PRIVACY POLICY



This privacy statement explains all aspects of the processing of personal data and ensures compliance with the principles of processing and respect for your rights regarding such data when you interact with us about products and services (EU) 679/2016 (GDPR), Law 190/2018 on Measures for the Protection of Data (EU) 679/2016 (GDPR) implementation of the GDPR and / or any other decisions that the National Personal Data Protection Supervisory Authority (ANSPDCP) may issue as a supervisory authority for the protection of personal data.



WHO ARE WE?
The company LEADERS ACADEMY SRL, headquartered in Bucharest, street Drumul Valea Furcii, 66, area 6, registered with the Trade Register under no. J40/16804/2018, CUI 40197328 (hereinafter referred to as “the Company” or “the Operator” or “us”) organizes offline and online courses (online), online and tuition programs via the www.academy4startup.com and / or through various video conferencing applications and / or specially designed course rooms.



For any processing carried out wholly or in part by automated means, as well as non-automated processing of personal data, which is part of a data recording system or which is intended to be part of a recording system of the data, we ensure that your data is:



processed legally, fairly and transparently;
collected for specified, explicit and legitimate purposes and not subsequently processed in a way incompatible with these purposes; further processing for purposes of archiving in the public interest for purposes of scientific or historical research or for statistical purposes is not considered incompatible with the original purposes;
appropriate, relevant and limited for what is necessary in relation to the purposes for which they are processed;
accurate and, if necessary, up-to-date, we will take all necessary measures to ensure that personal data which are inaccurate, in view of the purposes for which they are processed, are erased or rectified without delay;
stored in a form that allows you to identify yourself for a period that does not exceed the time required to meet the purposes for which the data are processed; personal data will be stored for longer periods as long as they are processed solely for purposes of archiving in the public interest for purposes of scientific or historical research or for statistical purposes;
processed in a way that ensures adequate security, including protection against unauthorized or unlawful processing and loss, destruction or accidental damage, by taking appropriate technical or organizational measures.


Our services are dynamic and we frequently introduce new functionalities, which may require the collection of new information. In the event that we collect personal data with material differences or make material changes to the use of the data, we will notify you and we will also modify this privacy policy accordingly.



WHAT ARE THE CATEGORIES OF PERSONS TAKEN?
There are different categories of targeted people, depending on the quality that the data subjects have in relation to our Company, we process the data of these individuals for various processing purposes, always based on a legal basis:



com visitors, anonymous people who only access and navigate the website;
com visitors, people who can place orders to buy and attend offline and online courses (webinars), educational and training programs organized by the Company, without having registered an account on the www website www.academy4startup.com, or accessing various services made available by the Company: use registration form (“Apply Online”); placement and / or order cancellation; purchase course; withdrawal from the contract and receipt of the price of the paid course; Register various requests using one of the communication channels provided by the Company (eg Facebook instant messaging and / or WhatsApp, Contact Form); download brochure presentation; newsletter subscription;
users of our website www.academy4startup.com, customers (prospective) or potential clients who are members of our academy have registered a user account on the academy4startup.com website and who use it for various services provided at Company provision: Application form application (“Apply Online”); placement and / or order cancellation; purchase course; withdrawal from the contract and receipt of the price of the paid course; Register various requests using one of the communication channels provided by the Company (eg Facebook instant messaging and / or WhatsApp, Contact Form); download brochure presentation; subscribe to the newsletter;
potential students or students participating in scholarships organized and offered by the Society;
potential partners or business partners of the Company, employees who are employees, collaborators, representatives or other potential partners, or direct or indirect shareholder or actual beneficiary, potential client / client, potential supplier / supplier or potential partner / partner business of the Company.


FOR WHAT PURPOSES WILL WE PROCESS PERSONAL DATA?


The primary purpose for which we process your personal data is to ensure that the contractual arrangements between us can be properly implemented so that contractual relationships can work smoothly and comply with legal requirements.



The company processes personal data for the following purposes:



providing access and using academy4startup.com services by ensuring the proper functioning of the website;
creating and administering the user account at academy4startup.com and / or www.mefi.ro;
operation, protection, improvement and optimization of academy4startup.com and user and customer experience such as analysis, statistics and research;
the conclusion of sales / schooling contracts for offline and online courses / seminars, webinars, educational and training programs organized by the Company, by entering and taking orders, including validation and billing; providing scholarships to participating students;
solving any withdrawals from the contract regarding the enrollments at the courses / courses purchased / paid and the reimbursement of their counter value according to the legal provisions; solving various requests / complaints of any nature regarding purchased products and services;
transmission of messages about the purchased products or services (cancellations, delays, changes of any kind regarding online / online courses / seminars, educational and training programs organized by the Company), updates, security alerts and account notifications;
marketing and advertising;
security and security (eg CCTV monitoring – video recordings, with / without sound in classrooms);
preventing, detecting or investigating fraud, security breaches and activities that are or may be prohibited or illegal, as well as for the defense and exercise of our rights under the law;
solving requests from public authorities or fulfilling legal requirements (eg, specific financial-accounting, tax or money-laundering legislation);
managing the business relationship between us and a prospective client / client, potential vendor / vendor, or other potential partner / business partner, if you are the collaborator, representative, or contact person of that customer, vendor, business partner;
If we intend to further process your personal data for a purpose other than that for which it was collected, we will provide you, before this further processing, with information on the purpose of the processing and any relevant additional information requested by you.


WHAT LEGAL BASES DO WE USE FOR THE PROCESSING OF YOUR PERSONAL DATA?
The legal bases for processing your data are:



Article 6 (1) (a) of the GDPR) in the case of taking pictures and / or video records of the paid courses that may be used by us to promote our products and services or the participants through different communication channels offline and online media;
the execution of a contract to which the data subject is a party or to take steps at the request of the data subject prior to the conclusion of a contract (Article 6 (1) (b) of the GDPR) for the purposes of creating and administering the online user account at academy4startup.com and / or mefi.ro; transmission of security alerts and account notifications;
the execution of a contract to which the data subject is a party (Article 6 (1) (b) of the GDPR) for the purpose of concluding sales / schooling contracts for our products and services (online / seminar courses / seminars, schooling organized by the Society); awarding scholarships to participating students and concluding contracts in this respect; solving any withdrawals from the contract regarding the enrollment at the courses / courses purchased / paid the bought courses and the reimbursement of the counter value according to the legal provisions; solving various requests / complaints of any nature regarding purchased products and services; the transmission of messages about the purchased products or services (cancellations, delays, changes of any kind regarding (cancellations, delays, changes of any kind regarding online / online seminars and seminars, educational and training programs organized by the Company), updates;
Article 6 (1) (b) of the GDPR) for the purpose of managing the business relationship between the Operator and a prospective customer / client, potential supplier / supplier or other potential partner / business partner, if you are a collaborator, representative, or contact person of that client, vendor, business partner;
legitimate interest (Article 6 (1) f) of the GDPR) for the purposes of providing access to and use of the academy4startup.com website services through its proper functioning; operation, protection, improvement and optimization of www.academy4startup.com and the experience of users and customers; marketing and advertising; security and security (eg CCTV monitoring – video recordings, with / without sound in classrooms); preventing, detecting or investigating fraud (eg by using videos of online / webinars and, implicitly, learners in the applications used to deploy them (eg Zoom);
compliance with legal obligations for purposes of security breaches and activities that are or may be banned or illegal; defense and exercise of our rights; solving requests from public authorities, or meeting legal requirements (eg, financial-accounting, tax or money-laundering legislation).


WHAT TYPE DATA WE COLLECT?
We collect data to work efficiently and provide you with the best experiences with our products. You can opt for the data we collect. When asked to provide personal data, you can refuse. If you choose not to provide the data that is required to provide a product, you may not be able to use the product.



For each purpose of the processing, we need some personal data from you as follows:



providing access to and using the academy4startup.com website services – we may collect information during your visit to the online store website through our automatic data collection tools (cookies): the internet protocol address ( IP), domain name (URL), access data, client access history (viewed pages, links to click), HTTP response code, web page access data, byte quality used when visiting, the data of the viewed pages or the browser type and language used;
concluding sales / schooling contracts for our products and services (offline and online courses / seminars, educational and training programs organized by the Company) by entering and taking orders, including validating and invoicing them; (cancellation, postponement, alterations of any kind regarding (cancellations, delays, changes of any kind regarding offline / online courses / seminars (webinars), educational and training programs organized by the Company): name , the name, the email address, the telephone number, the address, the bank details, the failure to forward this information will make it impossible to conclude a sales / education contract between you and us, issuing the tax invoice or processing a possible withdrawal from the contract and repaying the value of the product / the purchased service;
managing the business relationship between us and a prospective client, client, potential vendor or other potential partner / business partner, if you are the collaborator, representative or contact person of that client, vendor: name, surname, address email, phone number, mailing address; Failure to transmit this information will make it impossible to carry out in good faith the contract between the Company and you;
marketing and advertising: name, surname, email address, phone number, data collected from cookies; Failure to forward this information will make it impossible for you to submit newsletters to you and / or provide us with personalized marketing campaigns to you, containing general and thematic information, information about similar products / services to those you have purchased , information on offers and promotions;
marketing and advertising: names, surnames, photographic images, video (in case of interviews) and audio (in the case of postcasts); used to take and display interviews for course participants; viewing the testimonials of course participants both on our academy4startup.com website and on social networks and various offline and online media communication channels; Your non-acceptance of the use of this personal data will make it impossible to promote both our products / services and yours;
information, take-over of entries for courses, resolving possible withdrawals from the contract and reimbursing the value of the purchased products / services, solving various requests / complaints of the purchased products through the call center: the personal data necessary to solve your requests. audio recordings of telephone conversations conducted through our call center;
security and security, in accordance with applicable and appropriately flagged legal provisions: video, with / without sound in classrooms.


We may obtain your data directly from you or from persons acting on behalf of the customer, supplier or business partner of the Operator or from public authorities and institutions or publications and databases that are publicly or contractually available.



We can combine personal information with information about your transactions in the online environment and other interactions with us. We can also combine personal information with information we receive from other sources, such as marketing partners, public databases, publicly accessible pages on social platforms, and other third parties.



OTHER IMPORTANT INFORMATION

Analyzing communications within / through our website www.academy4startup.com



We may examine, scan, or analyze communications on our website www.academy4startup.com (eg distributing a dedicated event / course / seminar page published on www.academy4startup.com via various channels of communication – instant messaging, social media platforms, email) to prevent fraud, risk assessment, regulatory compliance, investigation, product / service development, customer research, analysis and support. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may scan, examine, or analyze messages to troubleshoot, improve, and expand product / service offerings. We use automated methods wherever possible. However, occasionally we may need to manually review some communications, such as fraud investigations and customer support, or evaluate and improve the functionality of these automated tools. We will not review, scan, or analyze your communications to send third-party marketing messages to you and we will not sell reviews or analyzes of these communications.



These activities are based on the Company’s legitimate interest in ensuring compliance with our Terms and Conditions, prevention, detection and fraud, security breaches and activities that are or may be prohibited or illegal to promote safety and to improve and ensure the proper performance of our services.



Linking third party accounts


You can sign in to your online user account with your account with a third-party social networking service (e.g., Facebook). Your contacts for these third-party services are called “Friends”. When creating this link:



some of the information you provide from your link to your accounts may be published on your academy4startup.com online user account profile;
your academy4startup.com activities can be displayed to your friends on that third party site;
a link to your public profile about your social networking third party may be included in your academy4startup.com online user account profile;
other academy4startup.com users can see any ordinary friends you can have with them or that you are a friend of their friend, if any;
other academy4startup.com users can see all the schools, hometowns or other groups you share with them, as listed in the associated social networking service;
the information you provide us about your accounts can be stored, processed, and transmitted for fraud prevention and risk assessment;
publishing and displaying information provided by academy4startup.com through this link is subject to your settings and authorizations on www.academy4startup.com and on the third party site.
We collect your information only from linked third party accounts to the extent necessary to ensure the proper performance of our contract with you or to ensure that we comply with the applicable laws or with your consent.


In addition, if you choose to sign in with your social media account to your client account or connect to your client account in your social media account, the social media website may share information about your use of of your services, including profile information, contact information, and the content you’ve watched or liked. See the privacy settings of the social media site to control how your information is shared.



Partners and third-party integration



The www.academy4startup.com platform may link to third-party sites or services, such as third-party integration, co-branding, or third-party service (“Third-Party Partners”). We do not own or control these third-party partners, and when interacting with them, you may provide information directly to the third party or to us or to both parties. These third-party partners will have their own rules on the collection, use and disclosure of information. We encourage you to review the privacy policies of the other sites you visit.



Parts of the www.academy4startup.com platform may use third-party services such as Google Analytics, WhatsApp, Zoom, YouTube, LinkedIn, Instagram, including payment processors APIs for products / services purchased on the www.academy4startup.com platform. The use of these services is subject to their privacy policies, such as Google Analytics, WhatsApp, Zoom, YouTube, LinkedIn, Instagram, Payment Processors).



HOW DO WE USE PERSONAL DATA?
We may use, store and process personal information to (1) Provide, Understand, Improve and Develop www.academy4startup.com, (2) Create and maintain a more secure and secure environment (such as compliance with legal obligations and insurance compliance with the www.academy4startup.com Policies) and (3) providing, personalizing, measuring and improving our advertising and marketing.



Providing, improving and developing our website www.academy4startup.com. We may use personal information to provide, improve and develop www.academy4startup.com to:



allows you to access and use www.academy4startup.com;
operate, protect, improve and optimize academy4startup.com and user and customer experience, such as performing analytics, statistics and research;
offer your own products and services or third party customers;
sends you messages about purchased products and services, event updates or cancellations, security alerts, and account notifications;
inform you, take charge of courses and resolve any withdrawals from the contract and reimburse the value of the purchased products / services, resolve various requests / complaints of purchased products through our call center.
We process this personal information for these purposes in view of our legitimate interest in improving www.academy4startup.com and our members’ experience of this and where it is required to properly carry out your contract with you.



Creating and maintaining a more trustworthy environment. We can use personal information to create and maintain a trusted and safer environment, such as:



fraud detection and prevention (by using videos of online / webinars and, as a matter of course, learners, in applications used to deploy them (eg Zoom), security breaches and activities that are or may be banned or illegal, spam, other harmful activities;
conducting security investigations and risk assessments;
Performing database and other sources of information checks, including substantive or police checks, to the extent permitted by the applicable laws (in limited circumstances, in the case of competitions and sports games) and with your consent;
compliance with legal obligations;
resolve any dispute with any of our members and apply our agreements with third parties;
compliance with our Terms and Conditions and other policies;
security and security, in accordance with applicable and properly signed legal provisions – video recordings, with / without sound, in the classrooms.
We process this personal information for these purposes in view of our legitimate interest in protecting www.academy4startup.com and to measure the proper performance of our contract with you and compliance with the applicable laws.



Providing, customizing, measuring and improving advertising and marketing. We may use personal information to provide, customize, measure and improve our advertising and marketing, such as:



Sending promotional messages, marketing, advertising, and other information that might be of interest to you based on your preferences (including information about our campaigns and services or partners) and media advertising through social platforms such as Facebook, YouTube, LinkedIn, Instagram, etc.;
personalizing, measuring and improving our advertising;
administration polls, contests or other promotional activities or events sponsored or managed by us or third parties;
subscribing to the newsletter via email; this will not affect the frequency of administrative emails that we may send about any purchased product or service. There is no charge for sending promotional emails to you. Please note that you may not be able to benefit from certain promotions if you do not have an online user account;
invitations to local events, promotions and opportunities, experiences at www.academy4startup.com;
Making and displaying interviews taken by course participants with video recordings; postcasts through voice audio recordings; photographic images of participants in offline and online courses / seminars (webinars), educational and training programs organized by the Society; as well as the display of the testimonials of course participants, both on our academy4startup.com website and within social networks and various offline and online media communication channels.
We will process your personal information for the purposes listed in this section, given our legitimate interest in marketing to provide you with products or services that might be in your best interests.



How payment processors (payment data operators) use the collected personal information. We may use personal information as part of payment services for:



let you access and use payment services;
detect and prevent fraud, abuse, security incidents and other harmful activities;
conduct security investigations and risk assessments;
to carry out database and other sources of information checks;
comply with legal obligations (such as anti-money laundering and anti-money laundering);
apply payment terms and other payment policies.
Payment processors (payment data operators) process this personal information in view of their legitimate interest in improving payment services and user experience about it and where necessary to properly comply with your contract and to comply with laws applicable.



HOW LONG WILL WE STORE YOUR PERSONAL DATA?
We store your personal data as long as it is necessary to provide the purchased products and services, conduct the transactions you have requested or for other essential purposes, such as compliance with legal obligations, resolution of disputes and implementation of our agreements. Because these needs may vary depending on the different data types in the context of different products, actual retention periods may vary. The criteria used to determine retention periods include:

maintaining and improving the performance of our products / services, maintaining our systems safely and maintaining appropriate business and financial records;
the period for which you have expressed your consent, or until you have expressed your intention in one of the ways set forth in this policy of not retaining them;
if it’s data that you have access to, data will be stored until you delete it (e.g., deleting your account from our website);
if your data is considered sensitive, then it will be stored for a shorter period;
the situation in which a law provides for the retention of personal data, the maintenance of data relevant for an investigation or the data to be kept in the event
of a dispute.


WHERE DO WE TRANSMIT / TRANSFER PERSONAL DATA?
Your personal data may also be processed by other operators, associate operators or authorized agents of the Operator, in strict compliance with the personal data protection legislation:



IT service providers as well as all companies in these categories of recipients from whom the Operator will contract services and products and have taken appropriate safeguards as required by law to ensure that they comply with their data protection obligations personal. If the empowered persons subcontract part of the activities involving the processing of personal data, the subcontractors will be subject to the same obligations regarding the implementation of the security, technical and organizational measures foreseen by the EU General Regulation on Data Protection, but also of the internal normative acts approved for the implementation of the EU General Regulation;
the contracting parties of the Operator, acting as an associated operator, to perform outsourcing services;
State authorities on the basis of their competencies under the applicable law;
your personal information may be disclosed in connection with your social sharing activity, such as signing in to your client account in your social media account. By linking your client account and your social media account, you authorize us to share information with your social media provider and understand that the use of the information we share will be governed by the privacy policy of the social media site;
we can share your information with our service providers who handle customer information and who perform services on our behalf, such as making promotions, sending messages to customers, conducting surveys, targeting and retargeting, etc. We have not authorized any of these service providers to do any other business with your information;
we can share your information when working with another company to offer or provide our customers with products, services, contests or promotions;
we may share information about you if necessary or appropriate in good faith to comply with laws or regulations or to respond to a valid quote, order or governmental request or to protect operations, privacy, safety, property or the Operator’s rights;
if you choose to pay for our products / services at www.academy4startup.com, your personal data will be passed on to electronic payment processors who will not transfer your bank details under any circumstances. For any complaints and complaints about this information or the way an online payment is made, please contact your payment processors directly;
in the unlikely event of a sale or merger of the Company, the personal information of our customers and other information we have collected as described in this policy may be among the transferred assets.


Your data will not be transferred abroad. If your data will be transferred to other companies / entities in other countries than the EU / EEA, you will be informed accordingly.



HOW DO I CHOOSE THE PROMOTIONS I RECEIVE?
Our company only wants to communicate with you if you have expressed or expressed your consent (consent) to that effect.



However, there is also the possibility that our company will send personalized offers to you if you have made an order / subscription at least once at www.academy4startup.com without having subscribed to the newsletter or where you have an online user account created on our website www.academy4startup.com (there is a contractual relationship to use the www.academy4startup.com website), based on our legitimate interest in marketing and advertising Article 6 (1) f of GDPR).



If you prefer not to receive promotional information, such as special offers and sales events, you can contact us by contacting our customer service as described in the “How can you contact us” section: https: // academy4startup.com/contact/ or you can click on the unsubscribe links in each newsletter sent by us.

WHAT OTHER DATA WE COLLECT?
Our website uses cookies or similar technologies to provide the best experience for you and to analyze trends, manage the website, track customer use within the website, and collect demographic information about the base users as a whole.



Cookies are small text files that are placed on the client’s device to track usage and record preferences. Our cookies do not contain information that can identify people. We collect certain automated information using cookies and tracking technologies such as Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), page references / outputs, pages viewed on our site ( eg HTML pages, graphics), operating system, date / time and / or clicks to analyze the trend as a whole and administer the website. Website users can control the use of cookies at the browser level, but if the user decides to disable cookies, this action will cause some features and features to be limited to our website and services.



A breakdown of how we use cookies in the relationship with the user can be found in the Cookies Policy section found at the following link: www.academy4startup.com/politics-cookie/



HOW IS MY INFORMATICS USED FOR BEVERAGE ADVERTISING AND WHAT OPTIONS AM?
We also work with third-party companies that use tracking technologies (including cookies and pixel tags) on our site to offer personalized advertising on our behalf and on behalf of other advertisers on the Internet. These companies can collect time information about your activity on our site and on other sites as well as about your interaction with our advertising and other communications and use this information to determine what ads you see on sites and apps third party. These technologies and the information you collect about you can also be used to track your activity on multiple devices. For more information on this practice and to understand your choices, including how to opt-out of receiving these personalized ads, visit http://www.aboutads.info.



Keep in mind that, whether you opt out of them, these tracking technologies can still collect data and you will still see ads, but they will not be targeted based on the information gathered through these tracking technologies.



WHAT LINKS TO OTHER SITES WE HAVE?
Our website may contain links to other sites that may have privacy policies that differ from their own. We are not responsible for the content or practices of a linked site. We recommend that you review the privacy policy of any site you visit through our website www.academy4startup.com.



HOW TO ACCESS OR CHANGE THE INFORMATION WHICH YOU HAVE NOT TRANSMITTED?
You may request that we update your personal information by contacting us as described in the section entitled “How can you contact us?” Below. Please note that any request to update your personal information may take up to 30 days for your emailed request and for 6-8 weeks for your request through classical postal services.



HOW CAN YOU ACQUIRE YOUR CONTACT?
For questions about privacy policy, to make choices for receiving promotional communications, to update your personal information you can contact by email, phone or email.



WHAT RIGHTS DO YOU HAVE?
According to the legislation on personal data protection, you have the following rights:



the right to information: the right to receive information on the processing of our personal data;
the right of access to data: the right to obtain confirmation that we process or not your personal data and, if so, access to data and provide information about data processing;
the right to rectification: the right to obtain, without undue delay, the rectification of inaccurate personal data concerning or the completion of personal data that is incomplete;
the right to delete data without undue delay in the following situations: (1) personal data are no longer required for the purposes for which they were collected or processed; (2) You withdraw your consent for data-based processing of consent; (3) you oppose personal data processing; (4) personal data has been processed unlawfully; (5) personal data must be deleted to comply with a legal obligation to the Operator.
the right to restrict processing in any of the following situations: (1) contest the accuracy of the data; (2) personal data processing is illegal, and you do not want to delete your personal data, but you want to restrict their use; (3) The operator no longer requires personal data, but you request them for the establishment, exercise or defense of a right in court; (4) oppose your processing. If you have obtained restriction of processing, you will be further informed by us before removing the processing restriction;
the right to data portability: the right to receive the personal data that you are viewing and that you have provided us in a structured, commonly used and readable form and to transmit this data to another operator when the technical means allow this.
the right to object: the right to oppose, for reasons related to your particular situation, the processing by us which has as its legal basis our legitimate interest.
the right not to be subject to an individual automated decision, including profile creation: (any automated processing that uses personal data to evaluate certain personal aspects of you) that produces legal effects that affect you or that affect you in a similar way a significant measure.
the right to withdraw your consent at any time and without giving any reason.
For further details regarding our processing activities and for the exercise of your rights in this context, please email us to contact@academy4startup.com.



This Privacy Policy has been reviewed and amended on 27th of May 2019.