PERSONAL DATA PROTECTION POLICY

1. Introduction

SMART COMMUNICATION SERVICES SRL, CUI: RO35182797, Reg. Com.: J23/3888/2015, Headquarters: Str. Gladiolelor nr 7 bl 1 ap. 10, Roșu village, Ilfov county, postal code 077040
(hereinafter referred to as “we”/”us” or “SMART”) respects the privacy of your personal data and is committed to protecting the personal information we collect and process in accordance with Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (GDPR).

In our business, we collect, store and process personal information about customers, suppliers and other third parties and we recognize that the correct and lawful treatment of this data is the basis for trust in the company and will ensure the proper performance of our business, as follows

• We process your personal data exclusively for the delivery, improvement and guarantee of the services we offer

• Your personal data are safely stored in a secure environment

• Personal data are strictly confidential and will not be passed on to third parties.

We use the data we collect to:

• Providing and administering the Services, including to display personalized content and facilitate communication with other users;

•Facilitating the technical functioning of services, including solving and solving problems, providing services and preventing fraud and abuse;

• Processing registrations and orders for courses, products, services, etc., as well as communicating with you. to respond to your questions and requests.

• Sending administrative messages and information, including messages from trainers and facilitators, notifications about changes to our services, and updates to our agreements;

• Asking for feedback and understanding your needs with the help of analytics service providers;

• Identification of unique users;

• Improving our services and developing new products, services and features;

• Analyzing trends and traffic on websites or promoting our services on websites and apps.

This policy sets out the principles and procedures for collecting and processing your personal information.

Please read this text carefully so that you understand our practices regarding your personal information, and how they are treated.

2. What data we collect and for what purpose

Personal data means any information relating to you. that allows us to identify you, such as your name, contact details, order reference number, payment details, and information about your access on our websites.

We may collect personal data from you, when you reserve a place to participate in events (directly or indirectly through our partners), when you create an account, when you use the websites and/or apps
and other sites accessible through the website, when you participate in a survey or contest, or when you contact us.

In the process of data processing, we follow principles of good practice, which stipulate that your personal information must be:

• processed lawfully, fairly and in a transparent manner;
• processed for specified, explicit and legitimate purposes;
• adequate, relevant and limited to what is necessary;
• accurate and up-to-date;
• maintained only as long as necessary;
• processed in a manner that ensures proper safety.
• Personal data collected, used, stored and transferred includes, but is not limited to:
• Identity data (name, home address, e-mail address, telephone number)
• Payment information
• Attendance history, including information about your courses and services booked in connection with your courses;
• Information you provide about your preferences and those of your companions in SMART programs and courses;
• Information about your purchases of products and services;
• Information about your use of our websites and/or apps;
• Technical data, including IP addresses, your login details, browser type and version, time zone setting and location, plug-in types and versions, operating system and platform, and other technologies used on the devices you use to access our site;
• Data about how you use our website, products and services;
• Marketing data, such as your preferences to receive information from us and third parties and your communication preferences.
• Communications you make with us or direct to us through letters, emails, chat services, calls, and social media.

We collect and process your personal data, to provide services such as:

• Online payment services

• Analytics and advertising through Google Analytics

3. Special data

Information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, or certain types of genetic or biometric data are known as ‘special data’. During our collaboration, we will not collect “special data” about you.

4. What does the processing of personal data mean?

“Processing” means any operation or set of operations performed on personal data or sets of personal data, with or without the use of automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, transmission by transmission, dissemination or otherwise making available, alignment or combination, restriction, deletion or destruction.

5. Principles regarding data processing

SMART undertakes to comply with the principles of personal data protection (hereinafter referred to as the “Principles”) set out in the GDPR, in order to ensure that all data are:

• Processed in a fair, legal and transparent manner;
• Collected for specified, explicit and legitimate purposes;
• Adequate, relevant and limited in relation to the purposes for which they are processed;
• Accurate and up-to-date;
• Kept in a form that does not allow the identification of data subjects for longer than is necessary in relation to the purpose of the processing;
• Processed in accordance with the rights of the data subject, in a manner that ensures adequate security of processing, so that the data is complete, confidential and available.

6. How we collect data

We may obtain personal information by interacting with you by:

• by placing orders for services or products through our website;
• by subscribing to our publications or by delivering marketing materials;
• correspondence with us by telephone, email, letters or in any other way;
• through automated technology when you interact with our website through the use of cookies and other similar technologies.

7. Purpose of using personal information

Your personal data can be used for the following purposes:

• We will use your personal information. only when the law allows us. Most commonly, we will use your personal information in the following situations:

– you have given your consent;
– we need to implement a contract that we are going to conclude with you or that is in the process of being executed;
– for our legitimate interests or those of third parties, and your interests and rights do not override those interests;
– to comply with a legal obligation (e.g. accounting requirements);

We will process your personal information. only for the purpose(s) for which we collected it, unless we reasonably believe that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information. For other purposes, we will notify you and explain the legal basis that allows us to do this. Please note that we may process your personal information. without your knowledge or consent, in accordance with the above rules, when required or permitted by law.

We may also process your personal data. in one or more of the following cases:

• To provide the products and services you request: we use the information you provide to us to perform the services you have requested in connection with your participation, including requested changes related to the courses;
• To contact you in the event of a schedule change or cancellation: we send you information in relation to the services you have requested and any changes to those services. The information is not for commercial purposes and you cannot unsubscribe from it during the term of the contract;
• We use your personal information for accounting, billing and auditing purposes and for the detection and/or prevention of any fraudulent activities;
• For administrative or legal purposes: we use your personal data for statistical and marketing analysis, systems testing, customer satisfaction studies, maintenance and development, or to resolve a dispute or claim.
• Security, health, administration, crime prevention/detection: we may share your information with government authorities or law enforcement bodies to comply with legal requirements;
• For customer service communications: we use your personal data to manage our relationship with you, as a customer and to improve our services and your experience with us;
• To provide personalized services: we use your personal data to provide information that we believe may be of interest to you before, during, and after your participation and to personalize the services we provide to you;
• Marketing: From time to time, we will contact you with information about promotional courses and ancillary products through online communications. You will have the option to unsubscribe from such communications by sending an email to this effect at office@smart communication.ro email address.

We will not keep your personal data more than is necessary to fulfil the purpose for which they are processed. To determine the appropriate retention period, we take into account the amount, nature and sensitivity of personal data, the purposes for which we process it and whether we can achieve these purposes by other means.

This is how we process your personal data.

• For the purpose of concluding and executing contracts – According to art. 6 para. 1 lit. b) of the GDPR, personal data may be processed for the purpose of concluding or performing the contract. In order to be able to offer you our products and services, we need to process your personal data.
• For the purpose of fulfilling legal obligations – According to art. 6 para. 1 letter c) of the GDPR, personal data may be processed for the purpose of fulfilling legal obligations. We request a range of personal data, including, in certain situations, your social security number, in order to fulfil our obligations imposed by the tax authorities in relation to invoicing and reporting to the tax authorities.
• For marketing purposes – According to art. 6 para. 1 lit. a) of the GDPR, personal data may be processed if the data subject has given consent to the processing of his/her personal data for one or more specific purposes. Thus, if you have subscribed to the Newsletter section, your personal data will be used for the purpose of sending you marketing messages, offers, news, future campaigns, invitations to various events. Your personal data will be deleted when you unsubscribe from the Newsletter section. You can unsubscribe at any time via the link attached to the communications received or by a written request addressed office@smart-communication.ro.

We also need to consider the periods for which it may be necessary to retain personal data in order to comply with our legal obligations or to deal with complaints, queries and to protect our legal rights in the event of a claim.

When your data is We no longer need them, we will safely delete or destroy them. We will also consider whether and how we can minimize the amount of personal data we use over time and whether we can ensure the anonymity of your personal data, so that they are no longer associated with you or identify you, in which case we may use that information without further notice to you.

8. Your Rights

Under the GDPR, you have a number of rights regarding the personal data that SMART processes:

• Right of free access to processing data – You have the right to access the personal data we hold about you, along with various information about why and how we use it, where we originally obtained the information and for how long we will use it;
• Right to rectification of data – You have the right to request that your Data be rectified if it is inaccurate or outdated and/or to complete it if it is incomplete.
• Right to erasure (“right to be forgotten”) – In some cases, you have the right to obtain the deletion or destruction of your Data. This is not an absolute right, as sometimes we may be forced to keep your Data for legal or legal reasons.
• Right to restriction of processing – You have the right to request the restriction of the processing of your Data. This means that the processing of your Data is limited so that we can keep the Data but not use or process it. This right applies in specific circumstances set out in the General Data Protection Regulation, namely:
• the information we hold about you is inaccurate;
• the processing is unlawful and the data subject (i.e. you) opposes the erasure of the Data and requests the restriction of its use;
• the controller (e.g. SMART) no longer needs the Data for processing, but it is requested by the data subject (i.e. you) for the establishment, exercise or defence of legal claims;
• data subject (i.e. you) has objected to processing based on legitimate grounds by the controller (in this case SMART), on the basis of verifying whether the legitimate grounds of the controller (SMART) outweigh those of the data subject (i.e. you).
• Right to data portability – You have the right to move, copy or transfer the data you are interested in from our database to another. This only applies to the data you have provided, where the processing is based on your consent or on the basis of a contract and is implemented by automated means.
• Right to object – You can object at any time to the processing of your data where such processing is based on a legitimate interest.
• Right to withdraw consent at any time – You can withdraw your consent to the processing of your data where such processing is based on consent. The withdrawal of consent does not affect the lawfulness of the processing based on the consent before its withdrawal.
• The right to lodge a complaint with the competent supervisory authority – You have the right to lodge a complaint with the data protection authority in your country of residence or domicile to challenge the data protection practices offered by SMART.
• The right to object to the processing of your data for direct marketing purposes – You can unsubscribe or opt out of our direct marketing communication at any time. You can do this by clicking on the “unsubscribe” link in any email or by sending an email to office@smart-communication.ro.
• The right to object to the processing of your data by us when we carry out actions in the public interest or in the legitimate interests of you or a third party – You may object to the processing of your data at any time where such processing is based on a legitimate interest.
• Right to disable Cookies – you have the right to disable cookies. The settings in Internet browsers are usually programmed by default to accept cookies, but you can easily adjust them by changing your browser settings.

You can exercise these rights, either individually or cumulatively, very easily, by simply sending a request to our headquarters in Roșu, str. Gladiolelor, nr. 7, bl. 1, ap 10, Ilfov county or by E-mail, at: alexandra@smart-communication.ro.

9. Data security and processing

SMART has adopted technical and organizational data processing measures, updated in accordance with the requirements of the GDPR, in order to protect your personal data against any actions of unauthorized access, misuse or transmission, unauthorized modification, destruction or accidental loss.

We follow strict security procedures in the storage and disclosure of your personal data and to protect them against accidental loss, destruction or damage. The data you provide to us is protected by SSL (Secure Socket Layer) technology. SSL is the industry-standard method of encrypting personal information and data so that it can be transferred securely over the internet.

All sign-up details are transmitted via an SSL connection and are stored in accordance with Data Security Standards.

We are continuously committed to implementing appropriate measures to protect your personal data. against unauthorized access, loss or alteration thereof.

All SMART employees and collaborators, as well as any third parties acting in the name and on behalf of SMART are obliged to respect the confidentiality of your information and the requirements of the GDPR, in accordance with the provisions of this Policy.

10. What happens if you are unable or refuse to provide us with certain personal information

It is a contractual requirement that you provide us with certain information, namely your first and last name, social security number, address, telephone number and email address. During the order process, you will be asked to provide payment information to the payment service provider of your choice. We don’t store any of your card details, if applicable. If you do not provide us with the information requested by us or the payment service provider, we may not be able to accept and process your request/order and/or we may cancel your order.

11. Cookies and security

We use cookies to improve the user experience on our website. By using our website, you consent to the use of these cookies in accordance with our cookie policy.

Cookies are small pieces of information sent from our website to your browser’s “cookie” file on your computer’s hard drive. Some files only stay for the duration of your visit. (known as “session cookies”), while others remain after you leave the site to help us remember details about you, “persistent cookies”). Cookies are used for several reasons:

– to allow you to fill in information on the pages of our website without manually re-entering it.

– monitoring website traffic and analysing how our website works. This will allow us to make changes in the future and make it more user-friendly.

– to send relevant advertisements by displaying products and services that you may be interested in based on your most recent visit to our website.

Currently, we have a “default consent” policy. This means that by continuing to use our website you agree to our use of the cookies listed above, unless you explicitly disagree. You have the possibility to accept or refuse cookies by changing the settings in your browser. Most browsers allow the user to change the settings used for cookies. Also, some cookies that are not directly linked to the site may actually be third-party cookies. As we cannot control these cookies, please check the third-party website
for more information about their cookies. Additional information about changing your browser settings can also be found by visiting aboutcookies.org.

Disabling cookies will restrict your access to our website. If you have set your browser to disable all cookies, then you will not be able to access many parts of the website. If your browser is set to ask when cookies are used, you will need to answer “yes” when prompted. To opt out of Analytics tracking across all websites, go to tools.google.com/dlpage/gaoptout.

Because we care about the security of your data, we have invested in a secure website, and for online payments all details are encrypted using standard Internet encryption technology (TSL / SSL).

If a site is secure, when you are in the personal data/payment card entry area, a padlock will appear at the bottom right of the screen. Occasionally, the lock won’t be visible, but the page is still secure. If you don’t see the padlock, you can check to see if you right-click anywhere on the page (except images) and select “Properties.” If the URL starts with https:// it means that the page is secure.

Third parties (including, for example, advertising networks and providers of external services such as web traffic analysis services) may also use cookies, over which we have no control. These cookies may be analytics/performance cookies or targeting cookies. You can block cookies by activating the setting in your browser, which allows you to refuse the setting of all cookies or only some. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our website.

12. Processing of contact or sign-up forms

SMART will use the information you provide in the appropriate contact section of the website solely for the purpose of processing your request.

By providing any personal data through the SMART website, you understand and agree that your data will be processed in accordance with the SMART policy.

Please note that in order to process your requests submitted in the registration section, we may, in certain circumstances, be required to transmit your data to the partners with whom SMART collaborates and/or to other third party service providers of SMART.

However, SMART has adopted appropriate technical and organizational measures to ensure the security of the data transfer, as well as the processing in accordance with the GDPR requirements of your data, by the aforementioned entities.

SMART undertakes not to process the personal data provided for a purpose other than the one for which it was transmitted, except in situations where there is your express consent to use them for other purposes.

13. Disclosure of your data

We may share your personal data with third parties. For example, to confirm your orders, resolve complaints, etc. To protect your privacy and for your personal data to be to be safe, we apply the following rules:

• we only provide third parties with the information they need to perform their specific services;
• we require all third parties to respect the security of your personal data, in accordance with the law;
• we do not allow our service providers to use your personal data,for their own purposes, but
• to process them only for the purposes specified in the contracts concluded with them and in accordance with our instructions;
• we work closely with third parties to ensure that your privacy is respected and protected at all times;
• If we no longer use their services, any information about you obtained through us will be deleted or anonymized.
Examples of third parties we work with are:
• mailing services;
• behavioral analysis services (Google Analytics, etc.);
• anti-fraud services;
• IT services;
• legal assistance services;
• social media services;
• law enforcement – we may be required to disclose your personal data to the police or other enforcement, regulatory or governmental bodies, in the country of origin or elsewhere, at their request. These requests are assessed on a case-by-case basis and take into account the privacy of our customers.

14. Where we store your personal data

All the information you provide to us is stored on our secure servers in Romania or the EU. We will take all steps reasonably necessary to ensure that your data is not available. are stored securely, including by taking the following measures:

• Network security. We implement security and monitoring tools that restrict access and warn us of any unauthorized behavior in our network and systems;
• Data transfers. All data transfers are carried out using multi-layered security measures to ensure the integrity and confidentiality of the data;
• Firewalls and encryption. We apply standard firewall protection and use up-to-date encryption technology;
• Methods of elimination. Paper documents are disposed of in a manner that ensures confidentiality.
• Training. We make sure that our team is trained on the importance of data security.

15. How long we will keep personal data

SMART may keep the processed data for different periods of time, assessed as reasonable, in accordance with the purposes indicated above. We only retain your data for as long as necessary to achieve the purpose for which we hold the data, to meet your needs or to fulfil our obligations under the law.

To know how long your data may be retained, we use the following criteria:

• When you purchase products and services, we retain your personal data for the duration of our contractual relationship;
• If you participate in a promotional offer, we keep your personal data for the duration of the promotional offer;
• If you contact us with a question, we keep your personal data for the duration necessary to process your questions, but no longer than 5 years from the last correspondence sent;
• If you create an account, we retain your personal data until you request that we delete it or after a period of inactivity (without active interaction with us) defined in accordance with local regulations and guidelines. In this regard, we mention that the data processed for this purpose
will be deleted 5 years after the last interaction with the account user (such as logging in to your account);
• Where you have given your consent to marketing, we retain your personal data until you unsubscribe or request that we delete it, or after a period of inactivity (without active interaction), as defined in accordance with local regulations and guidelines. In this regard, we mention that the data stored in our databases for the purpose of direct marketing communications are deleted from the records of these databases 5 years after the last interaction with you;
• If cookies are stored on your computer, we keep them for as long as necessary for them to fulfill their purposes (for example, for the duration of a shopping cart cookie session or session ID cookie) and for a defined period in accordance with local regulations and guidelines. In this regard, we mention that the data processed through cookies used to provide online behavioral advertising, to personalize our services for you and to allow the distribution of our content on social media sites (share buttons intended to display the site), will be kept for a maximum period of 5 years from their collection, based on your consent.

16. Opting out of marketing communications

You can ask us to stop receiving marketing communications by:

• use of the unsubscribe link in our emails

• Emailing office@smart-communication.ro

17. Third-Party Links

Our website may include links to third-party websites, plugins and applications. If you enable those links, or if you enable those connections, third parties may allow data about you to be collected or shared. We do not control these third-party sites and are not responsible for their privacy statements. When you leave our site, please read the privacy notice of each site you visit.

18. Updates to the Privacy Policy

We reserve the right to update this Privacy Policy from time to time. Any changes will be posted on our website.
Please do not continue to use the SMART website if you do not agree to such changes. We also recommend checking this page for any updates.
If you have any questions or concerns about this Privacy Policy, we encourage you to contact us at alexandra@smart-communication.ro.

19. What data we never store

The payment card data of the Client/User/Buyer will not be accessible or stored by SMART, but only by the Transaction authorization institution or another entity authorized to provide card identification data storage services, about whose entity the Client/User/Buyer will be informed, prior to entering the data.

3D Secure means a new global approach to authenticating buyers and sellers in secure transactions on the Internet. This security measure involves redirecting the user at the time of payment to a secure page, where the registration of each cardholder is done by assigning an authorization code for each online transaction. The cards accepted for payment are those issued under the VISA (Classic and Electron) and MASTERCARD logos (including Maestro, if they have a CVV/CV2 code).

20. Updating data

If any of the information you have provided to us has changed, e.g. your email address, name or payment details, please let us know by sending an email to office@smart-communication.ro

21. Disclosure of Information

We comply with data protection laws in Romania. We take all necessary measures to prevent unauthorized access to and use of your personal data. We are committed to keeping your data confidential and we will only use them to provide you with products and services that are relevant to you. We also want to send you information about special features of our website or any other service or products that we think may be of interest to you. If you do not wish to receive emails, please send an email to office@smart-communication.ro with your email address and your name.

22. Your Agreement

By transmitting your personal data, you agree to their use as provided in this policy. If we change our privacy policy, we will post the changes on this page so that you will be aware of the information we collect and how we use it at all times. Your continued use of the service will mean that you agree to any such changes. Due to the global nature of the internet infrastructure, the information you provide may be transferred to companies based in countries outside the European Economic Area that do not have similar protection with respect to your personal data and their use as set out in this policy.

Advertisements on our website may be provided by another organization. Our advertising partner will serve ads that it thinks you are most likely to be interested in, based on information about your visit to this site and other websites (this information is anonymous as it does not include your name, address, email address, or phone number). To do this, our advertising partner may need to place a cookie. For more information about this type of online behavioral advertising, cookies and how to disable this feature, please visit youronlinechoices.com

23. How We May Be Contacted

Questions, comments and requests regarding this policy are welcome and you can address them to our team by writing to the address mentioned above or by sending an email to office@smart-communication.ro