Privacy policy | Dōjō Feilen

Courtesy translation. In the event of any discrepancy, the Spanish version prevails.

Through this notice, Michelle Feilen Rigol informs users of the website www.aikifeilen.org, in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation), Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights, and other applicable legislation, of her personal data protection policy, so that users may decide expressly, freely and voluntarily whether to provide Michelle Feilen Rigol with the personal data requested of them when requesting information or contracting the various services offered in the field of organising, managing and teaching sessions and courses in yoga, jiu-jitsu, martial arts, capoeira, fencing and other related disciplines.

Unless specifically stated otherwise, all data requested on the form or similar document must be completed truthfully, accurately, completely and up to date. Otherwise, Michelle Feilen Rigol may, depending on the case, decline to register the user or refuse the specific service requested. All data provided by the user/data subject will be processed in accordance with the details set out below.

Information on the processing of personal data

Data controller: Michelle Feilen Rigol, with address at C/Xifré, 44-46, ground floor, 08026 Barcelona, tax ID (NIF) 38136358N. Contact email: dojofeilen@gmail.com.

Purpose of processing

All data provided will be processed for the following purposes:

To respond to requests made by the data subject.
To maintain any relationship that may be established.
To manage, administer, inform about, provide and improve the services the data subject decides to contract.
Commercial communications relating to our products and services.

The personal data provided will be kept for as long as the business relationship lasts, unless the data subject requests its erasure, or for as long as it is necessary for the purposes of processing. Data will not be destroyed where a legal provision requires it to be kept; in that case it will be blocked and kept solely at the disposal of public authorities, judges and courts, to deal with any liability arising from the processing, for the applicable limitation period.

No automated decision-making, including profiling, is currently carried out on the basis of your personal data. Should such automated decisions be made in the future, your prior consent will be requested.

Legal basis for processing

All processing of your personal data has been consented to by you in advance and expressly. Before giving your consent, you are informed of all the matters required by law so that you can give informed consent.

You may withdraw this consent at any time as detailed later in this document.

Recipients, disclosures and transfers of data

Your data will not be disclosed to third parties except where essential to provide the service or where required by law.

Likewise, your data will not be transferred to countries outside the European Union unless this is essential to fulfil the purposes and you authorise it in advance and expressly.

Michelle Feilen Rigol uses the WhatsApp application to communicate with her clients in order to manage the classes and courses taught at the centre. The company that operates WhatsApp is based in the United States of America, which is considered an international transfer of data to a country that does not comply with European data protection regulations. For this reason, you must expressly authorise us to use this communication channel by ticking the corresponding box on the forms where your consent is requested. We recommend that you read WhatsApp’s privacy policy before continuing. If you wish to use WhatsApp to communicate with us, please note that Michelle Feilen Rigol is only responsible for, and guarantees the confidentiality, security and processing of, data in accordance with current legislation with respect to data collected directly from the user, and has no control over or responsibility for any processing or subsequent use that WhatsApp may make of the data provided through this channel.

Rights of data subjects

You may exercise the rights detailed below at any time by post to Michelle Feilen Rigol, C/Xifré, 44-46, ground floor, 08026 Barcelona, or by email to dojofeilen@gmail.com. The request must include your first name, surname and documentation proving the identity of the data subject or their legal representative, together with proof of representation, the specific request, an address for notifications, the date and signature of the applicant and any documents supporting the request. If the request does not meet these requirements, you will be asked to correct it.

The rights of data subjects are access, rectification, restriction, portability, objection and erasure, defined as follows:

Right of access

The data subject has the right to obtain from the controller confirmation as to whether or not personal data concerning them is being processed and, where that is the case, access to the personal data and the following information:

the purposes of the processing
the categories of personal data concerned
the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organisations
where possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period
the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject, or to object to such processing
the right to lodge a complaint with a supervisory authority
where the personal data is not collected from the data subject, any available information as to its source
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Where personal data is transferred to a third country or to an international organisation, the data subject has the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer. The controller will provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested, the information will be provided in a commonly used electronic form.

Right to rectification

The data subject has the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of a supplementary statement.

Right to erasure

The data subject has the right to obtain from the controller the erasure of personal data concerning them without undue delay, and the controller is obliged to erase personal data without undue delay where one of the following grounds applies:

the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed
the data subject withdraws the consent on which the processing is based according to Article 6(1)(a) or Article 9(2)(a), and there is no other legal ground for the processing
the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2)
the personal data has been unlawfully processed
the personal data has to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject
the personal data has been collected in relation to the offer of information society services referred to in Article 8(1)

Where the controller has made the personal data public and the data subject has exercised the right to erasure, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps to inform third parties processing that information of the request for erasure of the data and of any links to, or copies or replications of, that data.

This right is limited by other rights, such as the right to freedom of expression and information, by compliance with a legal obligation, or where there are reasons of public interest.

Right to restriction of processing

The data subject has the right to obtain from the controller restriction of processing where one of the following applies:

the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify its accuracy
the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of its use instead
the controller no longer needs the personal data for the purposes of the processing, but it is required by the data subject for the establishment, exercise or defence of legal claims
the data subject has objected to processing pursuant to Article 21(1) pending verification of whether the legitimate grounds of the controller override those of the data subject

Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or of a Member State.

A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction is lifted.

Right to object

The data subject has the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on Article 6(1)(e) or (f), including profiling based on those provisions.

The controller shall no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

Where personal data is processed for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning them for such marketing, including profiling to the extent that it is related to such direct marketing.

Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

Where personal data is processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to their particular situation, has the right to object to processing of personal data concerning them, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Right to data portability

The data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format, and has the right to transmit that data to another controller without hindrance from the controller to which the personal data has been provided, where:

the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a), or on a contract pursuant to Article 6(1)(b), and
the processing is carried out by automated means.

In exercising the right to data portability pursuant to paragraph 1, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible.

The exercise of the right referred to in paragraph 1 of this article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.

Withdrawal of consent

A data subject who has given consent to the processing of their personal data may withdraw it just as easily. Withdrawal of consent shall not affect the lawfulness of processing carried out before its withdrawal.

The data subject has the right to lodge a complaint with the competent supervisory authority.

Where personal data is to be further processed for different purposes, the controller will inform the data subject accordingly.

Security measures

The data controller states that it has adopted the technical and organisational measures necessary to guarantee the security of the data and prevent its alteration, loss, processing or unauthorised access, taking into account the state of technology, the nature of the data stored and the risks to which it is exposed, whether from human action or from the physical or natural environment.

The website www.aikifeilen.org contains links to other websites that may be of interest to the data subject. Michelle Feilen Rigol assumes no responsibility for these links and cannot guarantee compliance with adequate privacy policies; the data subject therefore accesses the content of those websites under the terms of use set out on them and under their sole responsibility.

If you have any questions, concerns or suggestions about our privacy policy, you can contact us by email at: dojofeilen@gmail.com