Data protection policy
Last update: 02 February 2024
This policy details the Company's practice with regard to the processing of personal data of users of https://highlifementoring.maxwellleadership.ro/ (hereinafter referred to as the Site) as persons interested in purchasing tickets for the Step up and take the lead event (hereinafter referred to as the Event), with the aim of informing users about this subject.
Following the purchase of tickets to the Event, as detailed in the Terms and Conditions and within the limits indicated therein, the user will be entitled to access the https://www.johnmaxwellacademy.ro/ platform where he/she will be able to access various materials, depending on the type of ticket paid for, according to the information on the Event website. The way in which his/her personal data will be processed on that platform, as well as on any other related online platforms, is set out in the policies therein. Thus, this present Data Protection Policy, Cookie Policy and Terms and Conditions relate strictly to the Event page.
By using the Site further, you acknowledge that you have read and agree to this Data Protection Policy, the Cookie Policy, and the Terms and Conditions, all of which are posted on the Site.
CONTENTS:
1.Identification of the data controller
10.Data processing and storage time
11.Rights of the data subject with regard to the processing of personal data
12.Obligations of the Company. Security measures for processed data
14.Transfer to third countries/international organisations
Highlife Mentoring SRL (hereinafter referred to as the Company or HM)
Registered office: Romania, Timișș county, Timișoara, str. Gheorghe Lazăr nr. 24, et. 4, ap. SAD 29 (Fructus Plaza)
Registered at the Trade Register of the Timis Court under no. J35/1290/2010
Unique registration code RO46231968
Email: office@maxwellleadership.ro
Tel: +40.771.706.337
HM collects information from users of the Site in the following ways: directly from the user, from traffic reports recorded by the servers hosting the Site, and through cookies.
Information provided directly by the user:
Other personal data may be processed by the Company in case they are included in the information/request submitted by the user (e.g. additional contact data, data on the persons who will be able to access the user's account, etc.). Thus, HM has not requested such data, but to the extent that they are necessary to be able to respond to what has been transmitted, the processing of personal data will be carried out at the request of the Site user.
Using the email address or phone number in the "Contact" form is not mandatory for visiting the Site or purchasing tickets for the Event. Moreover, all this information can also be submitted in other ways (e.g. by asking a question at the Company's location or on HM's social media profiles).
In order to complete the purchase of the tickets, the data necessary for the payment of the price will be filled in (it is possible to pay by card or by bank transfer, in full or in instalments - see the Terms and Conditions for details on this subject), i.e. holder name, card number, bank - all of which may be personal data processed after pressing the "Register" button.
The purchase of tickets requires acceptance of the three check boxes at the end of the account creation form, related to the Terms and Conditions and Data Protection Policy, as well as the minimum age limit for Event participants.
You can choose to be added to the list of recipients of newsletters sent by HM by ticking the appropriate box at the end of the "Let's connect" section or on the first page of the Website by clicking the "Send" button.
The user who has chosen to receive newsletters from HM will be able to unsubscribe at any time by simply clicking on the active "Unsubscribe" link at the end of each communication received from the Company.
Information from the server traffic report:
When a website is visited or an application is used, users reveal certain information about themselves, such as IP address, time of visit, location from which the Site was accessed. HM, like other companies, records this information.
If a visitor to the Site has not completed a ticket order but has provided an email address or telephone number, the Company may email or contact the user for further information in this context.
Information obtained through the use of cookies:
Full details of how data is processed in this context are set out in the Cookie Policy on the Site.
The contact details that the user can use to submit any requests, notifications or complaints regarding this Data Protection Policy, the Terms and Conditions and the Cookie Policy, as well as any other information published on the Site, policies or operations carried out by the Company, are indicated in point 1 above.
The deadline for the Company to send a response is no later than 30 days after receipt of the request.
The company confirms that none of the personal data indicated above will be used for purposes other than those expressly indicated without complying with the legal provisions.
Since the Company processes personal data of the users of the Site, they are considered as Data Subjects. In the case of users who are legal entities, certain personal data of their representatives who are natural persons will be processed in accordance herewith.
By using the Site, each user assumes that he/she can take the steps required when filling in forms, purchasing tickets to the Event and generally using the Site, as well as sending messages, being over 18 years of age and can express his/her valid consent (where applicable) freely and without the need for prior approval from a third party that has not been obtained by that user.
In the event that the information/requests/forms submitted by users also contain personal data relating to other persons (and they thus acquire the status of data subject), the Company will process their data strictly in order to be able to respond to that information/request and does not assume any liability in addition to that provided for herein, in the Terms and Conditions or in the applicable legislation.
Any information relating to an identified or identifiable natural person, i.e. the Data Subject, may be personal data.
With regard to the purposes of the data processing indicated herein, the Company seeks to minimize the personal data processed.
Thus, according to the Cookie Policy, the Data Subject will be able to tick the applicable types of cookies where their use is not automatic, in order to ensure him/her a more complete and better experience when browsing the Site.
In order to send answers to requests/submissions communicated by users using the "Contact" form or telephone discussions with HM representatives by users, to purchase tickets to the Event via the "I register now" section or to send information for marketing purposes via the "Let's connect" or "Register now" sections, the Company processes the following personal data:
Depending on the cookie settings, other data may also be processed (in particular data related to user preferences and behaviour on the Site).
each user who sends a message can indicate there personal data of other persons. The company did not request them.
Depending on the content of the messages sent by users using the "Contact" form, other data may be processed to the extent indicated, although not requested.
The company undertakes to comply with the legislation on the protection of personal data also in relation to these third parties, without, however, being obliged to obtain any separate consent in this regard. It is the user who has transmitted such information who assumes full responsibility in this respect and declares that they have agreed to the processing carried out by HM and have been fully informed in this respect.
Processing is the carrying out of any operation or set of operations on personal data or on sets of personal data, whether or not by automatic means.
The Company accesses, collects, stores, uses and performs any other steps permitted by applicable law on personal data provided by users as indicated in point 4 above.
The Company processes the data of the users of the Site according to the purposes described below:
If the Company intends to further process the personal data for a purpose other than those indicated above, it will provide the Data Subject prior to such further processing with additional relevant information on the secondary purpose, subject to completion of the formalities required by law.
Personal data of the Data Subject are processed by:
The above list of suppliers is not exhaustive, but indicates the main such collaborating companies. They will be independent operators, associated operators or processors in relation to the Company. Regardless of their capacity, they are obliged to maintain the confidentiality and security of the data subject's personal data by taking appropriate technical and organisational measures.
Although they are not recipients according to legal interpretations, public authorities (including ANPC and ANAF) and courts may process any/all of the user data obtained through the Site.
The data processing activities carried out by the Company mainly concern:
The storage period of personal data collected is:
Upon expiry of the above-mentioned periods, all data will be deleted from the Company's records.
The Company's internal rules and policies are available to the Data Subject at all times and are posted on the Website. See in this respect this Policy, the Cookie Policy and the Terms and Conditions.
The Company reserves the right to modify/update the content of the Site, including the policies referred to, at its sole discretion, at any time and for any reason (including but not limited to the occurrence of legislative or case law changes that may affect the consequences of what is published on the Site). Future revisions to this policy will be indicated by a change to the "Last Updated" date at the top. After the date on which the updated policy is published, access to the Site will constitute the user's acceptance of those updated terms.
However, if there will be significant changes that could affect the rights and freedoms of users or it is mandatory to obtain their consent, informing them of such changes will be done by easily visible indications posted on the Site (pop-ups) or by sending e-mails to the addresses provided if applicable. Such significant changes will take effect for users within 15 days from the time of display of the pop-up in question or transmission of the e-mail by the Company (the manner in which the information will be provided will be decided by HM on a case-by-case basis).
Regardless of the extent of the change, however, the responsibility for checking the content of the Site to keep up to date with the latest versions will rest entirely with the user. Thus, STUDYING THIS DATA PROTECTION POLICY, TERMS AND CONDITIONS AND COOKIE POLICY IS A MUST FOR USERS EVERY TIME THE SITE IS ACCESSED AND BEFORE ANY RECORDS OR DATA SUBMISSIONS ARE MADE WHEN CHANGES MAY OCCUR.
Upon request, the Data Subject will be informed of the substance of the contracts concluded with the above recipients where possible and of the source of the data.
If the Data Subject would like information about the processing, he or she may send a request to the Company, which will reply within 30 days of receipt.
If the Data Subject wishes to rectify/complete the data, he or she may submit a request to the Company, which will respond within 30 days of receipt.
If the data subject wishes to have his/her personal data deleted, this is possible:
The cases of exception provided for in Article 17(1)(a) and (b) shall be excluded. 3 of European Regulation No 679/2016 are applicable.
Some data are part of the Company's records, which it keeps in relation to its legal obligations or legitimate interest. Therefore, not all data can be deleted, according to the law. However, any refusal to delete will be justified by the Company and will be based on a clear legal ground.
The restriction of processing may apply if the Data Subject finds that:
The Company may continue to process the restricted data if it is necessary for the establishment, exercise or defence of legal claims or the protection/defence of a person but only with the consent of the Data Subject.
The Company will communicate to recipients the rectification, erasure or restriction of data unless this is impossible or involves disproportionate effort.
The data subject or the person indicated by him may receive, upon request, the data processed by the Company. HM does not assume responsibility for the processing of the data by that recipient.
The obligation to ensure the right to portability is incumbent on the Company only if the processing of those data is based on the consent of the Data Subject or on the conclusion and performance of the contract. The steps shall be taken within a maximum of 30 days of receipt of the request.
If possible, the Company will stop the processing of the Data Subject's data who objects to the processing based on HM's legitimate interest or circumstances arise that give rise to the exercise of this right (including profiling).
However, the legitimate reason of fulfilling the Company's legal obligations or processing for the purpose of establishing, exercising or defending a right in court shall prevail.
The person concerned may submit:
However, the company wants any conflict/difference to be resolved amicably and is willing to do so.
The data subject may withdraw his or her consent at any time, without however affecting the lawfulness of the processing prior to the withdrawal or that based on another ground.
The company does not practice decision making based on automated data processing.
The company complies with the provisions of data protection legislation and has implemented appropriate technical and organisational measures to ensure the security of personal data processed and respect for the rights of Data Subjects. Thus, the Company has implemented measures such as:
The Company will also inform the competent data protection authority in the event of a data security incident without undue delay and, if possible, no later than 72 hours after becoming aware of it, unless it is unlikely to result in a risk to the rights and freedoms of individuals. If the notification to the authority is not made within 72 hours, it shall be accompanied by a reasoned explanation for the delay.
In the event of an incident involving the security of personal data, HM will also inform the Data Subject without undue delay if the breach of security of personal data is likely to result in a high risk to his/her rights and freedoms. However, the aforementioned information to the Data Subject is not required if any of the following conditions are met:
Any HM user traffic statistics that we provide to third party advertising networks or partner sites are provided only as aggregate data and do not include any identifiable information about any individual user.
Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. Accordingly, despite HM's efforts to protect users' personal data, it cannot ensure or warrant the security of any information transmitted by users through or uploaded to the Site. Users are therefore advised that any information submitted or uploaded to the online environment will be done so at their own risk.
In order to reduce this risk, HM offers all interested parties the possibility of sending requests/applications/addresses/messages in physical form to the Company's premises and not necessarily by electronic means.
The liability of the Company in relation to the Data Subject shall be determined in relation to the capacity held in the respective data processing operation, the reason and place of the incident, the security measures taken, the steps taken to avoid incidents and the compliance with the other legal obligations.
The Company does not transfer outside the EU personal data of the Data Subject collected through the Site.
This policy applies to the Company and users of the Site (whether registered or not).
The Company reserves the right to modify/update the content of the HM, including the policies referred to, at its sole discretion, at any time and for any reason (including but not limited to the occurrence of legislative or case law changes that may affect the consequences of what is published on the Site). Revisions to this policy in the future will be indicated by a change to the "Last Updated" date at the top. After the date on which the updated policy is published, access to the Site will constitute the user's acceptance of those updated terms.
However, if there are any significant changes that may affect the rights and freedoms of visitors, they will be informed of such changes by easily visible indications posted on the Site (pop-ups) or by sending e-mails to the addresses provided if applicable. Such significant changes will take effect for visitors within 15 days from the time of the display of the pop-up in question or the transmission of the e-mail by HM (the manner in which the information will be provided will be decided by HM on a case-by-case basis).