Privacy Policy

POLICY REGARDING THE PROTECTION OF PERSONAL DATA

The protection of your personal data is important to us, therefore we pay particular attention to the protection of the privacy of individuals who have provided us with their personal data, of visitors who access this site, as well as of those whose personal data was provided to us by a third party, or to which we had access from another source, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons regarding the processing of personal data and the free movement of such data (hereinafter referred to as “GDPR”).

Please pay special attention to reading the following Policy (hereinafter referred to as “PPD”) to understand how your information (“personal data”) will be treated.

The PPD explains the practices of BOONCO WORKS SRL (hereinafter referred to as “Enneagram Coaching” or “OUR ORGANIZATION”), regarding the application of the provisions of the GDPR, as well as the rights you enjoy regarding the way in which your information is processed by OUR ORGANIZATION.

The processing of personal data carried out by Enneagram Coaching will always be carried out in accordance with the provisions of the GDPR, as well as with the regulations on the protection of personal data, specific to each country in which Enneagram Coaching operates.

Through the PPD, OUR ORGANIZATION wishes to inform the data subjects about the nature of the personal data we collect and process, as well as about the purposes of the processing. In addition, data subjects are also informed through the PPD of their rights.

DATA PROCESSOR

This website, enneagram.ro, belongs to the Enneagram Coaching organization, with headquarters in Rasaritului str, no 51, room 1, apartment 2, sect 6, Bucharest 39824261.

DEFINITIONS

PERSONAL DATA

“Personal data” means any information that can identify you directly (for example, your name) or indirectly (for example, through pseudonymous data, such as a unique identification number). This means that personal data includes things like your email address, home address, mobile phone, username, profile photos, personal preferences and shopping habits, user-generated content, financial information and financial status information. It could also include unique numeric identifiers, such as your computer’s IP address or your mobile device’s MAC address, as well as cookies.

PERSONAL DATA PROCESSING?

“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, organization, structuring, storage, adaptation or modification, extract, consult, use, disclose by transmission, disseminate or otherwise make available, align or combine, restrict, delete or destroy.

WHAT ARE YOUR PERSONAL DATA THAT WE PROCESS?

Your personal data that can be processed, without being limited to, are the following: name, surname, physical address, e-mail address, city, county.

PERSONAL DATA OPERATOR

The operator of personal data (hereinafter referred to as the “operator”) is Enneagram Coaching.

DATA PROCESSING PRINCIPLES

OUR ORGANIZATION undertakes to comply with the personal data protection principles (hereinafter referred to as the “Principles”) provided by the GDPR, to ensure that all data is:

  1. Processed fairly, legally and transparently;
  2. Collected for specified, explicit and legitimate purposes;
  3. Adequate, relevant and limited to the purposes for which they are processed;
  4. Correct and up-to-date;
  5. Kept in a form that does not allow the identification of the data subjects for longer than is necessary in relation to the purpose of the processing;
  6. Processed in accordance with the rights of the data subject, in a way that ensures adequate security of the processing, so that the data is intact, confidential and available.

BASIS AND PURPOSES OF PERSONAL DATA PROCESSING

  1. For the purpose of concluding and executing contracts – According to art. 6 paragraph 1 section b) of the GDPR, specific personal data may be processed. In order to be able to offer you our products and services, we need to process your personal data.
  2. For the purpose of fulfilling legal obligations – According to art. 6 paragraph 1 section 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 personal identification number, in order to fulfill our obligations imposed by the tax authorities in relation to invoicing and reporting to the tax authorities.
  3. In order to fulfill the duties established by law 335/2007 with subsequent additions – According to art. 6 paragraph 1, section a) of the GDPR, personal data may be processed if the data subject has given his consent to the processing of his personal data for one or more specific purposes. Thus, in certain situations, your personal data will be used for purposes such as: carrying out the commercial/contractual activity and, to the extent you have agreed, for the purpose of marketing, promotion, advertisement, publicity, etc., in order to keep up to date with OUR ORGANIZATION’s products, services and initiatives.

PROCESSING THE CONTACT FORM

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

By providing any personal data through the website www.enneagram.ro, you understand and agree that your data will be processed in accordance with the PPD provisions of Enneagram Coaching.

Please note that in order to be able to process your requests submitted in the contact section of the website, it is possible that, under certain circumstances, we are obliged to disclose your data to partners with whom Enneagram Coaching collaborates and/or others third party service providers of OUR ORGANIZATION.

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

Enneagram Coaching undertakes not to process the personal data provided for a purpose other than that for which it was transmitted, except in situations where there is your express consent to use it for other purposes as well.

It is also possible for Enneagram Coaching to have access to other personal data as determined by a link with Enneagram Coaching, by processing the data communicated following telephone conversations, e-mail conversations, presentation at our headquarters in order to obtain information, etc.

By contacting Enneagram Coaching in any manner stipulated above or any other method involving mediated or direct communication between you and OUR ORGANIZATION, you understand and agree that your data will be processed in accordance with Enneagram Coaching’s PPD.

DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

The personal data processed by OUR ORGANIZATION may be disclosed and/or transferred to third parties only in the situation where there is your express consent to do so, except in situations where there is a legal/contractual obligation for OUR ORGANIZATION to proceed in this way.

Please keep in mind that in certain circumstances we may be required to disclose your personal data to partners with whom Enneagram Coaching collaborates and/or to other third-party service providers of Enneagram Coaching.

DATA PROCESSING BY THIRD PARTIES, OTHER SITES AND SPONSORS

The www.enneagram.ro website may contain, at any given moment, access links to other sites whose data processing policies may be different from those of Enneagram Coaching.

Please consider and consult the privacy policies of the other sites, Enneagram Coaching assumes no responsibility for the information submitted or collected by these third parties.

AUTOMATIC DATA PROCESSING. COOKIE

The www.enneagram.ro website uses cookie identifiers. In this regard, you can consult our Cookie Policy, available on the website, and you can exercise your right to disable Cookies, as specified below.

DATA STORAGE PERIOD

Enneagram Coaching can keep the processed data for different periods of time, judged to be reasonable, in accordance with the purposes indicated above. We keep your data only for the period necessary to achieve the purpose for which we hold the data, to satisfy your needs or to fulfill our obligations imposed by law.

To know how long your data can be kept, we use the following criteria:

  1. When you use our services we keep your personal data for the duration of our contractual relationship;
  2. If you participate in a promotional offer, we keep your personal data for the duration of the promotional offer;
  3. If you contact us with a question, we keep your personal data for the time necessary to process your questions, but no longer than 5 years after the last correspondence sent;
  4. 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). In this case, we note that the data processed for this purpose will be deleted 5 years after the last interaction with the account’s user (such as, for example, last logging in into your account);
  5. Where you have provided your consent for marketing, we retain your personal data until you unsubscribe or ask us to delete it, or after a period of inactivity (without active interaction with our brands) defined in accordance with local regulations and guidelines. In this regard, we note that the data stored in our databases for the purpose of direct marketing communications is deleted from the records of these databases 5 years after the last interaction with you;
  6. If cookies are stored on your computer, we keep them for as long as necessary for them to achieve their purposes (for example, for the duration of a session for shopping cart cookies or user ID cookies session) and for a defined period in accordance with local regulations and guidelines. In this regard, we note that the data processed by the cookie modules used to provide online behavioral advertising, to personalize our services for you and to allow the distribution of our content on social media sites (sharing buttons intended to display the site), will be kept for a maximum period of 1 year from their collection, based on your consent.

YOUR RIGHTS

In accordance with the GDPR, you have a number of rights regarding the personal data that Enneagram Coaching processes:

  1. Right of access to data processing – You have the right to access the personal data we hold. The first provision of information will be made free of charge. If you require further copies of information already provided, we may charge a reasonable fee taking into account the administrative costs of providing the information. Unfounded, excessive or repeated requests may not receive a response.
  2. Right to data rectification – You have the right to request that your Data be rectified if it is inaccurate or out of date and/or complete it if it is incomplete. If you have an account, it may be easier to correct your own data via the “My Account” tab.
  3. The right to data erasure (“the right to be forgotten”) – In some cases, you have the right to obtain the erasure or destruction of your Data. This is not an absolute right as we may sometimes be forced to retain your Data for legal reasons.
  4. The right to restriction of processing – You have the right to request the restriction of processing of your Data. This means that the processing of your Data is limited so that we may retain the Data but not use or process it. This right applies in specific circumstances provided for by the General Data Protection Regulation, namely:
  5. – the accuracy of the Data is disputed by the data subject (i.e. you), for a period that allows the operator (i.e. Enneagram Coaching) to verify the correctness of the Data;

– the processing is illegal and the data subject (i.e. you) opposes the deletion of the Data and requests the restriction of its use;

– the operator (OUR ORGANIZATION) no longer needs the Data for processing, but it is requested by the data subject (i.e. you) to establish, exercise or defend legal claims;

– the data subject (i.e. you) has objected to the processing based on legitimate grounds by the controller (in this case Enneagram Coaching) based on the verification that the legitimate grounds of the controller (Enneagram Coaching) outweigh those of the data subject (i.e. you).

  1. 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 data that you have provided, where the processing is based on your consent or on the basis of a contract and is implemented by automated means.
  2. Right to object – You can object at any time to the processing of your data when such processing is based on a legitimate interest.
  3. Right to withdraw consent at any time – You may withdraw your consent to the processing of your data where such processing is based on consent. Withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal.
  4. The right to file a complaint with the competent supervisory authority – You have the right to file a complaint with the data protection authority in your country of residence or domicile to challenge the data protection practices offered by OUR ORGANIZATION.
  5. 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. It’s easiest to do this by clicking on the “unsubscribe” link in any email or communication we send you.
  6. The right to object to the processing of your data by us when we carry out actions in the public interest or in our own or a third party’s legitimate interests – You can object at any time to the processing of your data when such processing is based on a legitimate interest.
  7. The right to disable Cookies – you have the right to disable cookies. Internet browser settings are usually programmed by default to accept cookies, but you can easily adjust them by changing your browser settings. Many cookies are used to enhance the usability or functionality of websites / applications; therefore, disabling cookies may prevent you from using certain parts of our websites or applications, as detailed in the relevant Cookie table. If you wish to restrict or block all cookies set by our websites/apps (which may prevent you from using certain parts of the website) or any other websites/apps, you can do so through your browser settings . The Help function in your browser will tell you how. For more information, see the following links: http://www.aboutcookies.org/;

You can exercise any of these rights in relation to the personal data that Enneagram Coaching processes by making a simple request to Enneagram Coaching’s DPO. In such a situation we may very well ask for proof of your identity.

LEGAL REQUESTS

We access, retain and provide your information to regulatory authorities, law enforcement or other entities:

  1. In response to a legal request, when we believe in good faith that the law requires us to do so. We may also respond to requests of a legal nature when we believe, in good faith, that the response required by the laws of that jurisdiction affects users in that jurisdiction and conforms to internationally recognized standards.
  2. When we believe, in good faith, that it is necessary to: detect, prevent and respond to acts of fraud, unauthorized use of any material belonging to us, violations of our terms or policies, or other harmful or illegal activity, to protect us (including our rights, property or materials), you and others, including in the context of investigations or inquiries by regulatory authorities or to prevent imminent death or personal injury. For example, if relevant, we provide information to and receive information from third parties about the reliability of your account to prevent fraud, abuse and other harmful activity within and outside of our materials.

The information we receive about you may be accessed and stored for a longer period of time when it is subject to a legal request or legal obligation, a government inquiry, or investigations into possible violations of our terms or policies, or in other cases to prevent damages.

RELATIONS WITH OTHER OPERATORS

Depending on the context, we may find ourselves in the situation of the absolute need to provide information at a higher level, both globally and internally or externally, to our partners and those with whom we transfer data in compliance with the GDPR, ensuring the provision of the most professional services possible. Information controlled by Enneagram Coaching may be transferred, transmitted or stored and processed in the EU or in countries other than your country of residence for the purposes described in this policy. These data transfers are necessary to be able to provide services at the highest level, as well as to continue to provide you with our materials at the best professional level. We use standard contractual clauses approved by the European Commission and rely on country-specific adequacy decisions issued by the European Commission, as appropriate, with respect to transfers of data from the EEA to the United States and other countries.

PROCESSING SECURITY

Enneagram Coaching has adopted technical and organizational data processing measures, updated in accordance with GDPR requirements, with the aim of protecting your personal data against any actions of unauthorized access, misuse or disclosure, unauthorized modification, destruction or accidental loss. All employees and collaborators of Enneagram Coaching, as well as any third parties acting on behalf and on behalf of Enneagram Coaching, are required to comply with the confidentiality of your information and the requirements of the GDPR, in accordance with the provisions of the PPD.

DISCLAIMER OF LIABILITY

The www.enneagram.ro website may contain links to other sites and/or other web pages that are not the property of Enneagram Coaching. OUR ORGANIZATION assumes no responsibility for the content of these sites and therefore cannot be held responsible for the content, advertising, goods, services, software, information or other materials available on or through these sites. Enneagram Coaching will not be responsible for the loss of personal data, any negative effects on visitors’ personal data or other moral and/or patrimonial damages caused by access to the respective sites.

UPDATES TO THE PROTECTION AND PROCESSING OF PERSONAL DATA POLICY

Please keep in mind that this Policy may be subject to periodic content changes, by updating the www.enneagram.ro website.

How will we notify you of changes to this Policy?

We will notify you before we make any changes to this Policy and give you the opportunity to review the revised PPD before choosing to continue using our materials.

Please do not continue to use the www.enneagram.ro website if you do not agree with such changes. We also recommend checking this page for any updates.

The terms of the PPD shall be construed in accordance with applicable law.

CONTACT

If you have any questions or concerns about how we treat and use your personal data or wish to exercise any of your rights, please contact us at anca@enneagram.ro.