Effective: September 2020
Last Updated: September 2, 2020
If you do not want your information collected or used in the manner described in this Policy, please do not use our Services or otherwise interact with us. By using our Services or otherwise interacting with us in any manner, you are deemed to have agreed to the provisions of this Policy, unless you are in the European Economic Area (“EEA”) or Switzerland in which case you are acknowledging that you have been provided this Policy. We may change, modify, add or delete portions of this Policy at any time. We encourage you to visit this Policy frequently to ensure you are aware of how it applies to you.
Chopra is a “data controller” subject to the General Data Protection Regulation (the “GDPR”) only insofar as we are offering goods or services to individuals in the EEA or where our Digital Properties may be used to monitor individuals' behavior as far as it takes place in the EEA. Nevertheless, this Policy provides a general description of how we process personal data, regardless of where individual users are from. If you have any questions about this Policy or want to exercise your rights pursuant to the Policy, please contact us using the details set forth below.
Chopra Global, LLC
P.O. Box 1944
New York, NY 10156
Chopra is committed to working with you to obtain a fair resolution of any complaint or concerns about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint with the competent EU Member State authority.
The nature of the information we collect from you depends on how you engage with us and generally consists of:
When, and to the extent, anonymous information is combined with PII, such information also becomes PII and is treated and protected as such in accordance with the terms of this Policy.
We collect PII and anonymous information that you directly provide to us as well as information you indirectly provide to us as you use our Services. We may also collect information about you from third parties.
Directly provided information
You may directly provide information to us, including PII such as your name, email address and password when you register for an Account with us, sign up for a newsletter or otherwise fill out a lead generation form regarding a particular product or service on our or third-party digital properties, including social media. You may provide further information to us, including information such as gender, birth date / location, payment information, postal address and phone number as well as physical characteristics and personal preferences, goals, experiences, aptitudes, attitudes and behaviors (i) when you edit your Profile, (ii) when you utilize tools and other services provided by us including calendars, journals, user surveys and online assessments such as the Dosha Quiz or Mind-Body Type Assessment (collectively, “MBTA”), etc., (iii) in the course of using our Apps or online programs or (iv) when you purchase a product or service from us through our online store.
We may also collect similar information from you in the course of your discussions with our sales personnel regarding potential purchases or to fully enroll you in our in-person events or other products and services. Please note that in order for us to accommodate your special needs or to ensure your suitability for certain in-person events or programs you may also provide us with specific health-related information including disabilities or allergies, among other information, and we may keep such information for future reference for your safety.
You may also provide information to us via communications at our in-person events, during telephonic or online group lessons, meditations, workshops and other sessions or via forums such as online groups, chat rooms and message boards, some of which may be a required or optional component of our product and service offerings. We also collect information from you when you place a request for customer service, when you respond to any censuses, surveys, or user interviews, provide any testimonials with respect to our products or services or apply for employment with us.
Indirectly provided information
Every time you engage with us we automatically collect certain information about you. This includes:
Information collected from third parties
Information we may collect from third parties includes:
We may combine any data we collect with other information we may have about you or use information we have to derive or infer other information. For example, we may be able to determine your approximate location using your IP address.
We may collect, store and use your information for any purpose relating to our business, subject to this Policy. This includes, for example:
Chopra will never sell or rent your PII to any third party under any circumstances and will only share or disclose your PII with third parties as set forth in this Policy and in all cases, for legitimate business reasons. As you interact with us, the following entities may obtain your information:
Other third parties may also have access to your information as a result of your interactions with us, including:
For the avoidance of doubt, you should assume that any information you provide in connection with the above actions may be read, collected, and used by others. To the extent this data is provided on any third-party property, the terms and privacy policies of such third-party property will apply to any such data under their control or in their possession. It is strongly recommended that you carefully monitor the information you share pursuant to the above activities as any such information may become a permanent part of the public domain and have unintended consequences. Chopra may not regularly monitor any such information and is under no obligation to do so. Please see our Terms for more information about what we consider User Generated Material and Footage and how we use such information.
We may also use and share anonymous aggregated info, including information about you and your activities that is de-identified and with respect to which you cannot reasonably be associated, for any purpose whatsoever, including for research studies, demographic profiles of our users and summaries of our users’ activities and behaviors.
We and, as discussed herein, certain third parties use Tracking Technology on Chopra Digital Properties or in connection with Chopra advertisements and activities on third-party properties for various purposes. These include Chopra-specific uses such as authenticating you and recognizing your preferences when you visit our Digital Properties, customizing your experiences with our Services, analyzing website analytics and such other purposes as set forth elsewhere in this Policy. Chopra Vendors use Tracking Technology to fulfill their service obligations to us. Other third parties use Tracking Technology for interest-based advertising, to provide their products and services directly to you or for other purposes as set forth in their respective terms and policies.
Tracking Technology includes:
We use Google Analytics to help us better understand activity on our Digital Properties. Data collected via Google Analytics is used by us according to this Policy and may also be used by Google according to its policies. For more information about Google Analytics, please click here. To opt out of the collection and processing of data by Google Analytics click here.
Please note that if you delete cookies, reset your device identifier or use another browser or device, you may need to repeat your opt-out choices. If you opt out of IBA, you will still receive ads, but these ads may be less relevant to you. If you disable cookies or opt out of IBA by any of the avenues set forth above, we will still collect data by other means and for the purposes set forth in this Policy.
To disable collection of precise location information from your mobile device, you can access your mobile device settings and choose to limit that collection.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track your online activities over time and across browsers and devices. Our websites do not support Do Not Track requests at this time, which means that we may collect information about your online activity both while you are using our websites and after you leave our properties.
If you have an Account, you may view and directly edit certain information we have about you, such as your email address, in your Profile. You can also contact us directly at email@example.com to edit your information.
You may request removal of information you provide for public display on our Digital Properties as set forth in the section entitled Who Else May Have Access to Your Information by contacting us at firstname.lastname@example.org. In some cases, we may not be able to remove such information, in which case we will let you know why we are unable to do so.
You also have the right at any time to stop us from contacting you by email for promotional purposes either by clicking “Unsubscribe” at the bottom of any email communication or in your Account settings on certain of our Digital Properties. Notwithstanding your indicated email marketing preferences, we may send you administrative emails regarding Chopra, including, for example, order confirmations and notices of updates to this Policy or the Terms if we choose to provide such notices to you in this manner.
At any time, you can manage our ability to send you push notifications by turning off the notification settings in the relevant mobile application or in the device settings of your mobile device. If you choose not to receive push notifications, you may still receive in-app notifications.
Any changes you request will take effect within 48 hours.
We do not intentionally collect or maintain PII from individuals who are under sixteen (16) years old. Protecting the privacy of minors is very important to us. Thus, if we obtain actual knowledge that we are holding PII of someone under 16 years of age, we will take steps to permanently remove that PII from our records. Should you, as a user's parent or legal guardian, become aware that a user who is under the age of 16 has provided us with PII, please notify us immediately by any means set forth below.
Chopra takes precautions to ensure that your PII is secured. We use a variety of industry-standard technical, contractual, administrative and physical security measures and procedures to help protect your PII from unauthorized access, use, alteration or disclosure. We restrict access to PII to those employees or contractors who need access to perform their job functions. Please note that despite our best efforts, no one can guarantee the security of PII. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of PII at any time.
Our Digital Properties may contain links to third-party websites. We do not control the privacy policies or practices of such websites. You should review the terms and policies of any property you visit before providing any PII on such property. Chopra is not responsible for the content or practices of any linked websites, and we provide these links solely for your convenience.
This section supplements the information contained in this Policy and applies solely to visitors, users, consumers and others who reside in the State of California ("consumers"). The provisions within this section have been adopted to comply with the California Consumer Privacy Act of 2018 (CCPA) and its regulations. Any terms defined in the CCPA have the same meaning when used in this section.
Chopra collects and maintains different types of personal information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). The CCPA sets out eleven categories of personal information, including:
Collection and sharing of personal information
Chopra collects and shares the following categories of personal information:
Chopra may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we endeavor to enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the relevant service on our behalf.
Pursuant to the CCPA, personal information does not include:
Use of personal information
We may use or disclose the personal information we collect as set forth in the section entitled How We Use Your Information or as otherwise set forth in the CCPA. We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.
Disclosures of personal information for a business purpose
In the preceding twelve (12) months, Chopra has disclosed the following categories of personal information for a business purpose: identifiers and California Customer Records personal information categories; protected classification characteristic under California or Federal law; internet or other similar network activity; sensory data; professional or employment related information; and inferences drawn from other personal information. We disclose your personal information for a business purpose to the following categories of third parties: Chopra Vendors, Partners, and other third parties as described in this Policy, including as set forth in the section entitled Who Else May Have Access to Your Information.
Sale of personal information
In the preceding twelve (12) months, Chopra has not sold personal information.
Your rights and choices
In addition, if we disclosed your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Other California privacy rights
Under California’s “Shine the Light Law,” Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request via email to email@example.com or by mail to:
P.O. Box 1944
New York, NY 10156
We store and process all PII for Chopra within the US.
If you are visiting our Digital Properties from outside the United States, please be aware that your information will typically be transferred to, stored, and processed in the United States where our servers are located and our central databases are operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your PII is protected. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Policy.
The legal basis for using European PII
When we collect information about you through our Digital Properties, generally the legal basis on which we process your PII is fulfillment of an agreement with you. When we use your PII outside of what is strictly necessary to perform a contract with you, we are doing so toward our legitimate interests of informing you about products, services or Materials we believe would be of interest to you; responding to your inquiries and service issues; better understanding our users and their interests more generally to help inform product and service development; to secure and maintain the integrity of your Account or the Services and infrastructure; and as otherwise set forth in the section entitled How We Use Your Information. We may also process your PII when you provide consent for us to do so or where it is necessary for us to comply with a legal obligation.
The processing of your PII may involve a transfer of data outside the EEA. Whenever we transfer PII out of the EEA: we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or, where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Please send us an email at firstname.lastname@example.org or write to us at Chopra Global, P.O. Box 1944, New York, NY 10156, Attention: Privacy if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Rights for EEA residents
In addition, if you are a resident of the EEA, you have the right to:
If you wish to exercise any of these rights, or raise a complaint on how we have handled your PII, please send us an email at email@example.com or call us at 800.858.1808.
No fee usually required
You will not have to pay a fee to access your PII (or to exercise any of the other rights set forth above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your PII (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We will only retain your PII for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your PII for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for PII, we consider the amount, nature and sensitivity of the PII, the potential risk of harm from unauthorized use or disclosure of your PII, the purposes for which we maintain and process your PII and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Please note that by law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for seven years after they cease being customers for tax purposes.
We may anonymize your information (so that it can no longer be associated with you) for research or statistical purposes and use this information indefinitely without further notice to you.
From time-to-time we may modify, update, add to, remove portions of or otherwise alter this Policy. Any changes will be posted or linked to from our Digital Properties, including at www.chopra.com, to ensure your ability to know what information we collect, how we collect and use that information, and when and to whom we may disclose such information. If you object to any such changes, you must immediately cease using our Services or otherwise interacting with us. You are bound by any changes to this Policy when using our Services or otherwise interacting with us after those changes have been posted.
When we receive formal written complaints, it is our policy to contact the person regarding his or her concerns. You also have the right to make a complaint at any time to the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data. We would, however, appreciate the chance to deal with your concerns before you approach any regulatory authorities so please contact us in the first instance.
If you have any questions about this Policy or to raise a complaint, you can always contact us in any of three ways: