make the Site available to browsers) |
To process and deliver your order(s) including:
|
Identity Contact Financial Transaction Marketing and Communications Course |
Performance of a contract with you* Necessary for our legitimate interests (to recover debts due to us) *Shared with third-party payment processor |
To make suggestions and recommendations on what class is appropriate for you |
Identity Contact Course Profile Special Categories of Personal Data: health and fitness level* |
With your consent* Assessment of your fitness level to select a class appropriate for you* Performance of contract with you *Only applicable for students who wish to enroll in higher level paid for classes |
To send you marketing emails about Company’s products, services and offers |
Marketing and Communications Contact |
With your consent |
To make suggestions and recommendations to you about goods or services that may be of interest to you |
Identity Contact Technical Usage Profile Marketing and Communications Course |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
To manage our relationship with you which will include:
|
Identity Contact Profile Marketing and Communications Course |
Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To administer and protect our business and this Site and associated mobile application, application programming interfaces (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
Identity Contact Technical |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and for use in the context of a business reorganisation or group restructuring exercise) Necessary to comply with our legal obligations |
To deliver relevant Site content, Services and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
Identity Contact Profile Usage Marketing and Communications Technical Course |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our Site, products/Services, marketing, customer relationships and experiences |
Technical Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy) |
To enable us to monitor your browsing habits by placing cookies onto your device |
Technical |
With your consent |
To enable us to provide you with access to our social media channels such as Facebook, Instagram, LinkedIn or Twitter |
Identity Contact Technical Course |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
5. ELECTRONIC COMMUNICATIONS
We comply with Canada’s anti-spam legislation (CASL) and we will not send you electronic communications in contravention of this law.
We will ensure that each e-mail includes an opt-out feature and instructions on how to un-subscribe if you no longer wish to receive future e-mails from us. You have the right to withdraw consent to electronic communications at any time by contacting us at privacy@puticollege.com.
6. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal information with the parties and for the purposes set out below:
- Internal Third Parties, means other organizations that provide us with IT system administration services, or other technical or web-site platform services required for the Site for the purpose of provision and receipt of such services.
- External Third Parties, which include (a) service providers (for example, IT services), business partners, suppliers and sub-contractors for the performance of any contract we enter into with you, but also when providing you with marketing communications, analytics and search engine providers that assist us in the improvement and optimisation of the Site; (b) professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services for the purpose of provision and receipt of such services; (c) payment processing providers, including Stripe, Inc. or any other payment processing provider as appointed by Company from time to time; (d) other Bodhi Meditation Centers; (e) government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include requirement to share your location information).
- Third parties to whom we may choose to sell, transfer or merge parts of our business, organization or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our organization, then the new owners may use your personal information in the same way as set out in this Privacy and Cookies Policy.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
7. INTERNATIONAL TRANSFERS
To provide you the Site and our Services, we may share your personal data within the Internal Third Parties and External Third Parties located in and outside of Canada, including Internal Third Parties located in Taiwan. These third parties may store, process and transfer your personal information on servers located outside of Canada in jurisdictions whose data protection laws may differ from those of Canada. As a result, your personal information may be subject to access requests from governmental authorities or law enforcement bodies in jurisdictions outside Canada according to the laws in those jurisdictions.
By visiting our Site or using our Services, you consent to storage of your data on servers located in and outside Canada. If you are visiting our Site or using the Services from outside Canada, you consent to the transfer, storage, and processing of your data to and from Canada or other countries. Specifically, personal data collected in the United States of America (“US”), United Kingdom (“UK”), Switzerland, and the European Economic Area (“EEA”) is transferred and stored outside those areas. Additionally, if you are located in the EEA, US, UK, or Switzerland, you also have the right to lodge a complaint with your data supervisory authority.
Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require our Internal Third Parties and External Third Parties to maintain protections on your personal information that are equivalent to those that apply in Canada.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out Canada.
8. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. POLICY CONCERNING CHILDREN AND TEENAGERS
For the purpose of this Privacy and Cookies Policy:
(a) the term “Teenager” refers to someone who is above the required age for consent to use online services where they live (for example, 13 years of age in the USA and Canada or 16 years of age in Ireland), but has not yet reached the adult age (for example, at least 19 years of age in Canada) in their province or territory of residence;
(b) the terms “Child” or “Children” refer to someone who is below the age of a Teenager in their province or territory of residence.
This Privacy and Cookies Policy does not apply to Teenagers living independently of their parents or guardians and who by federal, provincial or territorial statute or regulation are deemed to be adults.
We encourage parents and guardian to be aware of and participate in their Children’s and Teenagers’ online activities. Parents are requested to review this Privacy and Cookies Policy and discuss its main features with their Children and Teenagers, in a manner that the Child or Teenager will understand. Children may not use the Site or the Services unsupervised and we ask that you do not allow your Child to submit any personal information to us. We do not knowingly collect the personal information of Children. If you believe your Child has provided personal information, and you would like it deleted, please contact our privacy officer at privacy@puticollege.com. Teenagers may use the Site and free Services, but may not set up an account. Teenagers may set up an account and enroll in paid Services only with consent and under supervision of their parent or guardian. You can withdraw your consent to our collection, use and disclosure of your Teenager’s personal data by contacting us at privacy@puticollege.com.
10. DATA RETENTION
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your personal information: see Your Legal Rights below for further information.
11. COOKIES NOTICE
Our Site uses cookies and/or other further identifiers (such as pixel or tag). Certain cookies and identifiers are conveyed and controlled by us directly. We collect and process your personal information by means of these cookies and identifiers. To the contrary, other cookies and identifiers are conveyed and controlled by third parties, over which we have no control. We hereby invite you to read such cookies policies of the third parties carefully.
11.1 What cookies are
Like most organisations, Company uses cookies to capture information about our Site’s users. A cookie is a small file of letters and numbers that we save to your computer or device. Cookies allow us to recognise and count your visits, and to see how you move around our Site while you are using it. This helps us to provide you with a good experience while you browse and to improve the way our Site works, for example by making sure you can find what you need.
The cookies may have a duration limited to a single session of navigation on the browser (called session cookies), and, in such event, they deactivate automatically once the browser is closed by the user; or may have a predetermined duration and, in such event, they will remain memorised and active on your hard disk until the expiry date, thus continuing collecting information during different sessions of navigation on the browser (the so called permanent cookies).
11.2 Our use of cookies
The cookies are used for several purposes. Certain cookies are necessary in order to allow you to surf the Site and benefit of its functionalities (the so called technical cookies). Other cookies are used in order to obtain statistical information, whether in aggregate or not, about the number of users accessing the Site and how the Site is used (called monitoring cookies or analytics), some cookies are used in order to track your account and allow you to view advertisements that may be of interest to you (called profiling cookies).
As well as the cookies we set, we may use third party cookies and other similar technologies set by other websites when you visit them to help us understand some simple information about the age, location and interests of the people who visit our Site. Third parties may use these technologies to collect or receive information from our Site and elsewhere on the internet and use that information to measure their services engagement and to target adverts.
You can find more information about the cookies we use on the Site and the purposes for which we use them in the table below:
Cookie Name |
Purpose |
CookieConsent |
Used to track if user agrees to cookie usage |
CurrentLang |
Used to present the site with user selected language |
fver |
Used to track the version of our website |
Stripe service cookies |
We use Stripe to process payments for our website. |
Google service cookies |
We use a few Google services, i.e, google analytics, tag manager, youtube, google ads to track site performance and improve user experience. |
Microsoft service cookies |
We use a few Microsoft services, i.e, azure, bing, clarity to track site performance and improve user experience. |
11.3 How to manage the cookies and oppose to their use
You can manage, disable and remove the cookies. To do so, please follow the instructions provided by your browser’s producer to discover how to manage, disable or remove all the cookies.
Please be careful in making your choice. By blocking the receipt of all the cookies indiscriminately, including the technical ones, without providing a specific exception for the Site, you may no longer able to surf the Site or to benefit, in whole or in part, from its functionalities. Furthermore, removing the technical cookies could remove the preferences set up by using the Site.
In order to disable the third parties cookies or identifiers, please see the privacy policies of those third parties.
12. YOUR LEGAL RIGHTS
You have rights (“Your Legal Rights”) under data protection laws in relation to your personal information pursuant to the Personal Information Protection Act (British Columbia), the Office of the Information and Privacy Commissioner (British Columbia), Personal Information Protection and Electronic Documents Act (Canada), and the Office of the Privacy Commissioner of Canada, or the laws of your home jurisdiction. In particular, you have the right to: request access to your personal information, request correction of your personal information, request erasure of your personal information where there is no good reason for us continuing to process it, object to processing of your personal information where we are relying on our legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms, request restriction of processing of your personal information, request the transfer of your personal information to you or to a third party, withdraw consent to our use of your personal information where we are relying on consent to process your personal information. You can make such request by contacting us at privacy@puticollege.com.
No fee usually required
You will not have to pay a fee to access your personal data (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 could refuse to comply with your request in these circumstances.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
13. CHANGES TO THE PRIVACY AND COOKIES POLICY
This Privacy and Cookies Policy may be amended by Company from time to time in our sole discretion and without any prior notice to you. The collection, use and disclosure of your personal information by Company will be governed by the version of this Privacy and Cookies Policy in effect at that time. We will post the most current version on our Site and will indicate at the top of this page the date this Privacy and Cookies Policy was last revised.
14. LANGUAGE
The authentic language of the Agreement is English and any translations provided are for convenience only. If there is any conflict between the English language version of this Agreement and any translation, then the English language version will prevail. You agree we may communicate with you in English during the term of this Agreement.