Privacy Policy

Anamaya Limited of 6, Place des Eaux-Vive, Geneva, Switzerland (We, Us, Our) are the data controller in respect of your use of the App and the Websites referred to below, and We are committed to protecting and respecting your privacy. A copy of this policy is available on our website www.anamaya.co (Our Site) at www.anamaya.co/legal. We may amend this policy from time to time by updating Our Site and suggest you check back occasionally to ensure you are aware of any amendments, as by continuing to use the App or Our Site you are deemed to agree to any such amendments. This policy together with our end-user licence agreement as set out at www.anamaya.co/legal (EULA) and any additional terms of use incorporated by reference into the EULA, (together Our Terms of Use) applies to your use of: • The Anamaya Meditation mobile application software (App) once you have downloaded a copy of the App onto your mobile telephone or handheld device (Device); and • Our Site. This policy explains how We will process any personal data We collect from you, or that you provide to Us. Please read it carefully. INFORMATION WE MAY COLLECT FROM YOU We may collect and process the following data about you: • Submitted Information: information that you provide by filling in forms, clicking on icons, buttons and ads. This includes information provided at the time of creating a profile or registering to use the App or Our Site, posting material or requesting further services. We may also ask you for information when you report a problem. • Additional information: • if you contact Us, We may keep a record of that correspondence; • We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them; • details of transactions you carry out through Our App or Our Site and of the fulfillment of your orders, subscriptions or purchases. This data will include your name and contact details, and details of any transactions. • details of your actions through the App, such as the duration, dates and time spent meditating and visits to Our Site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for Our own billing purposes or otherwise and the resources that you access; and • Location information: when you use one of Our location-enabled Services, We may collect and process information about your actual location, including your general location as determined from your IP address and provided by your browser or Device. Some features of Our App and Our Site require your location or other personal data for the feature to work. If you disable location-sharing on your Device or through your browser, you may be unable to use such features. • Log information: when you use the App or view content on Our Site, We may automatically collect and store certain information in server logs including but not limited to internet protocol (IP) addresses, internet service provider (ISP), application IDs, details of links clicked on, browser type and language, pages you view and date or time stamps. • Unique application numbers: when Our App searches for automatic updates, an ID uniquely identifying your Device and the App, along with information about your installation, for example, the type of operating system, may be sent to Us. COOKIES Most web browsers automatically accept cookies, however you may delete, or disable cookies by following the instructions at http://www.allaboutcookies.org/manage-cookies/. Please note that you may not be able to take full advantage of a website if you disable cookies. Disabling cookies may impair your experience of the App or Our Site. Cookies are text files which are transferred to your computer or Device, and accessible only to the websites which create them. The App and Our Site may from time to time uses cookies and log files to distinguish you from other users, for statistical analysis, to understand user behaviour, to administer the App or Our Site, to tailor the information presented to a user based on their preferences, and to improve user experience. Any information gathered by Our Site through the use of cookies is compiled on an aggregate, anonymous basis. Further information about cookies can be found on the Interactive Advertising Bureau’s website www.allaboutcookies.org. Any financial transactions including your purchase of the App and any financial transactions carried out through the App will be administered by Apple Inc. and will be encrypted. The privacy policy of Apple Inc. can be viewed at https://www.apple.com/legal/internet-services/ itunes/. Submitted information and other information collected by the App is stored by Parse on their secure servers. The privacy policy of Parse can be viewed at https://www.parse.com/about/ privacy. Where We have given you (or where you have chosen) a password that enables you to access certain parts of Our Site or the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information 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 data transmitted through the App or to Our Site; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access. For example, Our security and privacy policies are periodically reviewed and enhanced as necessary, and only authorised personnel have access to user information. The App and Our Site include social networking, sharing and discussion features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users. WHERE WE STORE YOUR PERSONAL DATA The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for Us or for one of Our suppliers. These staff may be engaged in the fulfillment of your request, order or reservation, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.  USES MADE OF THE INFORMATION We may use this information to understand your needs and provide you with a better service, and in particular for the following reasons: • To supply to you services via the App, and to process your payments. To communicate marketing messages, newsletters and details of Our business or the businesses of carefully-selected third parties which We think may be of interest to you by post or email or similar technology (you can inform Us at any time if you no longer require marketing communications, see below). • For statistical purposes and analysis for management purposes in order to administer Our Site or the App or improve Our products and services. • Internal record keeping, and administrative purposes, and to inform you about Our events, services or products, or other related information that We think would be of interest to you. • To promote the App and meditation generally by publicising when and how often Our users meditate, and where they are based. If information about your usage of the App is used in this way, it will only be published anonymously, on an aggregate basis, and will only offer rough indication of your location. For example, We may display on a map that “5 users are meditating right now in London” or “over 1,000 people between the ages of 18-25 have meditated in Bristol using Our app in the last 24 hours”. • From time to time, We may also use your information to contact you for market research purposes or to customise the application according to your interests. If you are an existing customer, We will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which you have already obtained from Us. If you are a new customer, and where We permit selected third parties to use your data, We (or they) will contact you by electronic means only if you have consented to this. In some cases, where a page on Our App or Our Site includes content from a social network, such as a Twitter feed, or Facebook comments box, those services may set a cookie even where you do not click a button. As is the case for all cookies, We cannot access those set by social networks, just as those social networks cannot access cookies We set ourselves. Our Site uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). The information generated by the cookie about your use of Our Site (including your IP) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of Our Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP with any other data held by Google. Further information about Google’s privacy policy may be obtained from http://www.google.com/privacy.html. GOOGLE AND SOCIAL MEDIA If you share Our content through social media, for example by liking Us on Facebook, following or tweeting about Us on Twitter, or giving Us a '+1' via Google Plus, those social networks will record that you have done so and may set a cookie for this purpose. From time to time Our Site may display adverts delivered by Google or other advertising networks. They may store or retrieve a cookie from your computer when serving adverts, in order to display those which are more relevant to you. These cookies are used to record information including the number of times you have seen an advertisement, but will not lead to the transfer of your name, contact details or other personally identifiable information. Further information about Google advertising, their use of cookies, and how to opt out, please visit http://www.google.com/privacy_ads.html. We do not disclose information about identifiable individuals to Our advertisers, but We may provide them with aggregate information about Our users (for example, We may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data We have collected from you to enable Us to comply with Our advertisers' wishes by displaying their advertisement to that target audience. We may disclose your personal information to third parties: • In the event that We sell or buy any business or assets, in which case We may disclose your personal data to Our advisers, prospective partners and the prospective seller or buyer of such business or assets. This information will be passed on to the new owner of the business. • In the event of Our insolvency or a corporate restructuring of Our business, in which case We will share your personal information with the entity which is to assume control of Our business. The promises in this privacy policy will apply as between you and the entity which assumes operation of Our business. • If Our business or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. • If We are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request, in which case We will disclose the information as required by that legal obligation. DISCLOSURE OF YOUR INFORMATION In the event that Our business becomes incorporated, We may disclose your personal information to subsidiaries of the entity to which Our business is transferred and the ultimate holding company of that entity and its subsidiaries. For the purposes of this clause, the meaning of ‘subsidiary’ and ‘subsidiaries’ shall be as defined in section 1159 of the Companies Act 2006. • In order to: • enforce or apply the EULA, Our Terms of Use, and other agreements or to investigate potential breaches; or • protect Our rights, property or safety or that of Our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. YOUR RIGHTS If you would like Us to destroy information We hold about you, please let Us know. However, please note that if you use any of Our services which require you to provide personal information, deleting Our records may mean that you will need to resubmit it to continue using such services. You may request details of personal information which We hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you or if you have any questions relating to this Privacy Policy or how We use the personal information We have about you, please write to: Anamaya Limited, 6, Place des Eaux-Vives, Case Postale 3461 CH-1211, Geneva 3, Switzerland. Our Sites may, from time to time, contain links to and from the websites of Our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services. MINORS You may at any time ask Us to refrain from sending you marketing messages by sending Us an email with the words UNSUBSCRIBE in the subject box or by telephoning Us. If We contact you by email each time you receive a message you will also have the option to decline to receive further information of that type from Us. Our services are not intended to be directed to persons under the age of 13 or equivalent minimum age in the relevant jurisdiction and We do not knowingly collect personal information in respect of such persons. If We discover that a child under 13 has submitted personal information to Us We will take steps to remove this information and terminate the child’s account. Please notify Us immediately if you become aware that a child has provided Us with personal information. YOUR ACCEPTANCE OF THIS PRIVACY POLICY If you do not agree to this privacy policy, please do not use the App or Our Site.  By using Our App or Our Site, you consent to the collection and use of information by Us. Owing to the global nature of the internet infrastructure, the information you provide may be transferred in transit to countries outside the European Economic Area that do not have similar protections in place regarding your data and its use as set out in this policy. However, We have taken the steps outlined above to try to improve the security of your information. By submitting your information you consent to these transfers. HOW TO CONTACT US We welcome your views about Our Site, the App and Our privacy policy. If you would like to contact Us with any queries or comments please send an e-mail to support@anamaya.co To find out more about your rights under the Data Protection Act in the UK, visit the Information Commissioner’s website: www.dataprotection.gov.uk or read the Act online at: www.hmso.gov.uk/acts/acts1998/19980029.htm.


Please direct any questions to legal@anamaya.co.