1. SCOPE
1.1. This Privacy Policy applies to the processing of your personal data as part of your visit to one of the following websites: scientology.org, scientology.net, oxfordcapacityanalysis.org, volunteerministers.org, youthforhumanrights.org, cchrint.org, cchr.org, drugfreeworld.org and any website on which this Privacy Policy is published (“Websites”), your communication with us via email, telephone, fax and our social media channels (such as Facebook, Twitter and Instagram), your purchase of religious materials, your request for more information, your registration for or participation in an event, or your donation. This Privacy Policy also applies to any other context where you provide us with personal data. If, when collecting or processing your personal data, reference is made to another Privacy Policy, that Privacy Policy takes precedence over this one in the event of any conflict.
1.2. If you want more information on how we process personal data via cookies, social plugins and other types of tracking technology, you are kindly referred to our Cookie Policy.
1.3. If you want more information on the three mailings procedure, we kindly advise you to pay extra attention to Articles 5.6., 6.1.7. and 9.3. of this Privacy Policy. This three mailings procedure applies to the processing of your personal data when you fill out any form, whether online or on paper, that is followed by three post mailings as described in this Privacy Policy (“Three Mailings Form”).
1.4. Where reference is made in this Privacy Policy to laws or regulations, possible amendments to these laws or regulations are implicitly included.
1.5. We reserve the right to change and adapt this Privacy Policy on our own initiative. In that case, those changes and adaptations will be communicated to you via our Websites at least two weeks before those changes and adaptations will become applicable. Any further use of our Websites will be subject to the amended Privacy Policy.
2. WHO ARE WE?
2.1. We, the Church of Scientology International (“CSI,” “we,” “us,” “our”), 6331 Hollywood Boulevard, Los Angeles, CA 90028, United States of America, are committed to protecting the privacy and security of your personal data at all times. CSI is in charge of the ecclesiastical management of Scientology Churches and Missions. If you are located in the European Economic Area, please contact us via email at dpo@scientology.net. If you are not located within the European Economic Area, contact us via email at address@scientology.net.
2.2. The Church of Scientology Europe (“CSEU” or “Continental Liaison Office”), Fabriksparken 15, 2600 Glostrup, Denmark, is our main European establishment managing the Scientology Churches and Missions in Europe.
3. WHO IS THE CHURCH OF SCIENTOLOGY?
3.1. The Church of Scientology (“the Church”) is formed into an ecclesiastical structure which unifies and aligns a multitude of diverse religious activities. Spanning all entities belonging to the ecclesiastical structure is a system of international ecclesiastical management from Church of Scientology International through a series of Continental Liaison Offices responsible for geographic zones. This management structure supports, coordinates and works to ensure that the spiritual philosophy and technologies of Dianetics and Scientology are available to anyone who wishes to receive them and that Scientology services and practices are applied precisely as L. Ron Hubbard (“LRH”), the Founder of the Scientology religion, set forth.
3.2. Further, and to realize the greater humanitarian objectives of the Church of Scientology, the Church supports a series of Social Betterment Campaigns in the fields of morality (The Way to Happiness), drug rehabilitation and prevention (Narconon), criminal reform (Criminon) and literacy (Applied Scholastics), or Humanitarian Programs in the domains of drug prevention education (Drug-Free World), mental health (Citizens Commission on Human Rights), universal human rights (United for Human Rights) and disaster response (Volunteer Ministers). Social Betterment Campaigns are coordinated by the Association for Better Living and Education (ABLE).
3.3. The IAS (International Association of Scientologists) is the official membership organization of Scientology. Its purpose is to unite, advance, support and protect the Scientology religion and Scientologists in all parts of the world. Thanks to the support of its members, the IAS provides grants to sponsor the Social Betterment and Humanitarian Programs supported by the Church.
3.4. The World Institute of Scientology Enterprises (WISE) is an international membership organization whose members use L. Ron Hubbard Management Technology and embrace the responsibilities and ethical standards of WISE membership.
4. WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?
4.1. CSI acts as the data controller for the processing of the personal data that you provide to entities belonging to the ecclesiastical structure of the Church, such as directly to CSI via one of our Websites or to local Churches and Missions.
4.2. The local Churches and Missions, including CSEU, act as data processors on our behalf.
4.3. Personal data provided by you in the context of Social Betterment Programs coordinated by ABLE, are controlled by ABLE. For further information, please read the applicable Privacy Policy at www.able.org/online-privacy-policy.html.
4.4. Personal data provided by you to the IAS are controlled by the International Association of Scientologists Administrations (IASA). For further information, please read the IASA Privacy Policy at www.iasmembership.org/about/privacy-notice.html.
4.5. Personal data provided by you to WISE are controlled by the World Institute of Scientology Enterprises International (WISE International). For further information, please read the WISE Privacy Policy at www.wise.org/en_US/feature/legal/privacy.html.
5. WHICH OF YOUR PERSONAL DATA DO WE PROCESS?
5.1. When you use one of our Websites or our social media channels, we may process the following categories of personal data:
• Technical information, such as information concerning your device, IP address, browser type, geographical location and operating system;
• Browsing behavior, such as the length of your visit, the links you click, the pages you visit and the frequency with which you visit a page.
5.2. When you communicate with us by filling out a contact form on one of our Websites, or via email, telephone, fax or social media channels, we may process the following categories of personal data:
• Identity information you provide us with, such as your first name, last name, gender, birth date, age, the company you work for, preferences and interests;
• Contact details you provide us with, such as your email address, postal address, country, telephone number and mobile telephone number;
• Content of the communication, such as your request or question;
• Technical information of the communication, such as with whom you communicate at our end, date and time of the communication;
• Publicly available information about you, such as information publicly available on your social media profile;
• Any other personal data you provide us with.
5.3. When you take a Personality test, such as the Oxford Capacity Analysis (OCA) test, we may process the following categories of personal data:
• Identity information you provide us with, such as your first name, last name, gender, birth date, age, preferences and interests;
• Contact details you provide us with, such as your email address, postal address, country, telephone number and mobile telephone number;
• Personality information that we can derive from the answers you give to the questions asked during the Personality test.
5.4. When you take an e-course, we may process the following categories of personal data:
• Identity information you provide us with, such as your first name, last name, gender, birth date, age, preferences and interests;
• Contact details you provide us with, such as your email address, postal address, country, telephone number and mobile telephone number;
• Any other personal data you provide us with, such as your answers to the questions.
5.5. When you order or purchase materials, such as a book or an information kit, we may process the following categories of personal data:
• Identity information you provide us with, such as your first name, last name, the company you work for, preferences and interests;
• Contact details you provide us with, such as your email address, postal address, country, telephone number and mobile telephone number;
• Order details, such as the title of the book you purchased;
• Payment details, such as the amount you paid for your purchase.
5.6. When you request more information, express your interest in Scientology, register for or participate in an event, make a donation or if you fill out any other form to which this Privacy Policy applies, we may process the following categories of personal data (to the extent freely provided by you):
• Identity information you provide us with, such as your first name and last name;
• Contact details you provide us with, such as your email address, postal address, country, telephone number and mobile telephone number;
• Information necessary to carry out the registration or donation, such as criteria needed to evaluate whether you fulfill the criteria for participation;
• Information about your life, such as in what area of life you are most interested or what you would like to improve or change the most in your life;
• Information about your relationship with the Church, such as how you found out about the Church, how you liked the Church service or program, or whom you would like to invite to a Church service;
• Payment details, such as the amount you paid for your registration (in case of a donation or paid registration);
• Your photo if you pose for our photographer or if you give us permission to do so in any other way;
• Any other personal data you provide us with (such as your feedback after the event).
5.7. Please note that the various options described above may apply simultaneously. For example, if you take a Personality test via one of our Websites, both Articles 5.1. and 5.3. apply. We receive most of your personal data directly from you, but it may happen that we receive information about you third party from partners such as Google. If you require more information about the personal data these parties process about you and make available to others, you are kindly requested to consult their respective Privacy Policies.
5.8. When you view a video program or subscribe to one of our video series, we may process the following categories of personal data in addition to the personal data from visitors to our websites:
• What video was viewed and for how long.
• The video titles of any videos you add to a “watch later” queue.
• Your name, address and other contact information.
6. WHY AND ON WHAT LEGAL BASIS DO WE USE YOUR PERSONAL DATA?
6.1. In the table below, we explain the purposes for which we process your personal data and on which legal basis we do so. We rely on the following legal bases:
• Your consent, in which you are informed of what this consent means before you freely give your consent;
• A contract with you, in order to perform that contract or in order to take steps prior to entering into a contract with you;
• A legal obligation that we have to comply with;
• Our legitimate interest, such as continuous improvements of our Websites, social media channels, materials and services to ensure that you have the best experience possible, to keep them safe from misuse and illegal activity, to disseminate and promote them and to make them available to you, including our Social Betterment and Humanitarian Programs.
Purpose: 1. We process your personal data to send you promotional information for our materials and services, such as communications, promotions, offerings and newsletters, via email or other person-to-person electronic communication channels if you explicitly consented to receiving such promotional information.
Legal Basis: Your consent
Purpose: 2. In the framework of sending you promotional information, such as communications, promotions, offerings and newsletters, via email or other person-to-person electronic communication channels, we process your personal data to collect information to analyze our promotional information, such as which of our content in the promotional information you have accessed or on which links in the promotional information you have clicked (e.g., via tracking technologies such as web beacons in our emails).
Legal Basis: Your consent
Purpose: 3. We process your personal data to create a unique profile of you to enhance your experience based on your location, your order history, your preferences, your interests, the content in our promotional information you have accessed and, if you took a Personality test, the personality information that we can derive from the answers you give to the questions asked during the Personality test.
Legal Basis: Your consent
Purpose: 4. We process your personal data in order to be able to process your order and to be able to deliver to you the materials or information you request or to provide you with the services you request.
Legal Basis: A contract with you
Purpose: 5. We process your personal data to provide you, in a personalized and efficient way, with the materials, services or information you request via one of our Websites, email, telephone, fax or social media channels.
Legal Basis:Our legitimate interest,A contract with you
Purpose: 6. We process your personal data:
To comply with legal obligations that we have to comply with; or
To comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities; or
To transfer your personal data to the police or the judicial authorities upon our own initiative as evidence or if we have justified suspicions of an unlawful act or crime committed by you through your use of one of our Websites, our social media channels or other communication channels.
Legal Basis: A legal obligation
Purpose: 7. If you completed a Three Mailings Form, we process your personal data to send you three post mailings with information about our Church services and programs according to your areas of interest. However, you will not receive these post mailings if you have already received them in the last year, unless you have received these post mailings in the last year because you have completed another Three Mailings Form in another local Church. You may object to further receiving these mailings at any time by contacting dpo@scientology.net.
Legal Basis: Our legitimate interest
Purpose: 8. We process your personal data to send you promotional information for materials or services similar to those you previously purchased or received from us, such as communications, promotions, offerings and newsletters, via email or other person-to-person electronic communication channels. You may opt out from receiving such mailings by clicking the opt-out link in the email, or you can object to further receiving these mailings at any time by contacting dpo@scientology.net.
Legal Basis: Our legitimate interest
Purpose: 9. We process your personal data for other marketing purposes, such as on paper or via social media channels, i.e., to provide you with targeted promotional information, such as communications, promotions, offerings and newsletters of CSI and carefully selected partners. Also, we may publish your photo on one of our Websites or social media channels. If you do not agree, please do not pose for our photographer. If you would like to have a photo that has already been published removed, please contact our Data Protection Officer by sending an email to dpo@scientology.net.
Legal Basis: Our legitimate interest
Purpose: 10. We process your personal data to perform statistical analyses in order to be able to improve our Websites, promotional information, materials and services or to develop new materials and services.
Legal Basis: Our legitimate interest
Purpose: 11. We process your personal data to preserve our legitimate interests or to preserve the legitimate interests of a third party in case your use of one of our Websites, our social media channels or other communication channels can be considered:
• A violation of any applicable terms of use of one of our Websites or the intellectual property rights or any other of our or a third party’s rights; or
• A danger or threat to the security or integrity of one of our Websites, our social media channels or other communication channels or any of our, our select partners’ or a third party’s IT systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code; or
•In any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.
Legal Basis: Our legitimate interest
Purpose: 12. We process your IP address to determine from which country you are connecting to our Websites, in order to display the Cookie Privacy Notice which is legally requested in that jurisdiction.
Legal Basis: Our legitimate interest
7. DO WE SHARE YOUR PERSONAL DATA?
7.1. We will never disclose your personal data to third parties outside the Church of Scientology without your consent or another lawful basis, unless legally obliged to do so. For example, we may rely on service providers to:
• Provide you our Websites (such as a hosting provider); or
• Target our promotional information (such as a marketing company); or
• Process your order (such as a transport company to deliver you the materials); or
• Process your payment (such as a payment service provider or a credit checking agency).
• These third parties are only allowed to process your personal data on our behalf and upon our written instruction. We also warrant that all those third parties are selected with due care and are committed to observing the safety and integrity of your personal data.
7.2. Your personal data may be shared between national, regional or local affiliated organizations of the Church of Scientology, such as local Churches, Missions and Social Betterment and Humanitarian Programs (ABLE—if you require more information about the personal data that ABLE processes, you are kindly requested to consult its Privacy Policy: www.able.org/online-privacy-policy.html.) For example, we may share your contact details with a Church in your area if you have expressed an interest in joining a Scientology organization so that they can contact you. However, we will ensure that all Scientology organizations will take due care that all processing of your personal data is in line with what is set out in this Privacy Policy. Your personal data will also be processed by the CSEU, Fabriksparken 15, 2600 Glostrup, Denmark, our main European establishment managing the Scientology Churches and Missions in Europe. The CSEU is our central administration for the European continent.
7.3. If you become a member of the International Association of Scientologists (IAS) or the World Institute of Scientology Enterprises (WISE), these affiliated organizations might share your personal data with us. If you require more information about the personal data that affiliated organizations process about you as a member, you are kindly requested to consult their respective Privacy Policies.
• Privacy Policy IASA: www.iasmembership.org/about/privacy-notice.html
• Privacy Policy WISE: www.wise.org/wise-international-privacy-policy/
7.4. We may be legally obliged to share your personal data with competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.
7.5. We do not send your personal data in an identifiable manner to any other third party than the ones mentioned in Articles 7.1., 7.2., 7.3. and 7.4. without your explicit consent to do so. However, we may send anonymized data to other organizations that may use those data for improving materials and services as well as to tailor the marketing, displaying and selling of those materials and services.
8. WHERE DO WE PROCESS YOUR PERSONAL DATA?
8.1. We process your personal data both within and outside the European Economic Area (EEA), including in the USA. In order to process your personal data for the purposes outlined above, we may also transfer your personal data to third parties who process on our behalf outside the EEA. Each entity outside the EEA that processes your personal data will be bound to observe adequate safeguards with regard to the processing of your personal data. For CSI, such safeguards result from the fact that we are directly bound by compliance with EU legislation in the context of personal data protection. For third parties, such safeguards may be the consequence of:
• The recipient country having legislation in place which may be considered equivalent to the protection offered within the EEA; or
• A contractual arrangement between us and that entity; or
• An approved certification mechanism, as may be adopted by the European Commission.
8.2. We may transfer anonymized and/or aggregated data to organizations outside the EEA. Should such transfer take place, we will ensure that there are safeguards in place to ensure the safety and integrity of your data and all rights with respect to your personal data you might enjoy under applicable mandatory law.
9. WHAT QUALITY ASSURANCES DO WE COMPLY WITH?
9.1. We do our utmost best to process only those personal data which are necessary to achieve the purposes mentioned above.
9.2. Your personal data are only processed for as long as needed to achieve the purposes listed above or up until such time where you withdraw your consent for processing them. Your withdrawal of consent may imply that you can no longer use the whole or part of one of our Websites. We will de-identify your personal data when they are no longer necessary for the purposes outlined above, unless there is:
• An overriding interest of CSI, or any other third party, in keeping your personal data identifiable; or
• A legal or regulatory obligation or a judicial or administrative order that prevents us from de-identifying them.
9.3. If you fill out a Three Mailings Form, your personal data provided on the Three Mailings Form will only be retained until one year after the third mailing was sent unless you notify us that you object to such processing, except as otherwise permitted or required by a legal or regulatory obligation or a judicial or administrative order. If during this retention period you fill out another Three Mailings Form, your personal data provided on the Three Mailings Form you filled out second will only be retained as long as your personal data provided on the Three Mailings Form you filled out first is retained. If during this retention period, you enroll for a Church service or sign up to volunteer in a Social Betterment and Humanitarian Program, the personal data you provided in the context of your purchase will become part of your personal record for such Church service or program, and we may use it for the purpose of your participation therein consistent with our related Privacy Policies.
9.4. You understand that an essential aspect of our marketing efforts pertains to making our marketing materials more relevant to you. We do this by customizing your unique profile based on relevant characteristics as outlined in Article 6 of this Privacy Policy and then use this profile to provide you with communications, promotions, offerings, newsletters and other promotional information about materials and services that may interest you.
9.5. We will take appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss by tampering or destruction. Access by our staff members or third parties’ personnel will only be on a need-to-know basis and be subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations which can never be guaranteed.
9.6. If you are registered to receive promotional information, such as communications, promotions, offerings and newsletters, via email or other person-to-person electronic communication channels, you can change your preferences for receiving such promotional information by clicking the opt-out link provided in such promotional information.
9.7. If you are registered to receive paper promotional information, such as magazines, communications, promotions, offerings and newsletters, you can object to receiving further promotional information on paper by submitting a request to our Data Protection Officer in accordance with Article 11 of this Privacy Policy.
10. WHAT ARE YOUR RIGHTS?
10.1. You may at any time request information about your personal data, rectification, erasure or restriction of your personal data and you may object to further processing thereof by contacting the Data Protection Officer via dpo@scientology.net or the contact details below.
10.2. More specifically, you have the right to request access to all personal data processed by us pertaining to you, meaning that you have the right to ask us for a copy of your personal data. We reserve the right to charge a reasonable administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to us. Each request must specify which data categories you wish access to and for what processing activities.
10.3. You have the right to rectification, i.e., to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If you submit a request for correction, your request needs to be accompanied of proof of the flawed nature of the data for which correction is asked.
10.4. You have the right to withdraw your earlier given consent for processing of your personal data.
10.5. You have the right to erasure, i.e., to request that personal data pertaining to you be deleted if these data are no longer required in the light of the purposes outlined above or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by us against:
• Our and a third parties’ interests, which may override your interests; or
• Legal or regulatory obligations or administrative or judicial orders, which may contradict such deletion.
10.6. You have the right to restriction instead of deletion, i.e., to request that we limit the processing of your personal data if:
• We are verifying the accuracy of your personal data; or
• The processing is unlawful and you oppose the deletion of your personal data; or
• You require your personal data to establish, exercise or defend a legal claim, while we do no longer need your personal data for the purposes listed above; or
• We are verifying whether our legitimate interests override your interests if you exercise your right to object (see below).
10.7. You have the right to object to the processing of personal data for direct marketing purposes and, in addition, if:
• There are justified reasons connected with your particular situation that warrant such objection; and
• The processing is based on our legitimate interest and our legitimate interests do not override your interests.
10.8. You have the right to data portability, i.e., to receive from us in a structured, commonly used and machine-readable format all personal data you have provided to us if the processing is based on your consent or a contract with you and the processing is carried out by automated means.
10.9. If you wish to submit a request to exercise one or more of the rights listed above, you can contact our Data Protection Officer by sending an email to dpo@scientology.net. An email requesting to exercise a right will not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such a request should meet the following conditions:
• State clearly which right you wish to exercise; and
• State clearly the reasons for exercising your right if such is required; and
• Your request should be dated and signed; and
• Your request should be accompanied by a digitally scanned copy of your valid identity card proving your identity. If you use the contact form, we may ask you for your signed confirmation and proof of identity.
We will promptly inform you of having received your request. If the request meets the conditions above and proves valid, we will honor it as soon as reasonably possible and at the latest thirty (30) days after having received your request. If you have any complaints regarding the processing of your personal data by us, you may always contact our Data Protection Officer by sending an email to dpo@scientology.net. If you remain unsatisfied with our response, you are free to file a complaint with competent data protection authorities (see the list of national authorities at edpb.europa.eu/about-edpb/board/members_en).
11. DATA PROTECTION OFFICER
11.1. If you have any questions about this Privacy Policy, please contact our Data Protection Officer at Scientology Continental Liaison Office for Europe (DPO), Fabriksparken 15, 2600 Glostrup, Denmark, or send an email to dpo@scientology.net. If you are not located within the European Economic Area, contact us via email at address@scientology.net.
