The Held Space Privacy Policy

Last Update: 17 December, 2023

POLICY STATEMENT

The Held Space takes data privacy very seriously. We recognise the importance of protecting and respecting your personal data. This Privacy Policy describes the information we collect, how we use that information, to whom we pass the information, your rights and key contact information.

  1. Overview

In order for you to participate in one of our programs or retreats, we need to collect certain personal information about you. Our aim is not to be intrusive, and we won’t ask you unnecessary questions. Any information we receive about you will be subject to strict controls to minimise the risk of misuse, including unauthorised access to, or disclosure of, your personal data.

Please read this notice carefully, together with our “Terms and Conditions to Agreement and Process Ground Rules” and any other documents referred to in it. Here we set out the basis on which any information we collect about you or from you, or that you provide to us, will be processed by us and other parties so that you can participate in one of our programs or retreats.  The Held Space (referred to as “our”, “us” and “we”), commit to using your information only in accordance with the terms of this Privacy Policy.

For the purposes of this Privacy Policy, the term “information” means any confidential and/or personal data or other information related to users of The Held Space Services – including, but not limited to, corporate and individual customers and their connected parties.

By visiting this website, our partners’ websites, or providing your personal information to one of our employees, for example by telephone or e-mail, you accept and expressly consent to our use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy.

This includes consenting to the processing of any sensitive personal information you provide, as described below in Section 2. It also includes information you provide when you browse our social media sites or website, request to be added to our newsletter database, request more information, schedule a call with one of our Retreat Concierges, request a quote, participate in one of our programs, retreats, or volunteer events, enter a competition, promotion or submit a survey and when you contact us for other reasons.

If you have concerns about any of the terms of this Privacy Policy, please contact us at privacy@theheldspace.co.uk so that we can provide further information.

A special note about children

Children are not eligible to use The Held Space. We respectfully ask that minors (persons under the age of 18) do not submit any information to us or use The Held Space.

What information we collect

Information you provide to us

You may provide us with information when you browse our social media sites or website, request to be added to our newsletter database, request more information, schedule a call with one of our Retreat Concierges, request a quote, apply for or participate in one of our programs, retreats, or events, enter a competition, promotion or submit a survey and when you contact us for other reasons.

Initial information & Information we may collect from you

  • When you request information or contact us in the ways described above, we may capture your name, e-mail, Skype Name, phone number, gender, date of birth, nationality, profession, address, special skills, and course experience and feedback.

  • When you apply for one of our retreats, we collect highly confidential and personal sensitive data, including information about your mental, emotional, and physical health, any disability, life experiences, past trauma, and current issues, as well as criminal background (if relevant) and why you would like to do the workshop or retreat. It is important we gather this information to ensure your retreat experience is as beneficial as possible based on the individual issues that you are working with. We do not collect or use any other types of sensitive data. If you do reveal other sensitive data, for example in an e-mail, you will be giving express consent for us to process that information by storing the e-mail or other communication.

  • In order to pay for attendance at a The Held Space program or retreat, you may be asked to provide debit/credit card details, including the card number, start and expiry dates and the card verification value code (CVV/CVC). If you require a refund for one of our programs or retreats, we may require your bank information in order to process this refund. In either case, your information will not be retained by us, but by the banking institution in the country where you have applied for the workshop, and/or PayPal according to their regulations.  PayPal is PCI compliant through PayFlow. We do not store credit card details nor do we share financial details with any 3rd parties. We only retain your name, e-mail address, payment date and payment amount.

When we communicate

When you communicate with us for customer service or other purposes, including by phone, e-mail or using other methods, we retain that information and our responses to you.

When we speak to you by telephone, Skype, Zoom or WhatsApp, we collect your name, e-mail, Skype Name, and phone number.

Information we collect when you use our website

When you use the The Held Space website we collect information about the device you are using, such as your IP Address, Browser type, Settings, Plugins and Plugin Settings, Device Type, Operating System, IMEI Number, MAC Address, Wired or Wireless Connection, Mobile or fixed-line phone carrier or network. When you are using our site we collect Google Analytics Metrics, Behavioural Information such as mouse-overs, clicks, cursor patterns, and site movements. When you arrive at or leave our website we collect to/from URLs, click-throughs from paid advertisements, search engines or links on partner websites.

We place 1st party cookies, 3rd party cookies, web beacons and similar tracking technologies. The cookies we place are persistent and can be blocked by adjusting your browser settings.

Information about 3rd Parties

If it is necessary for you to provide personal information about other individuals in the course of dealing with us, for example emergency contact names or phone numbers, you should do so only where you are authorised by those individuals.

Privacy policy notification to 3rd parties

Although the information on 3rd parties is stored for a certain period of time in compliance with applicable law, we will not use it to market to 3rd parties.

Additionally, these 3rd parties have the same rights to access and correct information about themselves as registered users of  The Held Space. You should bring this Privacy Policy to their attention at the earliest opportunity so they aware of how their information will be processed by us and aware of their rights in relation to that information.

Information about you from other sources

When you pay for your workshop through PayPal, your financial data is captured as described above. We otherwise do not collect information about you from other sources, except in the rare situation where you may leave a retreat early, the course leader or facilitator may provide you, and The Held Space, with a recommendation for follow-up work.

  1.  How we use your information

Our primary purpose in collecting your information is to provide you with a safe, therapeutic, meaningful, and customised retreat experience. We use this information to determine the suitability of the workshop for you. We appreciate the sensitivity of this information and will ensure it is kept secure and only used and disclosed when required to individuals who need to, including the workshop organiser, the organiser or facilitator conducting your pre-workshop interview, and the workshop leaders and facilitators. By submitting your information to The Held Space and using The Held Space you agree that we may use your information for the following purposes:

Fulfilling your requests

We will use your information to process your registration, ensure the workshop is a good fit for you at the time of your application, and so that we can provide you with the best retreat experience possible based on your individual needs.  We ask whether or not you have any criminal convictions, as that will help us determine the suitability of the retreat for both you, and for the other people on the retreat.  We use the photographs to identify you, for example, when you arrive at the retreat centre, and it helps make registration move more quickly and smoothly.

Communication and customer service

We communicate with our users on a regular basis via e-mail to provide requested services, including:

  • Responding to customer comments and inquiries;

  • Sending information and follow-on communications to those who have requested more information;

  • Sending guidelines for professionals and follow-on communications to therapists who have requested more information;

  • Communicating with you regarding your interest or registration in one of our retreats;

  • Sending recommendations for work you can do at home (such as poems to read or meditation practices) after some of our retreat programs.

If you opt in to our database, we use your e-mail to:

  • confirm your newsletter preferences;

  • send you information about important changes to our products and services, including notice of any times that our services may not be available; and

  • send notices and other disclosures required by law. 

We communicate with our users via phone, Skype, Zoom or WhatsApp to provide these requested services:

  • If you schedule a call with a Retreat Concierge, we may conduct this call via phone, Skype, Zoom or WhatsApp, based on your preference

If you do not wish to receive our service communications in a particular way, please contact us to advise us of your preferred communication method.

Marketing

We also use your e-mail address to send you other types of communications that you can control, including newsletters, after-workshop recommendations, customer surveys and special promotions. These communications are to:

  • Provide you with information about retreats or programs offered by The Held Space, or offer retreats or programs that are similar to those that you have already enquired about or attended;

  • Provide articles, blogs and videos, along with information on our deeply enriching, life-changing personal growth and development retreats and workshops;

  • Provide updates on the retreats or programs we offer, and promotional offers when available;

  • Measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, which may be based on your activity on our website;

  • Send information such as schedules for meditation evenings, tailored sales e-mails, drip campaign and manual sales e-mails, product news and update e-mails, and marketing offers;

  • Keep you informed in the area of personal growth and development; and

  • tell you about new products, programs or other projects we are developing that you may find useful or interesting.

You can choose whether to receive some, all or none of these communications and the methods by which you receive them by updating your preferences on our newsletter portal, or by e-mailing us and requesting an amendment of your preferences. One of our administrators will respond to your request in person, usually within 2 business days.

Device information 

We will use this information to improve and streamline our website design to offer a better user experience and product to the customer and a more effective conversion of prospects.

Location information / IP (Internet Protocol) address: 

We will use information about your location, derived from your IP address to:

  • Understand where our potential clients are located, so we know where best to offer our retreats and programs;

  • For segmental analysis based on your country.

Third party information

We will use anonymised third-party information collected from Google Analytics to:

  • Improve and streamline our website design to offer a better user experience and product to the customer and a more effective conversion of prospects.

  • Improve existing, and develop new, products, services, on and off-line marketing, and capabilities

  • To assess users’ interests and needs

Questionnaires, surveys, and competitions 

From time to time we may offer you optional questionnaires, surveys and competitions. If you choose to answer these questionnaires, surveys or competitions, we may use your information to:

  • Improve existing, and develop new, products, services, on and off-line marketing, and capabilities;

  • To collect demographic information for segmental analysis; and

  • To assess users’ interests and needs.

Post-workshop survey feedback will be shared with your The Held Space leaders and facilitators, as well as our office staff, to help us understand how people experience our workshops (from the beginning of the registration process to our aftercare), to study the effectiveness of our workshops, and to make improvements where recommended and needed.

You will be given notice of how the information will be used prior to your participation in the survey, questionnaire or competition.

  1.  Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site and to provide interest-based advertising. You may adjust the settings on your browser to refuse cookies but some of the services on our website may not work if you do so. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy. 

  1.  Sharing information with third parties

To support our business and provide services to you

The Held Space works with third-party service providers who provide important functions that allow us to review and understand website visitor behaviour, safely and securely store the data you send us and pre-workshop interview notes, send newsletters and communications (only upon opt-in), and administrate your registration in our workshops.

By accepting this Privacy Policy and ordering services from The Held Space, you expressly consent to the transfer of your data to those third parties for the purposes listed.

  • Google Analytics uses analytics metrics to review and understand customer behaviour on our site, including linking to your IP address.

  • Google Analytics and our website hosting provider use IP information to review and understand customer behaviour on our site.

  • MailChimp is our e-mail marketing service provider. When you opt-in to our newsletter database, your information is sent to MailChimp. Depending on the form you use to opt into our newsletter, the information sent to MailChimp may include your name, e-mail, country, and IP address. If you do not opt in, this information is not stored in MailChimp.

  • If you book a course or request information about a course through our Contact Form or through e-mail, your information is passed to a Retreat Advisor in the relevant country who will contact you about your booking or course availability, or to provide additional information about the course.

  • When you register for one of our courses, the information you submit is sent to either our SSL-protected Customer Management System, which is hosted by our website hosting provider, or to our Customer Relationship Management System, hosted by Salesforce. It is also sent to the workshop organiser, and to the facilitator who conducts your pre-workshop interview.

  • When you use our graduate virtual board (for retreat graduates), you are working on our website hosting provider server which is protected with an SSL certificate. We consider your private posts confidential information, and no information on the virtual board is used for any business or marketing purposes for any reason whatsoever.  Virtual boards are only accessible by the people indicated in the user section (which you can view from your login), and the system administrators, who never read or interact with posts, but have access only to assist with administrative issues such as password resets.

Credit card associations and legal process

We may also disclose necessary information in response to the requirements of credit card associations or a civil or criminal legal process 

We may disclose or share your information in order to enforce or apply the “Terms and Conditions to Agreement’and other agreements between you and us, or to investigate potential breaches to protect the rights, property, or safety of The Held Space, our customers, or others. This includes exchanging information with other companies and organisations and, if required, to obtain professional advice. 

Where required by law

We may disclose necessary information to the police and other law enforcement agencies where we are legally compelled and/or permitted to do so. 

Mergers and acquisitions

As with any business, it is possible that in the future  The Held Space could buy, merge with, or be acquired by, another company. We may disclose your information to the prospective seller or buyer of such business or assets, along with its professional advisers. If  he Held Space or a substantial proportion of its assets are acquired by a third party, information held by us about our customers will be one of the transferred assets, and such successor company would continue to be bound by this Privacy Policy unless and until it is amended.

Affiliates

If you are referred to us by a third party, either via our affiliate network or other promotion, depending on the arrangement we may notify them when you click through to our site, fill out an application, or attend one of our workshops or retreats.

Third party websites

Our site may, from time to time, contain links to the websites of our business partners, advertisers and affiliates.  Please note that these websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any information to third party websites.

  1.  Transferring data overseas

The Held Space is committed to adequately protecting your information regardless of where the data resides and to providing appropriate protection for your information where such data is transferred outside of the EEA.

The information that we collect from you may be transferred to, and stored in, a country outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for our suppliers. These staff may be engaged in the fulfilment of your request, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

The laws in some countries may not provide as much legal protection for your information as in the EEA. In these circumstances, our policy to protect your data is to rely on findings of adequacy by the European Commission (for countries in scope of those findings), the EU-US Privacy Shield (for transfers to the USA) or standard contractual clauses adopted by the European Commission or the UK Information Commissioner (for all other countries).

Each time you visit our website, opt-in to our newsletters or apply for one of our retreats, The Held Space may transfer the data to Google Analytics, our website hosting provider, IONOS or Squarespace or Salesforce, who may have data processing locations outside the EEA, in order to review and understand website visitor behaviour, safely and securely store registration form data and pre-workshop interview notes, send newsletters and communications (only with opt-in), and administrate your registration in our workshops or retreats.

By submitting your information and making use of The Held Space, you agree to such transfers, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.

  1.  Data Retention Policy

We are obliged by law to retain your data for 7 years after it is submitted. In some circumstances, such as an enquiry from a law enforcement agency, we may have to hold it longer. We may also retain information if required to protect our interests, for example in case of litigation. When data falls outside those retention periods we will take steps to delete it from our system. Where you have asked us not to contact you, we will retain that information on a ‘do not contact’ list to reduce the risk of us contacting you in the future.

  1.  Systems Security Policy

The Held Space has security measures in place designed to prevent data loss, to preserve data integrity, and to control access to the data.  Only authorised employees of The Held Space and our business partners processing data on our behalf have access to your personal data.  All The Held Space employees who have access to your personal data are required to comply with our privacy policy. All business partners are requested by The Held Space to ensure that any of their employees who have access to your personal data have signed non-disclosure agreements. Contracts with business partners acting as data processors for The Held Space involving personal data require an adequate level of security and require that personal data is processed only as instructed by The Held Space.

We will do our best to protect your information, however we cannot guarantee the security of information you send to us by e-mail or other non-secure electronic methods; any such transmission is at your own risk. Once we have received your information, we will use protective procedures and security features to try to prevent unauthorised access.

System security and monitoring

Our server is protected with an SSL certificate.  Where we use hosted services (such as Salesforce and our website hosting provider) we rely on their integrated security measures and you can read their security policies for added reassurance.

Password security

To control access to our virtual board, each person is required to input a username and password. To help us protect your information, you are advised to do the following:

  • Do not choose a password that could be easily guessed by another person.

  • Avoid using personal information such as your name, birth date or telephone number, or ordinary words found in a dictionary.

  • Memorise your password – do not write it down.

  • Never reveal the password to anyone else. We will never ask you for your password and you should not disclose it to anyone claiming to work for us or our business partners.

  • Do not use the same password on other services.

Customer responsibilities

We keep our security technology up-to-date to protect your information, but we do not have control over the devices you use to The Held Space.

It is your responsibility to safeguard your online information and transactions by taking all reasonable measures which may include the following:

  • Do not share your information or provide any opportunities for anyone to gain access to your information through your devices, including tablets, phones, watches or laptops.

  • Do not click on any internet link contained in an e-mail or SMS which directs you to a The Held Space website. Always manually type our address (www.thehealdspace.co.uk into your internet browser.

  • Log out and close your browser before visiting other websites once you have completed your transactions.

  • Ensure that you use the latest version of your internet browser and that you have up-to-date anti-virus, firewall and other security software installed on your device. 

  1. Customer rights

You have the following rights:

To ask us to correct any information we hold about you if it is incorrect.

Whilst we endeavour at all times to keep your information accurate, we welcome your corrections. You can correct your profile at any time by e-mailing us, and we will respond to you within 2 business days. 

To ask us to erase your information if we no longer have any reason to hold it, also known as the ‘right to be forgotten’. 

Our Data Retention Policy (see section 7) explains the circumstances when we can or are obliged to retain information, however outside of those periods we will delete your information in line with our data retention policy and on request. We will maintain a record that you made an erasure request to reduce the likelihood of us contacting you in the future but we will use that information for no other purpose.

To ask us to return to you information you provided to us, also known as ‘data portability’.

You can ask us to send you in electronic format the information you provided to us under consent, or for the performance of a contract between us. 

To ask us not to process your information where you previously gave consent or where we are exercising our legitimate interest.

If you make a request for us to stop processing your information, we will investigate to see if there is a compelling reason for processing to continue and will discuss the conclusion of the investigation with you.

You cannot object to processing which is a legal obligation or where we must process your information to satisfy a contract to which you are a party. If you previously gave consent and we processed your data on the basis of that consent, you cannot object to that past processing, however you can ask us to stop processing it in the future.

To ask not to be subjected to automated decision making and profiling. 

The Held Space puts the human factor at the heart of our customer service. We don’t carry out any profiling or other automated decision making.

To ask for a copy of the information we hold about you.  

We will endeavour to respond to your request within 30 days, however at time of high demand we may need 90 days to compile a full response.

To ask us not to process your information for marketing purposes.

You can do this by checking or unchecking certain boxes on the forms we use to collect your information, or by clicking on the ‘unsubscribe’ link(s) at the foot of every marketing or promotional e-mail, or by contacting us at privacy@theheldspace.co.uk

You may exercise any of the above rights by contacting us at privacy@theheldspace.co.uk

  1.  Contacting us

The Data Controller

The Data Controller is Leigh Carrick-Moore leigh@thehelsspace.co.uk

Contacting us with questions or requests

If you would like to exercise your right to access your information or have any questions about this Privacy Policy, The Held Space’s information practices, or your dealings with The Held Space, you can contact us via privacy@theheldspace.co.uk or leigh@theheldspace.co.uk  or by writing to us at 206 Royle Studios, 31 Wenlock Road, London, N1 7HS

Complaints to us

If you believe that we have breached a privacy law with which we should comply, please send an e-mail to privacy@theheldspace.co.uk  We aim to respond in a reasonable time, normally within 30 days. Our Business Manager will look after your complaint and will give you additional information about how it will be managed.  

Complaints to the UK Information Commissioner

You have the right to complain to the UK Information Commissioner’s Office if you believe we have not handled your request in an appropriate manner. For information on contacting the Information Commissioner please see their website.

 

  1.  Changes to this Privacy Policy

We may amend this Privacy Policy at any time, as new features are added to The Held Space or as we incorporate suggestions from our customers. Any changes we may make will be posted on the The Held Space website, so please check back frequently. 

Your continued use of our website and The Held Space services after a posting of a new version of this Policy will constitute your acceptance of, and agreement to, any changes. If you disagree with the terms of this Privacy Policy, please contact our Business Manager at privacy@theheldspace.co.uk