Welcome to the privacy policy of Arathy Nair Kalpadruma House of Arts.
This privacy policy outlines, among other things: rules for contacting Arathy Nair who is running a sole proprietorship under the name of Arathy Nair Kalpadruma House of Arts with the registered office at ul. Czerwone Maki 49B/1, 30-392 Kraków, NIP: 6762672847, REGON: 529142437 (referred to as “Kalpadruma House of Arts” ), the rules for the collection, storage and processing of personal data by the Provider, the sources for the collection of personal data, the scope and purpose of the processing of personal data, the length of time for which personal data is processed and the rights of the individual in relation to their personal data.
Arathy Nair Kalpadruma House of Arts respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use our Services and fill our application form (regardless of where you fill it - on spot or remotely) and tell you about your privacy rights and how the law protects you.
1. Important Information
Purpose Of This Privacy Policy
This privacy policy aims to give you information on how Kalpadruma House of Arts collects and processes your personal data through your use of our Services, including any data you may provide through the application form when you apply for our Services.
The Terms and Conditions of service and this Privacy Policy are directed at our Customers and are not directed at children, as all Contracts are concluded with Customers above the age of 18. We do not knowingly collect data relating to children without the required lawful consent of their parent or legal guardian.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you or your child so that you are fully aware of how and why we are using this data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
By accepting this Privacy Policy, you declare that you accept its terms and undertake to comply with them.
Controller
Arathy Nair who is running a sole proprietorship under the name of Arathy Nair Kalpadruma House of Arts with the registered office at ul. Czerwone Maki 49B/1, 30-392 Kraków, NIP: 6762672847, REGON: 529142437 is the controller responsible for your personal data.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the contact details set out below.
We provide you a service. In doing so, we DO NOT handle personal data you are responsible for on your behalf. Because of this Kalpadruma House of Arts is not a personal data Processor, in terms of GDPR.
Contact Details
If you have any questions about this privacy policy or our privacy practices, please contact our data protection manager in the following ways:
Full name of legal entity: Arathy Nair Kalpadruma House of Arts
Email address: Not provided in the supplied policy.
Postal address: ul. Czerwone Maki 49B/1, 30-392 Kraków
You have the right to make a complaint at any time to the President of the Personal Data Protection Office, the Polish supervisory authority for data protection issues (https://uodo.gov.pl/en). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes To The Privacy Policy And Your Duty To Inform Us Of Changes
We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data or the personal data of your child changes during your relationship with us.
2. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you and your child which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier.
- Contact Data includes billing address, email address and telephone numbers.
- Technical Data includes IP address, browser type and version, time zone and location settings, plugin types and versions, operating system.
- Transaction Data includes the transactions and payments made.
- Usage Data includes information about how you use our application form and what kind of Services you use.
- Marketing and Communication Data includes your preferences in receiving commercial information and communications from us.
- Special Categories of Personal Data includes information about health necessary to provide adequate care and education.
- Image data includes images of the students attending our classes, used for promotional and information purposes.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
If You Fail To Provide Personal Data
Where we need to collect personal data by law, or under the terms of a Contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a Service you have with us, but we will notify you if this is the case at the time.
3. How Is Your Personal Data Collected?
We collect your personal data in the following ways:
| Method of collection | Types of data |
|---|---|
| Correspondence by post, phone, email or otherwise | Identity data; contact data |
| Automated technologies and interactions with the application form, including cookies and similar technologies | Technical data; usage data |
| Signing up for a service | Identity data; contact data; transaction data; special category data (student medical information); student image data |
| Photo and video footage during classes | Student image data; marketing and communication data |
| Sending information about offers or promotions | Identity data; contact data; marketing and communication data |
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the Contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
| Purpose / activity | Types of data | Lawful basis stated in the source policy |
|---|---|---|
| Answer inquiries or contact requests sent by telephone or email | Identity data; contact data | Performance of a contract |
| Administer and protect the business | Identity data; contact data; technical data | Legitimate interests (running the business, administration and IT services, network security, fraud prevention, and business reorganisation or group restructuring); legal obligation |
| Use data analytics to improve the application form, services, marketing, customer relationships and experiences | Technical data | Consent |
| Process a submitted application form | Identity data; contact data; transaction data; special category data (student medical information); student image data | Performance of a contract |
| Perform purchased services | Identity data; contact data; transaction data; special category data (student medical information); student image data | Performance of a contract |
| Send legitimate-interest messages such as invoices, important legal, privacy and security emails, and notices of changes to terms, conditions and policies | Identity data; contact data; transaction data | Legitimate interests; legal obligation |
| Informational and promotional communications | Marketing and communication data | Consent |
| Promotional use of student images | Student image data | Consent |
Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Change Of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Processing Of Students’ Images
When signing up for our Services we require that you provide us with a picture of the Student who will be attending our classes. This picture shall only be used for our own administrative and identification purposes and shall not be shared with other Students or Customers.
Notwithstanding the above, we may want to make pictures or videos during classes or performances and use them for promotional purposes, such as to share them on our social media accounts. Students will only be photographed or recorded after we receive your express consent to the above. This consent is voluntary and may be given when submitting the application form or at a later date.
Processing Of Medical Data
In order to safely provide our Services you are required to inform us about any potential medical conditions or limitations that your child may have. This is absolutely necessary in order to conclude a Contract. The medical data we collect for this purpose will not be shared with any other Students, Customers or third parties, with the exception of medical personnel in case of emergencies or other situations where we may be legally obliged to share this data.
Email Services
By signing up, you may receive messages related to Kalpadruma classes, such as:
- Important transactional messages – These include critical communications such as enrollment confirmations, payment receipts, or important updates regarding your child's safety, privacy, or security. These messages can also concern cancelled or rescheduled classes. If there are updates to our policies, changes to your child's class schedule, or other important notifications about classes, you will receive these messages as part of our service. These messages are essential and cannot be unsubscribed from.
- Non-essential messages with information about how our Kalpadruma programs work, including learning materials, class preparation steps and tips to help your child make the most of their learning experience. These messages are important for you to stay informed and enable us to better support your child’s participation in our classes. You can, however, unsubscribe anytime by informing us that you are not interested in receiving such messages.
- We may also send you occasional updates about program enhancements, new classes, or important announcements related to the Kalpadruma curriculum. You can opt out of these updates anytime by informing us that you are not interested in receiving such messages.
5. Disclosures Of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- External Third Parties, such as: a) payment operators, b) accountants and lawyers, c) IT support companies, d) social media sites, e) public authorities in the Republic of Poland.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
Since we use the services of Microsoft SharePoint in our operations (in particular for the purpose of collecting application forms and email correspondence), our business operations may involve transferring your data outside the European Economic Area (EEA). However, wherever possible we try to choose service providers who process personal data within the EEA or have servers within the EEA.
When dealing with entities outside of the EEA we ensure that at least one of the following safeguards is implemented:
- 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,
- We will apply Standard Contractual Clauses (“SCC”) adopted by the European Commission under the GDPR for the transfer of personal data outside the European Union. The SCC set forth the adequate safeguards for the protection of privacy and fundamental rights and freedoms of European individuals for such data transfers,
- we will receive the prior consent of the Data Subject.
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.
7. Data Security
Kalpadruma House of Arts has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risks represented by the processing and the nature of the personal data to be protected. We limit access to your data to those employees, service providers and other third parties which ensure a sufficient level of data protection and which are necessary for the proper performance of our Contract with you. We ensure that anyone acting under our authority who has access to the personal data does not process it except on our instructions, unless required to do so by EU or member state law.
How Long Will You Use My Personal Data For?
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data 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 personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
8. Your Legal Rights
In certain situations, you have the right to request us to view, correct, change, limit, rectify or delete your personal data that we administer and the right to object to the processing of your personal data by us. For this purpose, please contact us via the Contact details.
Please note that we will not always be able to fulfill your request to delete your personal data, namely due to individual legal obligations. In such cases, it will be communicated to you after making such a request. If you would like to receive more information on the individual rights set out in this section, please contact us according to the contact details on the 'Contact' tab.
You may, at any time, without giving any reason, withdraw consent to the processing of your personal data by sending a relevant request to us via the Contact details. Withdrawal of consent does not affect the lawfulness of the processing which was carried out on the basis of consent before its withdrawal. This means that the withdrawal of consent applies to the future, and not to the processing of data that took place in the past, in the period between giving and withdrawing consent. In situations in which we have another legal basis (apart from consent) to process particular personal data, we can continue to process this data despite receiving a withdrawal of consent.
You have the right to request that we send your personal data, which we control, to another controller of personal data, provided that the technical and organizational requirements allow us to conduct such a transfer of data.
Kalpadruma House of Arts shall, without undue delay - and in any event within one month of receipt of the above mentioned request - provide you with information about actions taken in connection with the request, or about any extension of our deadline for the provision of such information due to the nature of the request or the number of requests. In such a case we shall also provide the reasons for the rejection of your request and inform you about the possibility of submitting a complaint to the supervisory body and of taking legal action before a court.
The exercise of the rights set out above is free of charge. However, Kalpadruma House of Arts may charge you a reasonable fee if the presented request or requests are obviously unfounded, repetitive or excessive. In such cases, we may also refuse to comply with your request.
In order to meet individual requests, we may request specific information from you in order to verify your identity and ensure the exercise of individual rights. This is a security measure to ensure that personal data is not disclosed to unauthorized persons.
You also have the right to lodge a complaint with the supervisory authority, in particular in a member state: a. of your habitual residence, b. of your workplace, or c. where the alleged violation has been committed, if you believe that the processing of your personal data violates the GDPR. The complaint may be sent by post to the President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw or via e-mail to the address: kancelaria@uodo.gov.pl.
9. Complaints Concerning The Application Form
Kalpadruma House of Arts, acting with due diligence, urges to ensure the correct operation of the application form, however, it is not responsible for technical restrictions on the ability to use the application form arising from the technical condition of your equipment (understood as telecommunications equipment belonging to you, such as a mobile phone, smartphone, computer, tablet or other mobile device with access to the Internet) and arising in connection with the failure of data transmission (internet connection).
We ask to please report any irregularities related to the operation of the application form via the contact details. We will handle all such complaints within 7 days from the date of their submission. We will inform you about the positive or negative result of the complaint, stating the reasons for our decision.
You are also entitled to use out-of-court complaint settlement methods.
10. Final Provisions
Kalpadruma House of Arts reserves the right to amend this Privacy Policy. Amendments will take place on the day the new Privacy Policy is posted on the application form. Any significant changes to this Policy will be announced by the appearance of an appropriate message on the application form.
The provisions of this Privacy Policy are in accordance with generally applicable law.
If any provisions of this Privacy Policy prove to be invalid or ineffective, it shall not affect the validity or effectiveness of the remaining provisions of this Privacy Policy.
If any of the provisions of the Privacy Policy remain unclear to you, please contact via the Contact Details.