DATA PROTECTION

Responsible body within the meaning of data protection laws, in particular the EU General Data Protection Regulation (GDPR), is:

Daniela van Westing

07609 Llucmajor

Majorca

Phone 34 677 814 790

E-Mail: daniela@better-together.es

It is generally possible to use the Better Together website without providing personal data. However, if a data subject wishes to use the special services of our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we usually obtain the consent of the data subject.

The processing of personal data such as the name, address, e-mail address or telephone number of a data subject is always carried out in accordance with the General Data Protection Regulation and Westing's country-specific data protection regulations that apply to Daniela van. With this privacy policy, our company would like to inform the public about the type, scope and purpose of the personal information we collect, use and process. In addition, data subjects will be informed of their rights under this data protection guideline.

As the data controller, Daniela van Westing has taken numerous technical and organizational measures to ensure the most comprehensive possible protection of the personal data processed via this website. Nevertheless, internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, every person concerned is free to provide us with personal data in an alternative way, for example by telephone.

1. Definitions

The data protection declaration is based on the terminology used by European legislators and legislators when adopting the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

In this data protection declaration we use the following terms, among others:

a) personal data

Personal data is all information that relates to an identified or identifiable natural person (hereinafter "data subject"). A natural person is viewed directly or indirectly as identifiable, in particular through the assignment to an identifier such as a name, an identification number, location data, an online identifier or one or more special features that express the physical, physiological, the genetic, mental, economic , cultural or social identity of this natural person can be identified.

b) the data subject

Affected persons are all identified or identifiable natural persons whose personal data are processed by the person responsible for processing.

c) Processing

Processing means any process or series of operations in connection with personal data, such as collecting, recording, organizing, organizing, storing, adapting or changing, reading out, querying, using, with or without the help of automated processes; Disclosure by filing, distribution or any other form of provision, reconciliation or association, restriction, erasure or destruction.

d) Restriction of processing

The restriction of processing is the identification of stored personal data with the aim of restricting their future processing.

e) Profilerstellung

Profiling is any type of automated processing of personal data in which such personal data is used to evaluate certain personal aspects of a natural person, in particular aspects of work performance, the economic situation, health, the personal person. To analyze or predict the preferences and interests, reliability, behavior, whereabouts or relocation of this natural person.

f) Pseudonymisierung

Pseudonymization is the processing of personal data so that personal data can no longer be assigned to a specific data subject without additional information, provided that this additional information is stored separately and is subject to technical and organizational measures to ensure that the personal data are not identified or an identifiable natural person.

g) controller or controller

The person responsible for the processing is the natural or legal person, authority, corporate body or corporate body that alone or jointly with others decides on the purposes and means of processing personal data. If the purposes and means of such processing are determined by Union law or the law of the member states, the person responsible for the processing or the specific criteria for his designation may be provided for in accordance with Union law or national law.

h) processor

A processor is a natural or legal person, an authority, a body or a body that processes personal data on behalf of the person responsible for the processing.

i) Recipient

The recipient is a natural or legal person, agency, agency or other institution to whom personal data is passed on, regardless of whether it is a third party or not. However, authorities that may receive personal data in connection with a specific mission under Union or national law are not considered beneficiaries.

j) third parties

Thirdly, it is a natural or legal person, an authority, a body or body other than the data subject, the controller, the processor and the persons who are under the direct responsibility of the controller or the processor Processing of personal data are authorized.

k) consent

Consent is a voluntary and unambiguous expression of will by the data subject in the form of a declaration or another unequivocal confirmation act, in which the data subject is declared that he or she consents to the processing of the personal data concerning him or her.

2. Name and address of the controller

The responsible person within the meaning of the General Data Protection Regulation, other data protection laws in the member states of the European Union and other provisions with a data protection character is:

Daniela van Westing

07609 Llucmajor

Majorca

Phone 34 677 814 790

E-Mail: daniela@better-together.es

3. Cookies

The Better Together website uses cookies. Cookies are text files that are saved and saved on a computer system via an internet browser. Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier for the cookie. It consists of a string of characters that can be used to assign the Internet pages and servers to the respective Internet browser in which the cookie was saved. In this way, visited websites and servers can distinguish the person's browser from other internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

By using cookies, Daniela van Westing can offer the users of this website more user-friendly services that would not be possible without the cookie setting.

A cookie can be used to optimize the information and offers on our website for the benefit of the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter their login information each time they visit the website, as this is done by the website and the cookie stored on the user's computer system. Another example is a shopping cart cookie in an online shop. The online shop remembers the items that a customer has placed in the virtual shopping cart via a cookie.

The person concerned can prevent the setting of cookies via our website at any time by setting the Internet browser used accordingly and thus permanently object to the setting of cookies. In addition, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common internet browsers. If the person concerned deactivates the setting of cookies in the internet browser used, not all functions of our website may be fully usable.

4. Gathering general data and information

The Better Together website collects a range of general data and information every time a data subject or an automated system accesses the website. These general data and information are stored in the server's log files. The (1) browser types and versions used, (2) the operating system used by the access system, (3) the website from which an access system accesses our website (so-called references), (4) the sub-websites accessed via (5 ) The date and time of access to the website, (6) an IP (Internet Protocol) address, (7) the internet service provider of the access system and (8) other similar data and information that can be accessed when our information technology systems are attacked.

Daniela van Westing does not draw any conclusions about the data subject when using these general data and information. Rather, this information is required to (1) correctly provide the content of our website, (2) optimize the content of our website and advertise it, (3) the continued functioning of our information technology systems and the technology of our website and (4) to provide law enforcement authorities with the necessary information for law enforcement in the event of a cyber attack. This anonymously collected data and information is therefore statistically and further evaluated by Daniela van Westing in order to increase data protection and data security in our company and ultimately to guarantee the best possible level of protection for the personal data processed by us. The anonymous data in the server log files are stored separately from all personal data provided by a data subject.

5. Registration on our website

The data subject has the option of registering on the controller's website by providing personal data. The personal data to be sent to the controller are derived from the respective input mask used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the person responsible for processing and for his own purposes. The person responsible for processing can arrange for the transfer to be made to one or more processors, for example to a parcel service that only uses the personal data for internal use attributable to the person responsible for processing. By registering on the website of the controller, the IP address assigned by the Internet service provider (ISP) to the person concerned as well as the date and time of registration are also saved. This data is stored against the background that this is the only way to prevent misuse of our services, and this data may be used to clarify any violations that have been committed. In this regard, the storage of this data is necessary in order to secure the control. This data will not be passed on to third parties as long as there is no legal disclosure obligation or the passing on of the law enforcement authorities. By registering the data subject who voluntarily provides personal data, the controller serves to provide the data subject with content or services that, due to the nature of the case, can only be offered to registered users. Registered persons can change the personal data provided during registration at any time or delete them completely from the database of the person responsible for processing. The person responsible for processing must inform each data subject at any time upon request which personal data is stored about the data subject. In addition, the person responsible for processing corrects or deletes personal data upon request or notification of the person concerned, provided this does not conflict with the statutory retention requirements. All data subjects of the data controller are available to the data subject as contact persons in this context.

6. Subscribe to our newsletter

On the Better Together website, users have the opportunity to subscribe to our company's newsletter. Which personal data is transmitted to the data controller when the newsletter is ordered results from the input mask used for this purpose.

Daniela van Westing informs his customers and business partners about company offers at regular intervals via newsletter. Our company's newsletter can only be received by the person concerned if (1) the person concerned has a valid email address and (2) the person concerned registers for the newsletter. For legal reasons, a confirmation e-mail is sent to the e-mail address that a data subject entered for the first time for sending the newsletter using the double opt-in procedure. This confirmation email is used to check whether the owner of the email address, as the person concerned, has authorized the receipt of the newsletter.

When registering for the newsletter, we also save the IP address of the computer system that was used by the person concerned at the time of registration, as well as the date and time of registration assigned by the Internet service provider (ISP). The collection of this data is necessary in order to be able to trace the (possible) misuse of the e-mail address of the data subject at a later point in time, and therefore offers the legal guarantees for the person responsible for the processing.

The personal data collected when registering for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter can be informed by email if this is necessary for the operation of the newsletter service or for registration, as may be the case with changes to the newsletter offer or technical changes. The personal data collected as part of the newsletter service will not be passed on to third parties. The person concerned can cancel the subscription to our newsletter at any time. The consent to the storage of personal data that the data subject has given us for the newsletter can be revoked at any time. There is a corresponding link in every newsletter to revoke your consent. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller or to inform the controller in another way.

7. Newsletter-Tracking

Daniela van Westing's newsletters contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in the emails that are sent in HTML format to enable the recording of log files and the analysis of log files. This enables a statistical evaluation of the success or failure of online marketing campaigns. Based on the embedded pixel, Daniela van Westing can see if and when an e-mail was opened by a data subject and which links in the e-mail were called up by the data subject.

Such personal data, which is collected via the tracking pixels contained in the newsletters, is stored and evaluated by the controller in order to optimize the delivery of the newsletter and to better adapt the content of future newsletters to the interests of the person concerned. These personal data will not be passed on to third parties. Affected persons are entitled at any time to revoke the separate declaration of consent via the double opt-in procedure. After the revocation, this personal data will be deleted by the person responsible. Daniela van Westing automatically suggests unsubscribing from receiving the newsletter as a revocation.

8. Contact through the website

Due to legal requirements, the Better Together website contains information that enables quick electronic contact with our company and direct communication with us. This also includes a general so-called e-mail address (e-mail address). If a data subject contacts the person responsible for data processing by email or using a contact form, the personal data provided by the data subject will be automatically saved. These personal data, which a data subject voluntarily provides to the person responsible for processing, are stored for the purpose of processing or contacting the data subject. This personal data is not passed on to third parties.

9. Comments on the blog on the website

Daniela van Westing offers users the opportunity to leave individual comments on individual blog posts in a blog on the website of the data controller. A blog is a web-based, usually publicly accessible portal in which one or more people, known as bloggers or web bloggers, can publish articles or write down thoughts in so-called blog posts. The blog posts can usually be commented on by third parties. If a data subject leaves a comment on the blog published on this website, not only the comments left by the person concerned, but also information about the time the comment was entered and the user name (pseudonym) selected by the person concerned are saved and published. In addition, the IP address assigned to the person concerned by the Internet Service Provider (ISP) is logged. The IP address is stored for security reasons and in the event that the person concerned violates the rights of third parties or publishes illegal content by submitting a comment. The storage of this personal data is therefore in the own interest of the person responsible for the processing, so that it can be excused in the event of a violation of the law. There is no transfer of this personal data to third parties, unless such a transfer is not required by law or for the legal defense of the person responsible for the processing.

10. Routine deletion and blocking of personal data

The person responsible for the processing processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of the storage or, if this is prescribed by the European legislator and other legislators in laws or regulations, that of the Processing controller.

If the storage purpose is omitted or a storage period prescribed in European directives and ordinances or another relevant legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

11. Rights of the data subject

a) Right to confirmation

Each data subject has the right, as granted by the European Management and Regulatory Authority, to request the controller to confirm whether personal data concerning them will be processed. If a data subject wishes to exercise this right to confirmation, he or she can contact an employee of the controller at any time.

b) Right to information

Any person who is affected by the processing of personal data has the right from the European legislator and the legislator at any time to receive free information about the personal data stored about them and a copy of this information from the person responsible for the processing. In addition, the European legislator and the European regulatory authority have made the following information available to the data subject:

the processing purposes

the categories of personal data processed

the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations

if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration

the existence of a right to correction or deletion of the personal data concerning you or to the restriction of processing by the person responsible for the processing or a right to object to such processing

the existence of a legal remedy with a supervisory authority

if the personal data are not collected from the data subject: All available information on the origin of the data

the existence of automated decision-making including profiling in accordance with Article 22 Paragraphs 1 and 4 of the GDPR and - at least in these cases - meaningful information about the logic as well as the scope and intended effects of such processing on the data subject

In addition, the data subject has a right to information as to whether personal data has been transmitted to a third country or to an international organization. If this is the case, the data subject has the right to receive information about the relevant guarantees in connection with the transfer.

If a data subject wishes to make use of this right to information, he or she can contact an employee of the controller at any time.

c) Right to rectification

Every person affected by the processing of personal data has the right granted by the European directive and regulatory authority to request the immediate correction of incorrect personal data. In addition, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing.

If a data subject wishes to exercise this right to correction, he or she can contact an employee of the controller at any time.

d) Right of withdrawal (right to be forgotten)

Every person affected by the processing of personal data has the right granted by the European directives and regulatory authorities to request the controller to delete the personal data concerning them immediately, provided that one of the following reasons is met and the processing is not is required:

The personal data were collected or otherwise processed for purposes for which they are no longer required.

The data subject withdraws the consent on which the processing was based on Article 6 (1) (a) of the GDPR or Article 9 (2) (a) of the GDPR and has no other legal basis for the processing.

According to Art. 21 Paragraph 1 of the GDPR, the data subject objects to the processing, and there are no legitimate reasons for the processing, or the data subject objects to the procedure according to Art. 21 (2) GDPR processing.

The personal data was processed unlawfully.

The deletion of personal data is necessary in order to fulfill a legal obligation under Union or national law to which the controller is subject.

The personal data was collected in connection with services of the information society, which in accordance with Art. 8 Para. 1 GDPR.

If one of the above-mentioned reasons applies and a data subject wishes to have the personal data stored by Daniela van Westing deleted, he or she can contact an employee of the controller at any time. Daniela van Westing will ensure that the deletion request is met immediately.

If the personal data has been published by Daniela van Westing and our company is responsible for the deletion of personal data in accordance with Art. 17 Para. 1 GDPR, Daniela van Westing will take suitable, including technical measures, taking into account the available technology and the implementation costs to inform other data controllers who process the published personal data that the data subject has requested the deletion of all links to these personal data or copies or replications of such personal data from these other data controllers, provided that the processing does not is required. Daniela van Westing will arrange the necessary in individual cases.

e) Right to restriction of processing

Any person affected by the processing of personal data has the right granted by the European directive and regulatory authority to require the controller to restrict the processing if one of the following conditions applies:

The data subject disputes the correctness of the personal data for a period of time that enables the responsible person to check the correctness of the personal data.

The processing is unlawful, the person concerned refuses to delete the personal data and instead requests that the use of personal data be restricted.

The person responsible for processing no longer needs the personal data for processing purposes, but the data subject requests that he assert, exercise or defend legal claims.

The person concerned has objections to the processing in accordance with Art. 21 para. 1 GDPR and it is not yet clear whether the legitimate reasons of the person responsible outweigh those of the person concerned.

If one of the above conditions is met and a data subject wishes to request that the personal data stored by Daniela van Westing be restricted, he or she can contact an employee of the controller at any time. Daniela van Westing will initiate the restriction of processing.

f) data portability

Every person affected by the processing of personal data has the right granted by the European management and regulatory authority to transfer the personal data that concern them to a person responsible for the processing of the data subject in a structured, shared and machine-readable format To make available . It also has the right to pass this data on to another responsible person without hindrance by the person responsible for the processing to whom the personal data was transmitted, provided that the processing is based on the consent in accordance with Art. 6 (1) (a) GDPR or Art. 9 Para. 2 (a) of the GDPR or a contract according to Art. 6 (1) (b) of the GDPR and automated processing, unless the processing is necessary for the fulfillment of a task of public interest or for the exercise of the official authority assigned to the controller.

In addition, when exercising their right to data portability in accordance with Article 20 (1) of the GDPR, the data subject has the right to have the personal data transmitted directly from one person responsible for processing to another, provided that this is technically feasible and if this is not the case is the rights and freedoms of others.

In order to assert the right to data portability, the data subject can contact Daniela van Westing at any time.

g) Right to object

Every person who is affected by the processing of personal data has, for reasons that arise from their particular situation, the right at any time to allow the processing of personal data in accordance with Article 6 Paragraph 1 by the European Directive and regulatory authority. e) or f The GDPR objects. This also applies to the creation of profiles in accordance with these provisions. In the event of an objection, Daniela van Westing will no longer process the personal data unless we can demonstrate compelling legitimate reasons for the processing that outweigh the interests, rights and freedoms of the data subject, or the processing serves the purpose of claiming, Exercise or defense of legal claims. If Daniela van Westing processes personal data in order to operate direct mail, the data subject has the right to object to the processing of personal data for the purpose of this advertising at any time. This also applies to the creation of a profile insofar as it is associated with such direct advertising. If the data subject objects to processing for direct marketing purposes, Daniela van Westing will no longer process the personal data for these purposes.

In addition, for reasons that arise from their particular situation, the data subject has the right to object to the processing of personal data concerning him or her for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 (1) of the GDPR, unless such processing is necessary to fulfill a task of public interest.

The data subject can contact Daniela van Westing directly to exercise the right of objection. Regardless of Directive 2002/58 / EC, the data subject is free to exercise his or her right of objection through automated procedures using technical specifications when using information society services.

h) Automated decisions in individual cases including profiling

Every person who is affected by the processing of personal data has the right, in accordance with the European legislature and the legislature, not to be subject to a decision that is based solely on automated processing, including profiling, that has legal effects on them, or in a similar way affects it significantly; unless the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the data controller or (2) is based on the legal provisions of the Union or of the Member States to which the data controller is subject , permissible, and these legal provisions provide for suitable measures to be taken to safeguard the rights and freedoms and legitimate interests of the data subject; or (3) with the express consent of the data subject.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the data controller, or (2) it is made with the data subject's express consent, Daniela van Westing takes appropriate measures to safeguard the rights , Freedoms and legitimate interests of the data subject, including at least the right to obtain the intervention of a person by the controller, to express their own position and to contest the decision.

If the data subject wants to rely on automated decision-making rights, he or she can contact an employee of the controller at any time.

i) Right to withdraw consent under data protection law

Any person affected by the processing of personal data has the right granted by the European directive and regulatory authority to withdraw consent to the processing of personal data at any time.

If the data subject wishes to assert his or her right to withdraw consent, he or she can contact an employee of the controller at any time.

12. Legal basis for processing

Arts. 6 I lit it. A GDPR serves our company as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary in order to fulfill a contract to which the data subject is involved, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of other services or consideration, the processing is carried out on a basis on Art. 6 I lit. b GDPR. The same applies to processing operations that are required to carry out pre-contractual measures, for example when inquiring about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as the fulfillment of tax obligations, the processing is based on Art. 6 I lit up. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor to our premises were injured and their name, age, health insurance or other important information had to be passed on to a doctor, hospital or other third party. Then the processing would be based on type. 6 I lit it. d GDPR are based. Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that do not fall under one of the legal bases mentioned above are based on this legal basis if processing is necessary to safeguard the legitimate interests of our company or a third party, unless the interests, fundamental rights and freedoms of the data subject have priority . Such processing operations are particularly permissible because they have been expressly mentioned by the European legislator. In this context, the view was taken that a legitimate interest could be assumed if the data subject is a customer of the controller (recital 47, second sentence, DS-BER).

13. Qualifying interests in the processing that are being pursued by the controller or a third party

If the processing of personal data is based on Article 6 I lit.f DS-GMO is our legitimate interest in running our business for the benefit of all our employees and our shareholders.

14. Duration for which the personal data will be stored

The respective statutory retention period is the criterion for the duration of the storage of personal data. After the deadline has expired, the relevant data is routinely deleted if it is no longer required for contract fulfillment or contract initiation.

15. legal or contractual provisions for the provision of personal data; Necessity for the conclusion of a contract; Obligation of the data subject to provide personal data; possible consequences of non-supply

We make it clear that the provision of personal data is partly required by law (e.g. tax regulations) or can result from contractual agreements (e.g. information on the contractor). Sometimes it may be necessary for a contract to be concluded that a data subject provides us with personal data that we then have to process. For example, the data subject must provide us with personal data when our company concludes a contract with them. If the personal data is not provided, the contract cannot be concluded with the person concerned. Before personal data is provided by the person concerned, the person concerned must contact one of our employees. Our employee will inform the individual on a case-by-case basis whether the provision of personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what this would do for the non-provision of the personal data traced back.

16. Existence of automated decision-making

As a responsible company, we do not make automatic decisions or profile creation.

This data protection guideline was created by the data protection officer of the data protection officer in cooperation with RC GmbH, the recycling of used notebooks and the file sharing lawyers from WBS-LAW. This privacy policy is translated via Google Translate.