Palghar Vipassana Trust (registered address: gate no. 198/2A, Alyali, Palghar, Thane, Maharashtra 401404), registered as a Public Charitable Trust is responsible for managing Dhamma Vatika Vipassana Meditation Centre situated at, behind Alyali Cricket Ground, Alyali Village, Palghar 401404, with the website http://vatika.dhamma.org/ .
Palghar Vipassana Trust (hereinafter referred as “Dhamma Vatika” “or “Trust” or “Centre” or “we” or “us” or “our”) cares about privacy of our users (hereinafter referred as “user” or “users” or “applicant” or “student” or “you” or “your”).
The Trust aims to take great care when dealing with your data and your rights, in compliance with applicable rules and regulations, in particular, the information technology act, 2000 and the rules made thereunder.
The Information We Collect
- If you choose to register for a Vipassana meditation course via on-line platform, mobile app or conventional registration application (paper form, email, phone), the type of personally identifiable information that may be collected include: name, address, e-mail address, passport size photograph, telephone number, fax number, identity number of the photo identity document issued by the Government of India, passport number in case of the international applicants and all the other sensitive personal information that is called for on the application form. Generally, such information include date of birth, gender, profession, education, your medical information/history including mental health information, family relation & background, any special needs you may have, name of spouse, name of friends who are participating in the course, emergency contact, course history, donation details, PAN number in case of donations, native language and other languages spoken. Based on the details provided by you in your application, if required, we may request the additional information for proper evaluation of your application and to serve you in a better way.
- When you arrive at the Centre to attend the course, we will request you to bring duly signed application generated by the registration system or to fill out the physical copy of your application form.
- For the duration of the course we may store the keys and registration number of your vehicle, in case it needs to be moved in an emergency.
- In addition, if there are reasons why your application may not be accepted, or that your admission to a course should be subject to certain restrictions, prerequisites or qualifications, we may collect this information and the reason(s) thereof. Such decisions are based on data provided by you, but also on events or the observations made by the concerned persons or any past events/behaviour/records. Only the persons involved with the assessment have access to such information about you.
- As per the provisions of this policy, you have option of not providing your consent or the data requested by us. However, in that case, we will not be able to process your application or other request(s) any further.
Information our servers automatically collect when you access the website, such as your native actions that are integral to the website, including liking, re-blogging, or replying to a post, as well as other interactions with the website and other users via server log files.
The website/ any account created by the Centre with social networking sites to connect with the students, if any, may by default access your basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public from the social networking accounts, including, Apple’s Game Center, Facebook, Google+, Instagram, Pinterest, Twitter etc. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission for each such social networking site. For more information regarding such permissions, please refer to the permission preferences of the respective social networking sites.
The website/any account created by the Centre with social networking sites to connect with the students, if any, may access user information from social networking sites, such as Apple’s Game Center, Facebook, Google+, Instagram, Pinterest, Twitter, including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your account to such social networks. This information may also include the contact information of anyone you invite to use and/or join the website.
We may request access or permission to and track location-based information from your mobile or other device, either continuously or while you are using the website to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
We may request access or permission to certain features from your mobile or other device, including your mobile or other device’s bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
Device information such as your mobile or other device’s ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.
We may request to send you push notifications regarding your account or the website. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
In addition, we may send you text messages for certain events or details of group meditations/sittings, opportunities to serve. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the website the permission to access this information.
For the purpose of this policy, affiliates include joint venture partners, entities involved in the teachings of Vipassana meditation as taught by S. N. Goenka in the tradition of Sayagyi U Ba khin, or entities formed by Mr. S. N. Goenka/as per his guidance, any other entities that we control or that are under common control with us, entities with common goals as ours or any other sister concern.
Why we need your information
A Vipassana course can be very demanding. With the information you give us, we evaluate your application for admission to a course as a student or server and assess if you are mentally and physically capable of participating in a course or to serve.
We then use your information to:
- plan accommodation, sitting arrangement, food, providing proper infrastructure for instructions through audio/video modes, and transport;
- provide you with the special support (for e.g. hearing aid, native language discourses, translations of the instructions etc.) during the course;
- give you adequate guidance and assistance during the course;
- provide further useful information to you after your course;
- keep financial information for tax reasons, accounting purposes or other personal information required by law;
- To assist you, in any manner whatsoever within our capacity, in case you need the support after the course.
- We also use this information to process the data if you use ‘track application’ feature of the app or IVR facility offered by Vipassana Research Institute (VRI) or through a third party.
In certain cases, we need to keep personal details when course applicants are considered at risk of harming themselves or others, or the Centre or other Vipassana organisations/Centres in this tradition or our affiliates.
We have found that people who attend/serve a Vipassana course frequently also attend/serve subsequent courses over their lifetime. In order to facilitate subsequent attendance/serving at courses and to maintain a record of a student’s/server’s history and experience, we may maintain the data of each applicant indefinitely in the absence of a legal prohibition to do so. In particular, if you have been assessed as ineligible for participation in a course or serving a course in the future, or eligible only under certain restrictions, pre-requisites or qualifications, to protect your interest, we may keep this information indefinitely in the absence of a legal prohibition to do so.
Some people also apply for multiple courses at the same time in different Vipassana Centres or for back to back courses in a short span of time in the same Vipassana Centre, which is not beneficial for that particular applicant and is not fair for other applicants. Sometimes, due to heavy volume of applications, we are required to reject many applications. Upon applicant’s requests, we consider such applications for the later courses. In such cases, sometimes we need to verify and discuss with the applicant, if there is any major discrepancy in the information provided in the earlier application and information submitted in the applications for later courses. Considering all these aspects, we may maintain the data of each applicant indefinitely in the absence of a legal prohibition to do so.
- The Centre may store and use user’s name, postal address and/or email address to send the information about Vipassana related activities, facilities and newsletters, if users have not opted-out of such contact.
- The Centre may use the information that user provide about others while sharing the information or pages or media content to enable the Centre to send them user’s greeting and Centre website address.
- We may use the non-personally identifiable information that we collect to improve the design and content of our website and to enable us to understand requirements of our users, location of the user and which files users are accessing within the website, i.e., to use this information in the aggregate to analyse site usage.
- The Centre may use the relevant information to assist law enforcement, respond to subpoena, legal obligations and for other lawful purposes.
- The Centre may use the required information to deliver any content/product/newsletter or any other material as per the request of a specific user, whenever necessary.
- The Centre may de-identify and aggregate data collected through the Services and use it for any purpose. Such information does not identify you individually.
- To enable users to view and/or download books, newsletters, and to play/download audios and videos, as per user’s requirements.
In addition, the Centre may use the information for the following purpose(s):
- Compile anonymous statistical data and analysis for use, either internally or with the third parties.
- To perform necessary activities regarding various features offered through website.
- Create and manage your account.
- Send you an email regarding your account or donation.
- Fulfil and manage payments and other transactions related to the services offered through website.
- Generate your personal profile to make future visits to the website more personalized.
- Increase the efficiency and operation of the website.
- Monitor and analyse usage and trends to improve your experience with the website.
- Notify you of updates to the website.
- Perform any other activities as needed, to serve you in the best possible way.
- Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
- Request feedback and contact you about your use of the website.
- Resolve disputes and troubleshoot problems.
How we process your information
If you apply to attend a Vipassana course, or to give service, online or through a mobile app, or any other way, your data goes through a front end web portal called ‘scheduler’ to a registration software called ‘DIPI’.
Vipassana Research Institute (VRI), registered as a Public Charitable Trust, with its registered office at Green House, 2nd floor, Green street, Fort, Mumbai – 400 023, India, manages this registration software, a front end web-portal.
The Centre is responsible for the further processing of this data for the purposes mentioned above. When we process your personal information, we follow a set of principles according to our policies and applicable regulations. Subject to the applicable regulations, we store your information indefinitely to serve you in a better way, to safeguard interest of the Centre or the student(s)/server(s), for accounting, taxation, or because a special law requires us to do so and other regulatory purposes and for such other reasons as provided in this policy.
All the information is stored on the servers of the Amazon Web Services, located in Mumbai, India.
DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:
We do not ever make your personally identifiable information available to third parties, for commercial or any other reason. However, we may accept credit/debit card based donations, in which case, personal information related to those financial transactions is processed in the usual manner. Otherwise, we do not disclose your personal information outside of the facilities of regional, national and international Vipassana organizations in this tradition, our affiliates and their common infrastructure, except as provided in this policy.
Affiliated Vipassana organisations/Centres in this tradition who use the same registration software as ours will be generally able to view your attendance status, status of your application in other centres where you have applied and your address. In a rare and specific event, if a student/server has been placed in any kind of special list for such reason as mentioned in this policy, course registrars of other Centres will be able to view the details regarding the same as provided in the registration software.
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, regulation, or to assist law enforcement and respond to subpoena/summon. This includes exchanging information with other entities for fraud protection and credit risk reduction.
We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, IVR, email delivery, hosting services, or any other services.
When you post comments, contributions or other content on the website, your posts may be viewed by all users and may be publicly distributed outside the website in perpetuity.
For the welfare of the student(s)/server(s), the Centre or the local or regional Vipassana organization in this tradition may consider it necessary to take and retain notes on any health concern or behaviour in relation to the course that is inconsistent with the Code of Discipline or that otherwise indicates that a student should be restricted from attending or serve future courses or will need additional support during future course(s). In the rare event of this occurring, such notes will be entered on a computer and shared in confidence with assistant teachers and authorized course registrars involved in future courses or by entering necessary details in the registration software and by following such other procedures as may be required. Your attendance at a course or serving thereof will constitute unequivocal consent to the handling and storage of such notes and the cross-border transfer thereof subject to applicable laws, including those discussed below (“Specific Privacy Requirements”).
If you connect to the website through a social network, your contacts on the social network will see your name, profile photo, and descriptions of your activity.
Since the Centre and various Vipassana organizations in this tradition and our affiliates do not control the privacy policies of third parties, you are subject to the privacy customs and policies, if any, of that third party, and the Centre or any other vipassana organizations in this tradition and our affiliates shall not be responsible for the use or dissemination of your personal information by that third party. Therefore, we encourage you to ask questions before you disclose your personal information to others.
If you are using the website for the registration for the courses, you will be governed by the terms of additional policy for processing, disclosures and consents for course applications, which you can view while applying for the course.
In addition to the above, if required, the Centre may disclose your personal information with your consent.
A "cookie" is a text file containing a small amount of information which our server downloads to your personal computer when you visit our website. The file contains a unique number so that our server knows which PC/mobile/other device it is talking to. We create a session cookie when you use our online application form to register for a course. We may also use a session cookie to know whether you have logged in as an old student or not. Some cookies are allocated to your PC/mobile/any other device only for the duration of your visit to a website, and these are called session based cookies. These are automatically deleted when you close down your browser.
We may also partner with selected third-party vendors to allow tracking technologies on the website through the use of first party and third-party cookies, to, among other things, analyse and track user’s use of the website, determine the popularity of certain content and for better understanding of online activity. These software(s) may record data such as how often you engage with the services available on the website, the events that occur within the website, aggregated usage and performance data, and where the products/mobile app were downloaded from. We may link the data we store within the analytics software to any personal data you submit within the website.
As is true for 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 may combine this automatically-collected log information with other information we collect about you.We may use log data to monitor use of our sites and services, for security purposes and for technical administration.
In accordance with the U.S. Children's Online Privacy Protection Act of 1998 (and comparable legislation of other countries, including GDPR), we will never knowingly request or solicit personally identifiable information from anyone under the age of 18 without verifiable parental consent. In the event we receive actual knowledge that we have collected such personal information without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is practical.
SECURITY OF YOUR INFORMATION
We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please note that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security of your personal information.
Our application forms and the personal data contained therein are handled by storage and processing on computers. In addition, the computers of the different Vipassana organizations are located in various countries of the world. Your submission of an application form to attend one of our courses constitutes your unequivocal consent to the storage. In addition, in some cases the email service of a centre to which an application is submitted may be provided through Google/android apps and apple store. As a result, the handling of the data in your application to that centre is subject to the privacy and security policies of Google/ android apps and apple store, as set forth in their publications that are available on their websites.
User’s rights and choices REGARDING INFORMATION
You may at any time review or change the information in your account or terminate your account by:
- Logging into your account settings and updating your account.
- Contacting us using the contact information provided on the website to delete/deactivate the account or to delete the data provided by you.
After you deactivate your account or after deletion of your data upon your request, you will not be able to sign into the website or access any information stored in connection with previous receipt/account with our website. You may open a new account at any time.
Upon termination/deletion of your account and data on the website, you may not be able to avail the features like IVR facility, track the application etc.
If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:
- Noting your preferences at the time you register your account with the website.
- Logging into your account settings and updating your preferences.
- Contacting us using the contact information provided on our website.
If you no longer wish to receive correspondence, emails, or other communications from third parties, you are requested to contact the third party directly.
C.Controls for Do Not Track (DNT) features
The Centre, VRI, regional Vipassana organizations, affiliate entities may provide you with the opportunity to "opt-out" of having us/them send you e-mail or postal mail about our/their services or other information related to Vipassana including serving opportunities. In other cases, it may be possible for you to "opt-in" to certain local or regional Vipassana related distribution lists. If you choose to have your name, email address or other personally identifiable information removed from any of those databases, you can do so by contacting such local or regional Vipassana organizations, and request removal.
E.Specific Privacy Requirements
Please note that individual countries may have particular privacy law requirements. The Centre is committed to protecting the “rights and freedom” of individuals whose information it collects in accordance with such laws including but not limited to the General Data Protection Regulation (GDPR).
Pursuant to the applicable privacy regulations, you may have the following rights, among others, with regard to any data we collect or retain that relates to you:
- the right of access, i.e. the right to obtain confirmation as to whether or not personal data is being processed, and where this is the case, to obtain access thereto;
- the right to rectification and erasure, i.e. the right to have inaccurate data rectified and/or to have incomplete data completed, and the right to have personal data erased for legitimate reasons;
- The right to impose restrictions on the processing of personal data, i.e. the right to request the suspension of data processing for legitimate reasons;
- the right to data portability, i.e. the right to receive the data in a structured, commonly used and easily readable format, as well as the right to transmit the data to another data controller;
- the right to object, i.e. the right to oppose the processing of data where legitimate reasons for this exist, including data processed for marketing and profiling purposes, if this is envisaged;
- the right to contact the competent data protection authority in case of unlawful data processing.
You may exercise the rights listed above by writing to the Centre at [email protected] . In addition to the foregoing rights, each application form to register for a Vipassana Meditation course or related activity contains a series of disclosures and consents, which are also intended to protect your rights.