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Our Data Privacy Notice

Hale Breathing in Stockholm Data Privacy Notice

Introduction

This Data Privacy Notice (this “Notice”) applies to Hale Breathing in Stockholm AB, with corporate ID number 559219-1893, (“Hale Breathing”, “us” or “we”) when we process personal data about you when you visit our website, inform you about our products and services, engage you as a new customer or business partner, or when you contact us for general queries.

When we refer to “personal data” in this Notice, we mean any information that directly or indirectly can identify you as a natural person and any other information that qualify as personal data under applicable data protection law, including the General Data Protection Regulation 2016/679 (the “GDPR”). Hale Breathing always aims to process personal data in accordance with the GDPR and other applicable national data protection law. For example, we will only process personal data set out herein if we have a legal ground to do so, and to the extent necessary to fulfil the purposes set out in this Notice.

For information about how we use cookies and similar technology, please see “Cookies” herein.

As explained in this Notice, we will under certain lawful circumstances transfer your personal data to third parties, and in some instances to a different country to the country in which you live or work. Such country may be located outside the EU/EEA. Please see “Transfer outside the EU/EEA” for further information below.

You have certain rights relating to how we process your personal data. You have the right to object to the processing of your personal data, to request access to and rectification of your personal data, to request restriction of the processing and erasure of your personal data, and to request data portability. Your rights, for example to object and/or delete personal data about you, will vary depending on the processing purpose and our legal ground for processing your data. Please see “What rights do I have as a registered person?” for further information and how to enforce your rights.

This Notice covers all personal data that you provide to us when you visit our website or otherwise and that is in any form processed, including personal data that is kept, stored, collected, transferred, disclosed or otherwise handled.

1. Personal data processed by us

We mainly process the following categories of personal data about you under this Notice:

Basic personal information: for example, contact information (name, postal address, email address, telephone number and date of birth).

Communications data: communications to and from us and related information stored or processed for example in our IT systems or in our email service and information collected on our website.

We must ask you to never provide any data to us that could be considered sensitive (for example health data, political and/or religious beliefs or biometric data) or information about criminal offences.

Our purposes for processing your personal data, wherefrom we receive your personal data, how long we save it and our legal grounds for the processing is disclosed in the “Data Processing Table” below.

2. To what categories of third parties will my personal data be disclosed to?

Group companies

Your personal data set out herein, depending on the purpose of the processing, may be transferred to our affiliates in order to fulfil our purposes with the processing described in this Notice.

Service providers

We use third party service providers (“Service Providers”), which perform certain services as requested by us that involve the processing of your personal data. Such services may include provision of communication systems (for example email system), IT systems and support, web booking systems, document management systems, accounting and invoicing services and website services.

Only personal data that is necessary for the fulfillment of the relevant and respective purpose will be provided to our Service Providers. A Service Provider must only process personal data to perform the specific services requested by us and will always be obliged, under a written agreement, to act in accordance with our instructions, to follow applicable law and to implement appropriate technical and organizational measures for the protection of your personal data.

Authorities and other data controllers

Personal data may be disclosed to relevant authorities (e.g. the police, courts and the tax authority) to fulfil legal obligations.

3. How we keep your personal data secure

Hale Breathing has taken necessary and appropriate technical and organizational measures to ensure adequate protection of your personal data. Access to your personal data is limited and only authorized Hale Breathing personnel have access to your personal data on a “need-to-know” basis, and have committed themselves to necessary confidentiality undertakings. In case we should receive personal data from you that we need to process for another purpose, we will inform you accordingly.

4. Transfer outside the EU/EEA

We always aim to process your personal data within the EU/EEA. However, in order to fulfil our purposes herein, personal data may be transferred to our Service Providers which may be established in or provide support functions from other countries. Such other countries may offer a lower level of protection for personal data than the country where you live. We only transfer your personal data if it is ensured that the personal data is adequately protected by the receiving parties in such countries and the transfer can be made under applicable law.

Adequate protection may typically be to impose on the receiving party contractual obligations, stipulating that such party maintains the same high level of privacy and data security as practiced by Hale Breathing, according to applicable law and the GDPR. Such safeguards are for example the EU Commissions Standard Contractual Clauses, which therefore imply lawful mechanisms for such third country transfer of personal data.

5. What rights do I have as a registered person?

You have several rights when it comes to our use of your personal data. A summary of these rights are set out below.

Please see further information on how you can make use of your rights under the section “How do I make use of my rights?” below. If you want to make use of your rights you can do so by sending an email to the email address in “Contact details” below. You can also use that email address if you have any questions.

Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data where the processing is based on the legal ground of public interest or when we base the processing on a legitimate interest. You also have the right to object to the processing for direct marketing purposes, including profiling.

If you lodge an objection, we will no longer process your personal data that we process based on a legitimate interest, unless we can demonstrate compelling and legitimate grounds for such processing which overrides your privacy interest or for the establishment, exercise or defence of legal claims. If you object to processing for direct marketing purposes, including profiling, we will immediately stop processing your personal data for that purpose.

Even if you object to certain processing, we may still continue such processing if permitted or obligated to do so under applicable legislation, for example to be able to fulfil legal requirements or to fulfil contractual obligations in relation to you.

Right to access and rectification

You always have the right to request access to your personal data. This includes the right to:
– be informed whether or not personal data about you is being processed;
– the type of personal data that is being processed; and
– the purpose of such processing.

You also have the right, upon request, to access information about any legitimate interest assessment we are required to conduct, when we process your personal data based on our legitimate interest.

Furthermore, you have the right to rectify or complete personal data if the personal data is inaccurate or incomplete. As soon as we become aware of any inaccurate personal data being processed, we will always rectify such personal data without undue delay and notify you accordingly.

Right to restriction

You have the right to request restriction of the processing of your personal data, if:
– you contest the accuracy of the personal data, and we must restrict the processing for a certain period to enable us to verify the accuracy of relevant data;
– the processing is unlawful and you oppose the erasure of the personal data but instead requests restriction of the use;
– the processing is no longer necessary for the purposes it was collected or otherwise processed as stipulated in the “Data Processing Table” in this Notice, but the personal data is required by you for the establishment, exercise or defence of a legal claim; or
– you have objected to processing pursuant to what is set out under the Section “right to object” above, and our verification of the legitimate grounds is pending.

Right to erasure

You may also request us to erase your personal data if, for example:
– the personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
– you object to the processing of your personal data, in accordance with the “right to object” as set out above, and we do not have an overriding legitimate interest;
– the processing is unlawful; or
– the personal data has to be erased to enable us to comply with a legal requirement.

If you have any questions about your right to erasure, please use the contact details stated below. However, please note that even if you request erasure of your personal data, we may still continue to process it if we have a legal ground to do so.

Right to data portability

If you request access to your personal data that you have provided to us yourself, and (i) the personal data is being processed automatically, and (ii) in accordance with a contract between you and us, you may request that the personal data is provided in a structured, commonly used and machine-readable format, and you may also request that the personal data is transmitted to another controller, if this is technically feasible.

6. How do I make use of my rights?

Please send an email to the relevant contact person, as specified below, if you want to make a request in relation to the processing of your personal data. Please note that we may contact you and ask you to confirm your identity to ensure that we do not disclose your personal data to any unauthorized person. We may ask you to specify your request before we perform any actions.

Once we have confirmed your identity, we will handle your request in accordance with applicable law. Please note that even if you object to certain processing of personal data, we may still continue the processing if permitted or required to do so by law, for example to enable us to fulfil legal requirements or to exercise, enforce of defend our business from legal claims.

You always have the right to lodge a complaint with the relevant authority in particular where you live, work or where an alleged infringement of the GDPR has occurred. The relevant data protection authority in each country can be found here. The competent data protection authority in Sweden is Datainspektionen.

7. Cookies

We are using so-called cookies and similar technology on our website to make the website function properly and in order to obtain information regarding visits on the website. We also use cookies in order to customise your user experience on our website and to conduct statistics.

According to applicable law, cookies may only be stored on your equipment and information may only be collected through cookies based on your consent, except for cookies that are strictly necessary in order to use our website. Thus, the purpose of this section is to provide you with necessary information regarding our use of cookies and the storage of such cookies on your device when you access our website. This to enable you to make a choice whether you wish to enable non-essential cookies to be placed on your device.

You may choose to avoid deployment of cookies on your device at any time, by adjusting your cookies settings in our cookie banner or through your web browser.

What are cookies?

A cookie is a small text file which is stored on your device and which contains information. The information stored is typically history of your movements within the website you have visited. Cookies are used to track such movements, but also to help you resume where you left off, remember your registered login, theme selection, preferences, and other customization functions.

There are “persistent” types of cookies and “session” cookies. Persistent cookies consist of a text file sent by a web server to a web browser and will be saved on your device until the cookie expires according to its expiration date, or removed by you before that date. The other type of cookie, a session cookie, is a temporary cookie and will be set when you open a web browser on your device and will expire when you close the web browser.

Cookies can also be divided into “first party” and “third party” cookies. First party cookies are placed by our website on your device when you enter our website, while third party cookies are not placed by our website, but by other companies on other websites (such as advertising companies), which are used to assemble your movements on other websites in order to, for example, provide targeted advertising based on such movements on the current website you visit.

Please see below what cookies and similar technologies we use on this website.

What cookies do we use?

We use the following cookies for the following purposes:

Strictly necessary cookies:
Strictly necessary cookies are necessary for our website to function properly. These cookies do not collect any personal information. If you disable such strictly necessary cookies through your browser, you will not be able to use all the functions of the website. The strictly necessary cookies we use are [session / persistent] cookies and will expire after [time].

Performance/analysis cookies:
Performance/analysis cookies are used to make the experience more user-friendly on our website for visitors. Information from these cookies is also used for statistical purposes, such as to maintain statistics regarding the use of the website and to optimise the use of the website.
We use Google Analytics cookies to measure how users interact with our website and content. Google Analytics cookies are persistent cookies and will expire after [time].

For more information about Google Analytics, please see below:
– Google ads preferences: https://adssettings.google.com/authenticated?hl=en
– Google privacy policy: https://policies.google.com/privacy?hl=en-GB&gl=uk
– To opt out of being tracked by Google Analytics visit http://tools.google.com/dlpage/gaoptout.

How can you avoid cookies?

When entering our website, you can always choose which non-essential cookies you want to enable in our cookie banner. Please note that strictly necessary cookies are necessary in order for you to use our website and if you disable such cookies, our website will not function properly.

You can also choose whether you wish to accept cookies in your web browser. By adjusting the web browser, you will avoid deployment of cookies on your device and you can also use your browser to delete cookies. The method used to block or delete cookies will depend on the web browser used, consult the “Help” menu in your web browser for instructions. Where you choose to allow us setting cookies on your device, we will collect information as stated above until you withdraw your consent, which can be done at any time by adjusting your cookie choices in our cookie banner or through your web browser.

To find out more about cookies, including how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org. If you have any questions regarding your choices around cookies, please contact us on the below contact details.

Cookies on third party websites

When using Hale Breathing’s services, you will be able to book a class through our Service Provider MINDBODY, Inc.’s website Mindbody Online. For more information about the cookies used by Mindbody Online, please see below:
– Mindbody privacy policy: https://company.mindbodyonline.com/legal/privacy-policy
– Mindbody cookie policy: https://company.mindbodyonline.com/legal/cookies-and-similar-technologies-policy

8. Updates to this Notice

In order to ensure that we comply with data protection law, this Notice may be changed by us at any time. We will publish any changes made.

Please notify us of any changes to the personal data relating to you to enable us to process personal data accurately and securely (see contact details below).

9. Contact details

If you have any questions about our processing of your personal data, or want to enforce your data subject rights as stated above, please contact us at the below contact details:

contact@hale.center

Data Processing Table

Personal data type and source

Purpose

Legal ground

Retention time or criteria

Basic personal information: for example, contact information (name, postal address, email address, telephone number and date of birth).

Source: Directly from you (collected from our website, face-to-face meetings, calls, email conversations and similar).

In order for us to provide our services to customers, including enforcing the general terms and conditions for the use of our services.

Performance of contract

The personal data is stored until the term of the contract.

In order for us to send relevant information about our services to customers, for example welcome e-mails, information on updates to the services etc.

To communicate with you and to respond to your questions.

Legitimate interest

The personal data is stored for 24 months from the contact with customer support.

In order for us to reach out and engage new clients and/or to engage new projects with existing clients.

The personal data is stored until the purpose is fulfilled with the processing, or until you have opted out from the processing, and will thereafter be deleted, unless we have another legal ground and purpose to process the personal data (which we will inform you about, in such case).

To market our products and services to you, including sending you our newsletters, press releases, updates, campaigns and/or offers (which you may opt-out to at any time).

Communications data: communications to and from us and related information stored or processed on our IT systems, email system or information collected on our website.

Source: Collected through our website or in our IT systems.

To communicate with you and to respond to your questions.

Legitimate interest

The personal data is stored for 24 months from the contact with customer support.

To market our products and services to you, including sending you our newsletters, press releases, updates, campaigns and/or offers (which you may opt-out to at any time).

The personal data is stored until the purpose is fulfilled with the processing, or until you have opted out from the processing, and will thereafter be deleted, unless we have another legal ground and purpose to process the personal data (which we will inform you about, in such case).

Legal claims and personal data: In terms of legal claims related to the above purposes, we will store the information in the table above in order to defend ourselves in or from claims and to be compliant with mandatory law for a period of maximum ten (10) years in terms of any claims. However, we will minimize such information and only store the information necessary to fulfil this purpose. The personal data will, after this purpose has been fulfilled, be deleted.

Latest update on 22 September 2020