We kindly ask you to read this Privacy Policy carefully, which describes how we use the data you provide to us, in accordance with REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (GDPR), Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), and other applicable regulations.
Our goal is to offer transparency in the information provided, so that you, as a user, can understand it clearly. If you still have any doubts after reading this, you can contact us through any of the communication channels available, and we will be happy to clarify them.


I. DATA CONTROLLER

Controller’s contact details:
CRISTINA FERNÁNDEZ NELSON (hereinafter referred to as “the Controller” or simply “CRISTINA FERNÁNDEZ NELSON”), ID: 53412106B
Address for notifications: Apolonio Morales, 8 · 28036 Madrid, Spain.

Data protection contact:
You may contact us at the postal address indicated above or by email: estudio@palmahabana.com


II. PRINCIPLES IN ACCORDANCE WITH THE GDPR

We are committed to processing personal data (hereinafter “data”) in accordance with the following principles set out in the General Data Protection Regulation (GDPR):

  • Lawfulness: We collect your data only for specific, explicit, and legitimate purposes and will not process them in a way incompatible with those purposes.

  • Legitimacy: According to Article 6 of the GDPR, data will be processed only with your express, free, and informed consent, or when necessary to execute a contract, fulfil legal obligations, protect vital interests, carry out public interest tasks, or for legitimate interests that do not infringe upon your fundamental rights and freedoms.

  • Fairness and transparency: In compliance with Article 5 of the GDPR, we inform you about all processing activities and their purposes.

  • Data minimisation: We collect only the data strictly necessary for the intended purposes.

  • Purpose limitation: We will only process your data for the stated purposes.

  • Accuracy: We will keep your data accurate and up to date.

  • Data security: We apply appropriate technical and organisational measures to ensure the security of the data and prevent unauthorised access, alteration, loss, or disclosure.

  • Data subjects’ rights: You may exercise your rights to access, rectify, erase, limit processing, data portability, and object to automated decisions. Your request will be answered within one month, extendable to two in complex cases.

  • Storage limitation: Data will be retained only for as long as necessary for the purposes for which they were collected.


III. USER CONSENT

By filling out our contact forms and accepting this Privacy Policy, the user gives unequivocal consent to the automated processing of their personal data. Consent is also considered granted when the user contacts us through other means made available on the website, as this is considered a clear affirmative action.

In all cases, the data collected will be the minimum required to respond to requests for information about the therapies offered.

No special category data will be collected at this initial contact stage. Such data may be required later to provide the therapy service.

You may withdraw your consent at any time using any of the communication methods provided.


IV. PURPOSES OF DATA PROCESSING

Your data will be used for the following purposes:

  • Responding to information requests about therapies, working methods, pricing, etc.

  • Management, administration, invoicing, communication, and service delivery.

  • Follow-up actions tailored to each specific therapy or case.


V. DATA RETENTION PERIOD

Data will be retained for as long as necessary for the intended purpose: either to provide requested information or to deliver therapy services.

Once the data are no longer needed and no consent exists to retain them, they will be blocked for the duration of legal limitation periods to attend to potential responsibilities. After this period, they will be definitively deleted.

Blocking, under Article 17.3 of the GDPR, means data will not be used and will be inaccessible, except if legally required or for liability claims.


VI. LEGAL BASIS

Data is processed based on the user’s consent, including special category data required for therapy (if contracted). You may exercise your data rights at any time.

Providing personal data is necessary to contact us and process your request. If you do not provide the requested data or reject the Privacy Policy, we will not be able to process your request.


VII. DATA RECIPIENTS

CRISTINA FERNÁNDEZ NELSON will not transfer your data to any third party except in cases required by law, such as:

  • Public authorities

  • Tax agency

  • Law enforcement

  • Courts and tribunals


VIII. DATA PROTECTION RIGHTS

You may exercise your rights of access, rectification, erasure, objection, restriction of processing, and data portability by contacting the Controller at the address or email mentioned above.

If you are a client, you may also revoke your consent or object to commercial communications at any time by emailing estudio@palmahabana.com.

If you believe your request has not been properly handled, you may file a complaint with the Spanish Data Protection Agency (AEPD).

A) RIGHT OF ACCESS

Article 15 GDPR gives you the right to know whether your data is being processed, for what purposes, and for how long.
Download access request form (PDF)

B) RIGHT TO RECTIFICATION AND ERASURE

Articles 16 and 17 GDPR allow you to request correction or deletion of inaccurate or unnecessary data.
Rectification form
Erasure form

C) RIGHT TO RESTRICT PROCESSING

You may request data restriction under certain circumstances, such as challenging the accuracy of the data.
Restriction form

D) RIGHT TO DATA PORTABILITY

You have the right to receive your personal data in a structured, commonly used, machine-readable format or have it transferred to another controller.
Portability form (same as access)

E) RIGHT TO OBJECT

You may object to processing for direct marketing purposes at any time.
Objection form

→ Learn more at: https://www.aepd.es/derechos-y-deberes/conoce-tus-derechos


IX. MINORS

This website is not intended for minors under 18 years of age, and they must be accompanied by a legal guardian.

Only users aged 14 or older can legally consent to data processing. CRISTINA FERNÁNDEZ NELSON takes all reasonable steps to verify users’ ages but cannot be held liable for breaches in this regard.


X. SECURITY LEVEL

CRISTINA FERNÁNDEZ NELSON implements all necessary technical and organisational measures to prevent unauthorised access, loss, or alteration of personal data.

If a security breach occurs that may affect your rights, we will notify the Spanish Data Protection Agency (AEPD) within 72 hours and affected users as soon as possible.

This Privacy Policy applies solely to this website. We are not responsible for the security of third-party websites accessed via external links.


XI. CONFIDENTIALITY

All collected personal data will be treated confidentially. CRISTINA FERNÁNDEZ NELSON is committed to maintaining strict confidentiality and ensuring all personnel involved in data processing are bound by confidentiality agreements.


XII. INTERNATIONAL DATA TRANSFERS

If any personal data is transferred outside the European Economic Area (EEA), for example, for hosting purposes, such transfers will comply with the GDPR using standard contractual clauses or other mechanisms recognised by the European Commission.

We ensure that any third party handling data outside the EEA meets adequate levels of data protection and security.


XIII. LIABILITY

Users are solely responsible for providing false, inaccurate, incomplete, or outdated information. Please notify us of any changes or errors by contacting: estudio@palmahabana.com

We will take all necessary measures to update or delete incorrect information.


XIV. CHANGES TO THE PRIVACY POLICY

This Privacy Policy complements any other existing legal obligations. In case of a conflict, the applicable data protection legislation shall prevail.

CRISTINA FERNÁNDEZ NELSON reserves the right to modify this Privacy Policy at any time, especially in response to legislative or service changes. Any update will be published at least ten (10) days in advance, and users will be notified accordingly.

You may also consult the most recent version of this Policy at any time on our website.