Spirit Rock Privacy Policy

Last Updated: January 31, 2024

1. Introduction

Spirit Rock Meditation Center, a California nonprofit religious corporation (“Spirit Rock,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy (as updated from time to time, this “Policy”) applies to information we collect on or through the Spirit Rock website [www.spiritrock.org], including our online teachings, programming, Dharma Library, and other features, and any other related services provided by us including our on-site events, trainings, other programming, and other on-site services (collectively, the “Service”), and through our other communications with you in connection with the Service. As used in this Policy, the terms “you,” “your,” or “user” refer to you as a user of the Service. The provisions of the Spirit Rock Terms of Service [www.spiritrock.org] (the “Terms”) also apply to this Policy. Any defined terms not defined in this Policy shall have the meanings set forth in the Terms.

This Policy describes the types of information we collect from and about you and our practices for using, protecting, disclosing, and sharing that information, as well as your choices regarding your information. Please review this Policy carefully before using the Service. By using our Service, you represent that you agree and consent to our use, disclosure, and handling of your information, as described herein.

2. Permitted Users

The Spirit Rock website and online services (the “Online Services”) are not intended for children under the age of 16. By using the Online Services, you represent that you are 16 years old or older. If we learn or have reason to believe a user is under the age of 16, we will terminate that user’s account and delete any personal information in that account.

3. Changes to This Policy

We may change, update, or replace this Policy from time to time by posting any changes or updates to the Service. If we make significant changes, we will notify users via e-mail (unless they have unsubscribed from receiving such e-mails) or by posting a banner notice on the Service. You understand and agree that your use of the Service after such changes have been posted will constitute your acceptance of and consent to the updated Policy to the extent permitted by applicable law. We encourage you to review this Policy regularly for the latest information about our privacy practices.

4. Information We Collect About You

Spirit Rock collects various types of information from and about you as a user of our Service, such as:

• Information that clearly identifies you (including your name or e-mail address);
• Information about your interactions with our Service; and
• Any other information that you choose to submit or provide to us through the Service or otherwise.

The information we collect about you includes information that personally identifies you (“personal information” or “personal data”), as well as other information that does not identify you (“non-identifying data”), such as statistics and general data. We reserve the right to use and disclose non-identifying data in any manner, to the extent permitted by applicable law.

5. How We Collect Your Information

1. Information You Provide. We collect information about you when you post or submit it through the Service, such as when you create an account, fill out our forms, make donations, submit feedback or requests, register for or participate in our programming, or contact us. As a few examples:
   1. Account Information: When you create an account, you will be required to provide your first and last name, e-mail address, phone number, and a password.
   2. Registration Information: When you register for our programs, you need to provide information such as your name, e-mail address, mailing address, phone number, emergency contact information, meditation experience, and other information, but the specific information varies by program.
2. Other Information You Choose to Provide. As you use and interact with the Service, you may also be asked to (or may voluntarily choose to) provide additional information including:
   1. Credit card information, billing address, and other billing information;
   2. Age or date of birth;
   3. Location, including your postal code, state, province, or country;
   4. Information about your parent or guardian, if you are a minor;
   5. Vaccination status (including for Covid-19 or other vaccines);
   6. Feedback and reviews;
   7. Subjects and programs that are of interest to you; and
   8. Meditation experience.

For example, in order to pay program registration fees, purchase on-demand courses, or make a donation you will be required to provide your credit card information, billing address, and e-mail address in order for your payment to be processed.

3. Sensitive Information. In some cases, we also collect information that may be considered sensitive, such as information regarding race, ethnicity, gender identity, religious beliefs, sexual orientation, dietary restrictions, accessibility needs, or health conditions (“Sensitive Information”). We use Sensitive Information to improve our programming and planning, to promote and improve inclusivity in our services, to accommodate your needs, to facilitate and improve accessibility, or if such information is relevant to a program for which you are registering.
4. User Posts & Submissions. You may choose to share information through public portions of the Service or other Service features. For example, you may choose to include information about yourself in a post to a [public] forum or to a discussion group as part of an online program. Please be aware that if submit information through the Service’s features, anyone with access to those features (including instructors, program participants, other users, or even the public) will also have access your information.
5. Data Collected Through Cookies & Other Technologies. We also use cookies (including third-party cookies), web beacons, and pixel tags to automatically collect information about you and your use of, navigation of, and interactions with the Service (“Activity Data”), which may include personal data, such as information relating to Internet Protocol addresses, browser type, operating system, browser language, pages visited, features used, geolocation data, and other similar information.
   1. How We Use & Share Activity Data. We use Activity Data, and share such data with our third-party service providers, in order to make certain features of the Service available to you, to improve and optimize user experience, to collect statistics on use and navigation of the Service, to track e-mail communications, to optimize marketing and promotional e-mails regarding our services (subject to any opt-outs), and for analytics purposes. We also share Activity Data with third-party service providers to facilitate the information syncing across the different features, functions, and platforms included in the Service.
   2. Cookies. Like many online services, we use “cookies” to collect Activity Data. Cookies are small text files that are placed on your device, which uniquely identify your device, and which can be transferred to your hard drive to keep records of your visit to a site. You may choose to refuse or delete cookies, and most browsers and mobile devices offer their own settings to manage cookies. If you refuse or delete cookies, you may not be able to use or access certain parts of the Service, or certain features may not function properly. For example, we may not be able to recognize you, your devices, or your preferences.
   3. Google Analytics & Similar Services. We also use Google Analytics and other services to collect Activity Data. Google Analytics uses cookies and web beacons to report on user interactions on the Service and on third-party websites. We use information collected through such services to better understand how users use and interact with the Service and to improve user experience. For more information about Google Analytics and its handling of your information, please visit: https://policies.google.com/technologies/partner-sites. For information on opting-out of Google Analytics please visit: https://tools.google.com/dlpage/gaoptout.
   4. Do Not Track Signals. We do not receive Do Not Track Signals or similar signals. In the event we receive any Do Not Track Signals, we will not comply with them, as that is not part of the functionality of our Service.
   5. Third-Party Use of Cookies and Other Technologies. Certain services, applications, or content, including advertisements, are served by third-parties like advertisers, ad networks and servers, and application providers. These third parties may use cookies, alone or in conjunction with other technologies, to collect information about you when you use the Service. The information they collect may be associated with your personal information and/or they may collect information about your or your online activities over time across third-party websites or online services, and they may use this information to provide you with interest-based (behavioral) advertising or other targeted content. For example, Google Analytics may track your activities or collect your information across third-party websites or services when you use the Service. We do not control these third parties, their tracking technologies, or how they are used. Any questions about an advertisement or targeted content, should be directed to the party that provided it. For information about opting-out of targeted advertising, see Section 10 below (“Your Data Choices”).

6. How We Use Your Information

• We use user information collected by or provided though the Service, which may include your personal information for the following purposes:
• To provide the Service, along with any other services, information, or actions you request;
• To improve, plan for, and provide our content, materials, and programming;
• To provide a safe and inclusive environment for participants in our online and on-site programs;
• To send you e-mails or notices about your account or about changes to the Service, the Policy, or the Terms, and to otherwise communicate with you in connection with the Service;
• To carry out our obligations and enforce our rights under contracts or agreements with you;
• To protect against, identify, and remediate any unauthorized use of or access to the Service;
• To improve and optimize the Service, store user preferences, customize user experience, collect general data and statistics, and analyze usage of and interaction with the Service;
• In any other way disclosed to you when you provided the information, subject to applicable law;
• To fulfill any other purposes for which you provided such information; and
• For any other purpose with your consent, to the extent permitted by applicable law.

To Promote Our Programs & Services: We also use your information to contact you by e-mail, through the Service, or otherwise about our services, programs, or other resources that may be of interest to you. However, you have the right to opt out of such communications, if you do not wish to receive them. For information and instructions on exercising your opt-out rights please see Section 10 below (“Your Data Choices”).

7. How We Share Your Information

We disclose personal information collected from or about you as part of the Service to third parties for the purposes described below, as follows:

• Service Providers: To our contractors, service providers, vendors, and other third parties:
  • To provide the Service, along with any other services, information, or actions you request;
  • To store and retain your information;
  • To monitor, protect against, identify, and remediate unauthorized use, access, or misuse of user information or the Service;
  • To improve and optimize the Service, store preferences, customize user experience, collect general data and statistics, and analyze usage of and interactions with the Service;
  • To fulfill the purposes for which you provide your information
  • For any other purpose disclosed to you when you provide such information; and
  • With your consent.
• Court Orders; Legal Rights; Protecting the Service and Others: To comply with any court order, applicable law, or legal process (including responses to government or regulatory requests), to enforce contracts and agreements, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of users, the Service, Spirit Rock, or others.
  
• Dissolution and Other Changes: Upon a dissolution, restructuring, reorganization, or other transfer of some or all of our assets.
• Instructors, Teachers, and Presenters: When you register for a course, workshop, training, or other program, we may share your name, e-mail address, and other information which is relevant to that program with the relevant instructors, teachers, or presenters, only if you provide your consent to such disclosure, during the registration process for such program or otherwise.
• Partner Centers & Joint Programs: From time to time, Spirit Rock collaborates with partner centers and other organizations (our “Partner Centers”) in order to provide present co-authored, co-hosted, co-sponsored, and joint content, programming, events, and resources. Spirit Rock may share your name, email address, and information about the subjects of interest to you, with our Partner Centers, only if you provide your consent.
• Promoting and Marketing Our Services: Unless you opt-out, Spirit Rock may disclose information such as your name, email address, subjects or programs of interest to you, programs you previously attended or completed, age, and location to third-party service providers engaged by us, in order to tailor and present offers, program and content suggestions, and recommendations related to the Service to you, or to otherwise offer, promote, and market Spirit Rock’s services to you.
• Third-Party Marketing Subject to User Consent: Spirit Rock does not use or share your personal information with third parties to market third-party services to you; provided, however, that we may share your information with certain Partner Centers in order to promote their programs to you, only if you expressly consent to such sharing of your information.
• Non-Identifying Data: Spirit Rock reserves the right to use and disclose information non-identifying data without restriction, to the extent permitted by applicable law.

8. International Users

Our privacy practices are subject to applicable laws in the countries in which our users are located. In light of this, we engage in the data practices described in this Policy, with respect to a user, only to the extent such practices are permitted under the applicable law of the country where the user is located. Depending on the country where you are located, you may have certain additional privacy rights under the laws of the country where you are located.

9. Cross-Border Data Transfers

Spirit Rock is located and operated in the United States. If you are located in a country other than the United States your information may be transferred internationally in connection with your use of and access to the Service. Whenever your personal information is transferred, stored, or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. These steps include obtaining your express consent to the transfer of your personal information to the United States or other lawful means of transferring your personal information.

10. Your Data Choices

We strive to provide you with choices about the personal information you provide to us and how it is processed. To that end, we have created tools to allow you exercise control over your information, such as the right to opt-out of certain data practices.

1. Cookies & Tracking Technology. You have the option to set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Please note that if you disable or refuse cookies, some parts of the Service may be inaccessible or may not function properly. For example, the Service may not be able to recognize you or your devices and may not be able to accommodate your preferences or settings.
2. Other Options for Opting-Out of Targeted Advertising. We do not control the collection or use of your information to serve interest-based advertising. However, such third parties may provide you with ways to choose not to have your information collected or used for such purposes. For example, you can opt-out of receiving targeted advertisements from the members of the Network Advertising Initiative (“NAI”) on the NAI website.
3. Marketing Communications from Spirit Rock. If you do not wish for us to use your email address or other contact information to promote Sprit Rock’s programming, resources, content, and other services to you, you have the right to opt-out by changing the preferences in your account. Our promotional and marketing emails also include a link, which you can use to update your preferences and unsubscribe from such communications.
4. Communications from Instructors, Teachers, Presenters, & Partner Centers. As described above, we may share your personal information with teachers, presenters, instructors, and Partner Centers, if you have provided your consent to such disclosures. If you have consented to such disclosures, you may opt-out of receiving such communications at any time by sending a request to [email protected].

11. Accessing, Correcting, and Updating Your Data

You may have certain additional privacy rights under the laws of the jurisdiction where you are located. Nevertheless, Spirit Rock provides our users with a number of rights, with respect to your personal information, including the right to request access to, change, or remove your personal data, or to change your marketing preferences (as described above). If at any time, you would like to modify, update, correct, review, or request access to the personal information we have about you, you may do so through your user account (for certain corrections and updates) or by sending a request to [email protected] or:

Spirit Rock Meditation Center
PO Box 169
Woodacre, CA 94973

Spirit Rock reserves the right to use reasonable measures to verify your identity before modifying, updating, correcting, removing, or providing access to the personal information of any user.

12. Account Termination; Retaining Your Information

You can close your account at any time by sending an account termination request to [email protected]. If you choose to close your account, we will remove all or part of certain posts from view and/or dissociate them from your user profile or account. However, we will retain your information so long as it is needed in order to provide the Service or as otherwise permitted by applicable law. For example, we may retain information to comply with our legal obligations. We may also maintain residual copies of your information in our backup systems.

13. Data Storage & Security

We use reasonable technical, administrative, and other measures, to (i) secure and store the information collected by us (or on our behalf) through the Service and under this Policy and (ii) to attempt to prevent the misuse of, loss of, and unauthorized access to, such information, such as access controls and password requirements. We also use industry-standard service providers, with data protection and security measures that meet industry standards, to host and store your information. All third-party service providers engaged by Spirit Rock are vetted for security, privacy, and compliance purposes. Although we strive to protect your information, we cannot guarantee the security of information submitted, collected, or received through the Service and under this Policy. The transmission of such information in connection with the Service is at your own risk.

14. Third-Party Services & Data Practices

Our Service includes links to third-party websites or services that are not operated or provided by Spirit Rock. Such third parties may collect information from or about you. We are not responsible for, and make no representation of any kind regarding, such third parties or their data practices. If you choose to click on any links to, interact with, visit, use, or otherwise engage with any third-party websites, services, or entities, you do so entirely at your own risk. You should review the policies and terms applicable to such third parties and make any other investigation that you deem appropriate before using or visiting any third-party websites or services. You are solely responsible for any information you choose to post, submit, share with, or make available to any third parties.

15. Contact Us

If you have any questions about this Policy or our data practices, please contact us at [email protected].