PRIVACY AND COOKIE POLICY

I. INFORMATION ABOUT THE PERSONAL DATA OPERATOR AND CONTENT OF THIS POLICY

MENTAL COACHING FOR PERFORMANCE SRL, legal entity without patrimonial purpose, based in Bucharest, 79 Viscolului Street, Bucharest, sector 6, registered in the Trade Register under no. J40 / 10570 / 17.06.2021, fiscal registration code 44455799, legally represented by Mrs. Alexandra Nae-Dumitrescu - Administrator is the operator of personal data processed through the website www.alexandra-nae.ro (also called "website"), telephone number 0736.709.521 and e-mail addresses belonging to SRL- .

Under this Privacy and Cookies Policy (also called the "Policy"), the term "personal data" has the meaning set out in the applicable law and refers to any information about an identified or identifiable individual; An identifiable person is a person who can be identified directly or indirectly, in particular by reference to an identifying element or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity ( also called “Data”).

As the protection of personal data is a fundamental obligation of the Association, it acts with the utmost diligence when processing such Data, in accordance with the provisions of the General Data Protection Regulation 2016/679 / EU on the protection of individuals with regard to the protection of personal data. concerning the processing of personal data and on the free movement of such data, and repealing Directive 95/46 / EC (hereinafter referred to as "RGPD"), as well as national data protection legislation, including Law no. 190/2018 on measures to implement the RGPD.

The object of the policy is the confidentiality of the data belonging to the following categories of data subjects: website visitors, potential beneficiaries of the / services provided by SRL through the website www.alexandra-nae.ro, individuals who contact the SRL, as well as and Data belonging to the representatives of the contractual partners and potential employees and / or collaborators, persons participating in training courses or events organized by or with the involvement of the LLC and apply to the Data collected through this website, as well as the Data that the SRL- collects them through the platforms www.depreter.ro and www.paxonline.net and the e-mail addresses belonging to the SRL.

The policy includes detailed information on:

• the purposes for which the LLC collects and uses the Data;

• the grounds for data processing;

• the categories of Data that the SRL processes;

• Data source;

• duration of the Data processing process;

• recipients of the Data (persons to whom the LLC may disclose the Data);

• your rights as a data subject and how you can exercise those rights;

• use of cookies

II. PURPOSE OF DATA PROCESSING, DATA CATEGORIES AND PROCESSING GROUNDS

1. When using the website

Purpose:

The legitimate interest of the LLC to monitor the activity on the website and to ensure its functionality.

Data Categories:

Internet Protocol (IP) address, the general location of your computer or device (city level), browser type, operating system, access date, page link accessed, website page viewing history , device information, viewed programs, device id (notifications and identification), timestamp, request / action.

Basis:

The legitimate interest of the Operator (art. 6 paragraph 1 letter f of the RGPD).

The website also uses cookies, which you can read about in Chap. VIII below. For the use of cookies that are not strictly necessary for the functionality of the website, your consent is required, which the SRL requests when entering the website. Your cookie options may be changed at any time by following the instructions in Chap. VIII below.

2. When you create a user account

Purpose:

User account administration.

Data Categories:

The website is specifically designed to provide psychological counseling services, which is only possible if you create a user account by filling out the dedicated form.

If you create a user account, SRL will process all the data mentioned in the respective forms and provided directly by you (such as name and surname, username and password, e-mail address).

Basis:

In order to take steps at your request, prior to concluding a contract (art. 6 paragraph 1 letter b of the RGPD)

3. When you log in to the user account and use the tools provided in the account (you are a potential beneficiary / beneficiary of the psychological services offered by SRL)

Purpose:

Providing counseling, testing and psychotherapy services through the tools available in the user account.

Carrying out the registration formalities within the events organized by SRL.

Data Categories:

Identification data (name and surname, age, sex, as well as any other data provided by you voluntarily in the context of providing psychological counseling services), health data.

Identification data (name, surname), contact details (telephone number, e-mail address).

Basis:

Carrying out the steps for concluding and executing the contract for the provision of psychological counseling services (art. 6 paragraph 1 letter b of the RGPD);

Processing is necessary for purposes related to the provision of medical or social assistance (art. 9 para. 1 letter h of the RGPD).

The processing is carried out in order to carry out the steps for concluding and executing the contract for the provision of psychological counseling services (art. 6 paragraph 1 letter b of the RGPD).

4. If you contact the LLC (via contact and scheduling forms and / or email)

Purpose:

Maintaining a contractual relationship and communicating with you.

Making an appointment for a specialist consultation.

Communication of information requested by the data subject.

Data Categories:

Name and surname,  age, gender, e-mail address, and any data you provide directly to the LLC via e-mail.

Name and surname, age, sex, e-mail address, as well as any data that you provide directly to the SRL through the appointment form.

Name and surname,  age, sex, e-mail address, as well as any data that you provide directly to the SRL through e-mail correspondence / contact form.

Basis:

In order to take steps before concluding the contract and respectively the execution of the contract to which you are a party (art. 6 paragraph 1 letter b of the RGPD).

In order to take steps before concluding the contract and respectively the execution of the contract to which you are a party (art. 6 paragraph 1 letter b of the RGPD).

The legitimate interest of the Association for the promotion of its activities and the attraction of new members (art. 6 paragraph 1 letter f of the RGPD).

5. If you are a person who participates in training courses or events organized by or with the involvement of the LLC

Purpose:

Conducting events organized by or with the involvement of the LLC.

Data Categories:

Name and surname, age, gender, photo / video recordings and other personal data that are provided to your LLC directly or by the organizer of the event you attended, as appropriate.

Basis:

The legitimate interest of the LLC to increase the degree of awareness regarding the rights, freedoms and obligations of citizens, according to the mission of the LLC and its field of activity (art. 6 paragraph 1 letter f of the RGPD).

6. If you subscribe to the newsletter service

Purpose:

Sending, in electronic format, the informative notes of the SRL regarding the activity carried out by it, but only if you have given your express consent regarding this processing by subscribing to the newsletter.

Data Categories:

Name and surname, e-mail address, telephone number, address, and other personal data that you may communicate directly.

Basis:

Your express consent (art. 6 paragraph 1 letter a of the RGPD).

You may withdraw your consent at any time by expressing your option not to receive further information notes in the future by clicking on the "Unsubscribe" link upon receipt of the email or by submitting a request to that effect. using the contact details shown in Chap. VI below.

III. DATA SOURCE

If, in order to carry out the activities mentioned above for your benefit, it is necessary for you to directly provide certain Data to the LLC, please communicate all the categories of Data requested for the purposes mentioned in Chap. II above. If you do not provide the SRL with accurate / complete data, we inform you that the SRL may not be able to carry out its activity or provide you with the requested services, in some cases it will not be possible to conclude the contract between you. and SRL.

You will not be able to use your account features without providing your credentials. The SRL has configured the required fields so as to request the minimum amount of information it needs to identify you and be able to benefit from the requested services.

If, in order to carry out the above-mentioned activities for the benefit of third parties, but at your request, it is necessary to provide the Data Association belonging to those third parties, please inform them before disclosing the Data concerning them, about how SRL- intends to process the Data as set out in this Policy.

IV. DURATION OF THE DATA PROCESSING PROCESS

The LLC will store the Data that it collects and processes in accordance with this Policy for the entire duration of the contract concluded between the data subject and the LLC, as well as after the termination of the contract, in accordance with the personal data processing policy applicable to the LLC and with the legal obligations incumbent on the Operator.

If the Data are not processed in the context of the conclusion and execution of a contract, these Data will be kept for as long as necessary to fulfill the purpose of processing the Data and for the following periods of time, but without the listing below. an exhaustive character:

1. The data associated with your account is retained for 60 days from the date of account closure, except for invoices that are retained for the duration mentioned in point 3 below;

2. 10 years for the supporting documents underlying the entries in the financial accounts, calculated from 1 January of the year following the transaction;

3. 3 years for photographic images / video recordings made in the context of your participation in an event organized by or with the involvement of SRL;

4. The end of the recruitment period, but not more than one year from the date of application for a position within the LLC / from the date of expressing the agreement regarding the data processing for future recruitment campaigns.

V. RECIPIENTS OF DATA

Although, as a general rule, we will not disclose Third Party Data, we may disclose the required portion of your personal data only to the extent necessary and only to the following categories of third parties / subsequent third parties:

• entities that provide the SRL with relevant services for the website, such as traffic analysis, integrations with social media services, marketing service providers (newsletters), website advertising providers, IT system providers, maintenance service providers and providers services of the LLC (including proxies), in particular in order to facilitate the obtaining of discounts and benefits deriving from the contractual relations concluded with them. A list of them can be obtained on request. Regarding the companies that place cookies through the website, you can find this information in Chap. VIII below;

• public authorities and institutions, accountants, auditors, lawyers and other external professional advisers, if their activity requires knowledge of the Data, or if the LLC has a legal obligation in this regard;

• nutritionists, sports counselors, alternative therapists, psychiatrists, and other health professionals, if you have given your consent;

• to the general public, by publishing photographic / video images recorded in the context of events organized by or with the involvement of SRL, on the websites www.alexandra-nae.ro or on social platforms such as Facebook (details on how your data are processed personally on this platform can be found here).

VI. YOUR RIGHTS AND EXERCISE

Under the provisions of the RGPD, you have the following rights:

1. the right to access personal data - the right to obtain confirmation that personal data are processed by the LLC and, if so, to be up to date with the relevant details of these processing activities;

2. the right to rectification of personal data - the right to obtain the rectification of inaccurate personal data or to supplement the processing of personal data;

3. the right to delete data - the right to obtain the deletion of personal data, in compliance with the legal provisions in force (for example, if the data are no longer necessary in connection with the purposes for which they were collected);

4. the right to restrict the processing - the right to obtain, to the extent that the legal conditions are met, the limitation of the further processing of personal data concerning you;

5. the right to data portability - the right to receive personal data in a structured, commonly used and easy-to-read format, as well as the right to have this data transmitted by the LLC to another data controller, to the extent that the technical and legal conditions are met;

6. the right to object - the right to object at any time, for good and legitimate reasons related to your particular situation, to the personal data concerning you being processed, provided that the legal conditions are met;

7. the right not to be subject to an automatic decision or additional profiling related to automatic decisions - the right to request and obtain the withdrawal, cancellation or re-evaluation of any decision based solely on processing by automatic means (including profiling) which produces legal effects what concerns you or affects you in a similar way to a significant extent;

8. If your consent was required for the processing of certain personal data, you have the right to withdraw this consent at any time, which will not affect the lawfulness of the processing before the withdrawal of consent;

9. the right to file a complaint - you have the right to file a complaint with the National Authority for the Supervision of Personal Data Processing (ANSPDCP), by accessing the dataprotection.ro website.

In order to exercise your rights, please send your written request, dated and signed to the e-mail address psiholog.alexandra.nae@gmail.com - for the attention of Ms. Alexandra Nae.

SRL will process any request regarding personal data promptly, and will be informed within a maximum of one month from the receipt of your request regarding the actions taken in order to exercise one or more of the rights listed above. However, the above-mentioned period of one month may be extended in duly justified cases by a maximum of two months, taking into account the complexity and number of applications received, in which case you will be duly informed within a maximum of one month. one month after receiving your request.

ARE YOU COMING. AUTOMATIC INDIVIDUAL DECISIONS

Traditionally, the Operator does not use decision-making based solely on automatic processing, including profiling, which produces legal effects that affect or similarly affect you to a significant extent.

If you use the assessment and treatment tools or personal development for psychological symptoms on the website www.depreter.ro / www.paxonline.ro / www.alexandra-nae.ro, some tools may use forms automatic data processing by assessing personal aspects related to health, preferences or personal interests, as a result of which decisions are generated based on the algorithms of those platforms. In this case, you have the right to obtain human intervention from the Operator, to express your point of view and to challenge the decision.

VIII. COOKIES

1. WHAT ARE COOKIES AND WHAT ARE THEY USED FOR?

A cookie is a small file, consisting of letters and numbers, that is stored on the computer or mobile device from which the Internet is accessed. It consists of two parts: name and content / value.

The lifespan of a cookie is limited, and may vary significantly depending on the purpose of the placement. As you can see below, some cookies are used exclusively for one session (session cookies) and are not saved after the user closes the website, while other cookies are saved and reused by each once the user accesses the site (persistent cookies). However, cookies can be deleted by the user at any time from the browser settings.

From a technical point of view, only the web server that sent the cookie can access it again when the user returns to the site associated with that web server.

In addition to its own cookies, which are set on the website by its owner, SRL also uses third-party cookies, which are set by third parties. Third-party providers must also comply with the legal regulations in force and the privacy policies of the website owner.

SRL uses the necessary cookies to ensure the proper functioning of the website (for example, to remember that the visitor has logged in to the account). These cookies are automatically active, and their consent does not require the visitor's consent.

Additionally, SRL uses statistical / analysis cookies, through which the owner of a website understands how visitors interact with the website by collecting and reporting information anonymously. This type of cookie makes the experience of using the website to a high standard and at the same time allows measuring the audience, while also helping to improve the way the website works. Although cookies are unique identifiers, website usage statistics do not show information about individuals. Also, to exercise your right not to be tracked by Google Analytics, please visit http://tools.google.com/dlpage/gaoptout.

Last but not least, SRL uses advertising profiling cookies to allow the personalization of online advertising. This mechanism is widely used in the online industry, and the SRL applies it in order to make it possible to fulfill its mission and provide certain services using advertising funding. Since these cookies are placed by services controlled by SRL, and not by the advertising entity, the profiling through these cookies is performed by SRL as a data operator. You can opt out of being targeted by Google for advertising purposes at https://www.google.com/settings/ads.

2. USER COOKIE OPTIONS

Cookie options are configurable within the website. You can choose the desired level at any time, the default one being to accept only the necessary cookies.

It is important to note that disabling or refusing to receive cookies may make it difficult to view and use certain sections of content.

Stopping cookies. Most internet browsers are configured by default to automatically accept cookies. Users can configure their browser to reject all cookies or to alert the user when cookies are sent to the device. All modern browsers offer the ability to change cookie settings. You can configure your cookie settings by following the instructions at the following links:

Cookie settings in Internet Explorer

Cookie settings in Mozilla

Cookie settings in Safari

Cookie settings in Chrome

IX. POLICY CHANGES

This Policy is updated on the date it appears at the top of the document. SRL has the right to modify, when necessary, the data processing practices and to update and modify this Policy at any time. For this reason, in order to be up to date with up-to-date information on how SRL processes your Data, we encourage you to periodically check this document.