Privacy Policy

1. Data Controller

The data controller responsible for your personal data is Hiteke Zapevo, with its registered office at Bulevardul Unirii 72, Bucharest, Romania. You can contact us regarding data protection matters at [email protected] or by phone at +40 726 724 067.

2. Data We Collect

We collect personal data only when you actively provide it to us. The categories of data we may collect include:

• Contact and identification data: your name, email address, and telephone number, provided when you submit our contact form or newsletter subscription form.
• Communication content: the content of messages you send us, including any information you choose to include about your industry, employment situation, or workshop preferences.
• Technical data: IP address, browser type, operating system, pages visited, and time of visit, collected automatically when you use our website. This data is collected in aggregated or anonymized form where possible.
• Cookie data: information stored in cookies placed on your device, as described in our Cookie Policy. We collect only the categories of cookies you consent to.

We do not collect special categories of personal data (such as health data, ethnic origin, or political opinions) and we do not request such data at any point.

3. Legal Basis for Processing

We process your personal data on the following legal bases under Article 6 GDPR:

• Consent (Article 6(1)(a) GDPR): when you tick the consent checkbox on our contact or newsletter forms, or when you accept cookie categories through our cookie consent tool. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.
• Legitimate interests (Article 6(1)(f) GDPR): for the purpose of responding to enquiries sent to us, maintaining the security of our website, and managing our internal records. We have assessed that these interests are not overridden by your interests or fundamental rights.
• Legal obligation (Article 6(1)(c) GDPR): where processing is necessary to comply with Romanian law, including tax, accounting, and consumer protection obligations.

4. How We Use Your Data

Personal data collected through our website is used for the following purposes:

• Responding to enquiries submitted through the contact form
• Sending newsletter communications to subscribers who have consented
• Providing information about upcoming workshop sessions
• Maintaining records of workshop registrations and communications
• Improving the performance and usability of our website through anonymized analytics
• Complying with legal obligations applicable to our business

We do not use your personal data for automated decision-making or profiling as defined under Article 22 GDPR.

5. Data Sharing and Third Parties

We do not sell, rent, or trade your personal data to any third party. We do not share your data with advertising networks, data brokers, or marketing platforms.

We may share your data with the following categories of recipients only to the extent necessary:

• Email service providers: to deliver newsletter communications and contact form responses. Any such provider is bound by a data processing agreement.
• Hosting providers: our website hosting provider may process technical data as part of providing hosting services. They act as a data processor under a written agreement.
• Competent authorities: if required by Romanian law, a court order, or other legally binding obligation, we may disclose personal data to public authorities.

6. Retention Periods

We retain personal data only for as long as necessary for the purposes described in this policy, or as required by Romanian law.

• Contact form submissions: retained for up to 24 months from the date of submission, unless you request earlier deletion.
• Newsletter subscriber data: retained until you unsubscribe or request deletion.
• Workshop registration records: retained for the period required under Romanian accounting and tax law (currently 5 years from the end of the financial year in which the transaction occurred, per Law No. 82/1991 on accounting).
• Technical and cookie data: retained for the duration specified in our Cookie Policy, typically no longer than 13 months.

7. Your Rights

Under the GDPR and Romanian Law No. 190/2018, you have the following rights regarding your personal data:

• Right of access (Article 15 GDPR): you may request a copy of the personal data we hold about you.
• Right to rectification (Article 16 GDPR): you may request correction of inaccurate or incomplete data.
• Right to erasure (Article 17 GDPR): you may request deletion of your personal data, subject to legal retention obligations.
• Right to restriction of processing (Article 18 GDPR): you may request that we limit how we use your data in certain circumstances.
• Right to data portability (Article 20 GDPR): where processing is based on consent or contract, you may request your data in a structured, machine-readable format.
• Right to object (Article 21 GDPR): you may object to processing based on legitimate interests.
• Right to withdraw consent: where processing is based on consent, you may withdraw it at any time by contacting us.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing (Autoritatea Nationala de Supraveghere a Prelucrarii Datelor cu Caracter Personal, ANSPDCP) at www.dataprotection.ro.

8. Cookies

This website uses cookies. A cookie is a small text file placed on your device when you visit a website. We use cookies to ensure the website functions correctly, to remember your preferences, and, where you consent, to collect anonymized usage data. Full details of the cookies we use and how to manage them are set out in our Cookie Policy.

9. International Data Transfers

Where we use third-party service providers located outside the European Economic Area (EEA), we ensure that appropriate safeguards are in place as required by Chapter V of the GDPR. These safeguards may include Standard Contractual Clauses approved by the European Commission, adequacy decisions, or other lawful transfer mechanisms. We will provide further information on request.

10. Security Measures

We implement technical and organizational measures appropriate to the risk of processing, including encrypted transmission (HTTPS), access controls, and regular review of our data handling practices. No method of transmission over the internet is completely secure, and we cannot guarantee absolute security, but we take reasonable precautions to protect personal data against unauthorized access, loss, or disclosure.

11. Children and Minors

Our website and workshop services are directed at adults. We do not knowingly collect personal data from individuals under the age of 16. If you believe we have inadvertently collected data from a minor, please contact us and we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The "Last Updated" date at the top of this page indicates when the most recent revision was made. Continued use of our website after changes are posted constitutes acceptance of the updated policy. For significant changes, we will take reasonable steps to notify you.

13. How to Contact Us

For any questions, requests, or concerns relating to this Privacy Policy or the handling of your personal data, please contact us:

• Email: [email protected]
• Phone: +40 726 724 067
• Post: Hiteke Zapevo, Bulevardul Unirii 72, Bucharest, Romania