Privacy policy
Last updated: 2 August 2026
Your personal data is yours. Here I explain plainly what data I process, what for, for how long, who I share it with and what you can require of me at any time.
This policy is governed by Andorran Law 29/2021 of 28 October on the protection of personal data and its implementing regulation. Since the programme is aimed at people living in European Union countries, Regulation (EU) 2016/679 (GDPR) also applies where relevant.
1. Data controller
- Controller: Miryam Cámara Ruiz
- NRT: F-422030-T
- Address: Avinguda Santa Coloma 67, 1r 2a, AD500 Andorra la Vella, Principality of Andorra
- Contact email for data protection matters: conraizyalasyvolando@gmail.com
2. What data I process
I only process the data you give me yourself, through whichever channels you choose to use:
- Contact details: first name, surname, email address, phone number and country of residence.
- Information from our initial conversation: what you tell me about your situation, your goals and your expectations, so I can assess whether the programme suits you.
- Contractual information: the programme you have signed up for, dates, amounts and payment status.
- Data generated during the programme: attendance at sessions, exercises submitted, and the follow-up notes I take so I can support you properly.
- Technical browsing data strictly necessary to serve the website: IP address and request data, logged by the hosting provider for security and stability purposes.
3. Sensitive data
This is not a healthcare service and I do not need your medical records. It may happen, however, that in the course of the programme you voluntarily share information about your emotional state or health.
In that case, that information is processed solely for the purpose of supporting you, on the basis of your explicit consent, with access restricted to me alone, and subject to professional confidentiality. You can withdraw that consent at any time.
4. Why I process your data and on what legal basis
- To answer your enquiries and hold the initial assessment call. Basis: your request and pre-contractual steps.
- To deliver the service you have contracted: campus access, sessions, materials, follow-up and marking of exercises. Basis: performance of the contract.
- To manage payments, invoicing and accounts. Basis: compliance with legal, tax and accounting obligations.
- To send you news about new intakes or content, if you have subscribed. Basis: your consent, which you can withdraw at any time and in every message.
- To keep the site and the platform secure. Basis: my legitimate interest in protecting the service and the people who use it.
5. How long I keep your data
- Enquiries that don't lead to a contract: up to one year from the last contact.
- Contractual data: for the duration of the programme and thereafter for the legal, tax and accounting limitation periods applicable in Andorra.
- Follow-up notes and exercises: up to one year after the programme ends, unless you ask me to delete them sooner.
- Data processed on the basis of your consent: until you withdraw it.
6. Who else has access to your data
I do not sell or pass on your data to third parties. I do use technology providers acting as data processors, under a signed contract and solely on my instructions:
- The hosting and deployment provider for the website and the campus.
- The email provider and the video-call provider used for sessions.
- The provider hosting the campus videos.
- The payment services provider, for handling payments.
- An instant messaging service, if you choose that channel to contact me.
- Accounting and tax advisers, and public authorities where there is a legal obligation.
7. International transfers
Andorra has an adequacy decision from the European Commission (Decision 2010/625/EU), so data can move between the European Economic Area and Andorra without additional safeguards.
Where a provider processes data outside the European Economic Area or a country with an adequate level of protection, the transfer relies on standard contractual clauses or another safeguard provided for in the applicable law. You can ask me for a copy of those safeguards by writing to the contact address.
8. Your rights
You can exercise the following rights at any time, free of charge:
- Access: find out what data of yours I process and obtain a copy.
- Rectification: correct anything inaccurate or incomplete.
- Erasure: ask me to delete your data when it is no longer needed.
- Restriction: ask me to suspend processing while a dispute is resolved.
- Objection: object to processing based on my legitimate interest.
- Portability: receive your data in a structured, commonly used format, or have me send it to another controller.
- Withdraw consent at any time, without affecting the lawfulness of processing carried out beforehand.
9. How to exercise them and where to complain
Write to me at conraizyalasyvolando@gmail.com stating which right you wish to exercise. I will reply within one month at the latest. I may ask you to prove your identity if I have reasonable doubts about who is making the request.
If you believe I have not handled your request properly, you can complain to the Andorran Data Protection Agency (APDA), the supervisory authority in Andorra. If you live in the European Union, you can also contact the supervisory authority in your own country.
10. Security and confidentiality
I apply appropriate technical and organisational measures to protect your data: encrypted communications, access controls, backups, and access limited to what is strictly necessary.
I undertake to keep everything shared in sessions confidential, both during the programme and after it ends. What is said in the group or in one-to-one sessions stays there.
If a breach of the security of your data occurred that posed a risk to your rights, I will notify the APDA within 72 hours at the latest and will inform you where the law requires it.
11. Recording of sessions
The taught part of each weekly session is recorded and made available in the campus. The practical group part is never recorded, precisely so that it remains a space where you can speak freely.
One-to-one sessions are not recorded either, unless you expressly ask for it and authorise it in writing.
12. Minors
The services are aimed at adults. I do not knowingly collect data from minors. If I find that I have received data from a minor without the corresponding authorisation, I will delete it.
13. Cookies
This website does not use analytics, advertising or profiling cookies, and it includes no third-party trackers. The language is selected through the page address, not through cookies.
If a tool requiring non-essential cookies is added in future, your prior consent will be requested through a specific notice and this policy will be updated.
14. Changes to this policy
This policy may be updated if the services or the applicable law change. The version in force is the one published here, bearing the date shown at the top. If a change is substantial and affects participants, I will tell them directly.