POLICY

REGARDING THE PROCESSING OF PERSONAL DATA

Last Update: December 31, 2023

Your privacy is one of our fundamental commitments, and therefore, we take utmost care to process your personal data in accordance with the principles set forth in the applicable legislation, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation (“GDPR“).

We understand the importance of confidentiality, integrity, and security of your personal data (“Personal Data“, “Data“) and have drafted this information notice (“Privacy Policy“) to explain and detail how we process your Personal Data in the context of using the platform available at the URL address https://celtaromania.ro/ (“Platform”).

We reserve the right to amend the provisions of this Privacy Policy from time to time. If we make changes to this Privacy Policy, we will publish the updated version on the Platform and update the “Last Update” date. We will also notify you of any amendments to ensure that you are informed of how your Personal Data will be used. Any change to the Privacy Policy will apply from the date it was made, except for changes that require your prior consent, which will apply from the moment you express this consent.

1. CONTROLLER

For the use of the Platform and the services available on the Platform (the “Services”), IHB Language Training Center SRL, a company registered and operating according to the Romanian law, having its registered office in Bucharest, Sector 4, 29 Constantin Radulescu Motru street, Block 33, Entrance 3, Floor 8, Appt. 105, registered with the Trade Registry under no. J40/11822/2002, having sole registration code (CUI) 15026564 acts as controller (“Company“, “us“).

2. USE OF THE PLATFORM

If you use the Platform to access the Services, your Personal Data will be processed in the situations described in this Privacy Policy.

When you use the Platform as a visitor (i.e., any person accessing the Platform), all provisions of this Privacy Policy as regards user will also apply to you, to the extent possible.

2.1. Browsing data

Computer systems and software procedures used for the operation of the Platform generally acquire some Personal Data (so-called “log files“), the transmission of which is implicit in the use of Internet communication protocols.

This information is not collected to be associated with identified persons, but due to their nature, can, through processing and integration with certain data held by third parties, allow the identification of users. Such information includes IP addresses, the time of the request, the time zone, the method used to send the request to the server, the size of the file obtained in reply, as well as other parameters related to the user’s operating system.

Insofar such information leads to the identification of a user, the provisions of this Privacy Policy become applicable.

2.2. Filing in and submitting the application forms

When filling in and submitting the application forms, we will process the following Personal Data of the applicant: name, surname, date of birth, age, nationality, address, e-mail address, phone number, information about medical condition, title, information about education and training, school name, location, current job/position, information about the program; Personal Data of the indicated referees: name, address, phone numbers and relationship to the applicant; as well as any other information transmitted.

 2.3. Interview / Short discussions

During the interview / short discussions conducted as part of the program applying process, we will process all the information that the applicant is providing to us.

 2.4. Services provision

When providing the Services / attending a program, including when taking an assessment/exam, we will process the following Personal Data: name, surname, results obtained, image, voice and any other information provided to us.

2.5. Payment

When making a payment, we will process the following Personal Data: name, surname, phone number, email address, payment amount, services, bank details required to make the payment.

2.6. Invoice issuing

When we issue the invoice for the payments you make, we will process the following Personal Data: name, surname, e-mail address, address, ID card number and series, services, payment amount.

 2.7. Recruitment of trainers – situation applicable exclusively to trainers

If you wish to join our team of trainers and send us your CV, we will process the following Personal Data for the following purposes and on the following grounds:

2.7.1. Analysing the information provided

Personal Data processed: name, surname, e-mail address, telephone number, all information mentioned/indicated in the CV and any other information you provide to us.

 2.7.2 Contacting the trainers

Personal Data processed: name, surname, e-mail address, address, telephone number.

2.7.3. Interviewing the trainers

Personal Data processed: name, surname, e-mail address, telephone number, all information mentioned/indicated in the CV, salary expectations, telephone number, profession, workplace, studies, education, and any other information that you provide them to us.

2.8. Contacting us

You can contact us through several channels: contact form, e-mail, telephone. As part of this interaction, we will process any Personal Data you provide.

2.9. User notification

During the provision of the Platform, we will send you notifications / messages related to the provision of the Services offered through the Platform. For example, we will inform you about changes made to the terms and conditions of use of the Platform.

We will also contact you if you indicate certain aspects or problems to us in order to improve or solve them. If we contact you, we will process the following Personal Data: name, surname, e-mail address, telephone number, any other Personal Data provided by you.

2.10. Marketing (Newsletter, promotions, offers, commercial messages)

If you have opted in this way, we will send you marketing messages, in which case we will process the following Personal Data: name, surname, telephone number, e-mail address.

2.11. User opinion (feedback)

Your opinion is important to us, and if you decide to give us feedback, we will process the following Personal Data: name, surname, e-mail address, other information mentioned by you.

2.12. Testimonials

We can ask you for testimonials about the Services we provide. In such a case, if you agree to, we can publish the testimonial on the website or social media. In this case we will process your full name, quality, company (if the case may be) and any other information included in the testimonial.

2.13. Disputes

In certain circumstances, we may need Personal Data in order to have an accurate record of your relationship with us in the event of any complaints or if we reasonably believe there is a prospect of litigation. In this case, we will store your name, surname, e-mail address, phone number, any other information relevant to the case.

3. PROVIDING YOUR PERSONAL DATA

You may refuse to provide certain Personal Data but in such a case you may not be able to benefit from certain services specific to the relationship described in this Privacy Policy.

4. LEGAL GROUNDS

The legal ground for processing the Personal Data differs depending on the specific situation and the Personal Data processed.

When we process your Personal Data based on your consent, we will seek for your free, informed, specific, and unequivocal consent for the respective processing. By expressing your consent, you will agree that we may collect, use, disclose, process, and transfer Personal Data in accordance with this Privacy Policy.

5. AUTOMATED INDIVIDUAL DECISION-MAKING PROCESS

Your Personal Data shall not be processed in order to be subject to decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, pursuant to art. 22 para. (1) of GDPR.

6. STORAGE DURATIONS

The storage duration of Personal Data varies depending on the specific processing operation.

As a rule, we will keep Personal Data for the duration of the collaboration and subsequently for a period of 5 years.

However, in the case of processing operations based on your consent (such as in the case of sending commercial messages), we will process the Personal Data until you withdraw the consent.

In addition, in the case of Personal Data included in certain documents (such as those included in invoices), they will be stored for the mandatory period provided by the applicable legislation.

In certain circumstances, we may retain your Personal Data for longer periods of time in order to have an accurate record of your relationship with us in the event of any complaints or if we reasonably believe that there is a prospect of a litigation.

7. TRANSFER OF PERSONAL DATA

We may transfer Personal Data, to the necessary extent, to the following categories of recipients: IT services suppliers, marketing services suppliers, accounting services suppliers, facilitators of communication services, public authorities.

These recipients can be located in the European Union and/or in the European Economic Area. Where recipients are located outside the European Union and the European Economic Area, including in countries not recognized as ensuring an adequate level of protection, the transfer of Personal Data shall be carried out only if there are appropriate guarantees, in accordance with applicable law (such as the standard contractual clauses issued by the European Commission). You may request a list of recipients from third countries, as well as a copy of the agreed provisions that ensure an adequate level of protection of Personal Data.

8. SECURITY OF PERSONAL DATA

The security of your Personal Data is important for us. Your Personal Data will therefore be processed by applying reasonable technical and organizational measures to protect Personal Data, such as limiting access to Personal Data, encryption or anonymization of Personal Data, storage on secure environments. However, despite our efforts, we cannot always guarantee the effectiveness of the security measures implemented, and therefore we cannot guarantee the security of Personal Data at any time.

9. RIGHTS IN CONNECTION WITH THE PROCESSING OF YOUR PERSONAL DATA

Access right: You have the right to obtain confirmation from us that your Personal Data is processed by us, as well as information on the specific processing, such as: the purposes of processing, categories of processed Personal Data, recipients of Personal Data, the period for which Personal Data is stored, the source of Personal Data, if we transfer the Personal Data abroad and how we protect it, your rights, the right to lodge a complaint before the supervisory authority.

Right to rectification: You have the possibility to request rectification of your Personal Data, provided that the applicable legal requirements are met. In the event of errors, after notification, we will immediately correct your Personal Data.

Right to erasure: In certain cases, you have the possibility to request the deletion of Personal Data, namely when: (i) the Personal Data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent on which the processing is based and where there is no other legal ground for the processing; (iii) the Personal Data have been unlawfully processed; (iv) you exercise the right to object to the processing. We are not obliged to comply with your request when the processing is necessary (among others) for compliance with a legal obligation or for the establishment, exercise or defence of legal claims. There are also other circumstances in which we are not obliged to comply with this request for the deletion of Personal Data.

Restriction of processing: You may request us to restrict the processing of your Personal Data in the following circumstances: (i) you contest the accuracy of the Personal Data, for a period enabling us to verify it; (ii) the processing is unlawful and then you oppose to the erasure of the Personal Data and request the restriction of their use instead; (iii) we no longer need the Personal Data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; (iv) you have objected to processing, pending the verification whether our legitimate grounds override yours. However, we can continue to process your Personal Data (i) when you consent; (ii) for the establishment, exercise or defence of legal claims or (iii) for the protection of the rights of another natural or legal person.

Right to data portability: Insofar the Personal Data is processed based on your consent or on the execution of the agreement and the processing is carried out by automated means, you have the right to have your data Personal Data provided to you in a structured format, which is currently used and can be read automatically and you have the right to request us to transfer this Personal Data to another controller. This right shall not adversely affect the rights and freedoms of others.

Right to opposition: In certain situations, such as when we process your Personal Data based on a legitimate interest, you have the right to object to the processing of your Personal Data by us. In the event of unjustified objection, the Company is entitled to continue processing Personal Data. You also have the right to object to the processing of your Personal Data for marketing purposes.

Withdrawal of consent: Insofar you consented to the processing of your Personal Data, you can withdraw your consent at all times, without affecting the lawfulness of processing based on consent before its withdrawal.

Right not to be subject to any automatic individual decisions: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Such right cannot be exercised when the decision: (i) is necessary for entering into, or performance of, a contract between you and us; (ii) is authorized by law which lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (iii) is based on your explicit consent.

Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (“ANSPDCP“) in relation to any breach of your rights regarding the processing of your Personal Data. The contact details of ANSPDCP are: General Gheorghe Magheru Boulevard, Sector 1, postal code 010336 Bucharest, Romania; email: anspdcp@dataprotection.ro.

To learn more about the manner in which you may exercise the aforementioned rights, please contact us at the email below.

10. CONTACT

If you have any questions or concerns about this Privacy Policy or its implementation, you may contact us at: support@ih.ro