Policy on Privacy and Cookies

Policy for Privacy and Cookies in online teachings
on and through jayaashmore.org, opendharma.org, online courses and meetings with “Jaya” Julienne Ashmore as of May 2018

I respect the privacy of the personal information of visitors to the website, students on online courses and meetings, and subscribers to my email newsletters, as well as anyone else I may interact with in the course of sharing Dharma and life. I also insist on this respect as a major part of the ethos of our interactions, towards growing trust, ease and courage.

In short, I do not actively gather your private information. Where you have given your email address--either when you signed yourself up for my email newsletter, and/or if you have given donations through PayPal—then I use it to connect with you.
I passively receive, and may have potential access to, information that 3rd parties collect when you visit my websites or participate in my online teachings and meditations.

I have already abided by a strong sense of the value of protecting privacy and consent online. For instance, if you and another person in the sangha would like to connect, I ask both of you how you would like to be contacted rather than passing on email addresses without overt consent. For online courses, or meetings with more than one other person, it is essential that all participants keep all content confidential. In entering an online course, you agree to keep all interactions confidential, and to keep the live and recorded group meetings private.

I expect the same from you regarding my personal information, especially regarding the privacy of my phone number, Skype user name, physical location and bank details.
By continuing to interact with me online, you agree to my privacy policy including respect for my own privacy.

As required by law, I am posting what your rights are below a description of what, how, when, why, where, and for how long I and those who assist me collect, use, and share information when you contact me, meet me, or otherwise interact with me, my services and teachings. I also provide some information about what happens with your personal information through third-party companies including:
~wix.com or its related sites and services for my website,
~Google analytics or its related sites and services on my websites,
~Spun, inc., or its related sites and services for my websites,
~appointy.com or its related sites and services for scheduling one-to-one meetings, ~Schoology.com and
~gotomeeting.com or their related sites and services for online courses,
~PayPal.com for payments and donations, and
~mailchimp.com or its related sites and services for sending out email letters.
This policy also applies to any other third-party services I may use in the future.

This Privacy Policy does not apply to the practices of third parties that I do not own or control, including wix.com or any third party services you access through wix.com or any other company including but not limited to all those listed above.
Please reference the Privacy Policies of each company to learn more about its privacy practices.

What and How

For the newsletter, you gave your email address in order to be included on the mailing list to receive the “News and Letters.”

Any public comments, feedback, reviews, recommendations, and personal profiles you created are obviously available to me. I keep a copy of sharings in online courses in the form of static documents in my computer. Other participants including yourself are free to do the same unless otherwise agreed.

In any online media where you and I interact or meet, you may have given me sensitive information, such as your name and email address.
You may also choose to provide me with additional personal information, such as a skype name or whatsapp and/or phone number for specific interactions.
I do not come in contact with your financial information, because those gifts happen though PayPal or bank transfer.

On the websites, I do not actively collect any personal user information. You may sign up to be notified when I post on my blog on jayaashmore.org. Wix.com takes care of that notification.

jayaashmore.org is hosted by Wix.com. Wix uses cookies on every site.
Wix says these are the details of the cookies they use, although I found only 2 of all of these--XSRF-TOKEN and svSession.
Cookies related to security and last the duration of your session are:
1) incap_ses_${Proxy-ID}_${Site-ID}
2) incap_visid_${Proxy-ID}_${Site-ID}
Cookies related to security that are “persistent cookies” are:
1) nlbi_{ID}
2) XSRF-TOKEN
Cookies used to identify logged-in site members (currently inapplicable) that last 2 weeks:
smSession
And “permanent” cookies used to create activities and BI (also currently inapplicable):
svSession

I also found these cookies active on jayaashmore.org through wix.com
_ga, _gat, _gid, and hs

And through doubleclick.net, somehow connected to jayaashmore.org: IDE and test_cookie

And because I share some video teachings via youtube.com, there are these cookies via youtube: GPS, PREF, VISITOR1_INFO_LIVE, YSC, remote_sid, nextld and requests.
Youtube.com may change the cookies it uses, and I leave it up to you to enter youtube or not at your own risk.

I read anonymous site statistics through services such as wix.com, schoology.com, and Google analytics.

In all online settings, third-party web services may receive, collect and store any information you enter on my website or provide us in any other way. In addition, web services may collect the Internet protocol (IP) address used to connect your computer to the Internet and other computer and connection information. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page.

Why

I keep your email on my newsletter mailing list only as long as you stay subscribed to my newsletter.
The anonymous site statistics help us understand how our services are received and helps improve the teachings and the website to make it serve students and visitors better.

Apart from this, if you have signed up for online or other teachings, we may contact you regarding scheduling, to troubleshoot problems, to help you access teachings, to resolve a dispute, to collect fees, to poll your opinions through surveys or questionnaires, to send updates about our company, to thank you for a donation or for your particpation, or as otherwise necessary to contact you to enforce our User Agreement, applicable national laws, and any agreement we may have with you. For these purposes we may contact you via email, telephone, text messages, postal mail or other media. If you have given us contact details, then we accept your permission to use that information to contact you if needed in order to help you participate in the proper way.
Your personal information will be used for the specific reasons stated above only.

Legal bases for collecting, using, and sharing your information, include:

as needed to provide my services, such as when meeting on Skype or sending an email newsletter;
when you have asked or provided your affirmative consent, which you may revoke at any time, such as by signing up to receive the newsletter or to participate in an online course or meeting;
if necessary to comply with a legal obligation or court order or in connection with a legal claim, such as retaining information about movement of money if required by tax law; and
as necessary for the purpose of my legitimate interests, if those legitimate interests are not overridden by your rights or interests, such as 1) providing and improving my services. I use your information to provide the services you requested and in my legitimate interest to improve my services; and 2) Compliance with the third-party Policies and Terms of Use. I use your information as necessary to comply with my obligations under the third-party Policies and Terms of Use.

More about Why and something about How
I share your personal information for very limited reasons and in limited circumstances, as follows:

Third parties. I share information with third-parties as necessary to provide you my services and comply with my obligations under both the third-party Policies and Terms of Use.
Service providers. I engage certain trusted third parties to perform functions and provide services, such as scheduling.
Sometimes volunteers or paid employees may help with organizational work or teachings, and in that case, I share with my trusted colleagues the minimal personal information necessary, such as your name and email address, through encrypted communication.
I will share your personal information with these third parties, but only to the extent necessary to perform these services.
Organizational transfers. If I pass on or merge my organization, I may disclose your information as part of that transaction, only to the extent permitted by law.
Compliance with laws. I may collect, use, retain, and share your information if I have a good faith belief that it is reasonably necessary to: (a) respond to legal process or to government requests; (b) enforce my agreements, terms and policies; (c) prevent, investigate, and address fraud and other illegal activity, security, or technical issues; or (d) protect the rights, property, and safety of my students and participants, or others.

Where
is your private information stored?
~jayaashmore.org is hosted on the Wix.com platform. Wix.com provides the online platform that allows us to provide teachings, information and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.
All other web-related services are listed above, and similarly assure us that they try to keep our information safe.
I occasionally download the emails on the mailing list for the email newsletter and along with similar copies of online information, I store it on my computer behind a firewall.

How long
I keep your email on my newsletter mailing list only as long as you stay subscribed to my newsletter. You may edit your subscription any time.
In other contexts, I retain your personal information for as long as necessary to provide you with my services and as described in my Privacy Policy, up to 10 years.
After 10 years, I will ask for your consent again.
However, I may also be required to retain this information to comply with my legal and regulatory obligations, to resolve disputes, and to enforce my agreements.

You
Your Rights and Options

If you reside in certain territories, including the EU, you have a number of rights in relation to your personal information. While some of these rights apply generally, certain rights apply only in certain limited cases. I describe these rights below:

Access. You may have the right to access and receive a copy of the personal information I hold about you by contacting me using the contact information below.
Change, restrict, delete. You may also have rights to change, restrict my use of, or delete your personal information. Absent exceptional circumstances (like where I am required to store data for legal reasons) I will generally delete your personal information upon request.
Object. You can object to (i) my processing of some of your information based on my legitimate interests and (ii) receiving marketing messages from me after providing your express consent to receive them. In such cases, I will delete your personal information unless I have compelling and legitimate grounds to continue using that information or if it is needed for legal reasons.
Complain. If you reside in the EU and wish to raise a concern about my use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local data protection authority.

How to Contact Me

For purposes of EU data protection law, I, “Jaya” Julienne Ashmore, am the data controller of your personal information. If you have any questions or concerns, or would like to access, correct or delete any personal information I have about you, you are invited to contact me through a message via an online service provider such as Skype, or by email at jayajulie@yahoo.com if you have any requests or concerns related to privacy.

If you do contact me to access, correct or delete personal information held by 3rd parties, I may contact the 3rd party for assistance, or request that you send a request directly to the 3rd party.

This policy applies to Open Dharma’s online retreats with “Jaya” Julienne Ashmore.

Please read it through and feel free to ask a teacher or manager of Open Dharma with any questions you might have.

Intended use

Open Dharma is currently offering online retreats. Part of the retreat process involves using a registration intake form so that we can understand more about your personal history and experiences before entering into retreat together. Your registration intake form will be viewed by Open Dharma teachers and managers.

By participating in an Open Dharma retreat, individuals agree to not share or reproduce any of the material provided to them while on retreats. They also agree to respect the privacy of other retreat participants and not share photos or personal stories of fellow retreat participants without their explicit permission.

Information we collect

On our registration forms, we collect individuals’ names, email addresses, and short and honest answers regarding subjects such as history and ongoing experiences regarding meditation and mental health.

Third-party links and content

There are no 3rd party links or content within the forms that we use to collect information from participants. And we do not share your information with any other person or party.

Storage and Retention

Leading up to a retreat, Open Dharma uses JotForm (see below) to collect information from individuals., and other online services such as Schoology and GoToMeeting to run our online programs.
The content of the forms are then stored in the email accounts of Open Dharma teachers and managers. No one beyond the teachers and managers of Open Dharma has access to this data. We store the data from registration forms for up to a maximum of one year before deleting it from our email inboxes.
The content of the retreat is available to all participants.

Recordings, a special note

During a retreat, sessions are digitally recorded. If participants are not comfortable being recorded, they can indicate this to the teacher or manager before or during a retreat so that the recording can be paused during any moments that you speak.
If, following a retreat, you realize that you said something on recording that you wish to be removed from any future uses, please contact a manager or teacher in a timely manner who will do whatever they can to ensure it is removed. However, once a recording has been posted in a retreat group, participants may have already downloaded that recording, within the confidentiality agreement of the retreat or program.

Security

Open Dharma uses JotForm to collect data. By filling out Open Dharma’s registration intake form, you are agreeing to the collection and storage of your personal information under JotForm’s Privacy Policy.
We do not store your IP address or any personal information not specifically entered into your JotForm submissions.

Open Dharma programs also rely on other online services to organize and offer our programs. By participating in Open Dharma’s online programs, you are agreeing to the Privacy Policies of all these services, including Schoology, GoToMeeting, Wix.com, and Skype.

International Transfers of Information

Open Dharma teachers and managers reside in various countries in the EU, the UK, Israel, and India. Incoming data is thus received to a wide range of international IP addresses.

Your Consent

By participating in Open Dharma online retreats you consent to this privacy policy. An additional privacy policy, used more generally for events with Jaya Julienne Ashmore, can be found at the following website: https://www.jayaashmore.org/policy-on-privacy-and-cookies

Contacting Us

Please do not hesitate to contact Jaya directly, or through the retreat manager, if you have any questions or if anything is unclear. You may email us at manager@opendharma.org

Changes to this policy

If we decide to change our privacy policy, we will post those changes to the websites of Jaya Ashmore and of Open Dharma..

Summary of changes so far:

August 21, 2020: First published.

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.