GDPR (privacy policy)

 

Privacy Policy

In this data protection declaration, we inform you about the processing of personal data when using this website.

Responsible person

Responsible for data processing:

MMJG Mindful Life SL, C/ Goleta 5, 07610 Can Pastilla

hola@tres-m.com

Data protection supervisor

This information is only required if a data protection officer has to be appointed. This is the case in the following instances:

• • At least 10 employees in the company regularly process data in an automated manner, e.g. using computers.

• • Regardless of the number of employees, the company processes at least one category of the following personal data: ethnic origin, race, political opinion, religious belief, trade union membership, health or sex life.

• • The main focus of the business activity is the transmission of personal data as carried out, for example, by a credit agency, an address publisher or a market and opinion research institute.

Since none of the above points apply, the website operator is not required to provide a data protection officer. If you have any questions or concerns regarding data protection on this website, you can submit a written enquiry at any time. Please use the following email address for this purpose:  hola@tres-m.com 

 

Personal data

 

Personal data means any information relating to an identified or identifiable natural person (hereinafter ‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. This website only collects personal data that is provided voluntarily, for example by filling out a contact form integrated into the website and/or newsletter registrations.

Data when accessing the website

If you only use this website to obtain information and do not provide any data, we only process the data required to display the website on the internet-enabled device you are using. This includes, in particular:

• • IP address

• • Date and time of the request

• • The amount of data transferred in each case and data

• • the website from which the request comes

• • the websites accessed via this website

• • Visited pages and sub-pages on our website

• • Amount of data transferred

• • Browser type and browser version

• • Operating system

The legal basis for the processing of this data is legitimate interests in accordance with Art. 6 Para. 1 UAbs. 1 Letter f) DSGVO, in order to enable the presentation of the website in principle.

In addition, you can use various services on the website that process further personal and non-personal data.

 

Duration of data storage

The data will be deleted as soon as it is no longer required for the purpose for which it was collected. When providing the website, this is the case when the respective session has ended. The log files are stored for a maximum of 24 hours, directly and exclusively accessible to administrators, and analysed solely to improve the usability of the website.

Your rights

As the data subject, you have the following rights:

• • You have the right to request information about the personal data concerning you that the controller processes (Art. 15 GDPR),

• • You have the right to request the rectification of data concerning you if it is inaccurate or incomplete (Art. 16 GDPR),

• • You have the right to request the erasure of data concerning you (Art. 17 GDPR),

• • You have the right to request the restriction of the processing of your personal data (Art. 18 GDPR),

• • You have the right to data portability (Art. 20 GDPR),

• • You have the right to object to the processing of your personal data (Art. 21 GDPR),

• • You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (Art. 22 GDPR),

• • You have the right to complain to the relevant supervisory authority in the event of a suspected breach of data protection law (Art. 77 GDPR). The supervisory authority at your usual place of residence, workplace or at the place of the suspected infringement is responsible.

1. General information

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term ‘personal data’ comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

Data collection on this website

Who is the responsible party for the recording of data on this website (i.e. the ‘controller’)?

The data on

this website is processed by the operator of the website, whose contact information is available under

can be found in the ‘Note on the responsible party’ section of this

data protection declaration and the imprint.

 

How do we record your data?

 

On the one hand, your data is collected when you provide it to us. This may be data that you enter in a contact form, for example.

Other data is collected by our IT systems automatically or with your consent when you visit the website. This is primarily technical data (e.g. web browser,

operating system or time of page view). This data is collected automatically as soon as you enter this website.

 

For what purpose do we use your data?

 

Some of the data is collected to ensure that the website is provided without errors. Other data can be used to analyse your user behaviour. And to process and guarantee your order.

 

What rights do you have regarding your data?

 

You have the right to receive information about the origin, recipients and purpose of your stored personal data free of charge and at any time. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. Furthermore, you have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to appeal to the relevant regulatory authority.

Please do not hesitate to contact us at any time regarding this or any other questions on the topic of data protection.

 

Analysis tools and third-party tools

 

When visiting this website, your surfing behaviour may be statistically evaluated. This is done primarily with so-called analysis programs. Detailed information on

these analysis programs can be found in the following data protection declaration.

 

2. Hosting

 

External hosting

This website is hosted by an external service provider (hoster). The personal data collected on this website is stored on the host’s servers. This may include, but is not limited to, IP addresses, contact requests, metadata and communications, contact information, names, web page access, and other data generated through a web site.

The host is used for the purpose of fulfilling the contract with our potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the interest of a

secure, fast and efficient provision of our online offer by a professional provider (Art. 6 para. 1 lit. f GDPR).

Our hoster will only process your data to the extent necessary to fulfil its performance obligations and will follow our instructions with regard to this data.

We use the following hoster:

 

STRATO AG

Otto-Ostrowski-Straße 7

23552 Lübeck

 

Order processing

 

We have concluded a contract for order processing (AVV) with the above-named provider. This is a contract prescribed by data protection law that ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

 

3. General information and mandatory information

 

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy. When you use this website, various personal data is collected. Personal data is data that can be used to personally identify you. This

privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We would like to point out that data transmission over the internet (e.g. when communicating by email) can have security gaps. It is not possible to provide seamless protection of data from access by third parties.

Memory duration

Unless a more specific storage period has been specified in this data protection declaration, your personal data will remain with us until the purpose for processing the data no longer applies.

If you create an account for further orders and store your billing / delivery addresses and contact data there, the storage period is also until you delete this data yourself or assert a request for deletion.

Under no circumstances will payment data be stored.

If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

Note on data transfer to the USA and other third countries

Among other things, we use tools from companies based in the United States or other third countries that do not have adequate data protection laws. When these tools are active, your

personal data may be transferred to and processed in these third countries. We would like to point out that these countries may not guarantee a level of data protection comparable to that in the EU. For example, US companies are obliged to release personal data to security authorities without you as the data subject being able to take legal action against this. It cannot therefore be ruled out that US authorities may process, evaluate and permanently store your data on US servers for monitoring purposes. We have no influence over these processing activities.

Withdrawal of your consent to data processing

Many data processing operations are only possible with your express consent.

You can revoke consent you have already given at any time. The legality of the data processing carried out up to the point of revocation remains unaffected by the revocation.

Right to object to data collection in special cases and to direct advertising (Art. 21 GDPR)

If data processing is carried out on the basis of Art. 6 (1) lit. e or f GDPR, you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, including profiling based on those provisions. The respective legal basis for processing can be found in this privacy policy. If you file an objection, we will no longer process your personal data concerned unless we can prove compelling reasons for the processing worthy of protection which outweigh your interests, rights and freedoms or the processing serves the assertion, exercise or defence of legal claims (objection according to art. 21 para. 1 DSGVO).

Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object, your personal data will subsequently no longer be used for direct marketing purposes (objection under Article 21(2) GDPR).

Right of appeal to the competent supervisory authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the member state of their habitual residence, their place of work or the place of the alleged violation. The right to lodge a complaint exists regardless of any other administrative or judicial remedies.

Right to data portability

You have the right to have data which we process based on your consent or in fulfilment of a contract automatically delivered to yourself or to a third party in a standard, machine-readable format. If you require the direct transfer of data to another responsible party, this will only be done to the extent technically feasible.

SSL or TLS encryption

This site uses SSL or TLS encryption for security reasons and for the protection of the transmission of confidential content, such as the inquiries you send to us as the site operator.

Information, deletion and correction

Within the scope of the applicable legal provisions, you have the right to request information about your stored personal data, its origin and recipients and the purpose of the data processing and, if necessary, a right to correct or delete this data. You can contact us at any time with questions about this and other issues related to personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time regarding this. The right to restriction of processing applies in the following cases:

1. 1. a) If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. During the verification period, you have
   2. the right to request the restriction of the processing of your personal data.

1. 1. b) If the processing of your personal data was/is carried out unlawfully, you can request the restriction of data processing instead of deletion.

1. 1. c) If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.

1. 1. d) If you have objected to processing pursuant to Article 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

1. 1. e) If you have restricted the processing of your personal data, these data – apart from being stored – may only be processed with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of an important public interest of the European Union or a Member State.

Objection to advertising e-mails

We hereby object to the use of the contact data published in accordance with the imprint obligation to send unsolicited advertising and information material. The site operators expressly reserve the right to take legal action in the event of unsolicited advertising information being sent, for example by spam e-mails.

4. data collection on this website

Cookies

Our websites use so-called ‘cookies’. Cookies are small text files and do not cause any damage to your end device. They are either stored temporarily for the

session (session cookies) or permanently (permanent cookies) on your device. Session cookies are automatically deleted after your visit. Permanent cookies remain stored on your device until you delete them yourself or until they are automatically deleted by your web browser.

In some cases, third-party cookies may also be stored on your device when you enter our site (third-party cookies). These enable us or you to use certain services of the third-party company (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary because certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies are used to evaluate user behaviour or display advertising.

Cookies that are required for the performance of the electronic communications transaction (required cookies) or to provide certain functions you want to use (functional cookies, e.g. for the shopping cart function) or those that are necessary for the optimisation of the website (e.g. cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6 Sect. 1 lit. f GDPR, unless a different legal basis is cited. The website operator has a legitimate interest in the storage of cookies to ensure an optimised service provided free of technical errors. If consent to store cookies has been requested, the storage of the cookies in question is based exclusively on this consent (Art. 6 para. 1 lit. a GDPR); consent can be revoked at any time.

You can adjust the settings on your browser so that you are informed when cookies are set and only allow cookies in individual cases, accept cookies in certain cases or generally exclude them and activate the automatic deletion of cookies when closing the browser. If you deactivate cookies, the functionality of this website may be limited.

If cookies are used by third-party companies or for analysis purposes, we will inform you of this separately in the context of this data protection declaration and, if necessary, request your consent.

Contact form

If you send us enquiries using the contact form, we will store the information you provide in the enquiry form, including the contact data you provide there, for the purpose of processing the enquiry and in the event of follow-up questions. We will not pass on this data without your consent.

The processing of this data is based on Art. 6 para. 1 lit. b DSGVO, insofar as your request is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR), provided that the request was made.

We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Any mandatory statutory provisions, especially those regarding mandatory data retention periods, remain unaffected by this provision.

Request by email or phone

If you contact us by email or telephone, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We will not pass on this data without your consent.

The processing of this data is based on Art. 6 para. 1 lit. b GDPR, provided that your request is related to the execution of a contract or is required for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 para. 1 lit. f DSGVO) or on your consent (Art. 6 para. 1 lit. a DSGVO), provided that this has been requested.

The data you send to us via contact requests will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g. after we have finished processing your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

5. Analysis tools and advertising, plug-ins and tools

WordPress / JetPack statistics

This website uses ‘JetPack-Statistik’, a WordPress plug-in, to statistically evaluate visitor access. JetPack statistics uses technologies that enable the recognition of the user for the purpose of analysing user behaviour (e.g. cookies or device fingerprinting). WordPress Statistics collects, for analysis, log files (referrer, IP address, browser, etc.), the origin of website visitors (country, city) and what actions they have taken on the site (e.g. clicks, views, downloads). The information collected in this way about the use of this website is stored on servers in the United States. Your IP address will be anonymised after processing and before storage.

This analysis tool is used on the basis of Art. 6 Sect. 1 lit. f GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and its advertising. If a corresponding consent has been requested (e.g. consent to store cookies), the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; consent can be revoked at any time.

6. Newsletter

Newsletter Data

If you wish to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the

newsletter. Further data will not be collected or will only be collected on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.

The processing of the data entered into the newsletter registration form is carried out exclusively on the basis of your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke your consent to the storage of the data, the e-mail address and their use for sending the newsletter at any time, for example via the ‘unsubscribe’ link in the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.

The data you provide us with for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose for which it was stored no longer applies. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6 para. 1 lit. f DSGVO.

After you have been removed from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 sec. 1 lit. f GDPR). The storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

Google Web Fonts (local hosting)

This site uses so-called web fonts provided by Google to ensure fonts are displayed consistently. Google Fonts are installed locally. This does not involve a connection to Google servers.

Further information about handling user data, can be found at  https://developers.google.com/fonts/faq and in Google’s privacy policy: https://policies.google.com/privacy?hl=de.

Google Maps

This site uses the mapping service Google Maps and/or Google Maps Links. The provider is Google Ireland Limited (‘Google’), Gordon House, Barrow Street, Dublin 4, Ireland.

To use the Google Maps features, it is necessary to store your IP address. This information is generally transmitted to and stored by Google on servers in the United States. The provider of this site has no influence on this data transfer. If Google Maps is activated, Google may use Google Web Fonts for the purpose of a uniform display of fonts. When you access Google Maps, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.

The use of Google Maps is in the interest of making our website appealing and to facilitate the location of places specified by us on the website. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO. If a corresponding agreement has been requested, the processing is carried out exclusively on the basis of Art. 6 (1) (a) DSGVO; the agreement can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/gdprcontrollerterms/

and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.

For more information about how user data is handled, please refer to Google’s privacy policy:

https://policies.google.com/privacy?hl=de.

 

Google Analytics

This website uses Google Analytics, a web analysis service provided by Google Inc. (‘Google’).

Google Analytics uses cookies, which are text files placed on your computer, to help the website analyse how users use the site. Detailed information about cookies and Google Analytics can be found at the following link: https://policies.google.com/technologies/cookies?hl=en-US . By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out in the link. This website uses Google Analytics reports for demographic features only, which use data from Google’s interest-based advertising. This data cannot be traced back to a specific person and can be disabled at any time through the ad settings.

You can prevent the installation of cookies by adjusting your browser software accordingly; however, in this case, you may not be able to use all the functions of this website to their full extent.

 

Google reCAPTCHA

 

We use ‘Google reCAPTCHA’ (hereinafter ‘reCAPTCHA’) on this website. The provider is Google Ireland Limited (‘Google’), Gordon House, Barrow Street, Dublin 4, Ireland.

The purpose of reCAPTCHA is to determine whether data entered on this website (e.g. on a contact form) is being provided by a human or by an automated program. To do this, reCAPTCHA analyses the behaviour of the website visitor based on various characteristics. This analysis starts automatically as soon as the visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, time the website visitor spent on the website, or mouse movements made by the user). The data collected during the analysis will be forwarded to Google.

The reCAPTCHA analyses take place completely in the background. Website visitors are not advised that an analysis is taking place.

The data is stored and analysed on the basis of Art. 6 Sect. 1 lit. f GDPR. The website operator has a legitimate interest in protecting the operator’s web offerings against abusive automated spying and against SPAM. If a corresponding agreement has been requested, the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

For more information about Google reCAPTCHA, please refer to the Google Privacy Policy and Terms of Use at the following links:

https://policies.google.com/privacy?hl=de und https://policies.google.com/terms?hl=de 

 

Social media buttons/links

 

This website contains social media buttons (links) for the social network Facebook and Instagram. These are operated exclusively by these networks themselves, USA (Meta). The buttons and/or links are recognisable on the website by the Facebook and/or Instagram logo or the addition ‘Like’. This forwards the information that you have visited our website to Meta. If you are logged into Facebook and/or Instagram via your personal user account while visiting our website, the respective network can assign the website visit to this account. Through interaction, e.g. by clicking the ‘Like’ button or leaving a comment, this corresponding information is transmitted directly to Meta and stored there. If you wish to prevent such data transmission, you must log out of your Facebook/Instagram account before visiting our website and you should not use the ‘Like’ and/or ‘Share’ functions on this website for posts and/or content if they are available. The purpose and scope of data collection by Meta, as well as the further processing and use of your data there, and your rights and setting options for protecting your privacy, can be found in the following guidelines from Meta (Facebook / Instagram) at the following link: https://de-de.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

Furthermore, this website uses the meta pixel. This is used for analysis data and stores user behaviour. We use the collected data exclusively to constantly improve and optimise the user-friendliness of the website and, if necessary, for social media advertisements where there is a reference (button/link) to this website. All detailed information about the meta pixel can be found at the following link:

https://de-de.facebook.com/business/help/742478679120153?id=1205376682832142

 

Further information can be found below:

META

We use Meta’s social media channels (Facebook & Instagram) in enhanced privacy mode. According to Meta, this mode ensures that Meta does not store any information about visitors to this website before they click on Meta links. However, the enhanced privacy mode does not necessarily prevent data from being passed on to Meta partners. For example, Meta establishes a connection to the Meta DoubleClick network regardless of whether you like, comment on or similar on the website. As soon as you click on one of the above links, a connection to the Meta servers is established. This tells the Meta server which of our pages you have visited. If you are logged into your Meta account (Facebook & Instagram), you enable Meta to assign your surfing behaviour directly to your personal profile. You can prevent this by logging out of your account before visiting our site and not clicking on any of the Meta links.