PRIVACY AND COOKIES

Psych|Being is committed to protecting the security and privacy of our website visitors and customers. Our privacy policy, including our Cookies Policy, has been updated to reflect the General Data Protection Regulation (GDPR), and is effective from 1 December 2020.

This Privacy Policy describes how your data is collected, used, and shared when you visit or make a purchase from totsukuru.com (the “Site”). For more information about the cookies and other tracking technologies we use, visit our Cookie Policy.

We may update this Privacy Policy and Terms & Conditions from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

TYPES OF DATA COLLECTED

Among the types of Personal Data that this website collects, by itself or through third parties, there are: Tracker; Usage Data; email address; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); device information; User ID; first name; date of birth; gender; country. 

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.


Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this website.
Unless specified otherwise, all Data requested by this website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.


Users who are uncertain about which Personal Data is mandatory are welcome to contact me.


Any use of Cookies – or of other tracking tools – by this website or by the owners of third-party services used by this website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this website and confirm that they have the third party's consent to provide the Data to the Owner, Psych|Being and Wix. 

METHODS OF PROCESSING 

Psych|Being and Wix take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.


The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

LEGAL BASIS OF PROCESSING

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;

  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof

  • processing is necessary for compliance with a legal obligation to which the Owner is subject;

  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

 

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. ​

PLACE

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

RETENTION TIME

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

 

Psych|Being may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, Psyche|Being may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

PURPOSE OF PROCESSING

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Traffic optimization and distribution, Displaying content from external platforms, Analytics, Tag Management, Platform services and hosting, Interaction with data collection platforms and other third parties, Remarketing and behavioral targeting, Advertising, Handling payments, Registration and authentication, Interaction with external social networks and platforms, Managing contacts and sending messages, Contacting the User and Selling goods and services online. 

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Personal Data is collected for the following purposes and using the following services:

ADVERTISING

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below. 
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.


In addition to any opt-out feature offered by any of the services below, Users have the option to opt. out when they see fit. 

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

CONTACTING THE USER

Mailing and Communication

By booking an appointment or contacting through email, the User’s email address and other personal data provided will be added to the contact list of those who may receive email messages containing information solely regarding their request or requested work. No form of promotions or newsletters will be sent. 

 

Personal Data processed: date of birth; email address; first name. 

 

Category of personal data collected according to CCPA: identifiers. 

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this website and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

HANDLING PAYMENTS

Unless otherwise specified, this website currently does not process any payments. All payments made will be done via bank transfer or other external platforms and payment service providers done after confirmation and invoicing. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information to the owner of this website after consultation and agreement so that an invoice can be made. Any late payments will incur an added percentage fee. 

INTERACTION WITH DATA COLLECTION PLATFORMS & OTHER THIRD PARTIES 

This type of service allows Users to interact with data collection platforms or other services directly from the pages of this website for the purpose of saving and reusing data.


If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

INTERACTION WITH EXTERNAL SOCIAL NETWORKS & PLATFORMS

This type of service allows interaction with social networks or other external platforms directly from the pages of this website.
The interaction and information obtained through this Website are always subject to the User’s privacy settings for each social network.


This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on this website isn’t being connected back to the User’s profile.

PLATFORM SERVICES AND HOSTING

These services have the purpose of hosting and running key components of this website, therefore allowing the provision of this website from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. 


Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

WIX (Wix.com LTD.)

Wix is a platform provided by Wix.com LTD. that allows the Owner to build, run and host an e-commerce website.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Category of personal data collected according to CCPA: internet information. 

REGISTRATION AND AUTHENTICATION

By registering or authenticating, Users allow this Website to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this website will be able to access some Data, stored by these third-party services, for registration or identification purposes. 
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

TRAFFIC OPTIMISATION AND DISTRIBUTION

This type of service allows this website to distribute their content using servers located across different countries and to optimise their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this website and the User's browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

ADDITIONAL INFORMATION

In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.​

Selling goods and services online

The Personal Data collected are used to provide the User with services, including payment and possible delivery.


The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by or through this website depends on the payment system used.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it. 

  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

 

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document. 

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.


The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.​

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

How “Do Not Track” requests are handled

To the best of our knowledge, this website does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

CHANGES TO THE PRIVACY POLICY

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. 

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

 

DEFINITION AND LEGAL REFERENCE 

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

This Website (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Website as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

 

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

 

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Website, if not stated otherwise within this document.

Latest update: 19 June 2021