Updated: May 24th, 2018
Feldenkrais® Education of New England, Inc. (“FENE”), and Boston #3 Feldenkrais® Training (“BFT”), which is a Project under FENE, are committed to protecting your privacy.
If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland, or Switzerland, you may have additional rights with respect to your Personal Data, as further outlined below. These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”), if you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland.
Collection of your Personal Data
We may collect the following categories of Personal Data about you when you register or apply for participation in one or more of our Projects or Programs:
- Email address
- Home/work/mobile telephone number
- Postal or other physical address
- Credit/debit card information
- Electronic bank transfer information
- Financial documentation for waiver applications
We collect and/or process your Personal Data in connection with the below listed activities related to your participation in one or more of our Projects or Programs:
- Financial transactions
- Waiver award determination
- Participation in discussion groups
- Status determination regarding qualification for guild membership or certification
Processing of your Personal Data
FENE and BFT will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity (i.e. processing that is necessary for the performance of a contract with you, such as your Enrollment Agreement which allows us to charge you tuition) and our “legitimate interests” or the legitimate interest of others (e.g. our financial services company which processes payments) such as:
- Fulfilling requests such as consideration for waiver awards
- Complying with our legal obligations, resolving disputes, or enforcing our agreements
- Providing required information to oversight authorities to enable your participation in one or more of our Projects or Programs to count toward membership or certification
- Providing required information to other Education Directors in the event that you transfer from one or more of our Projects or Programs to a similar one elsewhere
- Protecting, investigating and deterring against fraudulent, harmful, unauthorized or illegal activity
We process Personal Data for purposes such as:
- To enroll you in one or more of our Projects or Programs
- To provide the ability to contact you and facilitate participation in one or more of our Projects or Programs in which you have enrolled
- To process payments including tuition or reimbursements, as well as paying those who provide services to us
- To determine whether and how much to award for requested waivers
- To allow you to participate in any pass-through purchases of Project- or Program-related materials
- To allow you to participate in any study groups or other support activities
- To meet contract or legal obligations
You can choose whether or not to provide Personal Data to FENE or BFT, but note that this would effectively end our contract with you, because we will be unable to process transactions with you without at least some of that Personal Data. Contact us as specified in the “Contact Us” section.
Data Subject Rights
You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may also be Personal Data, for example, if you wish to substitute another means or avenue of payment. In such situations, however, we will still respond to let you know of our decision.
To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this policy.
- Access: You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
- Objection: You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Portability: You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, this may make it impossible for you to continue your participation in one or more of our Projects or Programs.
- Right to File Complaint: You have the right to lodge a complaint about FENE’s or BFT’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
How long we retain your Personal Data depends on the type of data and the purpose for which we process the data.
FENE, BFT, and other Projects or Programs under FENE, do not participate in passive collection of data.
Cookies and Tracking Technologies
Sharing your Personal Data
FENE, BFT, and any other Projects or Programs under FENE, do not sell or rent your Personal Data to third parties.
We share Personal Data with third party service providers solely for the purpose of processing transactions or generating filings required by our obligations or by law.
As required by law, we may respond to subpoenas, court orders, or similar legal processes by disclosing your Personal Data and other related information, if necessary. We also may use Personal Data and other related information to establish or exercise our legal rights or defend against legal claims.
We collect and possibly share Personal Data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our contractual agreements, or as otherwise required by law.
Security of your Personal Data
FENE and BFT are committed to protecting the Personal Data you share with us. We use security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure. We shred financial data submitted in waiver applications.
If you participate in an open study group or discussion forum, you should be aware that the information you provide there will be made broadly available to others who have access to that study group or discussion forum. Also, please recognize that individual study groups and forums may have additional rules and conditions. Each participant’s opinion in a study group or forum is his, her or their own and should not be considered as reflecting the opinion of FENE or BFT.
Transfer and Storage of Personal Data
FENE’s Projects and Programs are hosted and operated in the United States (“U.S.”). We may transfer your Personal Data to the U.S. or to third parties acting on our behalf for the purposes of processing or storage. By participating in any of our Projects or Programs or providing any Personal Data for any of the purposes stated above, you consent to the transfer and storage of your Personal Data, whether provided by you or obtained through a third party, to the U.S. as set forth herein, including the hosting of such Personal Data on U.S. servers.
Attention: Privacy Officer
Feldenkrais Education of New England, Inc.
401 Edgewater Place, Suite 600
Wakefield, MA 01880
If you reside in the EU, United Kingdom, Lichtenstein, Norway or Iceland, you can also contact our Data Protection Officer at the same address.