Sati Center Security and Privacy Policy

Date of Last Revision: 10/13/2018

The Sati Center for Buddhist Studies (“Sati Center,” “we,” or “us”) is a nonprofit, tax-exempt organization. Sati Center supports the study and application of Buddhist teachings. We take very seriously the privacy and security of the information that individuals choose to share with us. It is the policy of Sati Center to collect, use, and maintain information from participants in our activities (“participants,” or “you”) that is necessary and helpful to running our organization and fulfilling our mission in a manner that respects your privacy interests and rights and provides security. This privacy policy applies to information collected through our website, other applications (including mobile applications) (“Apps”), and any other interactions we may have with you (collectively, the “Services”). It is intended to notify you of our policies and practices so that you have knowledge of our activities and a basis to consent to our use of information received from you.

Please read this policy carefully. We will post any changes to it here so that you will always know what information we gather, how we might use that information, and whether we will disclose that information to anyone. Sati Center may need to adjust its privacy and security policy in the future and reserves the right to change this privacy policy at any time.  By using our Services, you consent to the data practices described in this statement.

INFORMATION COLLECTED BY SATI CENTER

We collect people’s information provided directly to us in the following fashion.  When participants apply for our class offerings, we collect participants’ information through their application or enrollment forms.

Online donations to Sati Center through the Sati Center web site are done via Paypal. Sati Center does not collect or store individual’s information when the donations are made.

Usage Information. Usage Information may include IP address or other device identifiers, the type of browser, device, and operating system a user employs, the URL that referred users to our Services, how and when users interact with our website,  and other similar information. We do not actively collect such information. However, they can be automatically collected either directly or through a third-party service provider as they visit or interact our website.

If you would like us to remove your information collected via the class application process, please contact us at karuna@sati.org.

HOW SATI CENTER MAY COLLECT INFORMATION

Directly from Participants. As noted above, we may collect personal information directly from participants through the course application process when they apply for our class offerings.

Automatically through Cookies and Other Tracking Technologies. When you access or use our website, certain information about you may be automatically collected, including:

  • Log Data. As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, device identifier, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, and other usage data. We use log data to monitor use of our sites and services, for security purposes and for technical administration.
  • Device Information.  We may collect information about the device you use to access our web site, while hardware model, operating system and version, unique device identifiers and mobile network information is accessible through your use of the website, we do not actively use this information.

This information is largely collected using cookies and other tracking technologies automatically. We and our service providers may use various technologies to collect information relevant to the performance of our website, and electronic communications, including cookies (both session and permanent cookies) and web beacons.  Cookies are small data files stored on your hard drive or in device memory that help us to, among other things, improve services through our website and your online experience, see which areas and features of our services are popular, and count visits. Web beacons are clear, electronic images that may be used in our online services or in our emails and help deliver cookies, count visits, understand usage and communication effectiveness and determine if an email has been opened and acted upon.

We do not use cookies for collecting any personal information about you but do use them to collect other anonymous data in order to administer our website and online services. We do not use cookies or any other mechanism to profile your activity on other websites. Session cookies are automatically deleted after use, once all of your browser windows are closed down. Permanent cookies may be deleted, and doing so will not affect your ability to use our website.

You can set your internet browser software to disallow the use of cookies. You will find instructions on how to do this in the Help facility of your browser software. But please note that some forms on our website may require the use of session cookies for correction operation, and disallowing cookies will prevent you from using certain aspects of our website or app. You can find out more about cookies at https://en.wikipedia.org/wiki/HTTP_cookie.

HOW AND WHY SATI CENTER COLLECTS AND USES INFORMATION

Legitimate Organization Interests. It is our policy to collect and utilize information collected from participants that will aid in the pursuit of our organizational mission and as necessary, while accounting for and respecting participants’ interests and rights. Our mission includes introducing individuals and deepening their contact with the teachings of Buddha and related activities. Our guiding policy is that we collect information in furtherance of our mission and to assess how effective we are in pursuit of our mission, and not for other purposes.

Service Communications. We may contact you using the email address you provide to us for informational and operational purposes, such as delivering course communications.

Organization Announcements and Marketing. We do not rent, sell, or share personal information about our participants with other people or nonaffiliated companies for their direct marketing purposes. We do not use your personal information for marketing purposes.

Specific User Request or Consent. We process user information by request, for example, to deliver user-requested materials or to respond to an inquiry with user consent.

Aggregate Data. We may de-identify and aggregate data collected through the Services and use it for any purpose. It is important to remember that such information does not identify you individually.

Legal Obligations. We obtain and maintain some information to comply with legal obligations (e.g., records for sales tax collections), and we may be required to share certain information in response to a lawful request (e.g., insurance).

HOW SATI CENTER MAY SHARE INFORMATION

As Required By Law and Similar Disclosures. We may access, preserve, and disclose Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement requests and legal process, such as a court order or subpoena; (ii) respond to user requests; or (iii) protect users’, ours’ or others’ rights, property, or safety.

With Your Consent. We may also disclose your Personal Information or User Content with your permission.

Links to Other Sites. Our website contains links to affiliated vendor sites, such as social media sites. We are not responsible for the content or the privacy practices employed by those other sites. A link to another website does not constitute endorsement of that site or any of the content or information provided by that site.  We encourage our users to be aware when they leave our Site and to read the privacy policies of each website that collects personal information.

SECURITY OF YOUR INFORMATION

We take steps to ensure that personal information is treated securely and in accordance with this Privacy Policy. The methods we use to safeguard data include deleting user data as soon as it becomes unnecessary, limiting access to user data to specific individuals, and avoiding the collection of data we believe is unnecessary.

With respect to the deletion of data, our practices are as follows:

  • Deletion of Collected Information:  We delete all application information when class is completed except for people’s names and email addresses; we sometimes use these email addresses to send follow up emails after a class is complete or occasionally send information about a future, related class. The exception is for participation in courses that are part of specific program, such as a certification program, where we need to keep a record of course participation and completion.
  • Deletion by Request: A participant may request the deletion of his or her information. We will honor requests to delete personal information.

Unfortunately, the Internet is not completely secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using or receiving our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our website or by sending an email to you. You may have a legal right to receive this notice in paper or hard copy format. To receive free written notice of a security breach in paper or hard copy format (or to withdraw your consent from receiving electronic notice), please notify us at karuna@sati.org.

USER RIGHTS AND CHOICES

To Be Informed. You have the right to be informed about our data policies. This Privacy Policy is one of the tools we use to ensure customers understand when and why we collect data, which data we collect, and the uses we have for the data.

Correction.  You have the right to correct, amend, or delete personal information if it is inaccurate. You can submit correction requests to karuna@sati.org.

Portability: You may request to obtain certain data from us, in a generally readable format, and will be provided with a file containing their data. Alternatively, a file with your data may be forwarded to another entity at your request.

Utilization of Browser-Enabled Controls and “Do Not Track Requests.”  Your Internet browser and mobile device may allow you to adjust your browser settings – for example, you may be able to disable the use of cookies – so that “do not track” requests are sent to the websites you visit. Sati Center respects your wishes and will not track user activity once “do not track” signals have been activated.

California Privacy.  If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by Sati Center or its affiliates to a third party for the third party’s direct marketing purposes. To make such a request, please send an email to karuna@sati.org.

European Union Data Protection.   If our processing of your information is subject to the General Data Protection Regulation 2016/679 (“GDPR”), we have additional obligations and you have additional rights under the GDPR.  These rights and obligations are as follows:

We will process your personal data in order to provide the Services.  The lawful bases for processing your data may include:

  • When you have given consent
  • When processing is necessary for the offering of a class to which you are a party or in order to take steps at your request prior to the start of the class
  • When processing is necessary to protect our legitimate interests or that of a third party, except where such interests are overridden by your interests or fundamental rights.

We may rely on more than one of the lawful bases for processing your information described above.  If our processing is based on your consent, you have the right to withdraw the consent at any time.  However, if your consent is necessary in order to complete a transaction or provide a service you have requested, we may no longer be able to complete the transaction or provide the service. Subject to your right to erase personal data, we will store your information for as long as necessary for us to provide the Services.

You have the right to be informed about your personal data and how it is being processed, to access, correct and erase personal data, to restrict further processing, to obtain and reuse your data for your own purposes across different services and to object to processing.  You also have the right to lodge a complaint with the relevant EU supervisory authority.

If your information is transferred to us or to another recipient in a manner that requires to leave the boundaries of the European Economic Area (“EEA”), we will ensure that at least one of the following shall apply:  (i) the transfers will be to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; (ii) we have used specific model contracts approved by the European Commission which are intended to give personal data the same protection it has in Europe; (iii) where we use providers based in the US, we may transfer information to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between the Europe and the US, provided that if a competent authority determines in the future that Privacy Shield offers insufficient protection, we will utilize a different transfer method; or (iv) any alternative transfer mechanism that can under GDPR lawfully support the transfer.  Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Erasure: You may ask for your data to be erased from our system. We will comply with a request to erase all your data, even though this means we will no longer be able to serve this individual as a participant, and all services will be revoked.

Restriction of Processing: You may place a restriction on the processing of your data, and the request will be accommodated. But please note that restrictions on processing your data may inhibit your ability to utilize the Services.

Objection to Processing: A user may, at any time, object to our processing of his or her data. We will stop all processing of your data. If an objection was raised with respect to processing of data that is essential to the performance of our Services, we will no longer be able to provide the Services to you.

CHILDREN’S PRIVACY

Our Services are intended for adults older than 18 years of age, and we therefore do not knowingly collect, maintain, or use personal information from children under 18 years of age without parental consent, and no part of the Services is directed to children under the age of 18. If you learn that a child has provided us with personal information without your consent, you may alert us at karuna@sati.org. If we learn that we have collected any personal information from children under 18 years of age without parental consent, we will promptly take steps to delete such information.

INTERNATIONAL USERS

All personal information is stored on servers in the United States and is subject to American law. We also reserve the right to obtain and store data on servers located elsewhere. By choosing to use the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the state of Washington.

If you are visiting our website from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information you consent to any transfer and processing in accordance with this Privacy Policy

DATA RETENTION

We will retain your application information for as long as the class is active or as needed to provide you the Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION

If you would like to update or modify any personal information you have provided to us, you can do so by sending us an email to karuna@sati.org. If you have any questions or concerns about this Privacy Policy or the use of your information, please contact us at karuna@sati.org.

CHANGES TO OUR PRIVACY POLICY AND PRACTICES

Posting of Revised Privacy Policy. We may update this Privacy Policy to reflect changes to our information practices. We encourage you to periodically review this page for the latest information on our privacy practices.

ACCEPTANCE OF PRIVACY POLICY

By using www.sati.org or otherwise providing information to us, you signify your acceptance of our Privacy Policy. If you do not agree to this policy, we ask that you refrain from using this site or our Services. Your continued use of the Sati Center site following the posting of changes to these terms will mean that you accept these changes.

CONTACT INFORMATION

SATI CENTER FOR BUDDHIST STUDIES
karuna@sati.org

108 Birch St.
Redwood City, CA 94062
650-241-9108 (voicemail)