Last Updated: March 14, 2023
Through our websites (lochkelly.org, mindfulglimpse.com, mindfulglipses.com, effortlessmindfulness.com, or any other web URLs we may use)
Through our “Mindful Glimpses” application (“Mindful Glimpses app”) or other applications we may release
Through engagement in other ways, including sales, marketing, virtual, or in-person events
We also describe how that information may be used, with whom it may be shared, and how you can reach us to get answers to questions you may have about our privacy practices. Finally, we also set forth certain legal rights you may have, subject to applicable law, and how you can exercise them.
Please read this policy carefully, because by using the Services you are acknowledging that you understand and agree to the terms of this policy. In addition, please review our Terms of Service (available at https://effortlessmindfulness.com/terms), which governs your use of the Services and any content you submit to the Services.
If you still have any questions or concerns, please contact us at firstname.lastname@example.org.
Personal Information does not include “aggregate information”, which is data we collect about the use of the Services or about a group or category of services or users from which individual identities or other Personal Information has been removed.
Information You Provide to Us Directly
We collect information that you voluntarily provide in the following ways.
Information Collected When You Request a Trial or Sign In to the Mindful Glimpses App. When you request a free trial or sign in to the Mindful Glimpses app for the first time, we require that you provide us with your email address or Apple ID which we use to send you a code to sign into the app. We may also ask about your interest in the app, past meditation experience and the time of day and frequency with which you meditate.
Information Collected When You Set Up an Account and Populate Your Profile. If you create a NWC account, we give you the option to populate your profile with certain personal information (such as first and last name, the city in which you reside, and a mobile phone number). Doing so is entirely voluntary and is simply offered as a way to personalize your account.
Information Collected When You Purchase a Subscription. If you choose to subscribe to the Mindful Glimpses app, you will be required to provide your payment card information, which can include your name, card number, expiration date, security code, and billing address. If you subscribe from within our mobile app, your payment card information will be collected and stored by the third-party app store you use. If you subscribe through our website, your payment card information will be collected and stored by our third-party payment processor.
Information Collected When You Use Certain App Features. From time to time, we may offer features that require that we request additional permissions to certain aspects of your mobile device. No information will be collected unless you explicitly agree to these permissions and you can change the permissions you grant at any time using your device settings.
Information Collected When You Sign Up to Receive Newsletters or Other Email Communications from Us, Subscribe to Our Blog, or Complete a Survey. When you engage in one of these activities, we may collect your name, email address, and any additional information you choose to provide to us as part of that request (such as information about your satisfaction with our Services in response to a survey). The information you provide is used to deliver the services you requested. We may also track your participation in any of these activities for the purpose of understanding our customers and improving our services (such as tracking which online events you participate in to understand which events are popular).
Information Collected When You Participate in Online Events. From time to time, we may offer online events. To enable these events, we may stream video and audio feed of interactions between participants as well as the contents of any communications enabled by integrated chat functions within the third-party services, such as Zoom, which we may use to provide the events. This could include collecting your image, voice, movements, physical environment, and any other information provided during the event. Occasionally, we may record events and make those recordings accessible to other Mindful Glimpses users.
Information Collected When You Email Us to Ask a Question or Request Customer Service, or When You Communicate with Us Via a Third-Party Social Media Platform. When you contact us by email; through our branded social media accounts; or by telephone, SMS, or physical mail, we may collect your name, email address, phone number, physical address, and the contents of your communication which can include any information you choose to provide. We strictly use that information to provide the service or support you have requested.
Information Collected When You Share Our Services. Our Services allow you to share our Services with another person. In these cases, we will use the recipient’s email address solely to deliver the necessary information or invitation.
Information We Collect by Automated Means
We also collect certain information automatically as you navigate our Services or interact with our communications.
Certain pages on the Services may contain “web beacons” (also known as Internet tags, pixel tags, tracking beacons and clear GIFs). A web beacon is a transparent graphic image placed on a web page or in an email, which indicates that a page or email has been viewed or that an email has been forwarded. In addition, a web beacon allows third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the third party. A web beacon may also tell your browser to get content from another server.
The information we collect automatically can include the following:
Information About the Devices You Use to Access Our Services. This can include your internet protocol (IP) address or other unique device identifier, hardware model, operating system, and browser type.
Details About Your Interactions With Our Services. This includes information such as the date, time, length of stay, specific pages or features accessed during your visit; and search terms used to reach our Services. Within the Mindful Glimpses app, we may log which sessions you have selected and viewed, and which you have chosen to designate as a “favorite.” We use this information to determine the popularity of certain content, to save your preferences and allow you to track your progress, and to improve the app.
Usage Information. This includes the number and frequency of visitors to our Services; and
Location Information. Specifically, our third-party service providers may collect general location information inferred from your IP address which is used for purposes such as verifying your time zone.
Analytics and Advertising. NWC also uses third-party analytics and advertising tools to measure traffic and usage trends on our Services and to serve advertisements on our behalf across the internet. These tools assist us in improving our website and help us better understand which ads bring users to our Services. For more information about interest-based ads or to opt out of having your web browsing information used for interest-based advertising purposes, please visit https://www.aboutads.info/choices or https://www.youronlinechoices.eu.
Information We Collect from Other Sources
We may also obtain Personal Information from other sources. For instance, we may collect Personal Information about you from:
Payment Processors. In general, when you purchase a subscription from NWC, your payment card information is provided directly to our third-party payment processor and NWC does not collect or store that information. However, we may receive limited information about your payment card such as the last four digits of your card, the country of issuance, and the expiration date.
Another Mindful Glimpses User. We may collect Personal Information from another Mindful Glimpses user if that user provides us with your email address in order to share our Services with you.
Third-Party App Stores. We may receive certain transaction information from third-party app stores such as Apple’s App Store and Google’s Play Store when you use those platforms to install our app or purchase a subscription. For instance, when you make a purchase or cancellation, we collect information about the transaction, such as the date and time of the transaction, the price paid, and the expiration date for the subscription or free trial.
We may combine the information we collect about you from these various sources. If a combination of information that we collect identifies you as an individual, we will treat the combined information as Personal Information.
We use the information described above to do the following:
To provide the Services or information you request, including processing your purchases and identifying you when you sign-in to your account;
To provide notifications and meditation reminders, including through push notifications;
To provide recommendations to content and information we think will be of interest to you;
To communicate with you about products, services, offers, promotions, and events we offer;
To request feedback and to otherwise contact you about your use of the Services;
To communicate with you and respond to your emails, submissions, questions, inquiries, comments, requests, and suggestions;
To post testimonials;
To monitor and analyze Services usage and trends and otherwise measure the effectiveness of the Services;
To identify, fix, and troubleshoot bugs and service errors;
To send you confirmations, updates, security alerts, and support and administrative messages;
To protect against, identify, investigate, and respond to misuse of our Service or other unlawful behavior;
To notify you about important changes to our Services; and
To carry out any other purpose described to you at the time the information was collected.
We may share information about you with certain third parties in the following circumstances:
Companies under Common Control. We may share information between and among any current or future parents, subsidiaries, affiliates, and other companies under common control and ownership with NWC.
Third Parties Providing Services on Our Behalf. In order to carry out your requests, to make various features, services, and materials available to you through the Services, and to respond to your inquiries, we may share your Personal Information with third parties that perform functions on our behalf, such as companies or individuals that host or operate our Services, analyze data, or provide customer service.
Business Transfers. We may share Personal Information with another company in connection with or during negotiations of any merger, acquisition, financing, re-organization, bankruptcy, sale of all or a portion of our assets, or transition of services to another provider.
Legal Disclosure. We may transfer and disclose information, including your Personal Information, to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Service or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our Services, or the public.
Consent. We may share Personal Information with third parties with your consent and at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide that information. For instance, if you participate in an online event that we record and make available via our Services, we will ask for your consent to capture your image in connection with the recording and share it with other Mindful Glimpses users.
We may also share non-Personal Information, such as aggregate user statistics, demographic information, and usage information which cannot reasonably be used to identify you, for various purposes including compliance with various reporting obligations and for business or marketing purposes.
The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to use or disclose your Personal Information. To the extent those laws apply, our legal grounds are as follows:
Legitimate Interest. In most cases, we handle Personal Information on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
Providing the Service pursuant to our contract with our customers;
Marketing our business;
Protecting our customers, personnel, and property; and
Analyzing and improving our business.
Legal Compliance. We need to use and disclose Personal Information in certain ways to comply with our legal obligations.
To Honor Our Contractual Commitments to an Individual. Some of our processing of Personal Information is to meet our contractual obligations to the individual to whom the Personal Information pertains.
Consent. Where required by law, and in some other cases, we handle Personal Information on the basis of implied or express consent. For instance, in relation to direct marketing, we will obtain and rely on your consent in relation to the processing concerned.
You have a variety of rights and choices related to our use of your Personal Information.
Opting Out of Email Marketing. You can opt out of receiving our promotional emails at any time by following the instructions included in those emails. Please be aware that it may take up to 10 days for us to process your request, and you may continue receiving promotional communications from us during that period. If you opt out of receiving such communications, please be aware that we may continue to send you non-promotional emails (such as emails related to our business relationship or emails about changes to our legal terms).
Restricting Cookies/Do Not Track. Our Services are not currently designed to respond to web browser “do not track” signals. However, you can configure most browsers to reject cookies or to notify you when you are sent a cookie, giving you a chance to decide whether or not to accept it. You can consult the help section of your browser to find out how to do this. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. In the event that a universally accepted standard emerges on how organizations should respond to “do not track” signals, we will assess and provide an appropriate response to those signals.
Limiting Information in Your Profile. You can control the information we collect about you by limiting the information you provide through your profile.
Accessing, Updating, or Deleting Your Information. If you would like to access, update, or delete Personal Information you have provided you may do so by emailing us at email@example.com. Please note that if you choose to close your account, we may keep certain Personal Information as necessary to comply with our legal obligations or for legitimate business purposes, such as to resolve disputes or enforce our agreements. We may also keep cached archived copies of Personal Information for a certain period of time.
Disabling Push Notifications. With your consent, we may share push notifications or alerts to your mobile device. We use push notifications to inform you of important updates and to send you meditation reminders. You can manage or deactivate these notifications at any time by turning off the notifications setting in the app or by disabling notifications through the device settings on your mobile device. If you choose not to receive push notification, you will still receive in-app notifications in the “Notifications” section of the app.
Limiting Device Permissions. With your consent, we may access your mobile device’s camera, microphone, or storage features. However, we will never import any photos or audio files other than those you explicitly choose to share. At any time, you can turn off these features using the device settings of your mobile device.
Data Requests. Certain privacy laws, including the GDPR and the CCPA provide users with rights related to their Personal Information. Depending on your location, you may be eligible for a number of rights with respect to your information.
Right to Access & Portability: You may be able to access certain Personal Information associated with your account by visiting your account settings. You can also request a copy of your Personal Information in an easily accessible format along with information explaining how that data is used.
Right to Correction: You have the right to request that we correct information about you. You can correct and change certain Personal Information associated with your account in your account settings or by emailing us at firstname.lastname@example.org.
Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your Personal Information.
Right to Deletion: In certain circumstances, you have the right to request the deletion of your Personal Information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of the Services.
Right to Object: If we process your Personal Information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will stop processing your Personal Information unless we have a compelling legitimate ground to continue processing or where it is legally necessary.
Right to Withdraw Consent: Where we rely on consent, you can withdraw your consent to our processing by using various means we offer such as an email unsubscribe link or your account settings. This is without prejudice to your right to permanently close your account and delete your Personal Information.
The CCPA provides California residents with the following additional rights:
Right to Know. California residents may request disclosure of the specific pieces and/or categories of Personal Information that we have collected about them, the categories of sources for that Personal Information, the business or commercial purposes for collecting the information, the categories of Personal Information that we have disclosed, and the categories of third parties with which the information was shared. To request this information please contact us at email@example.com.
Right to Opt-Out. NWC does not sell Personal Information to third parties for monetary value. However, the term “sale” is defined broadly in the CCPA. To the extent that “sale” under the CCPA is interpreted to include any of the data uses described in Section 3, “How We Use the Information Collected” above, California residents are entitled to opt-out of the “sale” of data at any time. Please contact us at firstname.lastname@example.org.
Limiting use of, or deleting, your Personal Information may affect features and uses that rely on that information. However, we will not discriminate against you for exercising any of your rights, including otherwise denying you goods or services, providing you with a different level or quality of services, or charging you different prices or rates for services.
We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. Before responding to your request, we may require that you provide us with additional information to confirm your identity. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government-issued identification. We may verify the authenticity of the request directly with you. You also have the right to lodge a complaint with the authorities applicable to your situation. However, we invite you to contact us with any concern, as we would be happy to try to resolve it directly.
Notice of Collection: In addition to the rights and choices described above, the CCPA requires disclosure of the categories of Personal Information collected over the past 12 months. While this information is covered in greater detail in Section 2, “Information Collected on Our Services” above, the categories of Personal Information that we have collected – as described by the CCPA – are:
Identifiers, including your name, email address, IP address, and Unique Identifier (e.g., mobile device ID).
Other individual records, such as your city and the last four digits of your payment card. This category includes Personal Information protected under Cal. Civ. Code 1798.80e and overlaps with other categories listed here.
Commercial information, such as the subscriptions and gift cards you have purchased and your engagement with our Services.
Internet activity, including your navigation of our Services and what led you to NWC.
Geolocation data, including general location data derived from IP addresses.
Sensory information, including photographs.
Inferences, including information about your interests and preferences.
Business or Commercial Purpose for Collecting and Using Personal Information. We collect each category of Personal Information listed above for the business or commercial purposes described in Section 3, “How We Use the Information Collected” above.
Categories of Sources of Personal Information. We collect each category of Personal Information listed above directly from you, through automatic data collection means, or through the third-party sources described in Section 2, “Information Collected on Our Services” above.
Categories of Personal Information Disclosed. In the preceding 12 months, we have disclosed the categories of Personal Information listed above in the circumstances described in Section 4, “What Personal Information Do We Share with Third Parties” above.
Shine the Light. California Civil Code § 1798.83, also known as the “Shine The Light” law, permits California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Information in the immediately preceding calendar year. NWC does not share Personal Information with third parties for their direct marketing purposes.
We maintain generally accepted administrative, technical, and physical safeguards to help protect against loss, misuse or unauthorized access, disclosure, alteration, or destruction of your Personal Information. However, there is always some risk involved in transmitting information over the internet and storing information electronically. Please note that NWC cannot and does not guarantee absolute security.
Our Services are directed at adults and we do not knowingly collect Personal Information from children. If you are a parent or legal guardian and think your child under 13 (or a higher age threshold where applicable) has given us Personal Information without your consent, please contact us at email@example.com
Natural Wakefulness Center
P.O. Box 122
Stone Ridge, NY 12484