Privacy Policy for Online Yoga Classes and Meditation

We would like to inform you in the following about the processing of personal data in connection with the use of “Zoom”.

Purpose of the processing

We use the “Zoom” tool to conduct online yoga classes and online meditations (hereinafter referred to as “Online Meetings”). “Zoom” is a service of Zoom Video Communications, Inc. which is based in the USA.

Responsible person

The Sivananda Yoga Vedanta Centres are responsible for data processing directly related to the holding of online meetings.
Note: If you access the “Zoom” website, the provider of “Zoom” is responsible for data processing. However, to use “Zoom” it is only necessary to call up the website in order to download the software for using “Zoom”.
You can also use “Zoom” if you enter the respective meeting ID and, if necessary, other access data for the meeting directly in the “Zoom” app.
If you do not want to or cannot use the “Zoom” app, the basic functions can also be used via a browser version, which you can also find on the “Zoom” website.

What data is processed?

Various types of data are processed when using “Zoom”. The extent of the data depends on the data you provide before or during participation in an “online meeting”.
The following personal data are processed:

• User details: First name, last name, telephone (optional), e-mail address, password (if “Single-Sign-On” is not used), profile picture (optional), department (optional).
• Meeting metadata: Topic, description (optional), participant IP addresses, equipment/hardware information
• For recordings (optional): MP4 file of all video, audio and presentation recordings, M4A file of all audio recordings, text file of online meeting chat.
• When dialing in by phone: Information on incoming and outgoing phone number, country name, start and end time. If necessary, further connection data such as the IP address of the device can be saved.
• Text, audio and video data: You may be able to use the chat, question or survey functions in an “online meeting”. To this extent, the text entries you make are processed in order to display them and, if necessary, log them in the “online meeting”. In order to enable the display of video and the playback of audio, the data from the microphone of your terminal device and from any video camera of the terminal device will be processed accordingly for the duration of the meeting. You can switch off or mute the camera or microphone yourself at any time using the “Zoom” applications.
  In order to participate in an “online meeting”, you must at least provide information about your name to enter the “meeting room”.

Scope of processing

We use “zoom” to conduct online meetings. If we want to record online meetings, we will inform you in advance in a transparent manner and – if necessary – ask for your consent. The fact of the recording will also be displayed in the “Zoom” app.
If it is necessary for the purpose of recording the results of an online meeting, we will log the chat content. However, this will not be the case as a rule.
In the case of webinars, we may also process the questions asked by webinar participants for the purposes of recording and follow-up of webinars.
If you are registered as a user at “Zoom”, reports of online meetings (meeting metadata, telephone dial-in data, questions and answers in webinars, survey function in webinars) can be stored at “Zoom” for up to one month.
The possibility of a software-based “attention tracking” in “online meeting” tools like “Zoom” is deactivated.
Automated decision making within the meaning of Art. 22 GDPR is not used.

Legal basis of the data processing

For employees of the Sivananda Yoga Vedanta Centres, the French Data Protection Act is the legal basis for data processing. Should data not be required for data processing in connection with the use of “Zoom”, but nevertheless be an elementary component in the use of “Zoom”, Art. 6 Para. 1 letter f) GDPR is the legal basis for data processing. In these cases, we are interested in the effective implementation of “online meetings”.
For other participants in “online meetings” – insofar as the meetings are held within the framework of contractual relationships – Art. 6 Paragraph 1 lit. b) GDPR is the legal basis for data processing.
If no contractual relationship exists, the legal basis is Art. 6 para. 1 lit. f) GDPR. Here too, we are interested in the effective implementation of “online meetings”.

Recipient / passing on of data

Personal data processed in connection with participation in “online meetings” is generally not passed on to third parties, unless it is specifically intended to be passed on. Please note that the contents of “online meetings” as well as personal meetings are often used to communicate information with customers, interested parties or third parties and are therefore intended to be passed on.
Other recipients: The provider of “Zoom” necessarily obtains knowledge of the above-mentioned data, insofar as this is provided for in the context of our data processing agreement with “Zoom”.

Data processing outside the European Union

“Zoom” is a service provider based in the USA. Processing of personal data is therefore also carried out in a third country. We have concluded a data processing agreement with the provider of “Zoom” which meets the requirements of Art. 28 GDPR.
An appropriate level of data protection is guaranteed on the one hand by the “Privacy Shield” certification of Zoom Video Communications, Inc. and on the other hand by the conclusion of the so-called EU standard contractual clauses.

Last updated: 1 April 2020