Personal Data Policy
Version of 24 August 2018
Mindful Affirmations attaches great importance to respecting your privacy and protecting your Personal Data, as defined in Regulation No 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter “GDPR”). The following provisions constitute the Personal Data Policy in relation to the following types of processing carried out by Mindful Affirmations (Joan Anselm Cardona Serra, Argenteria 67, Barcelona, SpainMindful Affirmations, firstname.lastname@example.org) via the Site and the Application, in its capacity as controller of the aforementioned processing. It is pointed out that the Personal Data collected by Mindful Affirmations is adequate, relevant and not excessive for the purposes for which it is collected and its subsequent processing.
Purposes and legal basis of processing
Management and use of the Application and the Site:
Mindful Affirmations collects, processes and uses your Personal Data to:
enable you to use the Application and benefit from the Services;
communicate with you by email, text message or post;
improve our service (data analysis, research and development, detection of fraudulent behaviours, with no moderation decisions being taken solely on the basis of automated processing)
This processing of Personal Data carried out by Mindful Affirmations is necessary for the performance of a contract to which the Member is a party. As part of this processing, Mindful Affirmations collects and processes “sensitive” data (sexual orientation, etc. – see “Categories of personal data collected” below). The processing of this sensitive data is based on your explicit consent, given in the form of your registration.
Mindful Affirmations processes Personal Data in order to send you emails about products and services offered by Mindful Affirmations.
Mindful Affirmations has a legitimate interest in carrying out this processing of Personal Data for sales prospecting purposes. You have the option of objecting to such processing of your Personal Data.
Management of applications:
Through the Site, Mindful Affirmations publishes job offers for which you can apply. For this purpose, Mindful Affirmations performs processing of collected Personal Data on the basis of the applicant’s consent.
Categories of personal data collected
Management and use of the Application and the Site:
The Personal Data that must be collected by Mindful Affirmations is as follows (if this data is not provided, you will not be able to benefit from the Services):
The optional Personal Data that is collected by Mindful Affirmations is as follows:
Photo(s) for Browsing members, which are requested if a Chat request is sent
Data collected through surveys
Data collected through customer service: we collect the information that you give us as part of this interaction. Sometimes, we monitor or record these interactions for training purposes and in order to guarantee a high quality of service.
Data arising out of use of the service: All data relating to all activity on the Site and in the Application. This includes all actions performed via the Site and the Application, your logins, your login times and all interactions with other users.
Data relating to your peripherals: models and version of the operating system for the purposes of improving mobile applications.
Data from other partners: we may receive data from our partners which enables us to know which marketing source you joined Mindful Affirmations through.
In order to send you its newsletters, Mindful Affirmations collects and processes the email address provided. The user is free not to provide it. Provision of your email address is mandatory if you wish to receive newsletters from Mindful Affirmations. If you wish to apply for a vacancy published on the Site, Mindful Affirmations will collect the Personal Data that is strictly necessary to assess the applicant’s ability to do the envisaged job.
Personal Data is kept for no longer than the period necessary for the purposes for which it is collected and processed.
Sharing of your personal data
Management and use of the Application and the Site:
Your Personal Data is can be sent to the following third parties:
Members: other Members of Mindful Affirmations to whom the Member is suggested for the purposes of dates can access the Personal Data published by the Member through his/her profile.
Service providers: Mindful Affirmations may share your Personal Data with third parties who provide certain services on Mindful Affirmations’s behalf, such as external services, including for data hosting and maintenance, analyses, customer support, payment processing and security operations. We go through a rigorous screening process before hiring any service provider or working with any partner. All of our service providers and partners are bound by strict obligations in relation to confidentiality.
Recipients of your Personal Data are carefully selected by Mindful Affirmations and are required to implement a Personal Data policy which meets its requirements. Mindful Affirmations ensures that these requirements are met through contracts and other measures, so that your Personal Data is not processed for purposes other than those specified herein, including for advertising purposes.
Service providers: Mindful Affirmations may share your Personal Data with third parties who provide certain services on Mindful Affirmations’s behalf, such as external services, marketing and advertising. We go through a rigorous screening process before hiring any service provider or working with any partner. All of our service providers and partners are bound by strict obligations in relation to confidentiality.
Service providers: Mindful Affirmations may share your Personal Data with third parties who provide certain services on Mindful Affirmations’s behalf, such as external services, in order to recruit and follow up on applications. We go through a rigorous screening process before hiring any service provider or working with any partner. All of our service providers and partners are bound by strict obligations in relation to confidentiality.
Transfer of business: Your Personal Data may also be sent to third parties in connection with a transfer of business from Mindful Affirmations to a third company (merger, transfer, winding up, etc.). In this event, you will be informed of any such transfer of your Personal Data and will have the option of objecting to this transfer.
Other: Mindful Affirmations may pass on your Personal Data if this is required by law, by a court or by the authorities or appears to be necessary to enable Mindful Affirmations to establish that its rights exist or to exercise its rights. Mindful Affirmations may also pass on your Personal Data in order to protect its rights, for the protection and safety of the company, users, its staff or others, to comply with applicable law, or to enforce its GTUS or any other contract or policy.
Transfers of personal data
The sharing of your Personal Data referred to above sometimes involves cross-border data transfers, for example to the United States of America and other countries. Where transfers of Personal Data are made to countries, such as the United States of America, whose legislation does not provide an adequate level of protection, we use standard contractual clauses approved by the European Commission or other appropriate safeguard clauses to govern these transfers and protect the confidentiality and safety of your data.
Relationships with third parties
Links to third-party websites
The Site and Messages sent by other Members may contain links to third-party websites which are not controlled by Mindful Affirmations. Mindful Affirmations is not responsible for the practices of such third parties in terms of Personal Data protection and encourages you to take note of the statements and practices of such third parties in this regard. When you leave the Site or the Application, this Personal Data Policy no longer applies.
Mindful Affirmations takes all precautions necessary to protect the security of your Personal Data, including preventing it from being distorted or damaged and preventing unauthorised third parties from accessing it.
You have a right to ask Mindful Affirmations for access to information concerning you (art. 15 GDPR), rectification (art. 16 GDPR) or erasure (art. 17 GDPR) of such information, and restriction of processing (art. 18 GDPR). You also have a right to data portability (art. 20 GDPR).
You may also, as specified in article 21 GDPR, object to the processing of your Personal Data. To this end, you can unsubscribe at any time from Mindful Affirmations’s sales prospecting lists by sending an email to the address email@example.com.
You can also withdraw your consent at any time, without such withdrawal affecting the lawfulness of processing carried out on the basis of this consent prior to its withdrawal.
Lastly, you have the right to make a complaint to a supervisory authority.
You may exercise the aforementioned rights by writing to the following address: firstname.lastname@example.org. Mindful Affirmations will process your request within one month after the request is received, except in special circumstances.
This request must be accompanied by a photocopy of a form of ID which bears the holder’s signature.
If a Member’s requests are manifestly unjustified or excessive, in particular due to their repetitiveness, Mindful Affirmations may i) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the requested action, or ii) refuse to act on such requests.
Changes to the Personal Data Policy
Mindful Affirmations reserves the right to amend, add, remove or develop sections of this Personal Data Policy at any time and without notice in order to comply with changes in the law in this field, among other reasons.
A new version of the Mindful Affirmations Personal Data Policy will then be provided to you. If you do not agree to the terms of this new Personal Data Policy as applicable to all future use of the Application and the Site, please stop using the Application and the Site.
Contacting Mindful Affirmations
For all matters concerning your Personal Data (correction, updating, access, withdrawal of consent, etc.) or if you have any questions, please contact Mindful Affirmations by writing to the following address: email@example.com.