Privacy Policy

Guha Soulworks LLC (“Company” or “we”) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide to us, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

The Company provides educational products and services in the fields of health coaching, well-being, lifestyle, recipes and spirituality through our Site, as defined below, and other online products and services (collectively, the “Services”).

This policy applies to information we collect:
On all websites owned and operated by the Company, which include ashapaul.com, russillpaul.us, russilpaul.com, rusillpaul.net, and schoolofmantra.com (collectively, the “Site”);
In email, text, and other electronic messages between you and the Site or Company; and Offline or through any other means.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Site or our Services. By accessing or using the Site, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

CHILDREN AND UNDER 18: Our Site and Services are not intended for children or anyone under 18 years of age. No one under age 18 may provide any information to or on the Site. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Site or on or through any of its features, make any purchases through the Site, use any of the interactive or public comment features of this Site or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT: We collect several types of information from and about users of our Site and Services, including information by which you may be personally identified, such as your name, mailing addresses and e-mail address ("personal information"). We collect this information: (i) directly from you when you provide it to us or from third parties, for example, our business partners; (ii) automatically as you navigate through the site, such information to include usage details, IP addresses and information collected through cookies and other tracking technologies; and (iii) from third parties, for example, our business partners. The table at Annex I sets out the categories of personal information you provide to us and that we receive from other sources and how we use that information. The table also lists the legal basis which we rely on to process the personal information and information as to how we determine applicable retention periods.

The information we collect through the Site includes:
Information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, subscribing to our Services, posting material or requesting further services.
Information that you provide by filling in forms via our applications on third-party websites.
Records and copies of your correspondence (including e-mail addresses), if you contact us.
Details of transactions you carry out through our Site and of the fulfillment of your orders.
As you navigate through and interact with our Site, we may also use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
Details of your visits to our Site, including traffic data, location data, logs and other communication data and the resources that you access and use on the Site.
Information about your computer and Internet connection, including your IP address, operating system and browser type.
The information we collect automatically is statistical data and may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:
Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Site according to your individual interests.
Speed up your searches.
Recognize you when you return to our Site.
The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.
Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Web Beacons. Pages of our Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.


THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES: Some content or applications on the Site are served by third parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

HOW WE USE YOUR INFORMATION: We use information that we collect about you or that you provide to us, including any personal information: To present and conduct our Services; to provide you with information, products or services that you request from us or that we feel may be of interest to you; to fulfill any other purpose for which you provide it; to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; to notify you about changes to our Services or any products or services we offer or provide though it; in any other way we may describe when you provide the information; and for any other purpose with your consent.

DISCLOSURE OF YOUR INFORMATION: We may disclose personal information that we collect or you provide as described in this privacy policy: To our subsidiaries and affiliates; To contractors, service providers and other third parties we use to support our business and to provide our Services to you; to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about our Site users is among the assets transferred; to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide the information; or with your consent. We may also disclose your personal information: to comply with any court order, law or legal process, including responding to any government or regulatory request; to enforce or apply our terms of use found at [LINK} and other agreements, including for billing and collection purposes; if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others.

CONSENTED OPT IN: When you opt into one of our free products or Services, or submit a form on one of our sites, you are automatically added to our email list that you can opt out of at any time by clicking the unsubscribe button. We make an effort to provide high value content and services that enriches and improves lives. And we offer a generous amount of free content to those on our email list such as free webinars, downloads, and informative videos and blogs. In addition to free content, we also include special offers to our products and services.

EMAILS: We take care not to send too many emails to those on our newsletter list. We usually send out about one email a week. On occasion, we may send out two, especially when special sales are in effect with drastic price reductions. We do not spam, but send out emails only to those who consent to opt into our system out of their own choice because they are interested in the highly specialistic content we offer.
If you do not wish to receive our newsletter emails, please do not opt in to any of our free offerings or Services.

UNSUBSCRIBING: Unsubscribing from our emails will result in the loss of any and all products and services regardless of whether you have paid for them or not. You can always contact us and reinstate your email consent by going through a formal procedure of reinstatement. However, we are not responsible for any loss of time, energy, or cost as a result of you unsubscribing. Please be sure to review our Student Agreement and Website Terms of Use for further details on this matter.

RIGHT TO CONTROL OF INFORMATION: You can at any time request to know what information exactly we have on file for you. And you have the right to ask us to delete that information. Once you make this request, you will lose all rights and privileges to any and all content we offer, including that for which you have paid. Please read this page carefully to understand exactly what information we would have of you on our company computer. This is the information you can ask to know and to delete.

TECHNICAL AND BUSINESS COMMUNICATION: We will use our company email ([email protected]) to contact you only when there is some technical issue to be resolved regarding your access to our programs, products and services, or if you are repeatedly missing our communications to you, or when there is payment due. We will also use this email to communicate with you when you wish to contact us about your right to information or the deleting of that information.

WEBSITES: Any personal information you submit to us through our Site is received and processed through the specific integrated web platforms that we contract with. In other words, our Company does not process or store or manage this information on our own servers except for what is stated expressly on this page.

DATA PLATFORMS: SchoolofMantra.com and ashapaul.com are the Weebly platform; russillpaul.com is on Rainmaker platform; russillpaul.us is on the Kajabi platform; and russillpaul.net is on the Builderspot platform. These companies are responsible for the data you submit to them on our websites as they receive, collect it and store it on their servers. All of them are large, well-established, reputable companies that, to the best of our knowledge, comply with all laws, including GDPR compliance. You may review their compliance below.

DATA RETENTION: We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.

LINKS TO OTHER WEBSITES: We are not responsible for the practices employed by websites linked to or from the Site or Service, nor the information or content contained therein. Please remember that when you use a link to go from the Site or Services to another website, our privacy policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our website, is subject to that website’s own rules and policies for which we do not accept any responsibility or liability.

PAYMENT PROCESSING: To process payments through our websites: ashapaul.com, russillpaul.us, and schoolofmantra.com we utilize Stripe and Paypal; and to process payments through schoolofmantra.com, we utilize Paypal. When you purchase our products, it is one of these two companies that processes your personal information (see detail below) that includes your name, email address, credit card information and billing address and phone number. They pass on all of this information to us with the exception of your credit card information. You can learn more about our payment processing partner’s privacy policy here: https://stripe.com/us/privacy.

OTHER SERVICES: We also use data collection services, such as Leadpages, GoToWebinar and Vcita, which we use to collect nothing more than your name and email which is passed on to our email server Mailerlite. All of these listed companies are well-established, reputable firms that are to the best of our knowledge GDPR compliant and they have communicated to us via email that they are. You can view their compliance documentation via the links below.
Lead Pages: https://www.leadpages.net/privacy

GoToWebinar (LogMeIn): https://www.logmeininc.com/legal/privacy

Vcita: https://www.vcita.com/about/privacy_policy
https://www.mailerlite.com/legal/privacy-policy

SECURITY BREACH: We and our third-party service providers have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. However, the safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. If, at any time, we become aware that any of these companies have had a security breach that might have compromised your data in any way, we will be notify you within 10 business days of our becoming aware of this information.

DATA TRANSFER: From time to time, we import data and transfer it to Constant Contact, our email service provider from which we send out our emails and where we consolidate our email lists. We also use Kajabi email and Rainmaker email. This data is stored on our office business computers. This data is usually limited to your name and email address. If you have purchased products from us, this data will include your phone number and billing address as well. Once a year, we send out a regular snail mail envelope of our annual newsletter only to those based in the US and Canada along with our new programs and events. You may opt out of this at any time by emailing us or writing to us.

DATA COMPROMISE: In the event of any data breach of our office computers, external storage drives, or the remote backup services we use, such as BackBlaze or OneBackUp, we will inform you within 10 business days of our becoming aware of this information.

OTHER DOMAINS: We also manage the following domains: yogicmysteryschool.net, russillpaul.info, and yogicmysteryschool.com, When you enroll for our programs, trainings, courses, memberships or coaching products, some of our programs may be loaded up on these websites. However, these sites do not collect any personal information. If you find that they do, we ask that you do not submit data through them, but contact us immediately, as we do not use these sites to collect any personal information from any of our students.
International Data Transfer: The personal information we collect may be transferred to and stored in countries outside the jurisdiction you are in where we and our third-party service providers have operations. If you are located in the European Union (EU), your personal information will be processed outside of the EU including in the United States; these international transfers of your personal information are made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission.

RESIDENTS OF THE EUROPEAN ECONOMIC AREA (EEA): If you are a resident of the EEA, you have certain rights and protections under the law regarding the processing of your personal information. When we process your personal data, we will only do so in the situations outlined in Annex I. Further, in accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
Right of access and portability. The right to obtain access to your personal information along with certain information, and to receive that personal information in a commonly used format and to have it ported to another data controller.
Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.
Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.
Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
Right to object. The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.

www.russillpaul.com / russillpaul.us / schoolofmantra.com / ashapaul.com

Guha Soulworks LLC

Annex I

 Last Updated: March 17, 2020