This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

The words of which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Policy) refers to Sano: Sound & Yoga, a sole trader business operating in England.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: United Kingdom.
• Device means any device that can access the Service such as a computer, a mobile phone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Special Category Data means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, or data concerning a person’s sex life or sexual orientation. For the purposes of our Service, this primarily relates to health data collected to ensure participant safety.
• Service refers to the Website, any related class booking and scheduling platforms, payment processing systems, online content delivery platforms, and in-person services (including yoga classes, sound healing sessions, workshops, and retreats) provided by Sano: Sound & Yoga.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.
• Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to Sano: Sound & Yoga, accessible from www.sanosoundyoga.com.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Usage Data

To ensure the safety and suitability of our yoga classes, sound healing sessions, workshops, and retreats, We may collect health-related information from You. This data is classified as Special Category Data under UK GDPR and is processed only with Your explicit consent. This may include, but is not limited to:

• Injury history and current physical conditions (e.g. back injuries, joint problems, recent surgery)
• Pregnancy status and trimester
• Medical conditions relevant to participation (e.g. epilepsy, heart conditions, high or low blood pressure, tinnitus, metal implants)
• Mental health disclosures where voluntarily provided (e.g. trauma history relevant to sound healing, yoga nidra, or deep relaxation practices)
• Contraindication information specific to sound healing (e.g. epilepsy, first trimester pregnancy, pacemakers or metal implants near vibrating instruments)
• Medication that may affect Your ability to participate safely
• Emergency contact details for in-person classes, workshops, and retreats

This information is collected via pre-class health questionnaires (paper or digital), booking forms, or through direct communication with the instructor. You are under no obligation to provide health data, but We may be unable to safely accommodate You in certain classes or sessions without it.

Explicit Consent: By completing a health questionnaire or providing health information to Us, You are giving explicit consent for Us to process this Special Category Data for the specific purpose of ensuring Your safety during our services. You may withdraw this consent at any time by contacting Us, though this may affect Our ability to allow You to participate in certain activities.

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

When You attend in-person yoga classes, sound healing sessions, workshops, or retreats, We may collect Personal Data and Special Category Data through paper-based forms or verbal communication with the instructor. Paper forms containing Personal Data are stored securely in a locked location, are accessible only to the instructor, and are securely destroyed (by shredding or confidential waste) once they are no longer needed for the purposes described in this Policy or once the relevant retention period has expired.

The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:

• Google
• Instagram
• LinkedIn

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal Data that is already associated with Your Third-Party Social Media Service’s account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service’s account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies – Session Cookies administered by Us. These are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
• Cookies Policy / Notice Acceptance Cookies – Persistent Cookies administered by Us. These Cookies identify if users have accepted the use of cookies on the Website.
• Functionality Cookies – Persistent Cookies administered by Us. These allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: by email, telephone calls, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: to attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
• To ensure participant safety: to use health and wellbeing information You have provided to assess suitability for specific classes, sessions, or activities, and to adapt instruction where appropriate to reduce the risk of injury or adverse reaction.
• To manage class bookings and logistics: including managing waitlists, sending timetable changes and cancellation notices, facilitating workshop and retreat bookings, and communicating relevant logistical information.
• For insurance and liability purposes: to maintain records necessary for professional indemnity and public liability insurance in connection with in-person yoga and sound healing services.

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyse the use of our Service, to facilitate class bookings and payments, and to contact You. These may include:
• Booking and scheduling platforms (e.g. Momoyoga, BookWhen, or similar) used to manage class registrations and attendance.
• Payment processors (e.g. Stripe, PayPal, or similar) used to process payments for classes, workshops, and retreats.
• Email marketing platforms (e.g. Mailchimp, MailerLite, or similar) used to send newsletters, class updates, and promotional communications where You have consented to receive these.
• Website hosting and analytics providers used to host the Website and analyse usage patterns.
• Retreat venue partners where necessary to facilitate Your booking at a third-party venue for a retreat or workshop.

Each of these Service Providers processes Your data in accordance with their own privacy policies and, where applicable, under a data processing agreement with Us.

• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honour this Privacy Policy.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With other users: When You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Under UK GDPR, We are required to have a lawful basis for processing Your Personal Data. The lawful bases We rely on are:

• Consent: Where You have given clear consent for Us to process Your Personal Data for a specific purpose. This is the primary basis for processing Your health and wellbeing data (Special Category Data), which requires Your explicit consent under Article 9(2)(a) of UK GDPR. You may withdraw consent at any time by contacting Us.
• Performance of a contract: Where the processing is necessary for a contract We have with You or to take steps at Your request before entering into a contract. This includes providing class access You have booked and paid for, managing Your bookings, and processing refunds.
• Legitimate interests: Where the processing is necessary for Our legitimate interests or the legitimate interests of a third party, provided Your fundamental rights and freedoms do not override those interests. This includes marketing similar services to existing clients (soft opt-in), improving our Service, and maintaining the security of our systems.
• Legal obligation: Where We need to comply with a legal obligation, such as maintaining tax and accounting records, responding to lawful requests from public authorities, or complying with health and safety regulations.

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. Specific retention periods are as follows:

• Health questionnaire and contraindication data: retained for the duration of Your active participation in our services plus 3 years following Your last attendance, or longer if required for the defence of legal claims.
• Booking and attendance records: retained for 6 years from the date of the transaction, in line with HMRC requirements for financial and tax records.
• Payment and financial records: retained for 6 years from the end of the financial year in which the transaction took place, in accordance with HMRC guidance.
• Insurance-related records: retained for 7 years from the date of the relevant event or claim, in line with standard professional indemnity and public liability insurance requirements.
• Marketing consent records: retained for as long as Your consent remains active. If You withdraw consent or unsubscribe, a record of the withdrawal is kept for 2 years for compliance purposes.
• Usage Data: generally retained for a shorter period of time (typically 26 months), except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
• Paper-based records: paper health questionnaires and consent forms are securely destroyed (by shredding or confidential waste) once digitised or once the applicable retention period has expired.

Under UK data protection law, You have a number of rights in relation to Your Personal Data. You are not required to pay any charge for exercising Your rights. If You make a request, We have one calendar month to respond to You. These rights include:

• Right of access: You have the right to request copies of Your Personal Data (commonly known as a ‘data subject access request’).
• Right to rectification: You have the right to request that We correct any information You believe is inaccurate or complete information You believe is incomplete.
• Right to erasure: You have the right to request that We erase Your Personal Data, under certain conditions.
• Right to restrict processing: You have the right to request that We restrict the processing of Your Personal Data, under certain conditions.
• Right to object to processing: You have the right to object to Our processing of Your Personal Data, under certain conditions, including objecting to direct marketing.
• Right to data portability: You have the right to request that We transfer the data We have collected to another organisation, or directly to You, under certain conditions.
• Right to withdraw consent: Where We rely on consent to process Your Personal Data (including Special Category Data such as health information), You have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

If You wish to exercise any of these rights, please contact Us using the details provided in the Contact Us section below.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at www.ico.org.uk or by calling 0303 123 1113.

Your information, including Personal Data, is processed at the Company’s operating location and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of Your data and other personal information.

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so, including the retention periods outlined in the Retention section of this Policy.

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

We take the following measures to protect Your data:

• Digital records containing Personal Data and Special Category Data are stored in password-protected systems with access limited to authorised personnel only.
• Paper-based records (such as health questionnaires collected at in-person classes) are stored securely in a locked location, accessible only to the instructor, and are securely destroyed by shredding or confidential waste once they are no longer needed or once the applicable retention period has expired.
• We use encrypted connections (SSL/TLS) on our Website where Personal Data is transmitted.
• Third-party Service Providers who process data on Our behalf are required to implement appropriate technical and organisational security measures.

Our Service is designed for and directed at adults aged 18 and over. We do not offer classes, workshops, retreats, or any other services to persons under the age of 18.

We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that a person under 18 has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without appropriate consent, We take steps to remove that information from Our records.

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

If you have any questions about this Privacy Policy, Your Personal Data, or wish to exercise any of Your data protection rights, You can contact us:

• Via our website: www.sanosoundyoga.com