I. PRIVACY AND DATA PROTECTION POLICY
In this sense, the Holder guarantees the fulfillment of the effective norm in the matter of protection of personal data, reflected in Statutory law 3/2018, of 5 of December, Protection of Personal Data and Guarantee of Digital Rights (LOPD GDD). It also complies with Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016 on the protection of individuals (RGPD).
Identity of the person in charge
– Headline holder: Emanuel Poggio
– NIF/CIF: X8033560M
– Address: Valle Inclán 40, Polígono La Campana, Nueva Andalucía, Marbella (CP 29660). Province of Malaga, Spain
– Telephone: +34 951 91 69 36 / +34 637 88 67 88
– E-mail: firstname.lastname@example.org
– Website: healthfirststudio.com
Principles applied in data processing
When processing your personal data, the Data Controller will apply the following principles which are in line with the requirements of the new European Data Protection Regulation:
- Principle of legality, loyalty and transparency: The Holder will always require consent for the processing of your personal data which may be for one or more specific purposes about which he will inform you in advance with absolute transparency.
- Principle of data minimization: The Holder will only ask you for the data strictly necessary for the purpose or purposes for which it is requested.
- Principle of limitation of conservation period: The data will be kept for the time strictly necessary for the purpose(s) of the processing.
The Holder will inform you of the corresponding conservation period according to the purpose. In the case of subscriptions, the Holder will periodically review the lists and delete those records that have been inactive for a considerable time.
- Principle of integrity and confidentiality: Your data will be treated in such a way that their security, confidentiality and integrity is guaranteed. You should know that the Holder takes the necessary precautions to prevent unauthorized access or misuse of their users’ data by third parties.
Obtaining personal data
To navigate healthfirststudio.com you do not need to provide any personal information. The cases in which you do provide your personal data are the following:
- When contacting through the contact forms or sending an e-mail.
- When you make a comment on an article or page.
- When you sign up for a subscription form or a newsletter that the Owner manages with MailRelay.
- When signing up for a subscription form or newsletter that the Owner manages via email
The Holder informs you that regarding your personal data you have the right to
– Request access to the stored data.
– Request a rectification or cancellation.
– Request the limitation of their treatment.
– Oppose to the treatment.
– Request the portability of your data.
The exercise of these rights is personal and therefore must be exercised directly by the interested party, requesting it directly from the Holder, which means that any client, subscriber or collaborator who has provided their data at any time may contact the Holder and ask for information about the data they have stored and how they were obtained, request the rectification of the data, request the portability of their personal data, oppose the treatment, limit its use or request the cancellation of these data in the Holder’s files.
To exercise your rights of access, rectification, cancellation, portability and opposition you must send an email to email@example.com together with the proof valid in law as a photocopy of the D.N.I. or equivalent.
You have the right to effective judicial protection and to file a complaint with the control authority, in this case, the Spanish Data Protection Agency, if you consider that the processing of personal data concerning you infringes the Regulation.
Purpose of personal data processing
The personal data and the purpose of the treatment by the Holder is different according to the system of information capture:
- Contact forms: The Holder requests personal data among which can be: Name and surname, e-mail address, phone number and website address in order to respond to your queries.
For example, the Holder uses these data to respond to your messages, doubts, complaints, comments or concerns you may have regarding the information included in the website, the services provided through the website, the processing of your personal data, issues relating to legal texts included in the website, as well as any other query you may have that is not subject to the conditions of the website or the contract.
- Content subscription forms: The Holder requests the following personal data: Name and surname, e-mail address, telephone number and website address to manage the subscription list, send newsletters, promotions and special offers.
There are other purposes for which the Holder processes your personal data:
- To ensure compliance with the conditions set out in the Legal Notice and applicable law. This may include the development of tools and algorithms that help this website to ensure the confidentiality of personal data it collects.
- To support and improve the services offered by this website.
- To manage the social networks. The Holder has presence in social networks. If you become a follower in the social networks of the Holder the treatment of personal data will be governed by this section, as well as by those conditions of use, privacy policies and access regulations that belong to the social network that is appropriate in each case and that you have previously accepted.
You can consult the privacy policies of the main social networks in these links:
The Holder will treat your personal data with the purpose of correctly managing its presence on the social network, informing you of its activities, products or services, as well as for any other purpose that the regulations of social networks allow.
Under no circumstances will the Holder use the profiles of followers in social networks to send advertising individually.
Security of personal data
To protect your personal data, the Holder takes all reasonable precautions and follows industry best practices to prevent the loss, misuse, improper access, disclosure, alteration or destruction of your personal data.
Content of other websites
Pages on this website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves exactly as if you had visited the other website.
Legitimacy for data processing
The legal basis for the processing of your data is: consent.
Categories of personal data
The categories of personal data processed by the Holder are:
– Identification data.
Retention of personal data
The personal data you provide to the Holder will be kept until you request their deletion.
Recipients of personal data
– Mailrelay CPC Servicios Informáticos Aplicados a Nuevas Tecnologías S.L. (hereinafter «CPC») , with registered office at C/ Nardo, 12 28250 – Torrelodones – Madrid.
You will find more information at: https://mailrelay.com
CPC treats the data with the purpose of providing its email services to the Holder.
– Google Analytics is a web analytics service provided by Google, Inc. a Delaware company whose main office is at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, United States («Google»). You can find more information at: https://analytics.google.com
Google Analytics uses «cookies», which are text files placed on your computer, to help the Owner analyze how users use the website. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States .
– DoubleClick by Google is a set of advertising services provided by Google, Inc. a Delaware company whose main office is at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, United States («Google»).
You can find more information at: https://www.doubleclickbygoogle.com
You can also see a list of the types of cookies that Google and its partners use and any information about their use of advertising cookies.
When you browse healthfirststudio.com we may collect non-identifying information, which may include, IP address, geo-location, a record of how the services and sites are used, browsing habits, and other information that cannot be used to identify you.
The website uses the following third-party analysis services:
– Google Analytics
– DoubleClick by Google
The Holder uses the information obtained to obtain statistical data, analyze trends, administer the site, study navigation patterns and to gather demographic information.
Accuracy and truthfulness of personal data
You undertake that the data provided to the Holder will be correct, complete, accurate and in force, as well as to keep them duly updated.
As User of the Website you are solely responsible for the truthfulness and correctness of the data you submit to the site exonerating the Holder of any responsibility in this regard.
Acceptance and consent
To exercise your rights of access, rectification, cancellation, portability and opposition, you must send an email to firstname.lastname@example.org together with the legally valid proof such as a photocopy of your ID card or equivalent.
The exercise of your rights does not include any data that the Holder is obliged to keep for administrative, legal or security purposes.
These policies will be in force until they are modified by others duly published.
Respecting the established in the current legislation, healthfirststudio.com (from now on, also Website) commits itself to adopt the necessary technical and organizational measures, according to the level of security adequate to the risk of the collected data.
– Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (GPRD).
– The Organic Law 3/2018 of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights (LOPD-GDD).
– The Royal Decree 1720/2007, of December 21, which approves the Regulation of development of the Organic Law 15/1999, of December 13, 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 person responsible for the processing of personal data
The person responsible for the processing of personal data collected on healthfirststudio.com is: Emanuel Poggio, with VAT number: X8033560M, whose representative is: Emanuel Poggio (hereinafter referred to as the Data Controller). His contact details are as follows:
Valle Inclán 40, Polígono La Campana, Nueva Andalucía, Marbella (CP 29660). Province of Malaga, Spain
Contact telephone: +34 951 91 69 36 / +34 637 88 67 88
Contact email: email@example.com
Data Protection Officer (DPD)
The Data Protection Officer (DPD) is responsible for ensuring compliance with the data protection regulations to which healthfirststudio.com is subject. The User may contact the DPD designated by the Data Protection Officer of the treatment using the following contact details: Tel. +34 951 91 69 36 / +34 637 88 67 88 – firstname.lastname@example.org – Valle Inclán 40, Polígono La Campana, Nueva Andalucía, Marbella (CP 29660). Province of Malaga, Spain
Registration of Personal Data
In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by healthfirststudio.com through the forms extended in their pages will be incorporated and processed in our files in order to facilitate, expedite and fulfill the commitments established between healthfirststudio.com and the user or the maintenance of the relationship established in the forms that the user fills out, or to meet a request or consultation of the same. Likewise, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in Article 30.5 of the RGPD is applicable, a register of processing activities is kept which specifies, according to its purposes, the processing activities carried out and the other circumstances established in the RGPD.
Principles applicable to the processing of personal data
The processing of the User’s personal data will be subject to the following principles contained in Article 5 of the RGPD and in Article 4 and following of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights:
– Principle of legality, loyalty and transparency: the User’s consent will be required at all times, after being informed in a completely transparent manner of the purposes for which the personal data are collected.
– Principle of purpose limitation: personal data will be collected for specific, explicit and legitimate purposes.
– Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
– Accuracy principle: personal data must be accurate and always updated.
– Principle of limitation of conservation period: personal data will only be kept in a way that allows the identification of the User for the time necessary for the purposes of processing.
– Principle of integrity and confidentiality: personal data will be processed in a way that guarantees its security and confidentiality.
– Principle of proactive responsibility: the data controller will be responsible for ensuring that the above principles are complied with.
Categories of personal data
The data categories that healthfirststudio.com handles are solely identifying data. In no case, special categories of personal data are treated in the sense of article 9 of the RGPD.
Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. healthfirststudio.com undertakes to obtain the express and verifiable consent of the User for the processing of his/her personal data for one or more specific purposes.
The User has the right to withdraw his/her consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, withdrawal of consent shall not condition the use of the Website.
On the occasions when the User must or may provide his/her data through forms to make queries, request information or for reasons related to the content of the Website, he/she will be informed if the completion of any of these forms is compulsory due to the fact that they are essential for the correct development of the operation carried out.
Purposes of the treatment to which the personal data are destined
The personal data is collected and managed by healthfirststudio.com with the purpose of facilitating, expediting and fulfilling the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to respond to a request or consultation.
Likewise, the data may be used for commercial purposes of personalization, operational and statistical, and activities of the corporate purpose of healthfirststudio.com, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation and navigation of the Website.
At the time when the personal data is obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data will be used; that is, the use or uses that will be given to the information collected.
Retention periods of 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: 2 years, or until the User requests its deletion.
At the time the personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when this is not possible, the criteria used to determine this period.
Recipients of personal data
The User’s personal data will be shared with the following recipients or categories of recipients:
In case the Controller intends to transfer personal data to a third country or international organisation, the User shall be informed at the time the personal data are collected about the third country or international organisation to which the data are intended to be transferred and about the existence or absence of a decision of adequacy by the Commission.
Personal data of minors
Respecting what is established in articles 8 of the RGPD and 7 of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those who are over 14 years old can give their consent for the treatment of their personal data in a legal way by healthfirststudio.com. If the person is under 14 years of age, the consent of the parents or guardians will be necessary for the treatment, and this will only be considered licit to the extent that they have authorized it.
Secrecy and security of personal data
healthfirststudio.com undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and prevent the destruction, loss or accidental or unlawful alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication of or access to such data.
The Website has a SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted or unencrypted.
However, since healthfirststudio.com cannot guarantee the impregnability of the Internet or the total absence of hackers or others who access personal data in a fraudulent manner, the Data Controller undertakes to inform the User without undue delay when a violation of the security of personal data occurs that is likely to involve a high risk to the rights and freedoms of individuals. In accordance with article 4 of the RGPD, a personal data security breach is understood to be any breach of security that results in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication of or access to such data.
Personal data will be treated as confidential by the data controller, who undertakes to inform of and to ensure by means of a legal or contractual obligation that such confidentiality is respected by his employees, associates, and any person to whom he makes the information accessible.
Rights arising from the processing of personal data
The User has over healthfirststudio.com and can, therefore, exercise against the Responsible of the treatment the following rights recognized in the RGPD and in the Organic Law 3/2018, of December 5, of Protection of Personal Data and guarantee of the digital rights:
– Right of access: It is the right of the User to obtain confirmation of whether or not healthfirststudio.com is processing his or her personal data and, if so, to obtain information about his or her specific personal data and the processing that healthfirststudio.com has carried out or is carrying out, as well as, among other things, information available about the origin of such data and the recipients of the communications carried out or planned.
– Right of rectification: It is the right of the User to have his personal data modified if they are found to be inaccurate or, taking into account the purposes of the treatment, incomplete.
– Right of suppression («the right to forget»): It is the User’s right, provided that the legislation in force does not establish otherwise, to obtain the deletion of his/her personal data when these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his/her consent to the processing and it has no other legal basis; the User opposes the processing and there is no other legitimate reason to continue it; the personal data has been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to the deletion of the data, the data controller shall, taking into account the available technology and the cost of its implementation, take reasonable steps to inform the data controllers who are processing the personal data of the data subject’s request for the deletion of any link to those personal data.
– Right to limit processing: This is the right of the User to limit the processing of his or her personal data. The User has the right to obtain limitation of the processing when he or she contests the accuracy of his or her personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to make a claim; and when the User has objected to the processing.
– Right to the portability of data: Where processing is carried out by automated means, the User shall have the right to receive from the Data Controller his personal data in a structured, commonly used, machine-readable format and to transmit them to another Data Controller. Wherever technically possible, the data controller shall transmit the data directly to that other controller.
– Right of opposition: It is the right of the user to not have their personal data processed or to cease the processing of such data by healthfirststudio.com
– Right not to be subject to a decision based solely on the automated processing, including profiling: This is the right of the User not to be subject to an individualized decision based solely on the automated processing of his or her personal data, including profiling, unless otherwise provided for by law.
Therefore, the User may exercise his or her rights by means of written communication addressed to the Data Controller, specifying
– Name, surname of the user and copy of the ID card. In cases where representation is admitted, it will also be necessary to identify by the same means the person representing the User, as well as the document proving the representation. The photocopy of the DNI may be replaced by any other legally valid means of proof of identity.
– Request with the specific reasons for the request or information you want to access.
– Address for notification purposes.
– Date and signature of the applicant.
– Any document that accredits the request made.
This request and any other attached documents may be sent to the following address and/or e-mail:
Valle Inclán 40, Polígono La Campana, Nueva Andalucía, Marbella (CP 29660) Province of Malaga, Spain
Links to third party websites
The Website may include hyperlinks or links that allow access to third party web pages other than healthfirststudio.com, and which are therefore not operated by healthfirststudio.com. The owners of these websites will have their own data protection policies, being responsible in each case for their own files and their own privacy practices.
Claims before the control authority
In the event that the User considers that there is a problem or infringement of the regulations in force in the way his or her personal data is being processed, he or she shall be entitled to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State in which he or she has his or her habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).
II. COOKIES POLICY
Cookies are automatic procedures for collecting information relating to the preferences determined by the User during his/her visit to the Website in order to recognise him/her as a User, and personalise his/her experience and use of the Website, and may also, for example, help to identify and resolve errors.
Information collected through cookies may include the date and time of visits to the Website, the pages viewed, the time spent on the Website and the sites visited just before and just after the Website. However, no cookie allows the cookie to contact the User’s telephone number or any other means of personal contact. No cookie can extract information from the User’s hard drive or steal personal information. The only way for the User’s private information to become part of the Cookie file is for the User to personally give that information to the server.
Cookies are those that are sent to the User’s computer or device and managed exclusively by healthfirststudio.com for the best operation of the Website. The information collected is used to improve the quality of the Website and its Content and your experience as a User. These cookies allow us to recognize the User as a returning visitor to the Website and to adapt the content to provide you with content that fits your preferences.
Third Party Cookies
Cookies are used and managed by external entities that provide healthfirststudio.com with services requested by the latter to improve the Web Site and the user’s experience when navigating the Web Site. The main objectives for which third party cookies are used are to obtain access statistics and to analyze navigation information, i.e. how the User interacts with the Website.
The information that is obtained refers, for example, to the number of pages visited, the language, the place where the IP address from which the User accesses, the number of Users who access, the frequency and recurrence of visits, the time of visit, the browser used, the operator or type of device from which the visit is made. This information is used to improve the Website, and to detect new needs in order to offer Users optimum quality Content and/or service. In any case, the information is collected anonymously and Web Site trend reports are prepared without identifying individual Users.
You can obtain more information about cookies, information about privacy, or consult the description of the type of cookie used, its main characteristics, expiration period, etc. in the following link(s):
The entity(ies) in charge of supplying cookies may pass on this information to third parties, provided that this is required by law or that a third party processes this information for these entities.
Social Networking Cookies
healthfirststudio.com incorporates social network plugins, which allow access to them from the Website. For this reason, social network cookies may be stored in the User’s browser. The owners of these social networks have their own data protection and cookie policies, and are responsible for their own files and privacy practices. The User must refer to these policies to find out about these cookies and, where appropriate, the processing of personal data. For information purposes only, the links to these privacy and/or cookie policies are indicated below:
Disabling, rejecting and deleting cookies