Clairvision Privacy Statement

2 April 2022

The Clairvision School

This is the Privacy Statement of the Clairvision School, which is run by two not-for-profit bodies:

  • Point Horizon Institute is the operating body for the Clairvision School based in the United States of America and which runs courses in the Americas and Europe, in addition to the sale of books and self-paced courses on the Clairvision website; and
  • Clairvision School Limited is the operating body for the Clairvision School based in Australia and which runs courses in Australia, New Zealand and Asia.

In respect of the General Data Protection Regulation (GDPR) of the European Economic Area (EEA) and United Kingdom (UK), Point Horizon Institute is the “Controller” where it offers goods and services to people in the EEA and the UK respectively.

Both Point Horizon Institute and Clairvision School Limited can be contacted at info@clairvision.org.

The Clairvision School and your personal data

The Clairvision School respects your privacy. It is a key part of doing what we do, creating a safe space for people no matter how they engage with the school, whether that is by purchasing a book, attending a course or becoming a long-term student. The privacy laws in certain jurisdictions, such as the EEA and the UK, can be stricter than in others. The Clairvision School values the privacy of all and therefore chooses to apply the same high level of standards for everyone, regardless of where you are based and how you engage with the school.

We understand that some of the personal information you provide can be sensitive. The Clairvision School only collects information that is necessary for your participation, for your safety and that of others, and to facilitate the Clairvision School's operations.

Please read this carefully as this privacy statement explains how both Point Horizon Institute and Clairvision School Limited collect, use, store, protect and share your personal data. It also informs you of the rights you have.

The following will help you understand what personal information the Clairvision School processes, how it is collected, what is done with the personal information and why.

WHAT personal data does the Clairvision School process?

The Clairvision School will collect different kinds of personal data from you depending on the type of engagement you have with us. This could include:

  • Your name, date of birth and basic contact information, such as home address, telephone number and email address;
  • Your purchase history, for example, which self-paced courses you have purchased so that we know that you have met any prerequisites for purchasing additional courses or attending an in-person course;
  • Your payment information, in order to process an order at your request and to keep appropriate accounting records;
  • If you would like to attend a course, special categories of personal information such as religious / philosophical beliefs or health information, for example, any dietary requirements or physical concerns you may have, and any relevant medical or psychological history that is important to know to ensure that a course is suitable and conducted in a safe environment for you and fellow participants;
  • If you become a member of the online community operated by the Clairvision School, information to create a profile visible to other community members including your date of birth and a photograph of yourself, your use of the services and any content you choose to contribute to the online community (for example, sharing your experiences or sending an in-community message to another member).
  • If you browse the Clairvision School website, your IP address is received as part of the communication, however, this information is anonymized prior to any further use. The Clairvision School does not collect or track personal data related to your website use. The Clairvision School does not make use of cookies.

HOW does the Clairvision School collect your personal information?

As much as is possible, the Clairvision School will only collect your personal information directly from you. In some cases and only when necessary, the Clairvision School may collect your personal information indirectly. This includes:

  • If you are listed by a participant of a course as their emergency contact. This information will be provided by the participant at the time of registration when they nominate you as their emergency contact and will include basic details including your name, contact details and your relationship to the participant. This information will only be used to contact you in the unlikely event of an emergency involving the participant.
  • If you attend a course, the Clairvision School may collect personal information about you that arises during the course. This could include personal information about your progress from a course instructor and used to facilitate your training. For example, once you have completed a course, it could be used to help determine the most appropriate next steps for you if you would like to continue with another course.
  • If you attend a course and you have previously engaged with an IST practitioner, you have the option upon registration to ask the Clairvision School to contact your IST practitioner as it may facilitate your training. If you do request this, to protect your privacy, any contact between the Clairvision School and your IST practitioner will remain verbal and the Clairvision School will not create any written records. IST practitioners are independent operators and they do not process information on behalf of the Clairvision School, or vice versa.
  • The safety of all students and instructors is paramount. In the unlikely event that an incident or emergency occurs, the Clairvision School has a duty to document certain details related to the event and this could include personal information about you.

WHY does the Clairvision School process your personal information and on what legal basis?

The following outlines different reasons why the Clairvision School needs to collect your personal information. The Clairvision School will never collect your information unless it is permitted to do so by law.

In order to perform a contract

The Clairvision School will process your personal information in order to provide its services to you or to take pre-contractual measures. For example:

  • If you purchase a book or a self-paced course on the Clairvision School website, we will need to collect certain information in order to process and deliver your order.
  • If you attend an online or in-person course, the Clairvision School will need to collect personal information such as health information. This is designed to make sure the course is suitable for you. It is also because knowing some of your background is necessary to provide the best course for your needs. Your safety and the safety of everyone attending the course is paramount.
  • If you become part of the online community, the Clairvision School will need to collect certain information in order to create and manage your account and the community platform, for it to remain a safe and inclusive place for sharing experiences, for helping other students and to offer tools for you to help you develop further in the work.
  • If you are unable to provide the information, we may not be able to provide the requested service to you, for example, if you are unable to provide the requested information regarding your health, we may be unable to enroll you in a course.

For the purpose of the legitimate interests of the Clairvision School or others

The Clairvision School needs to process personal information to maintain its operations, for example, for financial reporting and regulatory obligations, and to protect its services by maintaining a secure environment and to prevent misuse. It is in your interests, but also in the Clairvision School's interests, that courses are run in a safe environment. For that reason, the Clairvision School collects personal information to ensure it upholds its duty of care to all participants and instructors. Should an emergency occur, it is also in the Clairvision School's interests to appropriately document the incident, which could mean keeping the record for a period of time.

Where you have given consent

The Clairvision School may ask for your consent to process your personal information. This includes for the processing of special categories of personal data (such as your health information or religious / philosophical beliefs). If you have given consent and you want to withdraw this consent, you can do that very simply and at any time by contacting info@clairvision.org.

In order to comply with a legal obligation

Sometimes the law requires the Clairvision School to process certain personal information, for example, to keep records for a minimum period of time. The Clairvision School will also keep personal information in connection with any potential legal claims.

To protect someone's vital interests

The Clairvision School may process personal data if we think someone's life is in danger, for example, if there was an urgent medical situation.

WHO does the Clairvision School share your personal information with?

The Clairvision School is run by two operating bodies, Point Horizon Institute and Clairvision School Limited, and information collected by Point Horizon Institute and stored electronically will be accessible by both bodies. This includes courses purchased and attended and the respective records; and any involvement in the online community.

Point Horizon Institute and Clairvision School Limited may also need to share your personal information with other third parties in order to conduct its activities and to provide services to you. Such third parties include:

  • Service providers
    This includes service providers that the Clairvision School uses to process transactions, for example, when you purchase a book online or pay for a course, a third party will be used to facilitate the actual payment and a third party will be used for accounting records. This includes service providers that host the Clairvision School's data and services and that provide for connectivity between you and the Clairvision School.
  • Emergency contacts
    For example, if an emergency occurs whilst you are in attendance at an in-person course, the Clairvision School may need to contact emergency services or the emergency contact you provided when you registered for the course. The Clairvision School will only do so in good faith and as necessary in order to respond to an emergency.

If you are based in the EEA or the UK: transfers outside of the EEA or UK:

In respect of GDPR of the EEA and UK, Point Horizon Institute is the “Controller” where it offers goods and services to people in the EEA and the UK respectively. Point Horizon Institute operates from its base in California, United States of America. In order to provide these goods and services to you, your personal data will be transferred to the United States of America.

Certain types of personal data will also be accessible in Australia by Clairvision School Limited. Point Horizon Institute may also store information on servers or equipment in other countries in order to provide and secure its operations. See section above “Who does the Clairvision School share your personal information with?”.

It is important to note that some countries may apply different data protection standards to those that apply in the EEA or the UK and this may involve risks.

Profiling

The Clairvision School does not make use of profiling, being the automated processing of your personal data to evaluate aspects related to you. Also, the Clairvision School does not make any decisions about you based on automated processing, including profiling.

How does the Clairvision School determine the period for which your personal data is kept?

The Clairvision School needs to process your personal information for different purposes. This means that your personal information may be kept for different periods of time, depending on the purpose. For example, whilst the Clairvision School may process your credit card information via a third party for an online purchase, it does not store your credit card information, but it will, however, keep other details of your purchase for its accounting records. When it is no longer necessary to keep your personal information, it will be deleted or archived with restricted access (for example, if a copy is kept in a rolling backup for security reasons). More specifically:

  • for information maintained for the Clairvision School's legitimate interests, this information will be kept until it is no longer required for those legitimate interests and where not overridden by your interests or fundamental rights and freedoms;
  • for information required by law or for the exercise or defense of legal claims, this information will be kept for as long as required to comply with the law and/or the relevant statutory limitation or legal proceeding; and
  • for personal information related to the online community, this information will be kept for as long as you remain a student of the Clairvision School.

What rights do you have and how can you exercise them?

You have the following rights:

  • Right of access: you have the right to know whether the Clairvision School processes your personal information and if so, access to the personal data.
  • Right to rectification: if the personal data that the Clairvision School has about you is incorrect, you have the right to have this information corrected. You also have the right to have incomplete personal data that the Clairvision School holds about you completed.
  • Right to erasure: you have the right to obtain from the Clairvision School the erasure of your personal data on certain grounds, for example, where the personal data are no longer necessary or you withdraw previously given consent and there is no other legal ground for processing. However, the Clairvision School may not be able to do so in certain situations, such as if it is required to keep it by law or for the establishment, exercise or defense of legal claims.
  • Right to restriction: you have the right to restriction of processing of your personal data under various circumstances, for example, where the accuracy of your personal data is contested.
  • Right to data portability: where processing of your personal information is based on consent or for the performance of a contract and carried out by automated means, you have the right to receive the personal data you provided to the Clairvision School in a structured, commonly used and machine-readable format and to have that transmitted to another controller.
  • Right to object: you have the right to object to the processing of your personal data, including profiling, under certain circumstances, for example, where it is based on the Clairvision School’s legitimate interests. If you no longer want to receive marketing information from the Clairvision School, you can unsubscribe at any time. All marketing messages include this possibility and you can exercise this right easily.
  • Right to not be subject to a decision based solely on automated processing, including profiling. The Clairvision School does not make any decisions about you based on automated processing, including profiling.
  • You also have the right to lodge a complaint with a supervisory authority.

If you do not provide the requested personal information to the Clairvision School or if you ask the school to delete, or restrict the processing of, your personal information, and that personal information is necessary to provide you with goods or services, the Clairvision School may not be able to complete that transaction or provide you with the goods or services.

Updates to this Privacy Statement

Changes in the law or in the products, services or operations of the Clairvision School may require changes to this Privacy Statement from time to time.