WEB PRIVACY POLICY

alexandratherapytouch.com

I. PRIVACY POLICY AND DATA PROTECTION

Respecting the provisions of current legislation, Alexandra Therapy (hereinafter also Website) commits to adopting the necessary technical and organisational measures, according to the security level appropriate to the risk of the data collected.

Laws incorporated in this privacy policy

This privacy policy is adapted to the current Spanish and European regulations regarding 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 guarantee of digital rights (LOPD-GDD).

  • Royal Decree 1720/2007, of 21 December, approving the Regulation developing 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 of personal data

The data controller of the personal data collected in Alexandra Therapy is: Alexandra Therapy, with NIF/CIF: Y4121754F, represented by Aleksandra Peneva Todorova (hereinafter, Data Controller). Contact details are as follows:

Address: Av. alpandeire, VIME la reserva de Marbella apartmentos, N 6120

Contact phone: 642 191 355

Contact email: contact@alexandratherapytouch.com

Personal Data Register

In compliance with the provisions of the GDPR and LOPD-GDD, we inform you that the personal data collected by Alexandra Therapy through the forms on its pages will be incorporated and processed in our file in order to facilitate, expedite, and fulfil the commitments established between Alexandra Therapy and the User or to maintain the relationship established through the forms the User fills in, or to attend any request or query from the User. Furthermore, in accordance with the GDPR and LOPD-GDD, unless the exception established in article 30.5 of the GDPR applies, a record of processing activities is maintained specifying, according to its purposes, the processing activities carried out and other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User’s personal data will be subject to the following principles set out in article 5 of the GDPR and articles 4 and following of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights:

  • Principle of lawfulness, fairness, and transparency: User consent will be required at all times after fully transparent information on the purposes for which personal data is collected.

  • Purpose limitation principle: personal data will be collected for specific, explicit, and legitimate purposes.

  • Data minimisation principle: only the strictly necessary personal data will be collected in relation to the purposes for which they are processed.

  • Accuracy principle: personal data must be accurate and kept up to date.

  • Storage limitation principle: personal data will only be kept as long as necessary to allow identification of the User for the purposes of processing.

  • Integrity and confidentiality principle: personal data will be processed in a manner that ensures its security and confidentiality.

  • Accountability principle: the Data Controller will be responsible for ensuring compliance with the above principles.

Categories of personal data

The categories of data processed by Alexandra Therapy are only identifying data. Under no circumstances are special categories of personal data as defined in article 9 of the GDPR processed.

The categories of data processed by Alexandra Therapy include both identifying data and special categories of personal data as defined in article 9 of the GDPR.

Special categories of personal data are understood as those revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data aimed at uniquely identifying 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, explicit consent from the User for one or more specific purposes will always be required.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Alexandra Therapy commits to obtaining the User’s express and verifiable consent for the processing of their personal data for one or more specific purposes.

The User has the right to withdraw their consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, withdrawal of consent will not affect the use of the Website.

When the User must or may provide data through forms to make inquiries, request information, or for reasons related to the Website content, they will be informed if any fields are mandatory because they are essential for the correct processing of the operation.

Purposes for which personal data is processed

Personal data is collected and managed by Alexandra Therapy in order to facilitate, expedite, and fulfil the commitments established between the Website and the User or to maintain the relationship established through the forms the User completes, or to respond to any request or inquiry.

Likewise, the data may be used for commercial purposes including personalisation, operational and statistical activities, and activities related to Alexandra Therapy’s social purpose, as well as for data extraction, storage, and marketing studies to adapt the content offered to the User and to improve the quality, functioning, and navigation of the Website.

At the time personal data is collected, the User will be informed of the specific purpose(s) for which the personal data will be processed; that is, the use(s) that will be made of the collected information.

Retention periods for personal data

Personal data will only be retained for the minimum time necessary for the purposes of processing and, in any case, only for the following period: 12 months, or until the User requests its deletion.

At the time personal data is collected, the User will be informed of the period during which the personal data will be retained or, when this is not possible, the criteria used to determine this period.

Recipients of personal data

The User’s personal data will not be shared with third parties.

In any case, at the time personal data is collected, the User will be informed about 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:

Google Analytics

If the Data Controller intends to transfer personal data to a third country or international organisation, at the time personal data is collected, the User will be informed about the third country or international organisation to which the data is intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In compliance with articles 8 of the GDPR and 7 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights, only persons over 14 years old may lawfully give consent for the processing of their personal data by Alexandra Therapy. For minors under 14, parental or guardian consent is required, and the processing will only be lawful to the extent that such consent has been given.

Confidentiality and security of personal data

Alexandra Therapy commits to adopting the necessary technical and organisational measures, according to the security level appropriate to the risk of the data collected, to guarantee the security of personal data and to prevent accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, as well as unauthorised communication or access to such data.

The Website has an SSL certificate (Secure Socket Layer), which ensures that personal data is transmitted securely and confidentially, with data transmission between the server and the User fully encrypted.

However, since Alexandra Therapy cannot guarantee the invulnerability of the internet nor the total absence of hackers or others who may fraudulently access personal data, the Data Controller commits to notifying the User without undue delay should a personal data security breach occur that is likely to pose a high risk to the rights and freedoms of individuals. As established in article 4 of the GDPR, a personal data breach is understood as any breach of security causing accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access to personal data transmitted, stored, or otherwise processed.

Personal data will be treated as confidential by the Data Controller, who commits to informing and ensuring, through a legal or contractual obligation, that such confidentiality is respected by its employees, associates, and any person to whom the information is accessible.

Rights arising from the processing of personal data

The User has the following rights regarding Alexandra Therapy and may therefore exercise them against the Data Controller, as recognised by the GDPR and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights:

  • Right of access: The User has the right to obtain confirmation as to whether Alexandra Therapy is processing their personal data and, if so, to access information about the specific personal data and processing carried out by Alexandra Therapy, including information about the origin of the data and recipients of any communications made or planned.

  • Right to rectification: The User has the right to have inaccurate personal data corrected or completed, considering the purposes of the processing.

  • Right to erasure (“right to be forgotten”): The User has the right, unless otherwise provided by law, to obtain the deletion of personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn consent and there is no other legal basis; the User objects to processing and there is no legitimate reason to continue; the data has been processed unlawfully; the data must be erased in compliance with a legal obligation; or the data was obtained from a direct offer of information society services to a minor under 14 years of age. In addition to erasing data, the Data Controller must, taking into account available technology and cost, take reasonable steps to inform other controllers processing the data of the User’s request to erase any links to, copies, or replications of that data.

  • Right to restriction of processing: The User has the right to restrict processing in certain cases, such as contesting the accuracy of data, unlawful processing, when the Data Controller no longer needs the data but the User needs it for claims, or when the User objects to processing.

  • Right to data portability: When processing is carried out by automated means, the User has the right to receive their personal data in a structured, commonly used, machine-readable format and to transmit it to another Data Controller. Where technically feasible, the Data Controller will transmit the data directly to the other Data Controller.

  • Right to object: The User has the right to object to the processing of their personal data or to have such processing stopped by Alexandra Therapy.

  • Right not to be subject to automated decision-making, including profiling: The User has the right not to be subject to a decision based solely on automated processing, including profiling, unless permitted by law.

The User may exercise their rights by written communication addressed to the Data Controller with reference “GDPR-alexandratherapytouch.com”, specifying:

  • Full name and a copy of the ID. Where representation is admitted, identification of the representative and proof of representation will also be necessary. The copy of the ID may be replaced by any other legally valid means of identity verification.

  • Request with specific reasons or information to which access is sought.

  • Address for notifications.

  • Date and signature of the applicant.

  • Any documents supporting the request.

This request and any accompanying documents may be sent to:

Postal address: Av. alpandeire, VIME la reserva de Marbella apartmentos, N 6120

Email: contact@alexandratherapytouch.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than Alexandra Therapy, and therefore are not operated by Alexandra Therapy. The owners of those websites have their own data protection policies and are individually responsible for their own files and privacy practices.

Complaints to the supervisory authority

If the User considers that there is a problem or infringement of current regulations regarding the processing of their personal data, they have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the country where they have their habitual residence, place of work, or where the alleged infringement occurred. In Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

The User must have read and agreed to the terms on the protection of personal data contained in this Privacy Policy, as well as accepted the processing of their personal data for the Data Controller to proceed accordingly, in the manner, within the timeframes, and for the purposes indicated. Use of the Website implies acceptance of its Privacy Policy.

Alexandra Therapy reserves the right to modify its Privacy Policy at its own discretion or due to legislative, jurisprudential, or doctrinal changes by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. Users are advised to periodically check this page to stay informed of 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 guarantee of digital rights.