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Конфиденциальность


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This data protection declaration explains to you the type, range and purpose of the processing of personal data (hereinafter referred to as «data») within our website and the associated websites, functions and contents as well as external online presences, e.g. our social media profile. (hereinafter jointly referred to as «online offer»). With regard to the terms used, such as «processing» or «person responsible», we refer to the definitions in Art. 4 of the GENERAL DATA PROTECTION REGULATION (GDPR).

Responsible

Instituto Feldenkrais España, S.L.U.
Patricio Simon
Calle Cid 6, int. 2° dcha.
28001 Madrid
Spain
patricio@institutofeldenkrais.com
+34 633 677 875

Types of data processed:

  • Inventory data (e.g. names, addresses)
  • Contact details (e.g. e-mail, telephone numbers)
  • Content data (e.g. text input, photographs, videos)
  • Usage data (e.g. visited websites, interest in content, access times)
  • Meta/communication data (e.g. device information, IP addresses)

Purpose of processing

  • Providing of online offer, its functions and contents
  • Response to contact requests and communication with users
  • Security measures
  • Range measurement/ marketing

Terms used

«Personal data» means any information relating to an identified or identifiable natural person (hereinafter referred to as «data subject»). An identifiable natural person is one who can be identified, directly or indirectly, in particular by assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more special features that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

«Processing» means any operation carried out with or without the aid of automated procedures or any such series of operations in connection with personal data. The term covers a wide range and covers practically every handling of data.

«Person responsible» means the natural or legal person, authority, institution or other body that alone or together with others decides on the purposes and means of processing personal data.

Applicable legal bases

In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consents is Art. 6 pa. 1 a) and Art. 7 GDPR. The legal basis for processing for the performance of our services and performance of contractual measures as well as for answering inquiries is Art. 6, par. 1 b) GDPR. The legal basis for processing to fulfil our legal obligations is Art. 6, par. 1 c) GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6, par. 1 f) GDPR. In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6, par. 1 d) GDPR serves as the legal basis.

Safety precautions

We ask you to inform yourself regularly about the contents of our data protection declaration. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

Cooperation with data processors and third parties

If we disclose data to other persons and companies (data processors or third parties), transmit the data to them or otherwise grant them access to the data, this shall only take place on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as payment service providers, in accordance with Art. 6, par. 1 b) GDPR is necessary for contract fulfilment ), if you have consented, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties with the processing of data on the basis of a so-called «data processing agreement», this is done on the basis of Art. 28 GDPR.

Transfers to third party countries

If we process data in a third party country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this only takes place if it occurs for the fulfilment of our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third party country only if the special requirements of Art. 44 ff. GDPR are met. This means, for example, processing is carried out on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g. for the USA by the «Privacy Shield») or compliance with officially recognized special contractual obligations (so-called «standard contractual clauses»).

Your privacy rights

You have the right to request confirmation as to whether data concerning you are being processed, request information about these data as a copy of the data in accordance with Art. 15 GDPR.

In accordance with Article 16 of the GDPR, you have the right to request the completion of data concerning you or the correction of inaccurate data concerning you.

In accordance with Art. 17 GDPR, you have the right to demand that relevant data be deleted immediately or, alternatively, to demand a restriction on the processing of the data in accordance with Art. 18 GDPR.

You have the right to request that the data concerning you and that you have provided to us with is kept in in accordance with Art. 20 GDPR and you have the right to request its transmission to other responsible parties.

In accordance with Art. 77 GDPR you also have the right to file a complaint with the competent supervisory authority.

Right of revocation

You have the right to revoke consents granted pursuant to Art. 7, par. 3 GDPR with effect for the future.

Right of objection

You can object to the future processing of the data concerning you in accordance with Art. 21 GDPR at any time. The objection may be made in particular against processing your data for direct marketing purposes.

Cookies and right of objection in direct advertising

Cookies» are small files that are stored on the user’s computer. Different data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his or her visit of an online offer. Temporary cookies, or «session cookies» or «transient cookies», are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie it is possible for example, to save the contents of a shopping basket in an online shop or information about a login traffic jam. Cookies are referred to as «permanent» or «persistent» when they remain stored even after the browser is closed. For example, the login status can be saved for when users visit a webpage again after several days. Likewise, the interests of users used for range measurement or marketing purposes may be stored in such a cookie. Third-party cookies» are cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only its cookies, they are referred to as «first-party cookies»).

We may use temporary and permanent cookies and clarify this within the framework of our data protection declaration.

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of a browser. The exclusion of cookies can lead to functional restrictions of this online offer.
A general objection to the use of cookies used for online marketing purposes can be declared for many of the services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.

Deletion of data

The data processed by us will be deleted or their processing restricted in accordance with Articles 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are necessary for other and legally permitted purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for legal or tax reasons. The legal rights and obligations of storage are 10 years for tax and social security offences (reform of the Criminal Code (Ley Orgánica 7/2012, de 27 de diciembre)).

Business-related data processing

Additionally we process from our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research:

  • Contract data (for example, contract object, term, customer category)
  • Payment data (e.g. bank details, payment history)

Hosting

The hosting services used by us are intended to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use for the purpose of operating this online offer.

We or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta- and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with Art. 6, par. 1 f) GDPR in conjunction with. Art. 28 GDPR (conclusion of order processing contract).

Collection of access data and log files

We, or our hosting provider, collect the following data on the basis of our legitimate interests within the meaning of Art. 6, par. 1 f) GDPR data on each access to the server on which this service is located (so-called server log files). Access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for a maximum of 14 days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data whose further storage is required for evidentiary purposes are excluded from deletion until the respective incident has been finally clarified.

Order processing in the online shop and customer account

We process the data of our customers in the context of the order processes in our online shop to enable them to select and order the selected products and services, as well as their payment and delivery, or execution.

The processed data includes inventory data, communication data, contract data, payment data and the persons affected by the processing include our customers, interested parties and other business partners. The processing takes place for the purpose of providing contractual services in the context of operating an online shop, billing, delivery and customer services. We use session cookies for storing the contents of the shopping cart and permanent cookies for storing the login status.

Processing is carried out on the basis of Art. 6, par. 1 b) (execution of order processes) and c) (legally required archiving) GDPR. The information marked as necessary is required to establish and fulfil the contract. We disclose the data to third parties only within the framework of delivery, payment or within the framework of legal permits and obligations to legal advisors and authorities. The data will only be processed in third countries if this is necessary for the fulfilment of the contract (e.g. at the customer’s request upon delivery or payment).

Users can optionally create a user account, in particular by viewing their orders. During the registration process, the required information will be communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to its storage is necessary for commercial or tax reasons according to Art. 6, par. 1 c) GDPR. Data in the customer account remain up to its deletion with subsequent archiving in the case of a legal obligation. It is up to the users to save their data before the end of the contract if they have given notice of termination.

When registering, re-registering and using our online services, we store the IP address and the time of the respective user action. The data is stored on the basis of our legitimate interests as well as the user’s protection against misuse and other unauthorized use. A passing on of this data to third parties does not take place in principle, unless it is necessary for the pursuit of our claims or there is a legal obligation according to Art. 6, par. 1 c) GDPR.

The deletion takes place after the statutory warranty and comparable obligations have expired. The legal rights and obligations of retention are 10 years for tax and social security offences (reform of the Criminal Code (Ley Orgánica 7/2012, de 27 de diciembre)) and a deletion takes place after their expiration.

Performance of contractual services

We process inventory data (e.g. names and addresses as well as contact data of users), contract data (e.g. services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services pursuant to Art. 6, par. 1 b) GDPR. The entries marked as obligatory in online forms are required for the conclusion of the contract.

When using our online services, we store the IP address and the time of the respective user action. The data is stored on the basis of our legitimate interests as well as the user’s protection against misuse and other unauthorized use. A passing on of this data to third parties does not take place in principle, unless it is necessary for the pursuit of our claims or there is a legal obligation according to Art. 6, par 1 c) GDPR.

We process usage data (e.g. the visited websites of our online offer, interest in our products) and content data (e.g. entries in the contact form or user profile) for advertising purposes in a user profile in order to show the user e.g. product information based on their previously used services.

The data will be deleted upon expiry of statutory warranty and comparable obligations, and the necessity of storing the data will be reviewed every three years. In the case of statutory archiving obligations, deletion shall take place after their expiry. Information in the possible customer account remain up to its deletion.

Administration, financial accounting, office organization, contact management

We process data within the framework of administrative tasks as well as the organization of our company, financial accounting and compliance with legal obligations, e.g. archiving. We process the same data that we process as part of the performance of our contractual services. The processing bases are Art. 6, par. 1 c) GDPR, Art. 6, par. 1 f) GDPR. Customers, prospects, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, thus tasks which serve the maintenance of our business activities, perception of our tasks and provision of our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the information provided in these processing activities.

We disclose or transmit data to the tax authorities, consultants, such as tax consultants or auditors, as well as other fee offices and payment service providers.

Furthermore, we store information on suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of making contact at a later date. We store this data, which is mainly company-related, permanently.

Registration function

Users can optionally create a user account. During the registration process, users will be informed of the required information. The data entered during registration will be used for the purpose of using our service. Users can be informed by e-mail about information relevant to the service or their registration, such as changes to the scope of the service or technical circumstances. If users have terminated their user account, their data will be deleted with regard to the user account, subject to its storage is necessary for commercial or tax reasons according to Art. 6, par. 1 c) GDPR. It is up to the users to save their data before the end of the contract if they have given notice of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.

As part of the use of our registration and login functions as well as the use of user accounts, we store the IP address and the time of the respective user action. The data is stored on the basis of our legitimate interests as well as the user’s protection against misuse and other unauthorized use. A transfer of this data to third parties does not take place, unless it is necessary to pursue our claims or there is a legal obligation according to Art. 6, par. 1 c) GDPR. The IP addresses are anonymized or deleted after 7 days at the latest.

Contact

When contacting us (e.g. via contact form, e-mail, telephone or social media), the user’s details are processed for processing the contact enquiry and its processing in accordance with Art. 6, par. 1 b) GDPR. User information can be stored in a customer relationship management system («CRM system») or comparable request organization.

We delete the requests if they are no longer necessary. We review this requirement every two years; the statutory archiving obligations also apply.

Newsletter

With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter you agree to the reception and the described procedures.

Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter «newsletters») only with the consent of the recipients or a legal permission. If the contents of a newsletter are specifically described within the scope of a registration, they are decisive for the consent of the users. In addition, our newsletters contain information about our services and us.

Double opt-in and protocoling: The registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can log in with other e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes the storage of the login and confirmation time, as well as the IP address. The changes to your data stored with the email service provider are also protocolled.

Login credentials: To subscribe to the newsletter, simply enter your e-mail address. Optionally, we ask you to enter a name in the newsletter in order to address you personally.

The dispatch of the newsletter and the performance measurement associated with it is based on the recipient’s consent pursuant to Art. 6, par. 1 a), Art. 7 GDPR.

The registration procedure is recorded on the basis of our legitimate interests pursuant to Art. 6, par. 1 f) GDPR. We are interested in the use of a user-friendly and secure newsletter system that serves both our business interests and the expectations of users and also allows us to provide proof of consent.

Cancellation/Revocation — You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. Before we delete them we may store the e-mail addresses we have un-subscriptions for up to three years on the basis of our legitimate interests in order to be able to prove a previously given consent. The processing of these data is limited to the purpose of a possible defense against claims. An individual application for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.

Newsletter — Email service provider

The newsletter is sent by the email service provider «MailChimp», a newsletter delivery platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. The data protection regulations of the email service provider can be viewed here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with the European data protection level (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). The dispatch service provider is used on the basis of our legitimate interests according to Art. 6, par. 1 f) GDPR and an order processing contract according to Art. 28, par. 3 GDPR.

The email service provider can use the recipient’s data in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. to technically optimize the dispatch and presentation of the newsletter or for statistical purposes. However, the email service provider does not use the data of our newsletter recipients to write them down itself or to pass the data on to third parties.

Transaction e-mails — Email service provider

E-mails relating to orders and registration confirmations, i.e. all e-mails that cannot be assigned to the newsletter, so-called transaction e-mails, are sent by the email service provider SendGrid, Inc. 1801 California Street, Suite 500, Denver, CO 80202, USA. The data protection regulations of the email service provider can be viewed here: https://sendgrid.com/policies/privacy/. Sendgrid Inc. is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with the European data protection level (https://www.privacyshield.gov/participant?id=a2zt0000000TRktAAG). The email service provider is used on the basis of our legitimate interests according to Art. 6, par. 1 f) GDPR and an order processing contract according to Art. 28, par. 3 GDPR.

The email service provider can use the recipient’s data in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. to technically optimize the dispatch and presentation of the newsletter or for statistical purposes. However, the email service provider does not use the data of our newsletter recipients to write them down itself or to pass the data on to third parties.

Newsletter — Performance Measurement

The newsletters contain a so-called «web-beacon», i.e. a pixel-sized file which is downloaded from our server when the newsletter is opened or, if we use a email service provider, from their server. Within the scope of this download, technical information, such as information about the browser and your system, as well as your IP address and time of download, are initially collected.

This information is used to technically improve the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our endeavor, nor, if used, that of the email service provider, to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.

Google Analytics

On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6, par. 1 f) GDPR) we use Google Analytics, a web analysis service of Google LLC («Google»). Google uses cookies. The information generated by the cookie about the use of the online offer by users is generally transferred to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our online offer by its visitors, to compile reports on the activities within this online offer and to provide us with other services relating to the use of this online offer and the internet. Pseudonymous user profiles can be created from the processed data.

We use Google Analytics only with IP anonymization enabled. This means that Google will reduce the IP address of users within Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

Further information on data use by Google, possible settings and objections can be found in Google’s data protection declaration (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
Users’ personal data will be deleted or made anonymous after 14 months.

Online presence in social media

We maintain online presences within social networks and platforms in order to communicate with active customers, interested parties and users and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.

Unless otherwise stated in our privacy policy, we process the data of users who communicate with us within social networks and platforms, e.g. write articles on our online presences or send us messages.

Integration of third-party services and content

Within our online offer, we make no representations or warranties of any kind based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6, par. 1 f) GDPR) content or service offerings of third parties to incorporate their content and services, such as videos or fonts (hereinafter uniformly referred to as «content»).

This always presupposes that the third party providers of this content perceive the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We make every effort to use only those contents whose respective providers use the IP address only for the delivery of the contents. Third-party providers may also use so-called pixel tags (invisible graphics, also known as «web beacons») for statistical or marketing purposes. Pixel tags» can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, as well as be linked to such information from other sources.

Vimeo

We can integrate the videos of the platform «Vimeo» of the provider Vimeo Inc, Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA. Privacy Policy: https://vimeo.com/privacy.

Please note that Vimeo may use Google Analytics and refer to the privacy policy (https://www.google.com/policies/privacy) and opt-out options for Google Analytics (http://tools.google.com/dlpage/gaoptout?hl=en) or Google’s settings for data use for marketing purposes (https://adssettings.google.com/).

YouTube

We integrate the videos of the platform «YouTube» of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated

Google Fonts

We integrate the fonts («Google Fonts») of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated

Google ReCaptcha

We integrate the function for the recognition of bots, e.g. for entries in online forms («ReCaptcha») of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated

Google Maps

We integrate the maps of the service «Google Maps» of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include in particular IP addresses and location data of the users, which, however, are not collected without their consent (as a rule within the framework of the settings of their mobile devices). The data can be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated

Amazon Affiliate Program

On basis of our legitimate interests (i.e. interest in the economical operation of our online offer in accordance with Art. 6, par. 1 f) GDPR) we participate in the Amazon EU partner program, which was designed to provide a medium for websites through which advertising and links to Amazon.es can earn reimbursement of advertising costs (so-called affiliate system). Amazon uses cookies to trace the origin of orders. Among other things, Amazon can recognize that you clicked on the partner link on this website and then purchased a product from Amazon.

For further information on Amazon’s use of data and possible objections, please refer to the company’s privacy policy: https://www.amazon.es/gp/help/customer/display.html/ref=hp_201908990_to_201909010?nodeId=201909010