FOREHUB, LDA, a company with registered office at Avenida D. João l, n.21, 1º esq., 2800-111 Almada (Portugal), with VAT number 513 652 752 and registered with the Commercial Registry Office of [tbc] under the same number (hereinafter referred to as “Forest Therapy Hub”) acts, under the terms of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”), as controller; it is the entity that determines the purposes and means of the processing of personal data and that processes the data for its own purposes and in order to comply with legal obligations regarding the provision of services such as, (i) training, (ii) certification or to (iii) send newsletters, as mentioned below.
If you have any additional questions, please feel free to contact us by the following email address: firstname.lastname@example.org
As per the General Data Protection Regulation, personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing of personal data means any operation or set of operations that are performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Forest Therapy Hub – as per the minimisation and storage limitation principles – keeps personal data in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. Therefore, it processes during mandatory legal periods (when applicable) or during the time strictly necessary. The data will be deleted after that period unless there is a pending dispute, in which case Forest Therapy Hub will keep the data until the decision is final.
The processing of personal data for a specific purpose must meet one of the legal grounds listed in the GDPR (as provided for in articles 6, 9 and 10 of the GDPR). Forest Therapy Hub may process your personal data on the following grounds:
- if you have given consent to the processing of your personal data for one or more specific purposes (article 6(1)(a), article 9(2)(a));
- if the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract (article 6(1)(b));
- if the processing is necessary for compliance with a legal obligation to which Forest Therapy Hub is subject (article 6(1)(c));
- if the processing is necessary for the purposes of the legitimate interests pursued by Forest Therapy Hub or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data (article 6(1)(f)).
3. Purposes of the processing
|Purpose||Legal Basis||Data Retention period|
|Direct Marketing||Consent||After the data subject has opposed or after the last interaction (e.g., attendance to an event), when the communications have no longer interest to the data subject.|
|Unsolicited communications and newsletters|
|Legitimate interests (with the possibility to opt-out), after any purchase or reservation of events||Legitimate interest (“soft opt-in” or “opt-out”)|
|Management of events and certifications||· performance of a contract;|
· compliance with a legal obligation to which Forest Therapy Hub is subject (e.g., tax obligations);
· legitimate interests pursued by Forest Therapy Hub.
|· 1 year after the event;|
· 1 year after the expiry or cancellation of the certification.
|Health questionnaire||Consent||1 year after the event|
In order to be able to carry out all its duties and provide you with the best possible service, Forest Therapy Hub might have to communicate or give access to your personal data to other entities.
Forest Therapy Hub will only communicate or give access to your personal data to the following categories of entities:
- Entities that provide services to Forest Therapy Hub or that are legally obliged to communicate some personal data;
- IT support;
- Marketing services and advertisements;
- Document management;
- Legal and accounting support;
- Logistical support;
- Human resources support (e.g., temporary job);
- Public authorities, such as, for example, Tax Authorities or Judicial Courts.
5. International Transfers
Forest Therapy Hub has appointed Mailchimp as a newsletter provider, which has its head office in the Unites States of America. Mailchimp is a Georgia limited liability company whose legal name is The Rocket Science Group LLC d/b/a Mailchimp.
To protect data subjects and comply with the GDPR, Forest Hub has concluded a Data Processing Addendum with Mailchimp incorporating the EU’s Standard Contractual Clauses.
Data subjects can find more information regarding the provider and GDPR compliance here.
6. Data Subject’s Rights
With regard to the processing of your personal data, and to the extent the legal requirements applicable are met, you have the rights described below, under the terms of articles 15 to 21 of the General Regulation on Data Protection.
Right of access
You have the right to obtain from the controller confirmation as to whether or not personal data is being processed by Forest Therapy Hub, and, where that is the case, access to the personal data and the following information:
(i) the purposes of the processing;
(ii) the categories of personal data concerned;
(iii) 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 organisations;
(iv) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
(v) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
(vi) the right to lodge a complaint with a supervisory authority;
(vii) the existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Right to rectification
If you consider your personal data to be inaccurate or incomplete, you have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Your right to rectification only applies to the personal data you have provided to Forest Therapy Hub and not to data resulting from Forest Therapy Hub’s actions (e.g., performance reviews).
Right to erasure
To the extent legally admissible, you have the right to obtain from Forest Therapy Hub the erasure of your personal data without undue delay and Forest Therapy Hub shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
(i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(ii) you have withdrawn consent on which the processing is based according to point (a) of article 6(1), or point (a) of article 9(2), and where there is no other legal ground for the processing;
(iii) you have objected to the processing pursuant to article 21(1) and there are no overriding legitimate grounds for the processing, or you have objected to the processing pursuant to article 21(2);
(iv) the personal data have been unlawfully processed;
(v) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which Forest Therapy Hub is subject;
(vi) the personal data have been collected in relation to the offer of information society services.
Right to erasure does not apply if the processing is:
(i) for exercising the right of freedom of expression and information;
(ii) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(iii) for reasons of public interest in the area of public health in accordance with points (h) and (i) of article 9(2) as well as article 9(3);
(iv) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
(v) for the establishment, exercise or defence of legal claims. After the exercise of the right of erasure in the terms legally admissible your personal data will be deleted.
Right to restriction of processing
You shall have the right to obtain from the controller restriction of processing where one of the following applies:
(i) the accuracy of the personal data is contested, for a period enabling the controller to verify the accuracy of the personal data;
(ii) the processing is unlawful and you have opposed to the erasure of the personal data and have requested the restriction of their use instead;
(iii) the controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
(iv) you have objected to processing pursuant to article 21(1) pending the verification of whether the legitimate grounds of the controller override yours.
Right to data portability
You have the right to receive your personal data provided by you, in a structured format, in common use and automatic reading. You also have the right to ask Forest Therapy Hub to transmit this data to another controller, as long as this is technically possible, where applicable under article 20 GDPR.
Right to object
You shall have the right to object, on grounds relating to your particular situation, at any time to processing of personal data which is based on point (e) or (f) of article 6(1), including profiling based on those provisions. Forest Therapy Hub shall no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
Right to lodge complaints with the supervisory authority
You have the right to file complaints with the competent supervisory authority regarding matters related to the processing of your personal data. In Portugal, the competent supervisory authority is the National Data Protection Commission. For more information, go to www.cnpd.pt.