Politique de Confidentialité
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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).
Instituto Feldenkrais España, S.L.U.
Calle Cid 6, int. 2° dcha.
+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
« 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 par 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, Art. 6, par. 1 d) GDPR serves as the legal basis.
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 Art. 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.
Deletion of data
The data processed by us will be deleted or their processing restricted in accordance with Art. 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)
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.
Microsoft Cloud Services
We use the cloud and cloud software services offered by Microsoft (« software as a service » for example Microsoft Office) for the following purposes: storing and managing documents, managing calendars, sending e-mail, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing websites, forms or other content and information, as well as chatting and participating in audio and video conferences.
The personal data of the users will be processed in this connection, as far as these become part of the documents and contents processed within the described services or are part of communication processes. This may include, for example, user master data and contact data, data on processes, contracts, other processes and their contents. Microsoft also processes usage data and metadata used by Microsoft for security purposes and service optimization.
In connection with the use of publicly accessible documents, websites or other content, Microsoft may store cookies on the User’s computer for the purpose of web analysis or to remember User settings.
We use the Microsoft cloud services on the basis of our legitimate interests in accordance with Art. 6 Para. 1f GDPR in efficient and secure administrative and cooperation processes. Furthermore, the processing takes place on the basis of an order processing contract with Microsoft.
Further information can be found in Microsoft’s data protection declaration (https://privacy.microsoft.com/en-US/privacystatement) and the security information on Microsoft cloud services (https://www.microsoft.com/en-us/trust-center). You may object to the processing of your data in the Microsoft Cloud in accordance with the legal requirements. In addition, the deletion of data within Microsoft’s cloud services is determined by the other processing procedures in which the data is processed (e.g. deletion of data no longer required for contractual purposes or storage for purposes of taxation of data required).
The Microsoft Cloud Services are offered by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA. If data is processed in the USA, we refer you to Microsoft’s certification under the Privacy Shield (https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active).
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.
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.
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 and mass communication
We send newsletters, e-mails and other electronic notifications (hereinafter « newsletters ») only with the consent of the recipients or a legal permission. If the contents of a newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Furthermore, our newsletters contain information about our services and about us.
In order to register for our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name (for the purpose of personal contact in the newsletter) or to provide further information if this is necessary for the purposes of the newsletter.
Double opt-in procedure: The registration to our newsletter is always done in a so-called « double-opt-in-process ». This means that after subscribing, you will receive an e-mail asking you to confirm your subscription. This confirmation is necessary so nobody can register with somebody else’s e-mail address. The registrations for the newsletter are recorded in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes of your data will also recorded by the mailing service provider.
Deletion and restriction of processing: Before we delete e-mail addresses, we may store them for up to three years on the basis of our legitimate interests in order to be able to prove that you have previously given your consent. The processing of this data is limited to the purpose of a possible defense against legal claims. An individual request for deletion is possible at any time, provided you confirm at the same time the former existence of a consent. In case of obligations to permanently honor objections to the reception of our newsletters, we reserve the right to store the e-mail address for this purpose alone in a blacklist.
The recording of the registration procedure is carried out on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Notes on legal bases: The dispatch of newsletters is based on the consent of the recipients or, if consent is not required, on our legitimate interests in direct marketing, if and to the extent permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to prove that it was carried out in accordance with the law.
- Contents: Information about us, our services, actions and offers.
- Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
- Affected persons: communication partners.
- Purposes of processing: direct marketing (e.g. by e-mail or post).
- Legal basis: Consent (Art. 6, par. 1 a) GDPR), legitimate interests (Art. 6, par. 1 f) GDPR).
- Opt-out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.
Used services and service providers:
Transaction e-mails service provider
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 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.
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.
Video conferences, online meetings, webinars and screen sharing
We use third-party platforms and applications (hereinafter referred to as « third-party providers ») for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings. The selection of third-party providers and their services is made in compliance with the legal requirements.
In this context, data of the communication participants will be processed and stored on the servers of the third-party providers, as far as they are part of communication processes with us. This data may include, in particular, registration and contact data, video and audio content as well as chat posts and shared screen content.
If users are referred to the third-party providers or their software or platforms in the course of their communication, business relations or other relations with us, the third-party providers may process usage data and metadata for security, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.
- Data types processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta- and communication data (e.g. device information, IP addresses).
- Persons concerned: Communication partners, users (e.g. website visitors, users of online services).
- Purposes of processing: Contractual services and performances, contact requests and communication, office and organisational procedures, direct marketing (e.g. by e-mail or post).
- Legal basis: Consent (Art. 6 par. 1 a) GDPR), fulfillment of contract and pre-contractual enquiries (Art. 6, par. 1 , 1b) GDPR), Legitimate interests (Art. 6 par. 1 f) GDPR).
Services used and service providers:
- Zoom: Messenger and conference software; service providers: Zoom Video Communications, Inc., USA; website: https://zoom.us/; data protection declaration: https://zoom.us/privacy, security information: https://zoom.us/docs/en-us/privacy-and-legal.html; Privacy Shield (ensuring data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TNkCAAW&status=Active .
- Skype: messenger and conference software; service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Website: https://www.skype.com/en/; Privacy Statement: https://privacy.microsoft.com/en-us/privacystatement, Security Notice: https://www.microsoft.com/en-us/trustcenter; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active .
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