1.   INTRODUCTION  

This privacy notice provides you with details of how we collect and process your personal data through your use of our site  https://www.almaamor.com/

Our website, courses and services are intended for individuals aged 18 years or over. We do not knowingly collect personal data from children under 18.

MARIE JOHNSTON WARD, trading as ALMA AMOR SELF MASTERY TRAINING and registered with the Superintendencia Nacional de Aduanas y de Administración Tributaria (SUNAT) in Peru under RUC 15612759119, is the data controller responsible for the personal data described in this Privacy Policy (referred to as "we", "us" or "our").

Contact Details

Our full details are:

Full name of legal entity: MARIE JOHNSTON WARD

Email address: marie@almaamor.com

Postal address: Calle del Medio 742, Ollantaytambo, Cusco, Peru

Telephone number: +51 921017665

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at marie@almaamor.com

2.  WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT 

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

·       Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

·       Customer Data includes personal information collected when you purchase our products or services, apply for mentorship or participate in our programmes. This may include your name, billing address, email address, telephone number, purchase history, transaction records, payment confirmations, application details, onboarding information, participation agreements and programme-related communications. Payments are processed through third-party payment providers. We do not directly collect or store your full payment card details. We process this information to deliver our products and services, manage customer relationships and maintain appropriate business records. Our lawful basis for this processing is the performance of a contract with you, or taking steps at your request before entering into a contract. Where applicable, we may also process certain records to comply with legal obligations.

·       User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

·       Technical Data includes information about how you access and use our website and online services, such as your IP address, browser type, device information, pages visited, navigation paths and time spent on our website. We process certain technical information to operate, maintain and protect our website. Where we use optional analytics or marketing technologies, these are subject to your cookie preferences and applicable consent requirements. Our lawful basis for essential website administration and security is our legitimate interests in maintaining a secure and functional website. Where consent is required for optional analytics or marketing technologies, we rely on your consent.

·       Marketing Data includes information about your preferences for receiving communications from us, your subscriptions to our mailing lists, your interests in our courses and services, and your responses to our marketing communications. We process this information to send you relevant updates, educational content, invitations to masterclasses, information about our programmes and other marketing communications where permitted by law. Our lawful basis for sending marketing communications is your consent or, where permitted by applicable law, our legitimate interests. You can unsubscribe from marketing emails at any time using the unsubscribe link provided or by contacting us directly.

·       We may use relevant Customer Data, User Data, Technical Data and Marketing Data to understand interest in our products and services, improve our communications and measure the effectiveness of our marketing activities. Where we use advertising platforms or tracking technologies that require consent, we will obtain your consent before activating them. We will only send marketing communications where we have an appropriate lawful basis to do so, and you may opt out of these communications at any time. 

3. SENSITIVE DATA

Our courses, coaching and mentorship programmes are designed for individuals who are generally in good psychological health and are seeking personal development, greater self-awareness and self-mastery. Our services are not intended to replace psychotherapy, psychiatric treatment or other professional mental health care.

For coaching and mentorship services involving guided meditation, trance work or similar practices, we may request relevant health and lifestyle information to assess suitability and support safe participation. This may include medical conditions, medications, recreational drug use and alcohol consumption where these could affect participation.

During coaching or mentorship, clients may also voluntarily disclose sensitive personal information relating to their wellbeing or personal circumstances.

We collect and process sensitive personal information only where necessary for a specified purpose, with an appropriate lawful basis and any additional protections required by applicable data protection law, including explicit consent where required. Access to this information is restricted, and it is treated confidentially and used only for the purposes explained to the client or otherwise permitted by law.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at marie@almaamor.com In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

4. MARKETING COMMUNICATIONS 

We may send you educational content, newsletters, updates, invitations to masterclasses and information about our courses, programmes and services where we have an appropriate lawful basis to do so. We may process your personal data for marketing purposes on the basis of your consent or, where permitted by applicable law, our legitimate interests in promoting and developing our business. Where consent is required, we will obtain it before sending marketing communications. If you have purchased a product or service from us, or requested information about our offerings, we may send you relevant communications about similar products or services where permitted by applicable law and subject to any applicable consent and opt-out requirements. We will not share your personal data with third parties for their own independent marketing purposes without your express consent.

You may withdraw your consent or opt out of receiving marketing communications at any time by clicking the unsubscribe link in our emails or contacting us at marie@almaamor.com. Opting out of marketing communications will not affect our ability to send you necessary transactional, administrative or service-related communications, or to retain and process personal data where required for contractual, legal or other lawful purposes.

5.  DISCLOSURES OF YOUR PERSONAL DATA  

We may have to share your personal data with the parties set out below:

•       Service providers who provide IT and system administration services.

•       Professional advisers including lawyers, bankers, auditors and insurers

•       Government bodies that require us to report processing activities.

•       Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require third parties with whom we share personal data to respect its confidentiality and security and to process it in accordance with applicable data protection laws. Where third parties process personal data on our behalf, we require them to act only for authorised purposes and in accordance with our instructions, subject to applicable legal requirements. Certain third parties, including payment providers and professional advisers, may process personal data as independent data controllers under their own legal obligations and privacy policies.

6.  INTERNATIONAL TRANSFERS  

We operate from Peru and use third-party service providers to support our website, communications, payment processing, educational programmes and business administration. Some of these providers may process or store personal data in countries outside Peru, including countries in which they or their service partners operate.

Where personal data is transferred internationally, we take appropriate steps to ensure that the transfer complies with applicable data protection legislation, including Peru's Personal Data Protection Law (Law No. 29733) and its implementing regulations.

Depending on the circumstances and applicable legal requirements, these measures may include:

Where UK or European data protection legislation applies to a particular transfer, we will also comply with the relevant requirements under that legislation.

For further information about the international processing or transfer of your personal data, please contact us at marie@almaamor.com.

7.  DATA SECURITY  

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

8.  DATA RETENTION  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax and accounting purposes, we retain basic customer information, including contact, identity, financial and transaction data, for the period required by applicable law.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9  YOUR LEGAL RIGHTS  

Under applicable data protection legislation, you may have certain rights in relation to your personal data. In accordance with Peru's Personal Data Protection Law (Law No. 29733) and its implementing regulations, these include, where applicable, the rights to access, rectify, cancel and object to the processing of your personal data (commonly referred to as ARCO rights). Depending on your location and the legislation applicable to the processing of your personal data, you may also have additional rights, including the right to request restriction of processing, data portability and withdrawal of consent. Where we rely on your consent to process personal data, you may withdraw that consent at any time, without affecting the lawfulness of processing carried out before its withdrawal or processing permitted on another lawful basis.

To exercise your rights or make an enquiry concerning your personal data, please contact us at marie@almaamor.com.

We may request information reasonably necessary to verify your identity before responding to your request, in order to protect your personal data against unauthorised disclosure. We will respond to requests within the time limits established by applicable law. We will not charge a fee for exercising your rights except where a charge is expressly permitted by applicable legislation. If you believe that your personal data has been processed unlawfully or that your data protection rights have not been respected, you may submit a complaint to Peru's Autoridad Nacional de Protección de Datos Personales (ANPD), administered through the Ministerio de Justicia y Derechos Humanos. Where UK, European Union or other data protection legislation applies, you may also have the right to complain to the relevant supervisory authority in that jurisdiction.

We encourage you to contact us first so that we have an opportunity to address your concerns directly.

10. THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. COOKIES  

This website uses cookies and similar technologies to support its operation and functionality. Essential cookies are used where necessary for the website to function correctly.

With your consent, we may also use optional cookies for preferences, analytics and marketing purposes. You can accept, decline or customise your preferences through our cookie consent settings. Optional cookies that require consent will only be used where the necessary consent has been obtained.

You can review or change your cookie preferences through the cookie settings available on our website. You may also manage cookies through your browser settings.