Privacy Policy

Introduction

Welcome to True Elk's privacy policy. True Elk’s mission is to organise and host creative retreats across the globe to enable individuals to connect with one another and the natural environment around them and to encourage individuals to unwind and express their creativity. To fulfill our mission, we may need to collect personal data about you.

True Elk respects your privacy and is committed to protecting your personal data.  This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how True Elk collects and processes your personal data through your use of this website and which you may have shared with us, including any data you may provide when you book onto one of our retreats or purchase goods from our online shop.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

True Elk is the controller and responsible for your personal data (collectively referred to as "True Elk", "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

Full name of legal entity: True Elk Limited

Email address:  info@trueelk.com

Postal address:  True Elk, Robin House Chickney Road, Henham, Bishop's Stortford, England, CM22 6BB

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk).  We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.  This version was last updated in January 2022. 

It is important that the personal data we hold about you is accurate and current.  Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, 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 websites and are not responsible for their privacy statements.  When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified.  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, maiden name, last name, marital status, title, date of birth, disability and gender.

  • Contact Data includes billing address, delivery address, email address and telephone number(s).

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

  • 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 this website.

  • Profile Data includes your username and password, purchases or orders made by you, interests, preferences and feedback and survey responses.

  • Usage Data includes information about how you use our website, products and services.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

  • Special Categories of Personal Data includes health information, racial or ethnic origin data, sexual orientation data, religious or philosophical beliefs, sex life, sexual orientation data, political opinions, trade union membership and genetic biometric data.


We will only collect Special Categories of Personal Data about you if you are attending one of our retreats and with your explicit consent for the purpose of ensuring the courses supplied at the retreat meet your interests and experiences. We do not collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms 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 a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions.  You may give us your Identity, Contact, Financial and Special Categories of Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise.  This includes personal data you provide when you:

  • Apply to attend one of our retreats;

  • Purchase our products or services;

  • Create an account on our website;

  • Subscribe to our newsletter or publications;

  • Enter a competition, promotion or survey; or

  • give us feedback or contact us.

  • Automated technologies or interactions.  As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.  Please see our cookie policy below for further details.

  • Third parties. We will receive personal data about you from various third parties as set out below:

    • Technical Data from analytics providers such as Google who may be based outside the UK; and

    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.


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 in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.

  • 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 data, except in relation to processing Special Categories of Personal Data, although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.  We have also identified what our legitimate interests are, where appropriate.

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 customer

(a) Identity

(b) Contact

(c) Special categories of personal data

Performance of a contract with you

To process and deliver your order/booking including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(c) organise individual requirements for the retreat 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(f) Special categories of personal data

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

(c) to ensure the safe and smooth running of the retreat

To manage our relationship with you which will include:

  1. To notify you about changes to our terms or privacy policy

  2. Asking you to leave a review or take a survey


(a) Identity

(b) Contact

(c) Profile

(e) Special categories of personal data


(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests, in order to keep our records updated

To enable you to partake in a competition/prize draw or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications


  1. Necessary for our legitimate interests

  2. Performance of a contract with you


To administer and protect our organisation and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our organisation, provision of administration and IT services, network security and to prevent fraud)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website, services and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests such as to keep our website updated, to inform you about relevant information and to develop our business

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

We will use the information you provide to:

  • Fulfil your requests, such as enabling you to book onto one of our retreats/or purchase goods from our shop or in relation to requests for further information about our retreats or any products we sell through our shop;

  • Prevent or detect fraud or abuse of our website;

  • Use data analytics to improve our website, services and the experience offered; and

  • Inform you of any changes to the Website Terms & Conditions and/or this Privacy Policy.

Marketing/Newsletters

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

When subscribing to our newsletter you are required to enter your email address only. We record the information relating to your declaration of consent which includes;

  • date and time of consent;

  • confirmation of the electronic checkbox being selected;

  • email address;

You can ask us to stop sending you newsletters at any time by contacting us at any time. Your contact details will be immediately deleted if you decide to unsubscribe from our newsletter.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

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 may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy below.


Change of purpose

We will only use your personal data 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 us.

If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

  • External Third Parties such as:          

    • Service providers acting as processors based in Canada who provide administration services.

    • Service providers acting as processors based in Canada who provide excursions as part of the retreat or hotels who provide accommodation as part of the retreat.

    • Third parties who attend the retreat to provide a service or provide the content and workshops for the retreat including writers, instructors, photographers or videographers or other trained professionals. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions


International transfers

Many of our retreats are based outside the UK. This will involve transferring your data outside the UK in order to allow us to book services on your behalf as part of the retreat (such as to complete hotel bookings, organise additional trips or excursions or book restaurant or related food services). Many of these external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data Security

We limit access to your personal data to those employees/volunteers 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. This does not apply to personal data or writing content which you have provided consent for us to use as part of any of our teaching material to be used during the retreat. 

We have put in place procedures to deal with any suspected personal data breach.


  1. Data retention

We will only retain your personal data 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 data 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 data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, tax, accounting, regulatory or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for statistical purposes, in which case we may use this information indefinitely without further notice to you.


Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request").  This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data where we are relying on a 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal data.  This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.

  • Where our use of the data is unlawful but you do not want us to erase it.

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party.  We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use.

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.  If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the details set out at the beginning of this policy.

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.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).  This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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.


Cookie Policy

Our website uses a limited number of cookies. A cookie is a small file of letters and numbers that we put on your computer which are essential for the website to function properly and which help to provide you with a better online experience. These cookies cannot be switched off and do not store any of your information. In time we may also use "analytical" cookies, which allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our website works, for example by ensuring that users are finding what they are looking for easily.