Privacy policy

This Privacy Policy applies to personal data that we collect in connection with our services, for example when you visit our European websites, when you communicate with us through social media platforms or when you contact us. Esengo BV is responsible for the processing of data collected from its customers. This Privacy Policy describes the categories of personal data that we collect about you, how we may use them, with whom we may share them, and your rights regarding the use we make of them. This Policy also describes the measures we take to protect the security of personal data, their retention period and how you can contact us to exercise your rights. This Privacy Policy may be amended from time to time to reflect changes in our personal data practices or applicable law.


Responsible for the collected data :

Esengo BV, registered at the BCE under the reference number BE0770.935.511, manages and operates under the name of Second Breath and Second Breath Yoga, as well as the websites www.secondbreath.eu and www.secondbreath.be

E-mail : hello@secondbreath.eu 


1. When and for what purpose Esengo BV collects personal data

In principle, it is possible to use and consult our website without entering personal data.

If you wish to use one of our services (eg our newsletter or our contact form), you enter your data freely. We only use this data (eg your name, address, email address, phone number) for the purpose for which you provided it to us (eg to process your contact request, to manage your reservations and payments, to send you your documents and to provide you with services such as sending newsletters for example) and within our own business activities. The information you send us helps us to process your booking, improve the services we offer you and avoid any abuse or fraud.

When you access our website, some general information is automatically collected. This information (server log files) includes, for example, the type of internet browser used, the operating system used, the domain name of your internet provider, and other information. It is therefore exclusively information that does not allow to establish a link with your person. This information allows us, from a technical point of view, to correctly provide you with the desired information on the website and are necessarily due in connection with the use of the internet. We evaluate this anonymous information to optimize the appearance of our website and the technical elements that underlie it. We do not sell your data or use it for any hidden purposes.

Your personal data is only used within Esengo BV and by the eventual professional partners to which we can possibly refer to in order to meet your expectations.


2. General information about our services

If you use our services, we will ask you to provide us with personal data (at the time of collection, we will explain what information is needed and which are optional)

Users who have registered for one or more services have the possibility, if necessary, to modify or delete at any time their data indicated during registration. Of course, we can also give you at any time information about your personal that we have stored. We will be happy to correct or delete this data upon request, provided that this does not constitute an infringement of any legal obligation to store. To contact us about this and to withdraw your consent, please use our email address hello@secondbreath.eu


3. Our services

a. Newsletter
If you have signed up for our newsletter, we use your data to send you tailor-made information about our offers, contests, and customer services.

For the registration to be valid, we need a valid email address. The data is used exclusively for sending the newsletter and is not transmitted to third parties.

You may at any time withdraw your consent to have your personal data saved and used for sending the newsletter. In each newsletter, you will find a corresponding link to do so. In addition, you may unsubscribe at any time by using the contact information provided at the end of this Privacy Policy.

By unsubscribing, we consider that your consent to the receipt of newsletters based on it is revoked. 

We evaluate the use you make of the newsletter that has been sent and the subsequent visits to our website to further improve the newsletter and our website, and to adapt to your current interests accordingly. We use the information we have, such as the history of web visits or the preferences and interests that you have actively transmitted to us via your registration or that we have monitored from your interactions with our newsletter. Added to this are the usual technologies such as cookies and web beacons used in our newsletter. The messages we send you will be personalized and tailored to your personal preferences and interests.


b. Games and contests
From time to time, you have the opportunity to participate to games and contests on our website or through our newsletter. As part of these actions, and in order to allow their processing, personal data (email address, name, address and, if necessary, other necessary data) will be collected and recorded in accordance with the participation conditions in force. The personal data transmitted to us in the context of an action of this type will only be used for the processing of the action in question (in the case of a game, for example to announce the names of the winners, inform winners and send the win) and deleted after the end of the action.

If you have expressly given us your consent as part of the action, we will send you our newsletter as described above. The subsequent withdrawal of your consent has no negative impact on your chances of winning or your ability to participate to a game.


4. Contact form

If you contact us by email or via the contact form, the data indicated by you will be saved to allow the processing of your request as well as for any additional questions or to send you the desired information.


5. Right to withdraw your consent

If you use any of the services mentioned on the basis of a consent, the following rules apply to this consent: you always freely give your consent and can withdraw it at any time, without having to indicate a reason, with effect for the future. To do this, you can also use the email address hello@secondbreath.eu


6. Data collection during the consultation of our website

In addition to the data you enter yourself, if you visit our website, we also collect other data about you via cookies or tracking tools. You will find more information on this subject below.


a. Cookies
On our website, "cookies" are sometimes used. Cookies automatically send us certain data such as your IP address, the browser used, the operating system installed on your computer or your Internet connection. Cookies can also be used to better tailor the offer of a website to the visitor's interests or to improve it more comprehensively through statistical evaluations. You can determine for yourself whether you want the browser you use to allow cookies or not. Please note that the functionality of websites may be limited or blocked if you do not allow cookies.


b. Embedded YouTube videos

On some of our web pages, we integrate YouTube videos. When you visit a page with the YouTube plug-in, a connection to the YouTube servers is established. YouTube knows what pages you're viewing. If you're signed in to your YouTube account, YouTube can link your browsing behaviour to you. To prevent it, you must first sign out of your YouTube account. When you launch a YouTube video, the provider places cookies that collect information about the user's behaviour. If you have disabled cookies for the Google Ad program, cookies will not be saved when you watch YouTube videos.


c. Social media
On our website, we offer you the possibility to use the "social network buttons". The buttons are integrated into the website only as images containing a link to the corresponding site of the supplier of the button. By clicking on the image, you are redirected to the services of the concerned supplier. Only then your data will be transmitted to the supplier in question. If you do not click on the images, there will be no data exchange between you and the operator of the social network button. For more information regarding the collection and use of your data on social networks, please consult the conditions of use of the concerned social network provider.


7. Recipients

a. Third parties
We only transmit the data that you have entered in connection with the performance of the contract, for example to service providers, or if required by law. For example: tax auditor, controller, insurance, accountant, tax advisors, experts.


b. Transfer of data to third countries
If we process the data in a third country (outside the European Union (EU) or the European Economic Area (EEA)), or if this is necessary in the context of recourse to third party services or the disclosure or transfer of data to third parties, this will occur solely for the purpose of fulfilling our contractual obligations, on the basis of your agreement, a legal obligation or in order to preserve our legitimate interests. This means that the processing of the data is carried out based on special guarantees, or that we make sure, by a contractual commitment, that technical and organizational measures will be taken to ensure that your personal data are processed in the context of a data protection system equivalent to that of the EU.


8. Obligation to provide data

In the context of contractual relations, you must provide us with the personal data allowing the registration, execution, and termination of the contract and which are necessary for the fulfilment of the contractual obligations or which we are legally required to collect for the organization of our services for example. Without this data, we will generally not be able to conclude a contract with you or execute it.


9. Deleting data

Under the principles of prevention and minimization of data, the data we record will be erased as soon as they are no longer necessary in view of the purposes for which they were collected and if the erasure does not conflict with any legal obligation to keep. Once the purpose concerned is obsolete or the time elapsed, the data will be erased or locked in a systematic way and in accordance with the legal requirements. If the processing of the data is based on consent, the obsolescence of the purpose is regularly caused by the nullity of the consent, following a withdrawal or expiry of the deadline. If the processing is necessary for the performance of the contract, this usually occurs once the contract is fully executed or after the expiration of the retention period established by commercial or fiscal law.


10. Your data protection rights 

You have a right of information, a right of modification, a right to the cancellation, a right to the limitation of the treatment, a right of retraction and a right of portability of the data in accordance with GDPR.

To apply these rights, you can contact our data protection officer: hello@secondbreath.eu

In addition, you have the right to introduce a claim with a supervisory authority regarding data protection.

If you have any questions about this policy or data protection, you can contact our data protection officer directly: hello@secondbreath.eu


11. Modification of our data protection rules

We reserve the right to adapt our privacy policy to comply with applicable legal requirements at all times or to introduce changes to our services in the privacy policy, such as when new services are created. The new privacy policy will apply to any subsequent visit. 

[name of website] Privacy Policy  

Introduction

This Privacy Policy outlines [fill in applicable company name] (" we ", " our " or " the Company ") practices with respect to information collected from users who access our website at [Fill in applicable linkable address] (" Site "), or otherwise share personal information with us (collectively: " Users "). 

Grounds for data collection 

Processing of your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter " Personal Information ") [add explanation regarding the legal grounds for processing personal information, such as:] is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions. 

What information we collect?

We collect two types of data and information from Users. 

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“ Non-personal Information ”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

The second type of information Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:
  • Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
  • [add types of personal information collected, and respective explanations, such as:]
  • Registration information: When you register to our Site you will be asked to provide us certain details such as: full name; e-mail or physical address, and other information.  
  • …
  • …

How do we receive information about you?

We receive your Personal Information from various sources:
  • When you voluntarily provide us your personal details in order to register on our Site;
  • When you use or access our Site in connection with your use of our services;
  • From third party providers, services and public registers (for example, traffic analytics vendors).

What information we collect?

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

We may use the information for the following:
  • [ add types of detailed uses, such as:]
  • Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have;
  • To communicate with you and to keep you informed of our latest updates and services;
  • To serve you advertisements when you use our Site (see more under "Advertisements"); 
  • To market our websites and products (see more under "Marketing"); 
  • Conducting statistical and analytical purposes, intended to improve the Site.
  • …
In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 
  • Hosting and operating our Site;
  • [Add and amend relevant types of third parties, such as:]
  • Providing you with our services, including providing a personalized display of our Site;
  • Storing and processing such information on our behalf; 
  • Serving you with advertisements and assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
  • Providing you with marketing offers and promotional materials related to our Site and services; 
  • Performing research, technical diagnostics or analytics;
We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

User Rights

You may request to: 
  1. Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information. 
  2. Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format. 
  3. Request rectification of your personal information that is in our control.
  4. Request erasure of your personal information. 
  5. Object to the processing of personal information by us. 
  6. Request to restrict processing of your personal information by us.
  7. Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. 

If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer (“DPO”) using the details provided below:
[add contacts details] .

Retention

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations. 

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies ' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy. 

How do we safeguard your information?

We take great care in implementing and maintaining the security of the Site and your information. [ explain about your security practices, such as: we employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorized use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy] . Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Transfer of data outside the EEA 

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

Advertisements

  We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser). 

[Add information regarding opt-out options from personalized advertisements, such as:] You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

Marketing

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you.  

Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists. 

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Minors

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at [add applicable email address] .

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at [add applicable email address] .

Please complete the details of the company

Last Modified __________