
I. PRIVACY AND DATA PROTECTION POLICY
In accordance with the provisions of current legislation, Abby Delsol Yoga (hereinafter, also the Website) undertakes to adopt the necessary technical and organisational measures, appropriate to the level of risk of the data collected.
Laws incorporated into this privacy policy
This privacy policy has been adapted to current Spanish and European regulations on the protection of personal data on the internet. Specifically, it complies with the following regulations:
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights (LOPD-GDD).
Royal Decree 1720/2007, of 21 December, approving the Regulation implementing Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).
Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).
Identity of the data controller
The controller responsible for the processing of personal data collected on Abby Delsol Yoga is: Abigail Davina Brain, with NIF: Y7713845G (hereinafter, the Data Controller). Their contact details are as follows:
The controller responsible for the processing of personal data collected on Abby Delsol Yoga is: Abigail Davina Brain, holding NIF/CIF: Y7713845G and registered at: the Mercantile Registry of Málaga with the following registration details: Volume 5896, Book 4803, Folio 181, Section 8, Sheet MA-153447, whose representative is:
Abigail Davina Brain (hereinafter, the Data Controller). Their contact details are as follows:
Address: Calle Cruz 23, 29492 Jubrique, Málaga
Contact telephone: +34603639855
Contact email: [email protected]
Register of Personal Data
In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that personal data collected by Abby Delsol Yoga via the forms provided on its pages will be incorporated into and processed in our file for the purpose of facilitating, expediting and fulfilling the commitments established between Abby Delsol Yoga and the User, or maintaining the relationship established through the forms completed by the User, or dealing with a request or enquiry from them.
Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained, specifying, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.
Principles applicable to the processing of personal data
The processing of the User's personal data shall be subject to the following principles set out in Article 5 of the GDPR and Article 4 et seq. of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights:
Principle of lawfulness, fairness and transparency: the User's consent shall be required at all times, following completely transparent information on the purposes for which the personal data are collected.
Principle of purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes.
Principle of data minimisation: the personal data collected shall be limited to what is strictly necessary in relation to the purposes for which they are processed.
Principle of accuracy: personal data must be accurate and kept up to date at all times.
Principle of storage limitation: personal data shall only be kept in a form which permits identification of the User for as long as is necessary for the purposes of processing.
Principle of integrity and confidentiality: personal data shall be processed in a manner that ensures their security and confidentiality.
Principle of proactive responsibility: the Data Controller shall be responsible for ensuring that the above principles are complied with.
Categories of personal data
The categories of data processed by Abby Delsol Yoga are identification data only. Under no circumstances are special categories of personal data, within the meaning of Article 9 of the GDPR, processed. The categories of data processed by Abby Delsol Yoga include both identification data and special categories of personal data within the meaning of Article 9 of the GDPR.
Special categories of personal data are understood to mean data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data intended to uniquely identify a natural person, data concerning health, or data concerning a natural person's sex life or sexual orientation.
For the processing of special categories of personal data, the explicit consent of the User for one or more specific purposes shall be required in all cases.
Legal basis for the processing of personal data
The legal basis for processing personal data is consent. Abby Delsol Yoga undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.
The User shall have the right to withdraw their consent at any time. It shall be as easy to withdraw consent as it was to give it. As a general rule, withdrawal of consent shall not affect use of the Website.
On occasions where the User must or may provide their data through forms in order to make enquiries, request information, or for reasons related to the content of the Website, they will be informed if completion of any of these forms is mandatory because such data are essential for the proper performance of the operation concerned.
Purposes for which personal data are processed
Personal data are collected and managed by Abby Delsol Yoga for the purpose of facilitating, expediting and fulfilling the commitments established between the Website and the User, or maintaining the relationship established through the forms completed by the latter, or dealing with a request or enquiry.
Likewise, the data may be used for commercial purposes of personalisation, operations and statistics, and activities inherent to Abby Delsol Yoga's corporate purpose, as well as for the extraction and storage of data and marketing studies to tailor the Content offered to the User, and to improve the quality, functioning and navigation of the Website.
At the time personal data are obtained, the User will be informed of the specific purpose or purposes for which the personal data will be used; that is, the use or uses to be made of the information collected.
Personal data retention periods
Personal data shall only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 18 months, or until the User requests their deletion.
At the time personal data are obtained, the User will be informed of the period for which the personal data will be kept or, where this is not possible, the criteria used to determine that period.
Recipients of personal data
The User's personal data will not be shared with third parties.
In any event, at the time personal data are obtained, the User will be informed of the recipients or categories of recipients of the personal data.
The User's personal data will be shared with the following recipients or categories of recipients: HIGHLEVEL: HighLevel, Inc., with registered address at 400 N. Saint Paul St., Suite 920, Dallas, Texas 75201, USA.
Note on International Transfer: As a US company, the data transfer is carried out under the Data Privacy Framework (DPF) or through the signing of Standard Contractual Clauses approved by the European Commission, guaranteeing an adequate level of protection.
Should the Data Controller intend to transfer personal data to a third country or international organisation, the User will be informed, at the time the personal data are obtained, of the third country or international organisation to which the data are intended to be transferred, as well as of the existence or absence of an adequacy decision by the Commission.
Personal data of minors
In accordance with the provisions of Article 8 of the GDPR and Article 7 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights, only persons over the age of 14 may lawfully give their consent to the processing of their personal data by Abby Delsol Yoga. In the case of a minor under 14 years of age, the consent of parents or guardians shall be required for processing, and such processing shall only be considered lawful to the extent that they have authorised it.
Secrecy and security of personal data
Abby Delsol Yoga undertakes to adopt the necessary technical and organisational measures, appropriate to the level of risk of the data collected, so as to guarantee the security of personal data and prevent its accidental or unlawful destruction, loss or alteration, whether transmitted, stored or otherwise processed, or unauthorised disclosure of or access to such data.
The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data are transmitted securely and confidentially, as the transmission of data between the server and the User, and vice versa, is fully encrypted.
However, as Abby Delsol Yoga cannot guarantee the impregnability of the internet, nor the total absence of hackers or others fraudulently accessing personal data, the Data Controller undertakes to notify the User without undue delay when a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach is understood to mean any breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data, whether transmitted, stored or otherwise processed, or unauthorised disclosure of or access to such data.
Personal data will be treated as confidential by the Data Controller, who undertakes to inform their employees, associates, and any other person to whom they grant access to the information, of this obligation, and to ensure such confidentiality is respected by means of a legal or contractual obligation.
Rights arising from the processing of personal data
The User has the following rights with regard to Abby Delsol Yoga, recognised under the GDPR and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights, and may therefore exercise them against the Data Controller:
Right of access: This is the User's right to obtain confirmation as to whether or not Abby Delsol Yoga is processing their personal data and, if so, to obtain information about their specific personal data and the processing carried out or to be carried out by Abby Delsol Yoga, as well as, among other things, information available on the origin of such data and the recipients of communications made or envisaged.
Right of rectification: This is the User's right to have their personal data amended where it is inaccurate or, taking into account the purposes of processing, incomplete.
Right to erasure ("the right to be forgotten"): This is the User's right, provided that current legislation does not stipulate otherwise, to obtain erasure of their personal data where it is no longer necessary in relation to the purposes for which it was collected or processed; where the User has withdrawn their consent to processing and there is no other legal basis for it; where the User objects to the processing and there is no other legitimate reason to continue it; where the personal data has been processed unlawfully; where the personal data must be erased in order to comply with a legal obligation; or where the personal data was obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to erasing the data, the Data Controller, taking into account available technology and the cost of implementation, must take reasonable steps to inform other controllers processing the personal data of the data subject's request to erase any links to that personal data.
Right to restriction of processing: This is the User's right to restrict the processing of their personal data. The User has the right to obtain restriction of processing where they contest the accuracy of their personal data; where the processing is unlawful; where the Data Controller no longer needs the personal data but the User needs it to make legal claims; and where the User has objected to processing.
Right to data portability: Where processing is carried out by automated means, the User shall have the right to receive their personal data from the Data Controller in a structured, commonly used, machine-readable format, and to transmit it to another controller. Wherever technically feasible, the Data Controller will transmit the data directly to that other controller.
Right to object: This is the User's right to prevent the processing of their personal data, or to have such processing by Abby Delsol Yoga discontinued.
Right not to be subject to a decision based solely on automated processing, including profiling: This is the User's right not to be subject to an individual decision based solely on the automated processing of their personal data, including profiling, unless current legislation provides otherwise.
The User may therefore exercise their rights by means of written communication addressed to the Data Controller with the reference "GDPR-abbydelsolyoga.com", specifying:
The User's first name, surname(s) and a copy of their national identity document (DNI). Where representation is permitted, identification of the person representing the User, by the same means, together with documentary proof of representation, will also be required. The photocopy of the DNI may be replaced by any other means valid in law that proves identity.
A request setting out the specific reasons for the request or the information they wish to access.
Address for notification purposes.
Date and signature of the applicant.
Any document evidencing the request made.
This request and any other accompanying document may be sent to the following postal address and/or email address:
Postal address: Calle Cruz 23, 29492 Jubrique, Málaga
Email: [email protected]
Links to third-party websites
The Website may include hyperlinks or links allowing access to third-party websites other than Abby Delsol Yoga, which are not operated by Abby Delsol Yoga. The owners of such websites will have their own data protection policies and will, in each case, be responsible for their own files and their own privacy practices.
Complaints to the supervisory authority
Should the User consider that there is a problem or infringement of current regulations in the way their personal data are being processed, they shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State where they have their habitual residence, place of work, or the place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (Agencia Española de Protección de Datos) (https://www.aepd.es/).
II. ACCEPTANCE OF AND CHANGES TO THIS PRIVACY POLICY
The User must have read and agreed to the terms concerning the protection of personal data contained in this Privacy Policy, and must accept the processing of their personal data, in order for the Data Controller to be able to carry out such processing in the manner, within the periods, and for the purposes indicated. Use of the Website shall imply acceptance of its Privacy Policy.
Abby Delsol Yoga reserves the right to amend its Privacy Policy at its own discretion, or as prompted by a legislative, case-law or doctrinal change on the part of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is advised to check this page periodically to keep up to date with the latest changes or updates.
This Privacy Policy was updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights.
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