WEBSITE USER AGREEMENT

1. Our commitment to your privacy

The non-profit association Zarabina asbl (hereinafter referred to as "Zarabina") is committed to protecting the privacy of our clients. The Zarabina Privacy Statement (hereinafter referred to as the “Privacy Statement”) shall apply to all personal data which are collected or posted by us on our websites (hereinafter referred to as our “websites”) and on mobile pages, applications, widgets and other mobile interactive features (hereinafter jointly referred to as our “apps”), on our official social media sites (hereinafter referred to as our “social media sites”) as well as on e-mail messages in HTML format that we sent to you, together with our media sites, apps and websites (hereinafter referred jointly to as the “sites”) whether on or off line. If you provide us with your personal data, you agree to the terms and conditions of this privacy policy.

2. Personal data

WHICH PERSONAL DATA DO WE COLLECT?

“Personal data” by which you are identified as a person such as:

  • Name
  • User name
  • Postal address
  • Telephone numbers (including private and mobile telephone numbers)
  • E-mail address
  • Profile picture
  • Country of residence
  • Demographic and other information which you provide
  • Location information
  • Aggregated information

HOW DO WE COLLECT PERSONAL DATA?

From you: information such as date of birth, sex, and postal code, as well as other information which you provide when using the website.

HOW DO WE USE PERSONAL DATA?

We can use personal data to:

Reply to your inquiries and to meet your requirements, e.g. send you information or reply to your questions and comments;

Send you administrative information, e.g. information about the sites and the changes of our conditions and guidelines;

Provide you with updates and notifications about our programmes and send you invitations to participate in special programmes;

Enable you to contact – and be contacted by -- other users via the sites, to the extent this is possible on the respective sites;

Enable you to participate in message boards, chats, profile sites, blogs and other services, to which you can send information and materials (including our social media sites).

Address internal purposes such as assessments, develop new products, improve our sites, improve our products and services, detect usage trends, adapt the sites to the experience and the content to your previous activities on the sites, assess customer satisfaction, provide customer service (including troubleshooting when customers have problems).

Proceed, as and when we deem it necessary or appropriate:

In accordance with the legislation in force, including laws outside your country of residence to: comply with legal requirements; reply to inquiries from public and governmental authorities, including public and governmental authorities outside your country of residence; enforce our terms and conditions of use; protect our business activities or those of a company affiliated with us; protect our and your rights, privacy, security and/or property, or the rights, privacy, security or property of companies affiliated with us or others, and be able to use the available legal enforcement means or to limit potential damage.

3. Online counselling and coaching

Zarabina asbl. offers online counselling and coaching via US based provider Zoom. Zoom complies with global privacy frameworks and have implemented data protection and privacy practices into our products and processes. For further information please refer to https://zoom.us/privacy-and-legal

Zarabina asbl. will neither record conversations nor provide data to third parties. Personnel-related data will neither be transmitted to Zoom nor transferred to third parties. Participating in online counselling and coaching will be on a voluntary basis in the knowledge of the used platform.

4. Security

We take appropriate organizational, technical and administrative measures to protect personal data under our control. Unfortunately, no full (100%) guarantee can be given for data transmission via the Internet or the data storage system. If you have reason to believe that your interaction with us is no longer secure, please inform us immediately by using the form in the “Contact” section.

5. Access, modification, options

To check, correct, update, hide, delete or otherwise limit our use of your personal data, please use the form available on our homepage under http://www.zarabina.lu/kontakt and specify your request explicitly. State clearly in your request which information you would like to change, whether you would like your personal data to be hidden from our database, or apprise us otherwise of which restrictions you wish to impose on our use of your personal data. We will try to respond to your request as promptly as possible. Please bear in mind that despite all our efforts, information might remain stored in our database and in other records, and might be impossible to remove or change.

6. Third-party sites

This Privacy Statement does not pertain to the privacy, information or other practices of third parties, including those who operate a site to which the Zarabina sites have a link, and we cannot be held liable in that respect. The inclusion of a link on the Zarabina sites does not imply that we, or companies affiliated with us, approve of the linked site. Furthermore, we can provide you access to functions of third parties, with which you can publish content on your social media account(s). Please bear in mind that all information which you provide by using such functions is subject to the privacy statement of the respective third party and not to this privacy statement. We have no control over and cannot be held liable for the use made by third parties of information which you provide by using such functions. We cannot be held liable either for the registration, use and disclosure guidelines and practices (including data protection practices) of other organizations such as Facebook, Apple, Google, Microsoft, RIM or other app developers, app operators, operators of social media platforms, operating systems, or mobile communications, or equipment manufacturers, including personal data which you disclose to other organizations through or in connection with the apps or our social media sites.

YouTube
Our website uses plugins from the YouTube site operated by Google. The operator of the pages is YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. 
When you visit one of our pages equipped with a YouTube plugin, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behaviour directly to your personal profile. You can prevent this by logging out of your YouTube account.YouTube is used in the interest of an appealing presentation of our online offers. This represents a legitimate interest within the meaning of Art. 6 Para. 1 lit. f DSGVO. Further information on the handling of user data can be found in YouTube's privacy policy at: https://www.google.de/intl/de/policies/privacy. 

7. Retention period

We will keep your personal data for the period necessary to fulfil the purposes set out in this policy statement.

8. Sensitive information

Sensitive information (e.g. information concerning race or ethnic origin, religion or other convictions, state of health or medical situation, or criminal background) which you send to us on or via the sites shall be secure.

9. Updates of this privacy statement

This privacy statement is subject to change. Please take a look at the reference text “last update” at the start of this site to find out when this privacy statement was updated last. Any changes to this privacy statement shall enter into force when we publish the amended privacy statement on a site. Your use of the sites after the changes shall entail that you accept the amended privacy statement.

10. Contact

For any questions about this privacy statement, please contact us via our homepage http://www.zarabina.lu/kontakt.