Privacy Policy | ayuwave

Your privacy

Please read this Privacy Policy carefully to understand our practices regarding your personal data and how

we will collect, use and store your personal data. We may update this policy from time to time so please

check it regularly. If there are significant updates, we will inform those people with whom we are in regular

contact, such as members and email subscribers.

1.Who we are

Ayuwave Limited and Sandhana Consulting LLP are two separate entities:

1. Ayuwave Limited

Ayuwave Limited is a private limited company governed by a Board of Directors through which we provide

our clinical ad therapeutic services, products development and sales, events, practitioner training and

development.

2. Sandhana Consulting LLP

Sandhana Consulting is a Limited Liability Partnership through which we provide academic research and

consultancy.

We refer to these two entities collectively as “Ayuwave’’ throughout this policy, and references to “we” and

“us” refer to the Ayuwave entities collectively.

Ayuwave Ltd and Sandhana Consulting LLP may each be data controllers of your personal data. They each

have different roles, but some activities they undertake overlap and personal data may be shared internally

for certain purposes. Information may be shared between them to facilitate, support and integrate their

respective activities, for example, Ayuwave Limited may administer invoices and payments made to

Sandhana Consulting LLP, who are themselves responsible for promoting and running an event. Where

possible and appropriate, we do try to be clear which entity is collecting your information and to explain

which entity does what, but there is inevitably some overlap.

Ayuwave Limited and Sandhana Consulting LLP are both registered at Apartment 114 Arizona Buildings,

Deals Gateway, London SE13 7QQ. Services are provided from our clinics in London, Milan and Zurich and

from our partner centres in India and Italy.

2.What personal data we collect and the purposes for which we use it

2.1 What personal data do we hold?

Some examples of the type of information we may collect and hold about you are as follows:

your full name and your title or an indication of the gender that you most closely associate with;
birth date or alternatively a relevant age range;
postal address;
telephone number(s);
email address;
records of your correspondence with us;
bank or credit card details (if you purchase something from us or donate to us);
donation and gift aid details (if you donate to us);
information you enter into our websites and digital products and details of how you use those
websites and digital products (more details can be found in our cookie policy at kew.org/cookies);
dietary, accessibility, and mobility information;
Photographs and digital images of individuals
But we may also collect, hold and process other personal data where it is appropriate and relevant, for
example:
details of why you have decided to contact us and how you may have heard about us and the work
that we do;
details of how you would like to be involved and what you intend to do with the information we
provide;
personal data about you that will enable us to be more precise in what we send you or how we
approach you; and
for purely business-related reasons, including managing relationships with third party and partner
organisations.
We will only process sensitive personal data also known as special categories of data (eg. in relation
to your health), with your explicit consent, for reasons of substantial public interests or where
necessary for the establishment, exercise or defence of legal claims.

2.2. How and why will we use this personal data?

2.2.1 We will use your personal data to:

provide you with the information, product or service you have requested from us, including such
things, specific events that we run, merchandise from our online shop, responding to your enquiries
and requests, attending educational activities and events, and to tell you about our work and our
fundraising;
provide you with other information which we feel may interest you. This may include newsletters,
tips, updates, information in relation to fundraising campaigns, voluntary surveys or questionnaires
for you to complete, details of any promotions and competitions we are running. We may also
send you details of events we think you may be interested in attending;
analyse and understand how people use our websites and digital products so we can improve and
personalise the experience for users and reflect your preferences and previous interactions;
keep a record of our relationship with you;
improve how we communicate with you, how we fundraise, and how we operate more generally;
keep in contact with you in the ways that you have requested or agreed to;
personalise our services and communications to you (for example, to ensure that they consider
your age, location and previous involvement with Ayuwave);
provide you with information about carefully selected third party events, products, campaigns and
competitions, where we are permitted to do so;
notify you about changes to our services;
administer and process payments you make for products, services and charitable donations made
to any of our entities;
verify your identity where required to use some of our services and benefits;
comply with applicable laws and regulations and requests from statutory agencies including for
such purposes as health and safety; the detection and prevention of crime and safeguarding; and
carry out any obligations or provide you with any other services, functionality or content which you
specifically request or agree to.

2.2.2 For the avoidance of doubt, Ayuwave does not use personal data for automated decision-making

which produces legal effects or similarly significantly affects individuals. However, Ayuwave may use profiling

techniques in certain circumstances for the purpose of evaluating personal data to provide you with more

targeted marketing and for the purpose of segmenting our database of clients and visitors so that we can

communicate with you in the most relevant way possible. In some cases, we use cookies to do this. Our

Cookies Policy (at ayuwave.com/cookies) explains in further detail the types of cookies we use to allow us to

do this.

2.3. Fundraising

Charitable giving is very important to Ayuwave’s ability to achieve its mission. We carry out a wide variety of

marketing activities to seek individuals’ support for our work, ranging from appeals for small one-off

donations, to large fundraising initiatives for specific projects, such as supporting children in the Doman

Foundation. We want to ensure that we are contacting you with tailored and appropriate communications,

and ensure we direct our resources and fundraising activities as efficiently and effectively as we can. We

also want to communicate with you from time to time to thank you for your support and tell you what we

have achieved with the help of your donation.

2.4. Research and profiling using information in the public domain

2.4.1. In order that our fundraising is appropriate, respectful, efficient and effective, we tailor our approaches

to different people in different ways. We use information you have given us, sometimes together with data

we collect from publicly available sources, to help us decide how best to do this.

2.4.2. For a small number of people, we may undertake research using publicly available information

relating to philanthropic activities, wealth and capacity to give, to create a profile of interests and

preferences. This helps us understand the background of the people who we believe may be willing to

attend events and enter a dialogue with us to learn more about supporting our work and

organisation. Ultimately it helps us to ensure that proactive requests for gifts are directed to only those who

we believe may be able and willing to give. This information is collected from public sources such as news

articles, Companies House, the Charity Commission, Who’s Who as well as specialist charity research

sources. Very occasionally we may work with similar organisations to undertake this research

collaboratively.

2.4.3. If we do collect such information about you, whether jointly or on our own, we will inform you within

one month of collecting this information in order to provide you with an opportunity to opt out of your data

being used for these purposes. You can also opt out by emailing us on privacy@ayuwave.com.

2.4.4. We also have an obligation to ensure we are undertaking appropriate due diligence on potential

donors, in accordance with guidelines set out by the Charity Commission and the Fundraising Regulator,

and we may collect information from the public domain information for this purpose too.

3.What lawful bases do we rely on to use your personal data?

The legal bases that we rely on for processing your personal data are:

3.1. You have provided us with your consent to use your personal data for a specific purpose:

We will ask for your consent to use your personal data to send you marketing emails and SMS.

You always have the right to withdraw your consent at any time.

3.2. It is necessary in connection with the performance of a contract with you:

Sometimes it is necessary to process your personal data so that we can enter contractual

relationships with you. For example, if you purchase something from our online shop, or become a

patient we will require your personal data to enable us to perform our agreement.

3.3. It is necessary for compliance with a legal obligation to which we are subject:

This would include where we must retain certain records, for example, to manage health and safety,

for the detection and prevention of crime, safeguarding obligations, for maintaining suppression lists

to ensure we comply with marketing laws, for tax reasons (such as those related to gift aid donations)

and undertaking due diligence before accepting certain donations or entering certain relationships.

3.4. It is within our legitimate interests:

Applicable law allows personal data to be collected and used if it is reasonably necessary for our

legitimate interests or a third party’s legitimate interests (if the processing is fair, balanced and does

not unduly impact individuals’ rights). We will rely on this ground to process your personal data

when it is not practical or appropriate to ask for your consent, and where we are confident that this

will not impact your rights. This may include where we undertake research on individuals including

before we proactively contact them, as set out in Sections 4.2 and 4.3.

Our legitimate interests include raising funds for a wide range of activities to support our charitable

objectives. We have a legitimate interest in publicity and income generation, campaigning and

fundraising to support our charitable objectives and undertaking due diligence to establish the

provenance of donations that are made, or may be made, to us.

Where you have provided your details to us, we may contact you by post and phone for certain

marketing and fundraising activities as set out in section 5 below (but we will explain this to you at

the point that we collect your details). You can opt out of this activity at any time by emailing us on

privacy@ayuwave.com.

We will also rely on our legitimate interests for the proper administration of Ayuwave, and to manage

our operations (for example, maintaining appropriate records and databases, for the detection and

prevention of crime and safeguarding all those who access our premises and facilities).

When we process your personal data to achieve such legitimate interests, we consider and balance

any potential impact on you (both positive and negative), and your rights under data protection laws.

We will not use your personal data for activities where our interests are overridden by the impact on

you, for example where use would be excessively intrusive (unless, for instance, we are otherwise

required or permitted to by law).

Please see section above for the limited legal basis for when we process sensitive personal data.

4.How we collect personal data

We collect information about you:

4.1. When you give it to us directly

You may give us your personal data to receive information from us; visit our facilities; buy products

or services from us including such things as taking part in any of our community programmes (or

request information about these); when you donate to us; when you respond to a survey or when

you otherwise engage with us on our websites and digital products.

4.2. When a third party provides us with your personal data

Your personal data may be shared with us by third parties in certain circumstances. This may include

(but is not limited to) individuals who may purchase products or services on your behalf, schools or

other institutions who work with us or receive our services, by mutual contacts who recommend you

to us or buy goods and services on your behalf or as a gift, and by our partners who may host and

run events (or help to run and host events) at our premises, or run competitions or prize draws jointly

with us. Where appropriate you should check any Privacy Policy of any third party when you provide

your personal data to them to understand fully how they will process your personal data.

4.3. When it is available publicly

We may combine personal data you provide to us with personal data available from external publicly

available sources such as Companies House and published articles and newspapers. Depending on your

privacy settings for social media services, we may also access personal data from those accounts or

services. We use this personal data to gain a better understanding of you, and to improve our

communications and fundraising approaches (see section 3 above).

4.4. When you use our websites and digital products

We may collect personal data about you when you use our websites and digital products. Whenever you

input personal data into our website (for example, if you purchase a product or request information,

support us through our website, or download any of our resources), we will collect the personal data that

you give to us.

We use “cookies” to identify you when you visit our websites and digital products. Amongst other things

this helps us to understand our website users and may enable us to improve the website experience for you

and/or other users. Please refer to our Cookies Policy for details on how and why we use this data at

ayuwave.com/cookies.

We may collect other personal data from your use of the websites, such as your IP address and access

times.

We may link our websites directly to other sites. This privacy policy does not cover external websites and we

are not responsible for the privacy practices or content of those sites. We encourage you to read the

privacy policies of any external websites you visit.

5.Communications and marketing

5.1 We may contact you by post and telephone, and, where you have provided consent, by e-mail, to let

you know about our events and activities (and we may also mention those of third parties, particularly

where they are collaborating with us or sponsoring our events) that might be of particular interest to you;

retail offers and promotions, or about the work of Ayuwave more generally; and to request donations and

provide you with information about and the opportunity to participate in our fundraising activities. We

provide the opportunity for you to opt-out from receiving our marketing communications every time we

contact you.

You can opt-out from receiving our marketing communications, or update your contact preferences at any

time by emailing:

5.2 Social media targeting

If you are a social media user, we will use certain social media tools as part of our relationship with

you. These tools include such things as Facebook and Instagram Custom/Lookalike Audiences, Google

Customer Match/Similar Audiences, Twitter Tailored/Lookalike Audiences and LinkedIn Matched Audiences.

Through using these tools, we will provide some of your data to the social media platform / organisation to

allow them to identify your social media profile with them. The social media platform / organisation will

then show you relevant advertisements relating to Ayuwave which we think you will be interested in seeing

on your newsfeed.

The social media platform / organisation will also use your profile to identify those with similar characteristics

to you who we think may also be interested in finding out more about Ayuwave and the work we do. These

identified individuals will then be shown advertisements about Ayuwave on their newsfeed. This activity is

governed by the social medial platform’s own privacy policy and terms and conditions, so please do refer to

these documents if you require any further information about this activity.

6.Data sharing

We do not sell your information under any circumstances. We may from time to time share your personal

data with third parties for them to use for marketing purposes or for us to use jointly with a third party

where we are embarking upon a joint fundraising project. However, we will only ever do this where you

have given us permission to do so or where we are carrying out joint research as detailed in section 2.4.2.

We may also, in certain circumstances, receive your details from charitable giving platforms such as Just

Giving, in accordance with a platform’s privacy policy. For example, where you donate to Ayuwave through

an online platform, they may then give us your address so that we can write to you and say thank you.

Please do review any such policies before giving your data to these platforms, to ensure that you are happy

for your data to be shared in this way.

Ayuwave Ltd and Sandhana Consulting LLP may share your personal data between themselves, so if you

give your information to Ayuwave then this may be shared with Sandhana Consulting LLP, for

example. Your personal data will only be shared between the entities for the purposes set out in section 2.2

of this policy.

We work with service providers and other third parties who help us to operate and to provide and improve

our information, products and services, and we may share information with them for this purpose.

Whilst we may allow our staff, consultants and/or external service providers acting on our behalf to access

and use your personal data for the activities we have described in this policy (e.g. to provide services or

products to you, deliver mailings, to analyse data and to process payments), we only permit them to use it

to deliver the relevant information, goods or services, and only if they apply an appropriate level of security

protection.

We may need to disclose your personal data upon request to regulatory and government bodies as well as

law enforcement agencies. We may also merge or partner with other organisations and in so doing,

acquire or transfer personal data but your personal data would continue to be used for the purposes set

out above.

The personal data we collect from you may be transferred to, shared and/or otherwise processed by

organisations or companies outside the European Economic Area (“EEA”). Where your personal data is

transferred outside the EEA, we will take reasonable steps to ensure that the recipient implements

appropriate measures to protect your personal data (for example, by including EU Commission approved

standard contractual clauses).

Unfortunately, the transmission of personal data 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 personal data

transmitted to or via our websites and digital products; any transmission is at your own risk. If you have any

questions about the international data transfer of your personal data, please contact us using the details

below in section 12.

7.Children's data

We may collect and manage personal data about children in some circumstances, such as where children

participate in our services or have requested to receive certain communications from us, such as

newsletters. Those aged under 13 are not permitted to receive our newsletters, or enter any competitions

or prize draws with us. We will not knowingly have any other direct contact with those aged under 13.

Where consent is required to process children’s personal data and the child is under 13 years, where

appropriate we shall seek consent from a parent or guardian or shall ensure such consent is in place before

any data is shared with us. We shall only hold personal data about children that is necessary for the

event/programme that they are applying for or participating in.

Where a parent or guardian gives consent on behalf of a child, we may contact that child after their 16th

birthday, to check if they wish to maintain their relationship with us.

8.How we keep your personal data safe and who has access to it

We are committed to ensuring that there are appropriate technical controls in place to protect your

personal data including protection from misuse and unauthorised access. For example, our network is

protected and routinely tested.

Your information is only accessible by staff and contractors who are bound by appropriate policies and

procedures to protect your information

9.Your rights

Please note that you may only use/ benefit from some of the following rights in limited circumstances. For

more information, we suggest that you consult guidance from the Information Commissioner’s Office (ICO)

– - or please contact us using the

details in section 12 below.

9.1.Right to restrict processing

In certain circumstances as outlined in the ICO guidance referred to above, you have a right to require us to

stop processing your personal data in a particular way.

9.2.Right to erasure

You have the right to request that your personal data is erased from our records in certain circumstances.

9.3. Right of access

You have a right to ask for a copy of the personal data we hold about you. If you want to access your

personal data, please send a description of the personal data you want to see and proof of your identity by

post to The Privacy Team, Apartment 114, Arizona Building, Deals Gateway, London SE13 7QQ

9.4. Right to rectification

We also want to make sure that your personal data is accurate and up to date. Please let us know if your

details change. You may also ask us to correct or remove personal data which is inaccurate.

9.5. Right to object

You can also opt-out of receiving all or some of our marketing/ fundraising communications or request that

we stop processing personal data about you for certain purposes at any time by contacting us using the

details below.

9.6.Right to data portability

In certain circumstances you have a right to data portability which means we will provide you (or a third

party you nominate) with your personal data in a structured, commonly used and machine-readable format.

10.Complaints

If you are unhappy with the way in which we have handled your personal data, please contact us using the

details below.

Please let us know if you have any queries or concerns about the way that your personal data is being

processed by us by contacting us on the details below. You are also entitled to make a complaint to the

Information Commissioner’s Office. For further information see the Information Commissioner’s guidance

here

11.Data retention

We keep personal data for as long as there is a need to keep it in connection with the purposes for which it

was collected. We may keep your personal data after a particular matter or exchange has concluded but

purely for record keeping purposes and to be able to respond to queries. In some cases, we are also

obliged to retain your personal data to comply with legal or statutory obligations (for example, to keep

records of contractual or financial matters).

Whilst the specific time periods vary depending on the circumstances, in general we will not keep records

that include personal data for more than 10 years after a particular matter or exchange has concluded. If

you ask us to stop sending you marketing communications, we will retain certain details, such as your name

and email address, but only to ensure that you are not contacted again.

12.Contact

For all enquiries in respect of this privacy policy, please contact or The Privacy Team,

Apartment 114, Arizona Building, Deals Gateway, SE13 7QQ.

13.Websites and digital products

In this policy “websites and digital products” refers to all Ayuwave websites, including the primary Ayuwave

website found at and all our digital products, such as email, applications and

digital channels, including social media.

14.Changes to this privacy policy

We keep our privacy policy under regular review. This privacy policy was last updated in April 2018.