Your personal data is processed for the following purposes, each with its own legal basis:
Answering your enquiries: legal basis: your consent.
Booking the discovery call: legal basis: your consent.
Providing coaching sessions, programmes and the Begin Again course, including your course account and progress: legal basis: performance of a contract.
Invoicing under Spanish tax law (Verifactu): legal basis: legal obligation.
The free Shoshin guide and the newsletter: legal basis: your consent. You can unsubscribe at any time.
3. Special Category Data
Information about your emotional wellbeing and your nervous system that you share in the pre-session questionnaire and in sessions is processed only to provide the service, with your explicit consent, and is never shared.
4. Service Providers (Processors)
To run this website and provide the services, the following providers process data on my behalf:
Lovable: website hosting, database, course accounts, sign-in and automatic emails (contact form notices, contracts and payment details). Emails are sent on my behalf by Lovable Labs AB (Stockholm, Sweden, EU). Transfers outside the European Economic Area (EEA) are covered by the EU Standard Contractual Clauses. Lovable's subprocessors, their purpose and location are listed at https://trust.lovable.dev/subprocessors.
Proton AG: email (walkwithsara@proton.me).
Meetergo and Zoom Scheduler: booking the discovery call and sessions.
Zoom: online video sessions.
Substack Inc.: newsletter and free Shoshin guide.
WhatsApp Ireland Ltd.: messages you choose to send via WhatsApp, including payment receipts.
Google (Google Analytics): visit statistics, only if you accept cookies.
Metricool: visit statistics, only if you accept cookies.
Bunny Stream: (BunnyWay d.o.o., Slovenia, EU), for video hosting and delivery.
5. International Transfers
For Lovable (hosting, database, accounts and automatic emails), transfers outside the European Economic Area (EEA) are covered by the EU Standard Contractual Clauses. For other providers that process data outside the EEA (Substack, Zoom, Google Analytics, Metricool, Meetergo and YouTube/Vimeo, where used), transfers are covered by the EU Standard Contractual Clauses or the EU-US Data Privacy Framework, depending on the provider.
6. Data Retention
Enquiries that do not lead to a contract: 1 year.
Contracts and invoices: 6 years.
Newsletter: until you unsubscribe.
Course account: until 12 months after your access ends, then deleted.
7. Your Rights
You have the right to:
Access your data
Rectify inaccurate data
Erase your data
Object to processing
Restrict processing
Data portability
Withdraw your consent at any time
To exercise these rights, write to walkwithsara@proton.me.
You also have the right to file a complaint with the Spanish Data Protection Agency (AEPD): www.aepd.es
8. Data Security
I apply appropriate technical and organisational measures to protect your personal data against unauthorised access, loss or alteration.
9. Policy Updates
This privacy policy may be updated to reflect changes in my practices or for legal reasons. In case of significant changes, I will inform you through the means available.
10. Begin Again online course
10.1. Controller
Sara Parada Vos ("Sastre de Vida") · NIF: 43147640P · Address: Carrer Joan Monserrat Parets 9, 1 H, 07007 Palma (Illes Balears), Spain. Contact: walkwithsara@proton.me
10.2. What data I collect, why, and on what basis
Name, email, language, password: To create your account and give you access. Legal basis: performance of the contract.
Course progress (sessions completed, ticks): To show your progress and remember where you left off. Legal basis: performance of the contract.
Self-check answers: So you can see your own process over time. They are stored privately with your explicit consent, which you give the first time you open a self-check. Only you can see them, and you can delete them at any time. Legal basis: your explicit consent, which you can withdraw at any time by deleting your answers.
Comments and display name: To take part in the community. Legal basis: performance of the contract; moderation based on legitimate interest.
Feedback and testimonial consent (first edition): To improve the course; to publish testimonials only if you say yes. Legal basis: consent.
Consent records (date and time): To prove the consents you gave. Legal basis: legal obligation.
Emails about new sessions and future programs: Session emails are part of the service; news about future programs only if you opt in. Legal basis: contract / consent.
Technical data and necessary cookies: For the platform to work securely. Legal basis: legitimate interest / necessary cookies.
10.3. Who can see your data
Only me. Your self-check answers are private and never shared with other participants. Other participants can only see your display name and your comments, and only within the same language group.
I use these service providers, which process data on my behalf:
Lovable: website hosting, database, private file storage, course accounts and automatic emails (contract, payment details, account notices). Emails are sent on my behalf by Lovable Labs AB (Stockholm, Sweden, EU). Transfers outside the EEA are covered by the EU Standard Contractual Clauses. Lovable's subprocessors, their purpose and location are listed on the page linked in section 4 of this policy.
Videos: Bunny Stream (BunnyWay d.o.o., Slovenia, EU), for video hosting and delivery.
If you write to me on WhatsApp, WhatsApp's own privacy policy also applies.
10.4. How long I keep your data
Account, progress and self-checks: while your access is active. After access ends, they are kept for 3 months, then deleted, unless you delete them earlier.
Comments: until you delete them, or until the course community is closed.
Billing data: for the period required by tax and commercial law (generally up to 6 years).
Testimonial consent: while the testimonial is published; you can withdraw it at any time.
10.5. Your rights
You can access, correct, delete, restrict or download your data, object to its processing, and withdraw your consent at any time. You can download or delete your course data directly from your course area, or write to walkwithsara@proton.me. You also have the right to file a complaint with the Spanish Data Protection Agency (AEPD): www.aepd.es
10.6. Cookies
The platform only uses necessary cookies by default. Analytics cookies are only used if you accept them. Course videos are delivered by Bunny Stream (EU).
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