PRIVACY POLICY

General, Kim Cupping OÜ
Thank you for reading this document. We like to inform you how your (personal) data are processed and/or used by us. In this way, we fulfill our obligations under the General Data Protection Regulation (AVG) and the Telecommunications Act.

This  statement applies exclusively to the services of Kim Cupping OÜ. Therefore, please be aware that we are not responsible for the privacy and/or cookie policies of any listed other organizations and companies on the www.transformationalcupping.com website (hereinafter, the Website).

Kim Cupping OÜ is located in Talinn, Estonia and is registered there under number EE102368747. Do you have questions about privacy and the protection of your  (personal) data? If so, please contact us at kim@kimcupping.com.

Use (personal) data
On the website you can leave your (company) (personal) data. Also as a (possible future) customer, we collect some of your (personal) data. It is good that you are aware of what will be done with this (personal) data, what rights you have and how you can indicate your wishes regarding your (personal) data.

We respect the privacy of all our customers, stakeholders and also of the users of the website. This means that the (personal) data we receive from you will be kept confidential so that it does not simply fall into the wrong hands. It sometimes happens that your (personal) data is shared with others, because they support us in our business operations. Consider the bank or hosting party, for example.

Personal data we may collect.
Below you will find an overview of the (personal) data we may process about you:
o your first and/or last name;
o Your address and/or post office box information;
o your company name & Chamber of Commerce number;
o your e-mail address and e-mail messages;
o your payment information;
o your date of birth;
o Your social media account names;
o your responses on social media;

The above information you gave yourself or can be inferred from public records or social media.

Why is processing personal data necessary?
Processing personal data is not just allowed. For this, we must have set goals, and so we did. For example, we may process personal data about you because you provide this personal data yourself (for example, by completing the contact form). Those purposes of the aforementioned processing of personal data we collect must be justified. The AVG therefore establishes six bases:
1. the public interest;
2. legitimate interest;
3. vital interests;
4. on an agreement basis;
5. based on a legal duty;
6. by consent.

Privacy&cookie statement
Kim Cupping OÜ
Version 1.2. Aug. 10, 2023

Special and/or sensitive personal data
We do not process sensitive personal data of customers, data subjects or website visitors other than as indicated in this statement. We do not intend to collect data on website visitors who are under the age of 18, unless they have parental or guardian consent. However, we cannot always verify that a visitor is over 18. If you are convinced that we have collected personal information about a minor without consent, please contact us and we will delete this information. We do collect your health information in some cases. These are special personal data. We need these to form a good picture of your symptoms and adjust treatment accordingly. You gave permission for this.

How long your data is kept
We do not keep your personal data for longer than is strictly necessary to fulfill the purposes for which the data is collected. We use the following retention periods:

Sharing data with third parties/others
Your data will not be sold to third parties and your information will only be provided if this is necessary for the execution of the agreement with you, because you have given your consent or to comply with a legal obligation. With companies that process data on our behalf (processors), we conclude a processor agreement in any case to ensure the same level of security and confidentiality of your data. However, we remain responsible for these processing operations. With third parties who are themselves responsible for processing (processors), we do not need to enter into an agreement.

We share personal data with the following third parties:

Third country transfers
We try to process personal data as much as possible within the EEA, but sometimes we cannot avoid using services from outside the EEA. These companies are located in an appropriate country designated by the European Commission. A processor agreement is in place with all processors, inside and outside the EEA. In any event, the Parties adhere to the “Privacy Shield principles” and are members of the U.S. Department of Commerce’s Privacy Shield program. This means that there is an adequate level of protection for the processing of any personal data.

Your right to access, modify or delete data
You have the right to see, correct or delete your personal data. Such requests can be emailed to kim@kimcupping.com. We will respond to your request in that case as soon as possible, but in any case within one month. If your request is disproportionate or very specific, the deadline can be extended by 2 months. Your rights to withdraw, object and data portability You have the right to withdraw your consent, if any, to data processing or object to the processing of your personal data by me and you have the right to data portability. That means you can make a request to send your personal data in a computer file to you or another organization named by you.

Secure
We take the protection of your data seriously. Therefore, we take adequate and appropriate measures to counter , for example, abuse, loss, unauthorized access, unwanted disclosure and unauthorized modification, by physical, administrative, organizational and technical measures, among others. No physical copies of your personal data will be made. For example, the website uses a reliable SSL Certificate to ensure that your personal data does not fall into the wrong hands. It also means that your connection to the website is private. You can tell this by the address bar “https” and the padlock in the address bar.

Furthermore, we always use only known secure Wi-Fi networks, unless this is not possible for weighty reasons. Website security is updated regularly and there is an anti-virus system on incoming and outgoing emails. The number of devices that can access your data will be limited to only those needed. These are a laptop and smartphone with login security by password and/or access code and/or fingerprint. In addition, the systems used are also all password and/or access code and/or fingerprint protected. No proper security or misuse of your data? If you have the impression that your data is not properly secured or there are indications of misuse, or if you would like more information about personal data security, please contact us at kim@kimcupping.com.

Your right to file a complaint
We would like to remind you that you have the possibility to file a complaint with the national supervisory authority, if you believe that we are not complying with the privacy regulations referred to in the AVG. The national regulator is the Personal Data Authority. You can file a complaint here .  

Changes
The texts of the website may be modified at any time due to ongoing developments. This also applies to this privacy statement. This version is dated Aug. 10, 2023, and if there are changes to the privacy statement, we always post the latest version of it on the website. If changes directly affect you, we will inform you directly as much as possible.

Cookies
The website uses several cookies. By having this cookie statement, we not only comply with the obligations of the Telecommunications Act & Cookie Law (future e-Privacy Regulation), but you also know exactly how to deal with these cookies.

What is a cookie
A cookie is a small text file that is stored on your computer, tablet or smartphone when you first visit the website. Cookies, in particular, ensure that the website works properly. For example, cookies remember your settings and cookies can also be used to optimize the website. Functional and social media related tracking cookies. The website uses functional cookies and social media related tracking cookies that do not invade your privacy. When functional cookies are set, there is no need to seek your consent. When setting the social media related tracking cookies, we ask for your permission. The website does not otherwise use other cookies.

Permanent cookie
A permanent cookie allows the website to recognize you when you visit the website again. This is a so-called functional cookie. This allows the website to be set specifically to your preferences. Even if you have given permission for cookies to be placed, the website can remember this through a cookie. This saves you from having to repeat your preferences every time, thus saving you time and allowing for a more enjoyable use of the website. Permanent cookies can be deleted through your browser settings.

Session cookie
A session cookie allows us to see which parts of the website you viewed with this visit. This is a so-called functional cookie. This allows the website to be set specifically to your preferences. This allows us to tailor our service as much as possible to visitors’ browsing behavior. These cookies are automatically deleted as soon as you close your web browser.

Social media related tracking cookie
The social media related tracking cookies such as the social media pixels, track website visits in order to build a profile of website visitors. They do this through the buttons Instagram and Facebook place on your device.

Google reCAPTCHA
In addition, the website uses Google reCAPTCHA. First, reCAPTCHA checks whether a cookie from Google has been previously placed on the computer. A cookie is then added to your browser and a full snapshot is taken of the browser window. Every pixel is captured in the process. For proper analysis, Google collects browser and user information and this includes:

• All cookies that Google has placed on your system in the past 6 months;

• How many mouse clicks you make (or tap if on a touch device) in the browser window;

• Your scrolling behavior 

• The CSS of the web page

• The system date and time;

• IP address;

• Whether you are currently logged into your Google account;

• The set language of your browser;

• All add-ons installed in your browser;

• All Javascript objects;

• The speed with which you fill out the form.
  

The information collected by Google is transferred to and stored by the parties on servers in the United States. They claim to adhere to “Privacy Shield principles” and are affiliated with the U.S. Department of Commerce’s Privacy Shield program. This implies (again) an adequate level of protection for the processing of any personal data. We have not allowed Google to use the information obtained through the website for other (Google) services. The retention period is 26 months and we have no control over it. You can read more about this in Google Analytics’ privacy policy.

Refusing, blocking and deleting cookies
You can reject cookies, you can block cookies and you can opt out of cookies. You do this by setting your Internet browser to stop storing cookies. You can always easily block and delete cookies via your Internet browser. You can also set your Internet browser to notify you when a cookie is placed. You can also specify that certain cookies should not be placed. For these options, check your browser’s help function. Because how you can adjust settings varies by browser. If necessary, consult your browser’s help function or click on one of the links below to go directly to your browser’s manual.

o Google Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform=Desktop&hl=nl
o Internet Explorer: https://support.microsoft.com/nl-nl/kb/278835
o Safari on smart phone: https://support.apple.com/nl-nl/HT201265
o Safari on Mac: https://support.apple.com/nl-be/guide/safari/sfri11471/mac

Please note that deleting cookies in your browser may affect the enjoyment of this website. So be aware that if you do not want cookies, we cannot guarantee that the website will work completely properly. You may lose some features of the site or even be unable to visit the site at all. In addition, refusing cookies also does not mean that you will no longer see ads at all. The
ads are then just no longer tailored to your interests and they may be repeated more often as a result. Some tracking cookies are set by third parties that, among other things, display advertisements to you through website tracking.

Unforeseen cookies
Cookies may also be set through the websites by others, of which we are not always aware. Come across unforeseen cookies that you can’t find in the overview? If so, let us know by email. You can also contact the third party directly and ask what cookies they set, what the reason for it is, what the cookie’s lifetime is and in what way they have guaranteed your privacy.

Opt-out
About the use of the above cookies, permission is requested on the website (where necessary). If you do not want your data tracked, we recommend that you do not consent (opt-out) or install privacy-enhancing browser plug-ins.

Changes
The texts of the website may be modified at any time due to ongoing developments. This also applies to this cookie statement. This version is from Aug. 10, 2023, and if there are any changes, we always post the latest version of this on the website.