Effective & Last updated 20th July 2022
1. OUR COMMITMENT
Navel Consciousness (OPC) Pvt. Ltd ("we", "us", “our”, "www.udumbaragesu.com", "School of Absolute Inner Clarity by Udumbara Gesu", "navelawakening.com", "www.thenewclearwoman.com", "navelconsciousness", “any other product or service floated by Navel Consciousness (OPC) Pvt. Ltd”, ”Navel Consciousness (OPC) Pvt. Ltd”, “Company”) is strongly committed to protecting and respecting your ("you", "subscriber", "user", “data subject”) right to privacy and in keeping your personal and financial information secure.
Please also keep in observance that our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information. We shall not be liable for any loss caused to you due to breach by a third party.
2. Kajabi, LLC, California
3. USER CONSENT
4. CHILDREN’S PRIVACY
The School of Absolute Inner Clarity or any other mentioned products of the company Navel Consciousness (OPC) Pvt. Ltd is not intentionally designed for or directed at persons less than 18 years of age or persons defined as minor in country of residence of such persons. Navel Consciousness (OPC) Pvt. Ltd does not knowingly permit any person who is under 18 years of age or persons defined as minor in country of residence of such persons to register with the services or to provide any other personally identifying information. If Navel Consciousness (OPC) Pvt. Ltd becomes aware that any personally identifiable information of persons less than 18 years of age of such persons has been collected by Navel Consciousness (OPC) Pvt. Ltd without verified parental consent, then Navel Consciousness (OPC) Pvt. Ltd reserves the right to take the appropriate steps to delete any such information and notify the parent.
However, we consider it the responsibility of parents to monitor their children's use of our services. Nevertheless, it is our policy not to collect and process any personal information from children below 18 years of age or persons defined as minor in country of residence of such persons or offer to send any promotional materials to persons in that category. Navel Consciousness (OPC) Pvt. Ltd does not seek or intend to seek or receive any personal information from children. Should a parent or guardian have reasons to believe that a minor has provided Navel Consciousness (OPC) Pvt. Ltd with personal information without their prior consent, please contact our support team to ensure that the personal information is removed.
5. ACCESSING THROUGH VPN
We will not be responsible or liable for any collection, storage or processing of your personal information or data if you use any mechanism or technology to access or use any Website or Services which conceals your actual geo-location.
6. INFORMATION WE COLLECT ABOUT YOU
We may collect both “Non-Personal Information” and “Personally Identifiable Information” about you. “Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. “Personally Identifiable Information” includes information that can be used to personally identify you, such as your name, address, phone number, status of marriage and email address. This data ranges from records including full name, and country, to more extensive records that include full name, telephone number, email address, home and work address, date of birth, phone number, email address, age and marriage details.
In addition, if you attend a programme, workshop or class or buy a product, we will also keep a record of that transaction to facilitate travel or other requirements when required as well as to be able to discern whether you meet the prerequisites for advanced classes.
In addition, we may also track information provided to us by your browser or by our mobile application when you view or use the Service, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Service, the time and date of access, and other information that does not personally identify you. We use this information for, among other things, the operation of the Service, to maintain the quality of the Service, to provide general statistics regarding use of the Service and for other business purposes.
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
Unless specifically requested, we ask that you not send us, and you shall not disclose, on or through the Services or otherwise to us, any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, national identification numbers, social security numbers, criminal background, trade union membership, or administrative or criminal proceedings and sanctions). We will not share or use any sensitive personal information or awkward moments of yours.
7. HOW WE USE YOUR INFORMATION
We use information held about you in the following ways:
Information you give to us:
We use information held about you for our legitimate business interests for the following purposes:
- Take steps in order to provide workshop services and anything else we decide to provide including:
- administering your account with us;
- providing guidance and education;
- To provide you Services including associated functionalities whether by us or by our designated representatives and/or business partners to you or to parties designated by you and any and all matters ancillary thereto including to carry out obligations from any contracts entered into between us. We rely on performance of our contract with you so as the legal basis for such processing;
- To verify and process payment when you subscribe to, purchase and/or obtain Services from any of our Website. We rely on performance of our contract with you so as the legal basis for such processing;
- For verification and record of your personal particulars, to authenticate you so that we know it is you and not someone else which includes comparing it with information from other sources and using the information to communicate with you. We rely on performance of our contract with you so as the legal basis for such processing;
- To conduct market research and statistical analysis of the users of the Website including the number of users, the frequency of use, profile of users and using such analysis for our business plans, the enhancement of our products and services, targeted advertisements and conveying such information in broad terms (but not information in relation to specific individuals) to third parties who have or propose to have business dealings with us. We rely on legitimate business interests as the legal basis for such processing and the legitimate interest is the analyzing the use of the Services and improving the same;
- To prevent fraud or other potentially illegal activities (including copyright infringement) and to block disruptive users and protect the safety of users of our Services. The legal basis for this processing is our legitimate business interests being the proper protection of our business against risks;
- To enforce our terms of Service. The legal basis for this processing being the protection and assertion of our legal rights and the legal rights of others; and
- In any case, if you would prefer that we do not use your Information to market or promote our products and Services to you, please either (i) tick the relevant box on the form through which we collect your information (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) contact us at the contact details set out below:
Contact details: [email protected]
Information we collect about you from your use of our Website
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
- To administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To keep our Website safe and secure;
- For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- To improve our Website to ensure that content is presented in the most effective manner for you and for your computer; and
- To allow you to participate in interactive features of our service, when you choose to do so.
8. WHO HAS ACCESS TO YOUR DATA?
Within The New Clear Woman or any other mentioned products of the company Navel Consciousness (OPC) Pvt Ltd, the individuals with access to your data are those requiring those data to be able to fulfil our contractual agreements with our customers and clients. These may include our communications and marketing team, our event organizers, administrative staff and contractors.
Furthermore, if you are an Navel Consciousness student, the support teams for the different groups of healers and spiritual leaders will have access to your data to be able to provide you with the support and information you require for your business as an independent contractor.
In addition, outsourcing work on specialist tasks within IT and accounting, for example, sometimes requires us to grant consultants access to your data whenever and wherever this is required to fulfil our legal obligations towards official authorities or to develop and improve our services.
In addition to our internal team and the external agencies with whom we work, all Navel Consciousness (OPC) Pvt Ltd healers and spiritual leaders listed on our Website are granted access to your basic data (full name, email address, mailing address country and phone number) when you register for one of their classes or workshops or counselling sessions
In general, we do not sell, trade, rent or otherwise share your Personally Identifiable Information with third parties without your consent. We may share your Personally Identifiable Information with vendors and other third-party providers who are performing services for Navel Consciousness (OPC) Pvt. Ltd. In general, the vendors and third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide for Navel Consciousness (OPC) Pvt. Ltd. For example, when you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery, or return a purchase, you consent to our collecting and using such personal information for that specific purpose, including by transmitting such information to our vendors (and their service providers) performing these services for Navel Consciousness (OPC) Pvt. Ltd.
9. HOW LONG IS THE DATA STORED?
We retain personal data for as long as required to meet our contractual obligations to you in our legitimate interests and for as long as is permitted under applicable law for instance in order to comply with our legal obligations. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our Services. You cannot be identified from aggregate information retained or used for these purposes.
10. OUR LEGAL BASIS FOR HOLDING YOUR INFORMATION
We hold your information for one of two reasons:
For the purposes of a contract with you, where we need information like your name and contact details so we can provide sessions and guidance at your request;
For our legitimate interests, having considered any impact on your interests and rights, for instance in promoting our organisation, to learn from our participants so we can improve our Website, our sessions and their general experience of Navel Consciousness (OPC) Pvt. Ltd.
11. ARE CUSTOMERS OBLIGED TO PROVIDE THEIR DATA?
Yes, as a customer or client, you must provide the data we need to be able to fulfil our contractual obligations within the various services we offer.
Depending on what Services you are requesting from us, we will ask you to provide information that may range from your full name, email address and country to more extensive details including full name, telephone number, email address, home and work address, as well as details of dependents.
12. OUR PROMOTIONAL UPDATES AND COMMUNICATIONS
Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information to provide you with promotional update communications by email, post and telephone about our products and services.
You can object to further marketing at any time by checking and updating your contact details within your account, or selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you, or by sending us an email to [email protected]
13. PAYMENT PROCESSING
This Payment Information is used to provide you your requested Services, to manage your account, to communicate with you, and enforce any terms of service or agreement related to the Website. We use any Payment Information we acquire from you only to fulfil your order
14. HOW WE PROTECT YOUR INFORMATION
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
15. COOKIES AND OTHER TECHNOLOGIES
Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen or manual will tell you how to do this. We also give you information about how to disable cookies here. However, you may not be able to take full advantage of our website if you do so.
A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser/or exit the Website. Others are used to remember you when you return to the Website and will last for longer.
We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests in improving our Website and engaging in a focused way which understand our users (where we have considered that these are not overridden by your rights).
We may be using the following types of cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognize you when you return to our website. This enables us, subject to your choices and preferences, to personalize our content, greet you by name and remember your preferences (for example, your choice of language or region).
16. DISABLING COOKIES
The effect of disabling cookies depends on which cookies you disable but, in general, the website may not operate properly if all cookies are switched off. If you only disable third party cookies, you will not be prevented from making purchases on our Website. If you disable all cookies, you will be unable to complete a purchase on our Website.
If you want to disable cookies on our site, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies as on date for the most popular browsers are set out below: –
For Microsoft Internet Explorer:
1. Choose the menu “tools” then “Internet Options”
2. Click on the “privacy” tab
3. Select the setting the appropriate setting
For Google Chrome:
1. Choose Settings> Advanced
2. Under “Privacy and security,” click “Content settings”.
3. Click “Cookies”
1. Choose Preferences > Privacy
2. Click on “Remove all Website Data”
For Mozilla Firefox:
1. Choose the menu “tools” then “Options”
2. Click on the icon “privacy”
3. Find the menu “cookie” and select the relevant options
For Opera 6.0 and further:
1. Choose the menu Files”> “Preferences”
17. YOUR RIGHTS TO YOUR PERSONAL INFORMATION
You have the following rights:
- The right of access - you have the right to obtain confirmation that your data is being processed and access to your personal data. This is so that you are aware of and can verify the lawfulness of the processing. If you request the information, we will provide a copy of the information free of charge. However, we will charge a ‘reasonable fee’ when a request is manifestly unfounded or excessive, particularly if it is repetitive. This also applies to additional copies of the same information. The information will be provided without excessive delay, and at the latest within one month of receipt. This period can be extended by a further two months where requests are complex or numerous. If this is the case, we will inform you within one month of the receipt of the request and explain why the extension is necessary. The information will be sent as a password-protected PDF. Where requests are manifestly unfounded or excessive, in particular because they are repetitive, we may charge a reasonable fee taking into account the administrative costs of providing the information; or refuse to respond.
- The right to rectification - to amend your personal information, address requests to the us and we will respond within 30 days, of receipt of your written request and confirmed ID.
If we have disclosed the personal information in question to third parties, we will inform them of the rectification where possible. We can also inform you about the third parties to whom the data has been disclosed where appropriate.
- The right to erase - this is also known as ‘the right to be forgotten’. The broad principle underpinning this right is to enable you to request the deletion or removal of personal data where there is no compelling reason for its continued processing. If you would like us to erase you from our database, please address requests to us. If we have disclosed the personal data in question to third parties, we will inform them about the erasure of the personal data, unless it is impossible or involves disproportionate effort to do so.
- The right to restrict processing - individuals have a right to ‘block’ or suppress processing of personal data. When processing is restricted, we are permitted to store the personal data, but not further process it. We are able to retain just enough information about the individual to ensure that the restriction is respected in future e.g. your name and email address on an email marketing suppression list.
The right to restrict processing applies in the following circumstances:
- Where you contest the accuracy of the personal data, we will restrict the processing until we have verified the accuracy of the personal data.
- Where you have objected to the processing (where it was necessary for the purpose of legitimate interests), and we are considering whether our legitimate grounds override yours.
- When processing is unlawful and you oppose erasure and request restriction instead.
- If we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.
If we have disclosed the personal data in question to third parties, we will inform them about the restriction on the processing of the personal data, unless it is impossible or involves disproportionate effort to do so. We will inform you if we decide to lift a restriction on processing.
- The right to object - you have the right to object to processing based on legitimate interests (including profiling) and direct marketing (including profiling). The objection must be on “grounds relating to his or her particular situation”. We will stop processing personal data for direct marketing purposes as soon as we receive an objection.
- The right to withdraw consent – you have the right to withdraw consent without detriment at any time, where the processing of your personal information by us is based on consent.
- The right to data portability - you have the right to obtain the data that the we process on you and use it for your own purposes. This means you have the right to receive the personal data that you have provided to the us in a structured machine readable format and to transmit the data to a different data controller.
This right applies in the following circumstances:
- where you have provided the data to the Navel Consciousness (OPC) Pvt. Ltd;
- where the processing is carried out because you have given the Navel Consciousness (OPC) Pvt. Ltd your consent to do so;
- where the processing is carried out in order to perform the service contract between you and the Navel Consciousness (OPC) Pvt. Ltd; and
- where processing is carried out by automated means.
Should you wish to exercise these rights, we require you to prove your identity with two pieces of approved identification. Please address requests to Connect@navelconsciousness.com and we will respond within 30 days, of receipt of your written request and confirmed ID. Please provide as much information as possible about the nature of your contact with us to help us locate your records.
18. WHERE WE STORE YOUR INFORMATION
Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. Additionally, when using or disclosing personal information transferred from the European Union, we use standard contractual clauses approved by the European Commission, adopt other means under European Union law for ensuring adequate safeguards.
19. PUBLIC FORUMS
20. DISCLOSURE TO THIRD PARTIES
Navel Consciousness (OPC) Pvt. Ltd may also carefully select other companies to send you information about their products or services which are related to the site's service but are not necessary to its operation (an "Extended Service"). If Navel Consciousness (OPC) Pvt. Ltd intends to use personally identifiable information for an extended service, the Navel Consciousness (OPC) Pvt. Ltd site will provide you with the ability and requisite instructions to decline this service.
You may also stop the delivery of informational or promotional mail from Navel Consciousness (OPC) Pvt. Ltd by following the instructions on the mail.
- Promotional Offers - We'll share or disclose your personal information outside of Navel Consciousness (OPC) Pvt. Ltd when we have your consent. For example, providing SMS and E-mail related services such as marketing newsletters, promotions and offers.
In the event Navel Consciousness (OPC) Pvt. Ltd is merged with or acquired by another company or in case of re-organization or re-structuring of business, we and our affiliates may share your personal information, wholly or in part, with another business entity.
- Legal – Navel Consciousness (OPC) Pvt. Ltd may disclose personally identifiable information if required to do so by law or in the good-faith belief that such action is necessary to:
- conform to the edicts of the law or comply with legal process served on the site or its owners;
- protect and defend the rights or property of the site-owners, the site or the users of Navel Consciousness (OPC) Pvt. Ltd ;
- Act under exigent circumstances to protect the personal safety of users of Navel Consciousness (OPC) Pvt. Ltd, the site, its owners, or the public.
21. SECURITY AND COMPLIANCE WITH LAWS
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we may use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Navel Consciousness (OPC) Pvt. Ltd account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us by contacting our customer support team.
22. CHANGE IN POLICY
23. GRIEVANCE REDRESSAL
Any complaints or concerns with regards to the processing of information provided by you or breach of these terms shall be immediately informed to the designated Grievance Officer as mentioned below via in writing by email to Grievance Officer, at [email protected]