Privacy Policy
Responsible Entity
We are pleased about your visit to our website. First, we would like to introduce ourselves to you as the responsible entity within the meaning of data protection law:
Refugio dos Sonhos Lda.
represented by Managing Director Birgit Moukom
Cam. Fonte do Livramento No. 52
9125-065 Canico de Baixo/Madeira
Phone: (+351) 291 930 948
E-mail: birgit.moukom@ashoka-ayurveda.com
Data Protection Officer (only required if at least 10 employees regularly process personal data or if a data protection impact assessment is mandatory)
Carlos Camacho
Phone: (+351) 291 930 948
We would like to inform you, in accordance with our legal obligations, about the collection and use of your personal data.
General Information
When you use our website, personal data about you is collected. This can occur when you actively provide the data yourself – for example, your email address. Our system also automatically collects data from you, such as information about your visit to our website. This happens regardless of which device or software you use to access our website.
Any data you enter on our website is voluntary. There are no disadvantages for you if you do not provide your data. However, without certain data we are unable to provide services or conclude contracts. We will inform you accordingly of any mandatory information.
On this website, personal data of users is collected only within the scope of applicable data protection law, in particular the General Data Protection Regulation (GDPR). The technical terms used in this text are defined in Article 4 of the GDPR.
Under the GDPR, data processing is permitted in particular in the following three cases:
• pursuant to Articles 6(1)(a) and 7 GDPR, if you have given your consent to data processing by us; we will inform you in advance in this privacy policy and at the time of consent in accordance with Article 4(11) GDPR about the purpose and circumstances under which your data will be processed;
• pursuant to Article 6(1)(b) GDPR, if the processing of your personal data is necessary for the initiation, conclusion, or performance of a contractual relationship;
• pursuant to Article 6(1)(f) GDPR, if, after balancing interests, the processing is necessary to protect our legitimate interests; these include in particular our interests in analyzing, optimizing, and securing the offer on our website – especially the analysis of user behavior, the creation of profiles for advertising purposes, and the storage of access data as well as the use of third-party providers.
Inventory Data, Usage Data and Advertising
Inventory Data
We collect inventory data (e.g., name, address, and email address, and possibly services used) insofar as this is necessary for the establishment, content design, or modification of a contractual relationship between us and the user.
Usage Data
We also collect usage data (e.g., visits to the website, interest in products) in order to enable and bill for the use of the services on our website by the user.
A combination of usage data is carried out by us only insofar as this is necessary for billing purposes. Otherwise, we only create pseudonymous usage data and only insofar as you have not objected to this. You can object at any time by sending a message to the address stated in the imprint or to the responsible entity named in this privacy policy.
The legal basis for this data processing is, on the one hand, our legitimate interests pursuant to Article 6(1)(f) GDPR in analyzing the website and its use, and, where applicable, the statutory permission to store data in the context of the initiation of a contractual relationship pursuant to Article 6(1)(b) GDPR.
Furthermore, our provider stores information each time this website is used, so-called server log files, which are automatically transmitted by your browser. These include:
• your IP address
• type and version of your browser
• hostname
• time of visit
• the page from which you accessed our website
• name of the page accessed
• exact time of access
• amount of data transferred
These data are used only for statistical purposes and do not allow us to identify you as a user.
Advertising
Before sending advertising material, we will ask for your explicit consent in accordance with Article 4(11) GDPR, unless it concerns advertising for similar products that you have already purchased. This applies in particular when you give us consent to receive our newsletter or complete a contact form.
Consent
If we ask for your consent to process your data, we will inform you in clear and easily accessible language for which purposes you are granting your consent. Any consent requested by us is voluntary. Any benefit you wish to obtain by granting consent can also be obtained without consent—simply ask us.
For every consent, you have the right to revoke your consent to the processing of your personal data at any time. This can be done by informal notification, for example via our contact form, an email to the address stated in the imprint, or an unsubscribe link (if provided). Your revocation does not affect the lawfulness of the data processing carried out until that time.
Storage Duration
Your data will generally only be stored for as long as is necessary for the purpose of the respective data processing. Extended storage may be considered in particular if this is still necessary for legal enforcement by us or due to our other legitimate interests, or if we are legally obliged to retain your data (e.g., due to tax retention periods, which are generally 6 or even 10 years).
Disclosure to Third Parties
We dislike spam just as much as you do. Therefore, we will not pass on your data to third parties unless this is legally permitted.
Your data may be disclosed:
• if necessary for the performance of a contract and permitted under Article 6(1)(b) GDPR;
• on the basis of our legitimate interest in effective service provision pursuant to Article 6(1)(f) GDPR;
• if covered by your consent;
• if we are legally required to do so pursuant to Article 6(1)(c) GDPR by a state authority or public body.
Where your data is passed on to third parties, this is stated in this privacy policy.
Disclosure to Third Parties
We dislike spam just as much as you do. Therefore, we will not pass on your data to third parties unless this is legally permitted.
Your data may be disclosed:
• if necessary for the performance of a contract and permitted under Article 6(1)(b) GDPR;
• on the basis of our legitimate interest in effective service provision pursuant to Article 6(1)(f) GDPR;
• if covered by your consent;
• if we are legally required to do so pursuant to Article 6(1)(c) GDPR by a state authority or public body.
Where your data is passed on to third parties, this is stated in this privacy policy.
Rights of Users
Right of Access
You may request free information at any time about the personal data stored about you. To prevent misuse, identification of your person is required.
Deletion, Rectification, Restriction
You may request at any time the correction (including completion) of incorrect data, restriction of processing, or deletion of your data. This applies in particular if the purpose of processing no longer applies, required consent has been withdrawn and no other legal basis exists, or if our data processing is unlawful. We will then correct, block, or delete your personal data immediately within the scope of the law.
Objection
For the right to object to receiving advertising, our consent text applies:
You have the right at any time to revoke any consent given to us for the processing of your personal data. This can be done by informal notification, for example via our contact form, by email to the address stated in the imprint, or by an unsubscribe link (if provided). Your revocation does not affect the lawfulness of the data processing carried out until that time.
Data Portability
You may request the transfer of your stored personal data in machine-readable form.
Complaint
If you believe that our data processing violates your rights, you may lodge a complaint with the competent supervisory authority (a list of authorities can be found here).
Changes to the Privacy Policy
If changes to this privacy policy become necessary for legal or factual reasons, we will update this page accordingly. No changes will be made to the consent given by users.
Encryption of Data Entry
If you enter data on our website, whether via a contact form, during registration, login, or for payment purposes, the website on which you enter the data is encrypted. This prevents third parties from reading the data you enter. You can recognize encryption by the lock symbol in your browser and the fact that the address line begins with “https” instead of just “http”.
Contact Forms
If you fill out a contact form, send us a booking request, or send us an email or other electronic message, your information will be stored for processing the request, possible follow-up questions, and related further inquiries, and will be used only within the scope of the request.
The entry of your data is encrypted so that third parties cannot read your data during entry.
The basis for this storage is your consent pursuant to Article 6(1)(a) GDPR, which you grant by completing the contact form or submitting another inquiry. You may revoke this consent at any time by informal notification to us (e.g., via contact form or email). The legality of the data processing carried out until that time remains unaffected.
Your data will remain stored as long as processing of the inquiry requires it, in particular as long as storage is still necessary for contract performance/processing, legal enforcement by us, or our other legitimate interests, or we are legally obliged to retain your data (e.g., tax retention periods).
Newsletter
If you order the newsletter offered on our website, we will inform you in detail about the content, which data will be stored, and for what purpose it will be used. We will not pass on your data to third parties and will use it only for sending the newsletter.
We will only send the newsletter to you if you have given your prior consent. For this purpose, you will receive an email with a link and further information requesting your consent. By clicking this link, you agree to receive the newsletter and advertising from us.
The basis for storage is your consent pursuant to Article 6(1)(a) GDPR, which you give when registering for the newsletter. You may revoke this consent at any time by informal notification (e.g., via contact form, email, or unsubscribe link in each email). The legality of the data processing carried out until that time remains unaffected.
Since we are legally required to document your consent under the so-called double opt-in procedure, your newsletter registration, the sending of our consent email, and your consent by clicking the link are logged and stored with date, time, and your IP address.
For sending the newsletter, we use the provider MailChimp (Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA) based in the USA, within the framework of our legitimate interest in technically flawless customer communication and analysis.
Your data will therefore be transferred to the USA. MailChimp is registered under the Privacy Shield and committed to complying with EU data protection regulations. Further information about your rights can be found at:
http://ec.europa.eu/justice/data-protection/document/citizens-guide_en.pdf
In addition, we will explicitly ask you in our newsletter to consent to the transfer of data to MailChimp and to the USA. By clicking the link, you grant this consent, which you may revoke at any time. For handling your data at MailChimp, please refer to MailChimp’s privacy policy. MailChimp will use your data only for sending and analyzing the newsletter on our behalf. MailChimp may also use the data to improve its own service, but will not use it to contact you or pass it on to third parties.
The data used by MailChimp contains a “web beacon” that sends information to MailChimp when you open the newsletter and/or click a link contained in it. Information about your browser, location, and IP address is transmitted. This information is used to optimize our communication with you.
Our newsletter provider also uses this data, but only in pseudonymized form (i.e., without enabling identification), to analyze and optimize its own service. Your data will never be used to contact you.
Your data will remain stored as long as it is kept in our email list, storage is still necessary for legal enforcement by us or our other legitimate interests, or we are legally required to retain it.
Social Media Links
General Information
We provide links to our social media profiles. Unlike social media plugins, links do not automatically inform the social media platform of your visit when you access our website. However, when you click the link, your data will be processed by the social media platform. The platform will usually store cookies on your device or even assign your usage behavior to your account, especially if you are logged in. The platform may analyze your user behavior and use it for interest-based advertising. This may result in advertising being displayed to you inside and outside the platform. Please decide for yourself whether you wish to accept this and only use social media platforms if you are sufficiently informed about their data processing and agree to it. We provide links to the respective privacy policies of the platforms.
Our website uses links to our Facebook presence operated by Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA. This is only a normal link; when you access our website, Facebook does not learn about your visit. However, when you click the link, you are redirected to Facebook, and Facebook learns that you visited our website.
Your data will be transferred to the USA. Facebook is registered under Privacy Shield and committed to complying with EU data protection regulations. Further information about your rights can be found at: http://ec.europa.eu/justice/data-protection/document/citizens-guide_en.pdf
We have no knowledge of or influence on the collection and use of your data by Facebook after clicking the link. Further information can be found in Facebook’s privacy policy at:
https://www.facebook.com/policy.php
YouTube
Our website uses links to our YouTube presence operated by YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA, represented by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. This is only a normal link; when you access our website, YouTube does not learn about your visit. However, when you click the link, you are redirected to YouTube, and YouTube learns that you visited our website.
Your data will be transferred to the USA. YouTube/Google is registered under Privacy Shield and committed to complying with EU data protection regulations. Further information about your rights can be found at: http://ec.europa.eu/justice/data-protection/document/citizens-guide_en.pdf
We have no knowledge of or influence on the collection and use of your data by YouTube after clicking the link. Further information can be found in YouTube’s privacy policy at: https://www.google.de/intl/de/policies/privacy/
Our website uses links to our Instagram presence operated by Instagram LLC, represented by Kevin Systrom and Mike Krieger, 1601 Willow Rd, Menlo Park, CA 94025, USA. This is only a normal link; when you access our website, Instagram does not learn about your visit. However, when you click the link, you are redirected to Instagram, and Instagram learns that you visited our website.
Your data will be transferred to the USA. Instagram is registered under Privacy Shield and committed to complying with EU data protection regulations. Further information about your rights can be found at: http://ec.europa.eu/justice/data-protection/document/citizens-guide_en.pdf
We have no knowledge of or influence on the collection and use of your data by Instagram after clicking the link. Further information can be found in Instagram’s privacy policy at: https://help.instagram.com/155833707900388
Google Ads
We use Google Ads within the framework of our legitimate interest in a technically flawless and economically efficient online offering and its optimization pursuant to Article 6(1)(f) GDPR. Google Ads is an online advertising program of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
This allows us to place ads within the Google advertising network, for example on other websites, in search results, or elsewhere on the internet. Google Ads displays our ads primarily to users who are likely to be interested in them. This makes our advertising more targeted and less intrusive. Interest-based advertising is enabled by Google through a cookie stored on your device and read by so-called web beacons on partner sites of the Google advertising network. These read the data stored in the cookie, including technical information about your system, websites you have visited, your interests there, and which ads you clicked.
We also use a so-called “conversion cookie” to create anonymous statistics. This contains no personal data that can be assigned to you, only statistical figures about users who clicked our ad.
Google also uses this data only pseudonymously and cannot assign it to you personally unless you have explicitly consented to personalized processing.
The data collected by Google may be transferred to countries outside the EU, in particular the USA. Google has submitted to the Privacy Shield Framework.
As already stated regarding cookies, you can prevent the storage of cookies through your browser settings, but this may restrict website functionality.
Alternatively, you can disable interest-based ads on Google and interest-based Google ads on the web in your browser by activating the “Off” button at: http://www.google.de/settings/ads
or by deactivating them at: http://www.aboutads.info/choices/
Further information on your settings and Google’s data protection can be found at: https://policies.google.com/privacy?hl=de#infochoices
Google Ads Conversion Tracking
We also use Google Ads Conversion Tracking pursuant to Article 6(1)(f) GDPR to measure the success of our advertising measures and enable customer-oriented communication. When you perform certain actions on our website – such as completing an order, submitting a contact form, or subscribing to our newsletter – this conversion is transmitted to Google. Google can recognize the number of conversions and determine which ads you clicked previously that led to the conversion using cookies set by Google.
If you do not wish this, you can make extensive settings or disable the service completely via the Ads Settings Manager at: https://www.google.com/settings/u/0/ads/authenticated
Otherwise, we refer you to our general explanations regarding cookies and Google Analytics for further configuration and opt-out options.