Last updated: 11 Feb 2019
You may browse, view and use Nalandabodhi’s websites without submitting any personal data. You may also voluntarily provide personal information such as your name and email address in order to contact us or use services on our websites. The processing of your personal data may then become necessary.
The processing of personal data, such as the name, address, email address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Nalandabodhi. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
As the controller, Nalandabodhi has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to send personal data to us by alternative means, e.g. by telephone or postal mail.
The data protection declaration of Nalandabodhi is based on the terms used by the European Parliament for the adoption of the General Data Protection Regulation (GDPR) of the European Union (“Union”) and Member States (regulation (EU) 2016/679). We intend our data protection declaration to be legible and understandable for the general public, as well as our customers and partner organizations. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use the following terms, among others:
a) Personal data
Personal data means any information relating to an identified or identifiable natural person (a “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
j) Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
3902 Woodland Park Ave N
Seattle, WA 98103
The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, existing cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable. (To learn how to disable or delete cookies, the following links may help: to disable: wikihow.com, howtogeek.com; to delete: lifewire.com, digitaltrends.com.)
4. Collection of general data and information
The website of Nalandabodhi collects general website access data when a data subject or automated system accesses the website. This general data is stored in the web server log files. Data collected may include (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using this general data, Nalandabodhi does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Nalandabodhi analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our organization, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
5. Registration on our website
The data subject has the option to submit personal data via registration forms and other input forms on the controller’s websites. The personal data that are transmitted to the controller is determined by the respective input form used. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a mailing service) that also uses personal data for an internal purpose which is attributable to the controller.
Our website registration and input forms may collect personal data such as:
Name and Contact Data. We may collect your first and last name, email address, postal address, phone number, and other similar contact data.
Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All such payment data is stored by our payment processors. You may review their privacy policies and contact the payment processors directly to respond to your questions.
Credentials. We may collect passwords, password hints, and similar security information used for authentication and account access.
When registering on the website of the controller, the IP address (assigned by the Internet service provider (ISP)) and used by the data subject, date, and time of the registration are also stored. The data is stored as a cautionary measure to prevent the misuse of our services, and to make it possible to investigate committed offenses. As such, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary submission of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data store of the controller.
The data controller shall, at any time, provide information upon request to each data subject as to what personal data is stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, provided that there are no statutory storage obligations. For these requests, please contact us following the instructions in section “17. Privacy contact” below.
6. Subscription to our newsletters
On Nalandabodhi’s websites, users are given the opportunity to subscribe to our organization’s newsletters. The input form used for this purpose determines what personal data is transmitted, as well as when the newsletter is requested from the controller.
Nalandabodhi informs its individual subscribers and partner organizations regularly by means of newsletters about organizational activities and offers. The organization’s newsletters may only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject registers for the newsletter subscription. Upon registration via our websites, a confirmation email will be sent to the email address provided by the data subject as a double opt-in procedure for legal compliance. This confirmation email is used to prove whether the owner of the email address as the data subject has authorized the sending of the newsletters.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the email address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for a newsletter will only be used to send the newsletter. In addition, subscribers to the newsletter may be informed by email in the event of changes to the newsletter’s terms or other technical changes relevant to the operation of the newsletter service or relevant to maintaining the subscriber’s registration. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for sending the newsletter, may be revoked at any time. For the purpose of unsubscribing, an “unsubscribe” link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time by communicating this to the controller in a different way, such as by contacting us using the instructions in section “17. Privacy contact” below.
7. Newsletter tracking
Nalandabodhi newsletters may contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, which are sent in HTML format to enable log file recording and analysis. This allows statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Nalandabodhi may see if and when an email was opened by a data subject. Nalandabodhi may also use unique URL links to track which links in the email were invoked by data subjects.
Such personal data collected via the tracking pixels and unique URLs contained in the newsletters are stored and analyzed by the controller in order to optimize the sending of the newsletters, as well as to adapt the content of future newsletters to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the consent they previously gave by means of the double-opt-in procedure. After such revocation, this personal data will be deleted by the controller. To revoke consent, please contact us following the instructions in section “17. Privacy contact” below.
8. Contact options via the website
Nalandabodhi websites contain contact forms that enable quick electronic contact with us, and provide organizational email addresses for direct email communication with us. If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller is stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
9. Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European Parliament or other laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European Parliament or other applicable regulations expires, the personal data are routinely blocked or erased in accordance with legal requirements.
10. Rights of the data subject
a) Right of confirmation
Each data subject shall have the right granted by the European Parliament to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact us following the instructions in section “17. Privacy contact” below.
b) Right of access
Each data subject shall have the right granted by the European Parliament to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact us following the instructions in section “17. Privacy contact” below.
c) Right to rectification
Each data subject shall have the right granted by the European Parliament to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact us following the instructions in section “17. Privacy contact” below.
d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European Parliament to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Nalandabodhi, he or she may, at any time, contact us following the instructions in section “17. Privacy contact” below.. Nalandabodhi staff shall ensure that the erasure request is complied with promptly.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. Nalandabodhi staff will arrange the necessary measures in individual cases.
e) Right of restriction of processing
Each data subject shall have the right granted by the European Parliament to obtain from the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
- The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Nalandabodhi, he or she may at any time contact us following the instructions in section “17. Privacy contact” below.. Nalandabodhi staff will arrange the restriction of the processing.
f) Right to data portability
Each data subject shall have the right granted by the European Parliament, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact us following the instructions in section “17. Privacy contact” below.
g) Right to object
Each data subject shall have the right granted by the European Parliament to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
Nalandabodhi shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If Nalandabodhi processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Nalandabodhi to the processing for direct marketing purposes, Nalandabodhi will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Nalandabodhi for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may contact us following the instructions in section “17. Privacy contact” below.. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
Please note that, per section “16. Non-use of automated decision-making,” Nalandabodhi does not use automated decision-making or profiling. Notwithstanding this, the data subject has the following right.
Each data subject shall have the right granted by the European Parliament not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, Nalandabodhi shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact us following the instructions in section “17. Privacy contact” below..
i) Right to withdraw data processing consent
Each data subject shall have the right granted by the European Parliament to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact us following the instructions in section “17. Privacy contact” below.
11. Data protection for employment applications and the employment application procedures
The data controller shall collect and process the personal data of applicants for the purpose of the processing employment applications. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding employment application documents by email or by means of a web form on the website to the controller. If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Other legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).
12. Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our organization is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our organization and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our organization or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European Parliament. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
13. The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our organizational operations and activities in favor of the well-being of all our employees, staff, and members.
14. Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
15. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary in order to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our organization signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject may contact us following the instructions in section “17. Privacy contact” below to obtain clarification as to whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of non-provision of the personal data.
16. Non-use of automated decision-making
17. Privacy contact
For privacy questions and concerns, please email firstname.lastname@example.org, or send postal mail with “attn: privacy” to the address below. Please provide specific information about the nature of your request to enable us to best respond to you.
3902 Woodland Park Ave N
Seattle, WA 98103
email@example.com • (206) 529-8258
© Nalandabodhi 2019