PRIVACY POLICY - SUMMARY

General Data Protection Regulation (GDPR) Framework

Purpose of this summary

This is a summary of the privacy policy of Vipassana Association (Lith. Vipasanos asociacija), legal person code 304540452, registered office address Vilnojos street 12, Sudervė village, Vilnius district, data collected and stored in the Register of Legal Persons of the Republic of Lithuania.

In this summary we explain who we are, why we need your data, what we do with it and how we help you to exercise your rights with respect to your data.

Our privacy policy aims to deal with great care with your data and your rights, in compliance with national and international rules and regulations, especially the General Data Protection Regulation (GDPR).

Who we are

When you apply for a 10-day Vipassana course your data goes through an online application process called CALM (standing for Course Application and Letters Management). All affiliated Vipassana organisations use this registration system to organise courses.

The CALM Foundation (located in Rotterdam, The Netherlands) controls this system and has its own privacy policy, which you can request by sending an e-mail to [email protected]. Vipassana Association is responsible for the further processing of your data, which are transferred by CALM to Vipassana Association.

Your data is used to process your application, provide you with a place on the course, a room and a place to meditate, and if necessary, to make special provisions for you.

Why we store your information

With the information you give us, we assess if you are mentally and physically capable of participating in a course. A Vipassana course can be very demanding.

We use your information in order to:

  • plan your accommodation, food or transport;
  • give you adequate guidance and assistance during the course;
  • provide additional services to old students (you become one after successfully finishing one 10 days Vipassana course), such as newsletters and after course mailings;
  • share opportunities to volunteer/serve or share other relevant information with you;
  • keep (i) financial information for tax reasons or (ii) other personal information required by law.

We will not do these things if you notify that you do not want us to.
There are cases, however, when we need to keep certain personal details because somebody could harm themselves or others by participating in a course.

The information we collect

We collect the following information: your name, date of birth, gender, profession, medical and/or mental health history (as provided by you), name of spouse, name of friends who are participating in the course, emergency contact, general contact information, your previous course history, native language and other languages spoken.

For the duration of the course we also store the licence plate number of your vehicle in case we need to remove it in an emergency.

If a teacher has grounds to decide that you cannot participate in a course, we will keep this information and the reason why. The decision may be based on data provided by you, but also on events or the observations made by a teacher. Only teachers involved with the assessment have access to this information.

How long it is stored

In CALM, all sensitive information and communication is removed 3 months after your course is completed. Only some basic information is stored, such as your name and if you completed a previous course.

An assessment that you cannot participate in a course in the future, or that you can participate only under certain conditions, is kept for a maximum of 10 years. This period can be prolonged after a new assessment.

Taking into account that Vipassana Association has no possibility and no sufficient resources to store the documents for a long period of time, paper application, which you complete upon arrival to the course, is sent for storage to Dhamma Dvara (Vipasaana-Vereingung e.V., having its registered office in Triebel, Germany), where it is destroyed upon expiry of 3 years as of the completion of the course. Vipassana Association (Lithuania) and Vipasaana-Vereingung e.V. (Germany) are responsible for protection of your personal data that were provided to them in compliance with applicable legislation.

However, we delete all information that we no longer need immediately after it becomes unnecessary to us.

In case you would need more details on the terms of storage of information, please contact the Data Protection Officer (DPO) or Privacy Contact Person (PCP) as indicated below.

How we process your personal information

When we process your personal information, we follow a set of below principles:

  1. your information is only used and stored in accordance with what we really need and as long as needed;
  2. we have an overview of all the type of information that is stored;
  3. if we don’t need your information anymore, we will delete it without delay;
  4. we give you access to your information;
  5. we keep your information properly secured;
  6. we only share your personal information within our organisation (this means: with Vipassana organisations in the same tradition with the same goals, provided there are safeguards in place (see below)).

The Data Protection Officer (DPO) and Privacy Contact Person (PCP)

The CALM foundation, responsible for the international online registration system, has a Data Protection Officer. Meditation centres that use the system, like Vipassana Association, are responsible for the further processing. Therefore, each country has a Privacy Contact Person. The Privacy Contact Person co-operates with the Data Protection Officer to protect your data. You can contact any of them at: [email protected].

Legal grounds

Personal information is only stored if we have a legitimate reason to collect it and if the law allows us to do so. For example, we collect personal information on the following grounds: by consent of a person, under a contract, because of any other legitimate interest (such as the vital interest of a student), or because a special law requires us to. We can always inform you of the legal reason why we are holding your information.

Security

Fellow workers/volunteers who process data for Vipassana Association are bound by confidentiality undertakings signed by them. Only the teachers (who are also bound by written confidentiality undertakings), involved with an assessment, have access to very sensitive information. Your personal information is kept securely and is not in any circumstances disclosed to a third party, unless such third party has been specifically authorised to receive that information and have signed (provided this does not contradict the applicable law) a confidentiality undertaking.

Personal data is kept:

  • in a locked room with controlled access; and/or
  • in a locked drawer or document storages; and/or
  • if computerised, personal data is password-protected in line with corporate policies procedures and regulations; and/or
  • if computerised, personal data is stored on computer media which are encrypted and are anonymized or pseudonymized wherever possible.

PC screens, monitors and terminals, used for processing data, are not visible except to authorised fellow workers/volunteers having the respective authorisations. Physical notes/records are not left where they can be accessed by unauthorised personnel and may not be removed from the workplace without prior authorisation.

Students rights

We respect your rights. More specifically we ensure that:

  1. we can provide an overview of all the information we keep about you;
  2. your information is correct;
  3. your information is corrected or removed at your request, unless we have a legal ground to process the information without your consent. You have a right to object such our decision;
  4. we will redirect you to the respective Data Protection Officer or Privacy Contact Person;
  5. you are offered the option to submit an objection to the processing to the appeals committee, our so-called Special Cases Committee.
  6. we will respect your right to file a complaint at the Data Protection Authority.

Access to information and objections towards the processing

If you want to find out what information we keep about you, or, if you do not agree with the data we keep, and if you want to submit an objection towards processing, you can fill in this form (Student Rights Form) and make the request by sending it to [email protected].

Data breaches

If there is a breach that may have repercussions for you, we will inform about this you and the Data Protection Authority. If you would like to report a breach, you can do it here: https://www.privacy-eu.dhamma.org/report-a-data-breach/.

International safeguards

Whenever we share your personal information with a Vipassana-organisation outside the European Union, we apply additional safeguards. To learn more about the safeguards we applied in your specific case, please contact us by e-mail [email protected].

In case you ask us to provide data to an organisation without adequate safeguards, we will inform you about the risks. In this case you will decide whether or not to provide the information to such organisation.

Contact information

If you have any questions or would like to contact us: [email protected] or https://www.privacy-eu.dhamma.org.