EU/Brazil Privacy Notice

Please note: if you are outside the European Union (EU), European Economic Area (EEA), the United Kingdom, Switzerland or Brazil, this EU/Brazil Privacy Notice does not apply to you. Instead, please review our General Privacy Policy, which applies to you.

Revised February 25 , 2024

Your information privacy is extremely important to us. We have prepared this EU/Brazil Privacy Notice (“Privacy Notice”) to explain how we collect, use, protect, and disclose information and data. This Privacy Notice applies to you if you are in the EU, EEA the United Kingdom, Switzerland or Brazil and:

you visit Golden Lotus Living, Inc. (“GLLI”,“Golden Lotus Community”, “GLC”, “we”, “our”, or “us”) websites, including those at goldenlotusliving.org (the “Site”), and use any other mobile application or internet services offered by GLLI (collectively, the “Services”);
you participate in activities offered by GLLI, have sought spiritual interaction from us, or have otherwise been in contact with us, whether over the internet or otherwise (we refer to you as an “Affiliate Member”); or
you are a volunteer or have applied to become a volunteer (“Volunteer” singly or “Volunteers” collectively) including volunteering with our meditation groups and as volunteer GLLI Council Members, Service Readers, Ushers, Sunday school teachers or other volunteers with GLLI or GLLI groups).

“You” as used in this policy also includes your child, if your child has contact with GLLI such as by registering for and participating in online and in person youth programs offered by GLLI.

1. GLLI as a Data Controller

This Privacy Notice is provided by GLLI, which is the data controller for your data under the EU General Data Protection Regulation 2016/679 (“GDPR”).

Our contact details are as follows:

Golden Lotus Living, Inc., PO Box 252, Elfrida, AZ USA

2. The Categories of Personal Data We Process

When you have contact with us whether over the internet or otherwise — by using our Sites or Services, joining an online meditation or service, creating an account with us, participating with GLLI as an Affiliate Member, making donations, volunteering, or through other contact with us — we may process the following categories of personal data about you (or about your child in the case of our youth programs).

Personal Information

Names, titles, and photographs (if you provide them).
Contact details such as telephone numbers, addresses, and email addresses.
Personal information that you provide to us including information in correspondence with us, or information you provide in the course of pursuing the Self-Realization Fellowship (SRF) Lessons and meditation techniques, spiritual interactions, or requesting prayers. This information may include information you provide to us about spiritual matters, personal or familial health, financial, marital or work-related matters, and other information about matters of a confidential nature.
Records of your donations or purchases and related payment information (such as bank account numbers, payment card numbers, and payment/transaction identifiers).
Records relating to your bequest to GLLI, including estate planning documents (wills, trusts and powers of attorney) and beneficiary designation forms.
GLLI records containing your personal data including information about your study of SRF Lessons.
Information in connection with activities, events and programs we offer, including name and contact information, information about participation and progress in the program. For example, if your child participates in a Sunday School or summer program, we collect registration information and information about your child’s attendance, participation and progress in the program, and any communications or work submitted as part of the program.
Information related to your Volunteer activities, including information in Volunteer applications, your Volunteer history, and information collected through our Volunteer portals and websites.
For programs and meetings offered online, video and audio recordings of the meetings and programs.
Other operational personal data created, obtained, or otherwise processed in the course of carrying out our activities, including but not limited to GLLI reference number and your history of activities with GLLI.

The data we process may constitute sensitive personal data because, as a religious organization, we necessarily process data suggestive of your religious beliefs. We may also process other categories of sensitive personal data including those about your mental and physical health, family or employment relationships, and other information of this nature that you have provided us.

Usage Data and Site Activity

As explained in our Cookies Settings, we and third parties with which we work use Strictly Necessary, Functional, and Targeting cookies. You can modify the Cookies Settings to disable Functional and Targeting cookies. Depending on your cookie settings, the information we and our third-party partners may collect includes recordings or records of your activity within our Sites and Services such as mouse movements and clicks; information you enter into forms; communications you enter into our chat windows; your domain name; your browser type and operating system; web pages you view; links you click; searches you perform; your IP address, Device Identifiers, and other persistent identifiers including identifiers we may assign to you; the length of time you visit our Sites and/or use our Services; the referring URL or the webpage that led you to our Sites; and approximate (at the level of a city) geolocation information (“Usage Data”). We, and third parties with which we work, may collect similar Usage Data if you join an online meditation, participate in a program offered online (such as an online youth program), or participate in a service via Zoom or a similar conferencing service. We, and third parties with which we work, use this information to provide services such as our chat feature; for analytics purposes; to monitor and improve the Sites and Services; and to enhance your online experience, so that GLLI may contact you about services that might be of interest to you (including through advertising to you on other websites) and so that GLLI may provide you with an easier and more personalized experience and level of service. We and third parties with which we work may be able to track your activity across our different Sites and Services.

Cookies and Online Identifiers

Please see our Cookies Settings for further information about the cookies we use and your choices regarding cookies. Please note that if you log in to our Site as an Affiliate Member, we will seek to set Functional cookies to allow GLLI to remember and personalize your Affiliate Member experience. This may override a choice you previously made for Functional cookies. However, you will be able to opt out of this use of Functional cookies at the time that you log in as an Affiliate Member.

3. Why We Process Your Personal Data

We use your personal data for some or all of the following purposes:

To provide religious and spiritual services including guidance, spiritual interaction, prayers, adult and youth programs and services, and other services that you request.
To contact and communicate with you: (i) in relation to your Volunteer activities, (ii) to keep you informed about news and events, activities and services in which you may be interested, and/or (iii) to respond to questions and communications from you.
To process your application or nomination for a Volunteer role with GLLI, determine your qualifications and fitness for the role, to manage Volunteer activities and schedules, to reimburse Volunteers as appropriate, and to provide you with services, support and guidance in performing your Volunteer role.
To assist you with and process any purchases or donations, or to receive and handle your bequest documents.
To provide activities for our Affiliate Members and Volunteers, for example, to provide and process registrations for a retreat, youth summer programs and Sunday School, or other activities, and to improve those programs for you and other Affiliate Members.
To maintain GLLI’s records.
To enable us to meet all legal and statutory obligations or requirements, and obligations to third parties.
For safeguarding purposes (including diligence and complaints handling), with the aim of ensuring that all children and adults are provided with safe environments in connection with GLLI activities.
To support SRF’s religious teachings to its worldwide membership, and to carry out any other voluntary, religious, or charitable activities for the benefit of the SRF community.
For personnel, administrative, accounting, and management purposes, for example, to maintain our accounts and monitor performance of groups and expenditures.
To provide you with the Sites and Services including allowing you to participate in online meditation and other programs, allowing you to post content, and sending you alerts about your account.
To improve your browsing experience by personalizing the Sites, to improve our online services, to better understand how users access and use our Sites and Services, to maintain, support, and improve our Sites, and for research and analytical purposes.

4. Legal Bases for Processing Your Personal Data

We will process your personal data pursuant to GDPR Article 6(1)(b) if it is necessary to deliver services that you have requested, or to take steps to provide those services. Thus, we process your data when it is necessary to: (i) provide you spiritual interaction, meditation services, retreats, youth programs, GLLI and Volunteer activities, prayers or other services that you request from us, or that you expect when you become an Affiliate Member, whether online or in-person; (ii) provide you with the Sites and Services, including communications related to your account, chat functionality and other elements of the Site that you request or utilize; (iii) provide communications that you request from us, such as when you request our eNewsletter or ask us questions; or (iv) process your orders or donations or to receive your bequest documents.

We process your personal data pursuant to GDPR Article 6(1)(f) because it is necessary for our legitimate interests, or the legitimate interests of a third party (such as one of our GLLI groups or for safeguarding you or other Affiliate Members). Our legitimate interests are: (i) to contact and communicate with you about our activities; (ii) plan and offer activities to you, our Affiliate Members and Volunteers, and improve those programs for you and other Affiliate Members and Volunteers; (iii) to determine your qualifications and fitness to serve as a Volunteer; (iv) to support and assist you in fulfilling your Volunteer role with GLLI, or a GLLI group, and provide the required guidance and support to help your group carry on its activities; (v) to maintain our accounts and records; (vi) to fulfill our legal obligations, and for our personnel, administrative and management purposes; (vii) to further our religious objectives; (viii) to perform diligence or safeguarding tasks and respond to any complaints or problems that may arise; (ix) to help maintain the security of our Sites and Services and better understand how users access and use our Sites and Services, to maintain, support, and improve our Sites and Services, to respond to user preferences, and for research and analytical purposes.

We obtain your consent (pursuant to GDPR Article 6(1)(a)) if you have volunteered to be the contact person of your group, and we would like to share your contact information with others, or if you have consented to us using your information to encourage others on the spiritual path or promote GLLI’s services.

As a religious organization, we process special categories of information, including about your religious and philosophical beliefs or health information, in connection with our purposes of providing religious and spiritual interaction, services and support, and maintaining our related records. This processing is pursuant to GDPR Article 9(2)(d).

5. Sharing Your Personal Data

Your personal data will be treated as confidential, and will be accessed by those persons within GLLI, including our Volunteers, who need to do so for purposes listed in the Why We Process Your Personal Data section of this Privacy Notice. We will never sell your information to third parties. It will only be shared with third parties or other data controllers where it is necessary for the performance of our tasks or where you first give consent. It is likely that we will need to share your data in the following circumstances:

We share information with our third party Service Providers who provide certain services to us. For example, we use a service provider to host our Sites and Services, and data that you transmit to or through our Sites and apps will be transferred through, or reside on, computers owned by these Service Providers. We also use Service Providers to manage some of our services and programs, provide certain analytics services to us, and host interactive learning websites. We also share payment information with third-party payment processors and financial institutions as necessary to process a payment or donation from you. We only provide our Service Providers with the information necessary for them to perform these services on our behalf, and Service Providers are prohibited from using Personal Information other than as specified by us.
In the event that a communication with you requires translation and our staff do not have the required language skills, we may ask an Affiliate Member of our organization to assist us with translation, but only after we have removed any names or contact information from the communication.
If you are a Volunteer, we may share your contact information with other Volunteers so that they may contact you in connection with your Volunteer role and for organizational and administrative purposes.
Where you have volunteered to be the contact person for your spiritual intentional community, and consented to have your contact information shared with others, we will share your contact information with others who are interested in participating in your spiritual intentional community.
With your consent, we may publicly share your image, likeness and other information about you to encourage others on the spiritual path or promote GLLI’s services.
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose personal data and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of our organization or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.
If you choose to share information on any public area of the Sites or Services (such as by using the “Share your story” feature or posting or submitting information to a public testimonial, comment or public discussion forum), that information is publicly displayed and may be accessed and viewed by anyone.
We may disclose to third parties, certain Usage Data regarding the Sites and Services. However, in such cases, your Usage Data is aggregated with the Usage Data of others and does not identify you individually and is not Personal Data.
We use third parties to provide the chat function on our website and to help us take surveys. These third parties record and help us respond to the communications you enter into the chat windows and record the information you enter into a survey.
We also use a third party e-mail provider to send emails to our email distribution and subscription lists. This e-mail provider may use cookies and tracking technology in our e-mails to understand how you interact with our e-mails.
In addition, we use third parties to enhance the functionality of our Sites, and these third parties set cookies. As examples, we may use Stripe, PayPal, or other payment processors to allow people to make purchases or donations using their services, or we may use the services of video or social media companies (such as Vimeo or YouTube or similar companies) to help display video or social media content on our Sites, and we use the services of online audio and video conferencing and communications providers (such as Zoom). As further explained in the Online Tracking section of this Privacy Notice, these third parties may also use cookies to track your activities on our Sites and on other sites, and you may use our Cookies Settings to modify your choices regarding cookies.

6. How Long We Keep Your Personal Data

We will keep some records permanently, including our organization records of affiliate membership status, or if we are legally required to do so. We may keep some other records for an extended period of time, including safeguarding records. In general, we will endeavor to keep data only for as long as we need it. This means that we may delete it when it is no longer needed.

7. Managing Your E-mail Preferences and Affiliate Member Portal Information

You can review, correct, update, delete, or change your Personal Information through your Affiliate Member Portal account or by e-mailing us at GDPR@goldenlotusliving.org. You can also opt out of receiving certain e-mails and other communications from us through your Affiliate Member Portal account, or by using the “unsubscribe” link in the e-mails, or e-mailing us at GDPR@goldenlotusliving.org. You are able to opt out of receiving our eNewsletter and most e-mails from us; however, you cannot opt out of receiving all e-mails from us, such as e-mails about the status of your account or orders.

8. Your Rights Regarding Your Personal Data under the GDPR

You have the following rights with respect to your personal data. When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases, we will need you to respond with proof of your identity before you can exercise these rights.

Right of access: the right to receive a copy of the personal information we hold about you and certain information concerning how such personal information is used;
Right to data rectification: the right to correct inaccurate personal information;
Right to deletion: in certain circumstances, the right to delete/erase your personal information (also known as the “right to be forgotten”);
Right to data portability: in certain circumstances, the right to receive the personal information provided by you in a structured, commonly used and machine-readable format and to transmit the personal information to another data controller;
Right to object: the right to object to the use of your personal information where such use is based on our legitimate interests or on public interests, and the right to object to any processing for direct marketing purposes;
Right to restriction of processing: in certain circumstances, the right to restrict our use of your personal information;
Right not to be subject to automated individual decision-making: the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you; and
Right to withdraw consent: you have the right to withdraw your consent at any time where our processing is based on consent.

If you would like to exercise your rights, please contact us using the information provided at the end of this Privacy Notice. We hope that we can resolve any question or concern you raise about our use of your information. However, should you not receive a satisfactory answer to your request, you have the right to lodge a complaint with a supervisory authority (see a complete list here: https://edpb.europa.eu/about-edpb/board/members_en).

9. Transfer of Data Abroad

GLLI is located in the United States. When you provide personal data to us, you transmit that information to the United States. Processing your data in the United States is also necessary for us to provide you with services that you request from us. The laws of the United States may not be as protective of your privacy as the laws of your home country.

10. Be Careful When You Share Information with Others

Please be aware that whenever you choose share information on any public area of the Sites or Services (such as by using the “Share your story” feature or posting information to a public testimonial or public discussion forum), that information may be accessed by others and the public. That information may be further passed along or further made public by others. This means that anyone with access to such information can potentially use it for any purpose including sending unsolicited communications.

11. Updates to this Privacy Notice or Changes in Processing

If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new Privacy Notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

In other circumstances, if we decide to change this Privacy Notice, we will inform you by posting the revised Privacy Notice on the Sites. Those changes will go into effect on the “Revised” date shown in the revised Privacy Notice. By continuing to use the Sites or Services after that date, you are consenting to the revised Privacy Notice.

12. Online Tracking

We use third parties to enhance the functionality of our Sites and Services (such as Stripe, PayPal, Vimeo and YouTube), and to send our e-mails. The third parties we use may set cookies and use other tracking technology collect certain information when you visit the Sites and use the Services, or interact with our e-mails. These third parties may collect your IP Address, mobile device identifiers and advertising identifiers or other identifiers they may assign to you, information from cookies they set during your visits to the Sites and other websites, and other information including clicks and mouse movements, information you enter into forms, information you enter into our chat window, content and videos you view, your domain name, your browser type and operating system, specific web pages you view, links you click, searches you perform, the length of time you visit our Sites and/or use our Services, the referring URL, the webpage that led you to our Sites, and geolocation information. These third parties may track your activity over time and across different websites, and may use the information they collect to provide advertisements about goods and services likely to be of interest to you. Our systems do not recognize browser “Do Not Track” signals, but several of the third parties who utilize these cookies on our Sites enable you to opt out of targeted advertising practices. To learn more about these advertising practices or to opt out of this type of advertising, you can visit optout.aboutads.info and optout.networkadvertising.org. Please also see our Cookies Settings for further information and to modify your choices regarding cookies on this Site.

13. Be Careful When You Share Information with Others

Please be aware that whenever you share information on any public area of the Sites or Services, that information may be accessed by others. In addition, please remember that when you share information in any other communications with third parties, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.

14. Security

We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. Although no data transmission over the Internet or other network can be guaranteed to be 100% secure, we strive to protect your personal data on or through the Sites or Services so that it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. However, we cannot and do not guarantee the security of any information you transmit on or through the Sites or Services, and accept no liability for any unintentional disclosure or misuse.

15. Links

Our Sites and Services may contain links to other websites or allow others to send you such links. A link to a third party’s website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites. You access such third-party websites or content at your own risk. You should always read the privacy policy of a third-party website before providing any information to the website.

16. Children’s Privacy and Our Sites and Services

The Sites and Services are intended for users who are 16 years old or older. We do not knowingly or intentionally collect Personal Information from children under the age of 16 in connection with the Sites or Services. If we become aware that we have inadvertently received Personal Information from a child under the age of 16 in connection with the Sites or Services, we will delete such information from our records.

17. Changes to this Privacy Notice

We keep this Privacy Notice under regular review and we will place any updates on our website goldenlotusliving.org under “EU/Brazil Privacy Notice.” This Privacy Notice was last updated February 25, 2024.

18. Our Contact Details

Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints at:

Mail: Attention: Legal Department, Golden Lotus Living, Inc., PO Box 252, Elfrida, AZ USA

Email: GDPR@goldenlotusliving.org.