Financial Information (Non-Donor)
Billing and other financial information (such as your credit card number or bank account number when combined with your billing address, and referred to collectively as Financial Information) will be required to register for certain Programs, book a visit to Kripalu Center, or related to other transactions, such as purchases made through the Kripalu Shop. Tokenized information – which Kripalu does receive – is not Financial Information for purposes of this Policy because Kripalu cannot access bank or card numbers via the token. All reservations and bookings (whether online, in-person, or over the telephone) are made and processed directly through a fully-integrated third-party solution unless otherwise noted.

For Financial Information relating to you in your capacity as a Donor to Kripalu (Donor Financial Information), please refer to the Donor-Specific Terms below.

Kripalu does not enter or store any Financial Information in its computers, networks, facilities, online database, or files, although tokens do reside on our systems until all transactions with you have been finalized.  Unless otherwise noted at the payment entry point, financial Information is processed and ultimately stored on a platform currently operated and controlled by Shift4 Corporation, a PCI-compliant service that handles all of our payment processing (Shift4). We do not review your Financial Information if you engage in a payment transaction, although we do know the amount that is charged to your credit card or debited from your bank account in any such transaction.  We may also receive your billing address.  Payment processing is governed by the Shift4 terms and privacy policies, available at www.Shift4.com, or via terms otherwise noted at the payment entry point.

Please note that we may change our Financial Information processor at any time, in which case, this Policy will be updated.

Information Voluntarily Submitted For Scholarship or Other Financial Assistance
Additional information may be requested as part of an application for a scholarship or other financial assistance.  Required details generally include your income level, the name of your employer (if any), demographic information, and and other information necessary for Kripalu to process your request for financial assistance.  Applicants are invited to provide additional information relevant to their applications. Kripalu solicits this information via a Kripalu-created form, hosted by Wufoo, and the information you provide in these cases will be processed by Wufoo and subject to the privacy and other terms of use posted at www.wufoo.com. These links will often be provided within the form itself.  Please familiarize yourself with the privacy and other terms applicable to your data prior to submitting this or other information via a Wufoo form.

Testimonials, Stories, Information Shared via Social Media
You may submit testimonials to us directly or via Program evaluations, and are also invited to tag Kripalu in social media postings. Information submitted or shared in this manner is subject to the terms of this Policy.

B. Information Collected Automatically

Meta Data
Certain information may be gathered automatically through a variety of mechanisms, including non-identifying information, an IP address, referring URL, browser, operating system, cookie information, and Internet Service Provider (Meta Data). Generally, this kind of information on its own cannot be used to identify you.

Kripalu does not use automatic means to collect Personal Data, but we may associate Meta Data with Personal Data you or someone authorized by you has provided to us. Whenever we associate Meta Data with your Personal Data, it will be treated as Personal Data.

Information Obtained from Other Sources
We may obtain information about you from other sources. For example, we may receive background information in connection with an employment application; or via an email list purchased from or otherwise shared by a third party. Once information is received by Kripalu, we will treat it in accordance with this Policy.

Internet-Based Third-Party Advertising and Do Not Track Technology
Our Sites and certain Services use third-party advertising companies, which sometimes utilize third-party services for data collection and analytics.  These companies may use information about your visits to our Sites and to other websites in order to provide advertisements about products and services which may interest you. In so doing, we or these third parties may use cookies or other technologies for the purpose of collecting certain information about you. This may include your server activity logging, browser cookies, web beacons, and embedded scripts.

We use this information for our own marketing purposes, including but not limited to informing, optimizing and serving ads to you online when you are browsing other websites. We use a variety of third-party services to collect and track this information. Each service has its own policy for handling Do Not Track signals and methods for opting-out of the collection of information for these purposes. By using the Sites and Services, you consent to potentially encountering third-party tracking technologies and you understand and agree that our statements under this Policy do not apply to the tracking technologies or practices of such third parties.

For more information on internet based-advertising, including options for opting-out, the Network Advertising Initiative has created a website, which you can access here https://www.networkadvertising.org/.

Third-Party Sites and Social Media Plug-Ins
When you click on links on our Sites that take you to third-party websites, you will be subject to the privacy practices of the operator of the third-party website. We encourage you to read the posted privacy statement on those sites (if any). We are not responsible for the privacy practices and policies of these or any other third-party websites and/or social medial plug-ins.

We use social media buttons or plug-ins on our Sites, for example for Facebook, Twitter, Instagram, and Pinterest. If you click on one of these buttons, your browser connects directly to the web servers of the associated social media network(s). If you are registered and logged into your account(s) on the(se) network(s), the network will receive and may store information about your use of our Sites. Even if you are not registered with the social media network or you are logged out when you visit our Sites, your IP address may be transmitted to and stored by these organizations. If you interact with our Sites through a social media network, then you may be permitting us to have access to information from your profile (such as your name, e-mail address, photo, gender, location, and the people/sites you follow). Each network has its own privacy policy. If you do not want the network to collect information about you or to share it with us, you must review the privacy policy on the network’s website and take the steps described there. In addition, you should log out of the relevant network before you visit our Sites.

A. Used for the Purpose Submitted
Other than as provided for in this Policy, we generally use Your Information for the purpose for which it was submitted. For example:

• If you provide Your Information as part of an employment application, we will use it to process your application and communicate with you about the same;
• If you provide Your Information to register for a Program or other visit to Kripalu Center, we will use Your Information to process the registration;
• If you apply for a scholarship or other financial assistance, we will use it to evaluate and process your application, and if you’ve provided permission, we may also share certain details with relevant individuals or organizations who funded the scholarship or other financial assistance.  In addition, if you’ve provided permission, we may include your story in Kripalu-generated media and publications; or
• If you request materials and Services, we will use Your Information to respond to and process your request, and may also add you to our database in order to provide you with additional materials and information in the future.

We also share or transfer Your Information as directed or authorized to do so by you or where you consent to such disclosure. We may aggregate Your Information with the information of other individuals in order to analyze and compare information as between users of our Sites and Services.

Other general uses include:

• To communicate with you generally about our Sites, Programs and Services;
• To solicit feedback about the Programs;
• To facilitate your participation in events conducted by Our Collaborators or to otherwise make you aware of Our Collaborators’ products and services;
• To facilitate contact from Third-Party Research Partners who may request your voluntary participation in a Research Study as part of a Program; and
• To communicate with you about our giving and donor opportunities.

The foregoing are just a few examples of certain uses tied to the nature of your interactions with us. The terms in the balance of this Section 2 provide additional details.

B. Other Uses

Research Studies
Research Studies may be performed by Kripalu on its own, by a Third-Party Research Partner, or as a collaboration between us and a Third-Party Research Partner. The information you provide in connection with a Research Study will be shared between Kripalu and its Third-Party Research Partners in order to research and evaluate data and feedback from Program participants and other resources. Specific to Programs (such as RISE™) where research is performed by Third-Party Research Partners and/or other of Our Collaborators, you may be asked to voluntarily provide information directly to the Third-Party Research Partners, which will then be shared by the Third-Party Research Partners with us. Study Questionnaires (if any) and related Program surveys will be sent to you from the Third-Party Research Partner and are distinct from Kripalu’s general surveys provided to all of our Program participants.

The Third-Party Research Partner will aggregate the information it collects via the Study Questionnaires and other materials you have provided, and will perform an analysis, which it will share with the rest of the research team in aggregate form, including its own Institutional Review Board, affiliates and others. Please refer to Section 1(A) regarding submission of information directly to a Third-Party Research Partner, which is always voluntary.

Programs & Our Collaborators
When you attend an onsite research and/or live or online training Program, we may use and share Your Information as follows: typically, we will only disclose or share aggregate, anonymous, or de-identified information for research, compliance, marketing, advertising, or other purposes. We may, however, publicize direct quotes or testimonials from responses to a survey or evaluation; provided, however, that we will not disclose the participant’s name associated with the quote without that participant’s express, prior permission.

Further, we may also disclose Your Information to Our Collaborators and Third-Party Research Partners. For instance, we may share Your Information to permit Our Collaborators to communicate with you, provide you with materials relevant to a Program, present the Program, or otherwise facilitate your registration in a Program to be provided by these third parties.

Third-Party Marketing Activities
You may be presented with opportunities to receive information and/or marketing offers directly from third parties, including in some cases, Our Collaborators. If you later decide that you no longer want to receive communication from a third party, you will need to contact that third party directly. Where information about you is voluntarily disclosed by you to third parties, all information you disclose will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review the privacy policies and practices of such third parties prior to agreeing to receive such information from them.

Third-Party Service Providers
We may use third-party vendors, consultants, and other service providers to perform certain services on behalf of Kripalu, such as hosting the Sites, hosting and processing Your Information and Meta Data, designing and/or operating features of the Sites and Services, performing analytic services that allow us to enhance the information we present to you either now or in the future, facilitating the delivery of our Services, or performing other administrative and operational tasks. In some cases, you will be required to submit information directly to these third parties. Exception: no mobile phone information will be shared with third parties, and no text messaging originator opt-in data nor consent data will be shared with third parties. 

We expect all of our third-party service providers to comply with federal and state laws regarding consumer privacy and data protection.

Furthermore, we may also provide our partners (and other third-party partners who might benefit from the information) with aggregated de-identified data (i.e., compiled data that does not in itself identify you) for research and commercial purposes.

We may also, on occasion, share, rent, or exchange all or part of our customer postal lists with carefully selected organizations with whom we have relationships, for our own, and their own, promotional purposes. The sharing activities described in this paragraph (either directly or through a list broker such as InfoGroup, Inc.) will be limited to your name and mailing address.

If you prefer that we do not exchange, rent, or otherwise share your name and postal address with our partners, please let us know by following the OptOut Procedures in Section 5 below.  But please note that in cases where you are providing information directly to or via a third party (such as with {Wufoo}), the third party’s terms and conditions will apply and you should communicate with the third party regarding management and use of your information

Kripalu Promotional and Marketing Activities; Recordings
At times, we may take photographs and/or make audio and video recordings of guests to promote the benefits of participating in our Programs and Services. If you are a guest of Kripalu, you will be required to sign a Guest Participation Agreement and Release upon arrival (a sample of which is posted at https://kripalu.org/guest-participation-agreement-and-release), which addresses permissions and other rules related to use of photographs and other recordings made by Kripalu.  In addition, Kripalu may use testimonial statements provided to us via an evaluation form or otherwise, as well as statements, photos, quotations and other information you share via a Kripalu social media account (including where you have tagged Kripalu in your own social media posts), for general marketing and promotional purposes.  This use may include reference to your social media name/account. 

Consistent with our Web Site Terms of Use and other documents governing online offerings, Kripalu reserves the right to record in any manner or medium, certain programs and sessions, and by participating in our programs, you agree that your voice, image and likeness may be recorded (audio, video, etc.).  The recordings shall constitute Kripalu intellectual property, and may be used, sold, licensed, broadcast, and otherwise commercially exploited as determined by Kripalu in its sole and reasonable discretion. 

Release of Your Information for Legal Purposes
We may access, use, preserve, transfer, and disclose Your Information (including Personal Data), including disclosure to third parties, to the fullest extent permitted by applicable law: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Sites’ Terms of Use or other policies applicable to the Sites or Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Services or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, to the fullest extent permitted by applicable law, we may use IP address or other device identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, Internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion. Such disclosures may be carried out without notice to you if permitted by applicable law.

Security and Protective Measures
We may, in our sole discretion, share or transfer Your Information to protect the security or integrity of our Sites and Services, to protect our business or reputation, to take precautions against legal liability, in the event of a business transition (see below), to protect and defend our rights or property, for required institutional risk control, or for resolving disputes, inquiries or complaints with respect to your use of the Sites and Services.

Meta Data
We use this information in the aggregate (combined with similar information collected from other individuals who are using our Sites and Services) to help us analyze, maintain, and improve our Sites and Services, to monitor the online usage of our Sites and Services, assess our Sites’ performance, ensure technological compatibility with your computer, and understand the relative importance of the information provided about our Sites and Services. We may also use this data to conduct statistical analyses on usage patterns, trends and other aggregated data. Additional uses are specified in Section 1(B).

A. How You May Access and Manage Your Information and How to Opt-Out
We want to provide you with meaningful choices regarding managing Your Information and the communications you receive from us, and you may choose to limit or opt-out of certain promotional/marketing communications and/or how and with whom we share Your Information. If you choose to opt-out of promotional/marketing communications, please note this will correspondingly result in automatically opting-out of any surveys we may send to evaluate your stay and any Programs you may have attended. In addition to responding to the provided link in our electronic communications, you may email contact@kripalu.org or call us at 800.741.7353 to opt-out or otherwise change your communication preferences (including being added to the “do not rent” list).

For catalog and programming requests, please email us at request@kripalu.org.

You may still receive administrative communications from us, such as order confirmations, notifications about your account activities (e.g., account confirmations, password changes, etc.), products or services you have requested, and other important announcements, and you may receive direct mail from us.

B. How to Contact Us About Our Privacy Policy
Should you have any questions or comments concerning our Policy you may e-mail us at legal@kripalu.org.

C. We Reserve the Right to Contact You
Kripalu reserves the right, but is under no obligation, to contact you for any reason regarding, related to, or arising from, the Services, Sites, your account or subscription, this Policy, the Terms of Use, or any other policies or agreements relevant to you. Our primary method of communication is email.

D. Your California Privacy Rights
Under California law, California residents who have an established business relationship with us may choose to opt-out of our disclosure of Personal Data about them to third parties for direct marketing purposes. Unless noted in this Privacy Policy, our policy is not to disclose Personal Data collected online to a third party for direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval, please contact us by email contact@kripalu.org.

E. Transfer or Sale as Part of a Business Transaction
In the event Kripalu goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Data might be among the assets sold or transferred and you hereby consent to such sale, transfer or assignment.

F. Governing Law
We, and our servers, are located in the United States and are subject to the applicable U.S. local and national laws. When you choose to use our Sites and Services, you do so on your own initiative and understanding that your use of the Sites and Services and our use of Your Information is subject to U.S. laws and regulations. If you choose to use our Sites and Services, you consent to the use and disclosure of information in accordance with this Policy and subject to such laws, including the transfer of your Personal Data to servers located in the United States.

G. Changes to this Policy
This Policy was last revised on the below date. Any changes to the Policy will be made through updates to the Policy and posted on our Sites, with a new effective date. Unless we clearly indicate otherwise, we will use information in accordance with the Policy under which the information was collected.