Terms and conditions

Last update: 02 February 2024

This policy details the Company's practice regarding the operation and use of the domain https://highlifementoring.maxwellleadership.ro/ (hereinafter referred to as the Website) created with the main purpose of providing the possibility to purchase tickets for the Step up and take the lead event (hereinafter referred to as the Event), with the aim of informing users about the commercial conditions of contracting.

Following the purchase of tickets to the Event, as detailed herein, the user will be granted the right to access the https://www.johnmaxwellacademy.ro/ platform, depending on the type of ticket paid for according to the information on the Event website, where they will be able to access various materials. The manner in which his/her personal data will be processed on that platform, as well as on any other related online platforms, including commercial terms, are set out in the policies therein. Thus, these Terms and Conditions, as well as the Data Protection Policy and Cookie Policy, relate strictly to the Event page.

By using the Site further, you acknowledge that you have read and agree to these Terms and Conditions, as well as the Data Protection Policy and Cookie Policy, which are posted on the Site.

Contents

1.      Identification of the company

2.      Date of contact

3.      Acceptance of the visitor to the Site with respect to the application of the Terms and Conditions

4.      Conclusion of the ticket purchase contract for the Event

5.      Services provided by HM through the Site

6.      Event ticket features offered by HM. Price

7.      Access to the Website and the Event

8.      Terms applicable to buyers

9.      Cancellation of the ticket purchase order for the Event. Return Policy

10.         Cancellation of the Event or change of date. Return Policy

11.         HM Intellectual Property Rights

12.         Force majeure

13.         Personal data

14.         Data collection

15.         Reality of information provided by users

16. Users' liability when using the Site

17.         HM liability

18.         Modification of applicable conditions

19.         Third party websites/applications

20.         Security

21.         Privacy

22.         Applicable law and dispute settlement

23.         Final provisions

1. Company identification

Highlife Mentoring SRL (hereinafter referred to as the Company or HM)

Registered office: Romania, Timiș 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. J35/2476/2022

Unique registration code RO46231968

Email: office@maxwellleadership.ro

     Tel: +40.771.706.337

2. Contact details

The contact details that the visitor to the Site can use to send any requests, notifications or complaints regarding the Terms and Conditions, Data Protection Policy, 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.

3. Site visitor's acceptance of the application of the Terms and Conditions

These terms and conditions are assumed by the Company and by the users of the Site (i.e. you).

Accordingly, use of the Site in any form by visitors/users automatically implies acceptance of all of the following and of the policies referred to (where the law does not require further steps to be taken to express acceptance), as well as an undertaking that they have the full and free right and ability to access the Site, place orders and provide information to the Company.

IF YOU DO NOT ACCEPT OR DO NOT FULLY AGREE TO THE TERMS AND CONDITIONS OR OTHER POLICIES DISPLAYED, PLEASE DO NOT USE THE WEBSITE, DO NOT SUBSCRIBE TO HM'S MARKETING INFORMATION, DO NOT PURCHASE TICKETS TO THE EVENT, AND DO NOT SEND MESSAGES USING THE "CONTACT US", "LET'S CONNECT" OR TELEPHONE NUMBER DISPLAYED ON THE WEBSITE AND INDICATED IN ARTICLE 1 ABOVE.

4. Conclusion of the ticket purchase contract at the Event

The visitor to the Site may access it without being obliged to purchase a ticket. The visitor to the Website may also freely send messages with requests, complaints or questions to HM using the dedicated boxes or contact details indicated in Article 1 above.

Prior to submitting the actual order for the purchase of a ticket to the Event, the purchaser may at any time view and/or modify the data submitted, identify any errors at the time of entry and correct them before placing the order by clicking on the "Register" button at the end of the "I am registering now" form or in any other way agreed with the Company (e.g. in subsequent discussions).

Once the user presses the order button, the ticket purchase contract will be valid and the user will be held to the payment of the price for the desired ticket option (general or VIP), as indicated on the Website.

5. Services provided by HM through the Site

1. Event ticket sales

2. Providing access to various resources made available by HM, relating to Maxwell procedures and methods, within the limits indicated in this policy

3. Transmission of information for marketing purposes

6. Event ticket features offered by HM. Price

Tickets can be purchased by individuals or legal entities who send the tickets to their designated persons. To this end, after the legal entities have submitted the order form and paid the corresponding price/first instalment (if payment in instalments is chosen), HM will contact the respective purchaser to request the details of the persons who will directly benefit from the tickets by attending the Event, given that the tickets are personal, non-transferable and a unique code is generated for each ticket.

The type of tickets is either general or VIP. The benefits offered by each type of ticket is indicated on the main page of the Website. Any additional information can be obtained by users through the forms on the Site or by contacting HM directly using the details indicated in Article 1.

Ticket prices are those displayed on the date and at the time of placing the order by the user, as indicated on the Site and in the order summary.

The total price can be paid according to the buyer's choice:

• in full, at the time of placing the order, by indicating your card details via the EuPlatesc platform (Visa/Maestro/Mastercard)

or

• in several equal instalments, with monthly recurring payment, according to the amounts and number of months indicated on the order form at the time of placing the ticket order. The option of paying the order price in instalments will still be available no later than 30 days before the date of the Event.

The equivalent in lei of the price indicated in euro will be made with reference to the BNR exchange rate on the day of payment.

Any change in ticket prices may be made freely by HM at any time, but will not affect customers who have already paid the ticket price or at least the first instalment of the ticket price if this payment option is preferred (they will not be charged extra if the price increases, nor will they receive any refund if the price decreases). Thus, unless otherwise expressly agreed in writing by the parties involved, any price changes applied by the Company will only affect tickets for which payment of the price begins after the change.

Invoices shall be sent by HM to the customer purchasing the ticket exclusively by electronic means to the address indicated by the customer on the order form. The invoice shall be deemed to have been paid when HM's account is credited with the full amount indicated on the invoice.

The payment method "Online by bank card" implies that the user wishing to purchase tickets to the Event must fill in certain card information on the secure payment processor page.

• Payments with credit/debit cards issued under the Visa and MasterCard brand (Visa/Visa Electron and MasterCard/Maestro) are carried out via the "3-D Secure" system developed by the organisations that ensure the same level of security for online transactions as those carried out at the ATM or in the physical environment at the merchant.

• "3-D Secure" primarily ensures that no card-related information is transferred or stored, at any point in time, on HM servers or payment processor servers, this data is directly entered into Visa and MasterCard systems.

For payments by bank card, no fee is charged.

7. Access to the Site and Event

Viewing the Site is free of charge. Participation in the Event is only possible after payment of the total price of the tickets ordered.

After payment of the total price of the tickets ordered or at least the first instalment of the price (if payment in instalments is preferred), the purchaser will have access to all the resources on Maxwell Academy, https://www.johnmaxwellacademy.ro/ (the Platform for short), depending on the type of Ticket paid for.

Thus, after paying the first installment, each buyer will automatically receive a unique login code on the Platform for each ticket (so there will be a unique code per ticket, not per buyer), and after creating a user account with email and password, will be able to access all the materials and information there. In case of failure to collect an instalment (whatever it is - 2nd, 3rd, etc.), the user's access to the Platform will be automatically restricted.

HM may, at its sole discretion, decide that in the event of any delay in the payment of any instalment, either simply to suspend the User's access to the Platform until the date of payment of all outstanding amounts, or to terminate the contract as of right without notice of default or other formalities and without refund of the amounts representing the instalments already received.

How the Platform works is described in the Terms and Conditions, Data Protection Policy and Cookie Policy posted there.

8. Terms applicable to buyers

Buyers of tickets to the Event must be people (individuals or companies through their employees/collaborators). Orders recorded by bots and other automated methods are not allowed.

HM may communicate with user customers via email about updates, news, feedback, statistics, upgrades, new services and other issues that are consistent with the original purpose of the data processing. If they wish to unsubscribe from the newsletter list, they can easily do so at any time by simply ticking the Unsubscribe button at the end of each newsletter they receive, or send a request to do so by email.

Users (individual customers/employees or collaborators of corporate customers) are responsible for maintaining the security of the orders they place and their account and password on the Platform. HM cannot and will not be liable for any loss or damage from Users' failure to comply with this security obligation.

Users are solely and fully responsible for all activity that takes place under their name - whether placing orders, making payments, signing up for newsletters, chatting on the Site, on the phone or on social networks.

The Company has a low tolerance limit so if we consider that any user is abusing the services offered, HM may temporarily suspend any access to the Platform or the sale of tickets to the Event if it considers that the customer's activity is of an illegal or immoral nature. Fake accounts and orders will be deleted immediately when detected.

9. Cancellation of the ticket purchase order for the Event. Return policy

The person whose details have been indicated on the order form may request the cancellation of the submitted order within 14 days from the date of placing the order (i.e. from the date of filling in the order form by clicking on the "Register" button), provided that the Event has not taken place within those 14 days. In the event of a request to cancel the order in whole or in part, under the above conditions, HM will refund the amount received for the tickets in question and will automatically suspend access to the Platform for the unique code for those tickets.

If you wish to cancel all or part of an order, you must send a request to the HM email address given in point 1 above.

HM will check that the request was received within the 14-day period and that the Event has not already taken place, and if these two conditions are met cumulatively, it will refund within 14 days of receipt of the cancellation request the entire price/fees already received for the tickets for which cancellation is requested. When refunding the amount, the Company will use the bank details indicated in the original order or in the cancellation request (if such details were indicated in the cancellation request).

In the event that cancellation of an order placed more than 14 days prior to the cancellation request is requested or if, although cancellation was requested within 14 days of the order being placed, the Event took place before the cancellation request was received by HM (whether or not it met the participant's expectations), the Company shall be entitled to retain the full price charged for the order and to demand payment of the full price of the order if payment in instalments has been chosen but the full price has not been charged.

From the date of cancellation of the order, the account created for the cancelled ticket can no longer be used to access the Platform.

 

10. Cancellation of the event or change of date. Return Policy

In the event that HM decides to cancel the Event for a later (undecided) date or to change the date of the Event less than 30 days prior to the date indicated at the time of placing the order by the purchaser, it will offer purchasers the option of a full refund of all ticket payments or to use the tickets on the new date.

Changing the Event schedule without changing the day of the Event or changing the date of the Event announced more than 30 days before the Event date indicated at the time of placing the order by the buyer, will not entitle the buyer to a refund of the price paid (not in part).

11. HM Intellectual Property Rights

The Company owns all intellectual property rights (including copyright) in the services provided, the Site, the name, and any information relating to the Event or Maxwell programs.

Users shall not act in any way that could infringe the rights of the Company and undertake not to use any sign or name similar or identical to the trademarks or names used by the Company on the Site.

With reference to the above, it is agreed that persons purchasing tickets to the Event will have a strict right of use of the tickets for the purpose of access to the Event and the Platform. After the date of the Event, purchasers who have made an account on the Platform will no longer have any access or right to use the Platform.

No user may copy, modify, adapt, reproduce, distribute, reverse engineer, decompile or disassemble any aspect of the Site.

12. Force majeure

Neither party shall be liable for failure to perform its obligations if such failure to perform on time and/or properly, in whole or in part, is caused by an event of force majeure. The parties agree that such an event may be the virus infection of the Website or the IT platform behind it for reasons not related to an action of the Company, not requiring a certificate issued by an authority in this respect, but the notification (by e-mail or on the Website) of the persons affected. To the extent that the legislation applicable to personal data provides for other obligations in such cases, HM will comply with those legal conditions.

13. Personal data

For extensive information on how such data is processed, please study the Data Protection Policy.

14. Data collection

The Company collects information from visitors/users in three main ways: directly, from traffic reports recorded by the servers hosting the Site, and through cookies.

• information obtained directly

The data is collected when accessing the Site; when filling in the data in the "Contact", "Let's connect" or "Sign up now" section or by telephone through recorded conversations; and when filling in the necessary fields in the "I'm signing up now" form to place the order. The processing is carried out as indicated in the Data Protection Policy.

• information obtained from the server traffic report

When a website is visited, users automatically reveal certain information, such as IP address, time of visit, location from which the website was accessed.

• information obtained through cookies

The site uses cookies for better functionality. Depending on the preferences chosen by visitors/users, HM may also use other types of cookies in order to facilitate tracking preferences as well as traffic data and to promote certain aspects. For more details, please review the Cookie Policy.

Visitors to the Site should also be aware that whenever they voluntarily disclose personal information in online communication environments (such as online forums, social networking sites, discussion groups), the information disclosed can easily be collected and used by unauthorized persons.

ALTHOUGH THE COMPANY TAKES ALL REASONABLE STEPS REQUIRED BY APPLICABLE LAW TO PROTECT THE PERSONAL DATA OF VISITORS TO THE SITE, IT CANNOT ENSURE OR WARRANT THE SECURITY OF ANY INFORMATION TRANSMITTED. THEREFORE, THE TRANSMISSION OF INFORMATION IN AN UNSUITABLE ENVIRONMENT IS AT THE USER'S OWN RISK.

15. The reality of user feedback

When filling in the forms on the Site and during telephone discussions with the Company's representatives and when placing orders or returns, as well as when subscribing to newsletters, users are obliged to communicate to the Company real and valid data.

Also, by using the Site, each visitor/user assumes that he/she can take the steps required when filling in forms, creating accounts, placing orders and sending messages, being over 18 years of age and can express valid consent (where applicable) freely and without the need for prior approval from a third party that has not been obtained by that visitor/user.

If the data provided undergoes any changes, users are obliged to notify the Company immediately so that it can comply with its legal and contractual obligations.

16. User responsibility for use of the Site

Visitors/users are solely responsible for choosing, obtaining, configuring and maintaining the equipment used to access the Site.

Thus, the Company does not offer any guarantee regarding aspects relating, among others, to: the compatibility of the Site with the hardware and software used by visitors (however, HM hereby informs that users should install recent versions of the recommended browser Google Chrome, for example); the effects of using the Site (including but not limited to the generation of viruses, the possibility of fast access), as well as the smooth and trouble-free operation of the Site. However, HM's liability with respect to the processing of personal data is not excluded by this clause, nor is it reduced below the minimum permitted by the specific legislation in this field.

It is forbidden to insert references and links to the Site, to copy/modify/transmit/publish/use in any way the information indicated in the content of the Site, without the express, written and prior permission of the Company.

 

In addition, visitors declare that they will use the Site only for lawful activities that do not infringe the rights of third parties. Furthermore, they will not submit documents or requests pretending to be another person, nor will they take any action that could affect the integrity of the Site or the data contained therein (including but not limited to viruses, deletion or modification of information, electronic abuse, fraud, use of personal data without right).

The User is solely responsible for choosing tickets and filling in information on the Site, as well as for using the Platform.

The legal entity user expressly declares that the natural persons who have submitted completed forms to the Company, as well as those who will submit requests or messages, are authorised to carry out these actions and can fulfil their obligations, the legal entity user therefore summing up all actions and documents submitted/signed by those persons.

Failure to comply with the obligations set forth herein, as well as with any other obligation established by law for visitors to websites, will result in their liability and the obligation to cover damages caused by the culpable act.

Also:

• Users understand that the Company uses third party vendors and hosting partners to provide the hardware, software, information, networking, storage and related technology necessary to deliver the Event services.

• Users agree not to resell, duplicate, reproduce or exploit any part of the Site or the Notes without the Company's express prior written permission.

• Users may not use the Site to store, host or send unsolicited email (spam), chat or any other unsolicited messages to other users on the Site or Platform or to transmit viruses or malicious content. The Site is aligned with anti-spam rules and the Company does not authorize or permit the sending of spam through the automation service by users. If there is evidence of spam, access to the Platform may be suspended without notice or even your account or tickets to the Event may be cancelled, as such activity is considered unethical. Accidental spam must be reported immediately to the Company to prevent the above consequences from being applied.

• Ticket buyers declare that they are over 18 years old. In case of doubt, HM may request further proof of the age of the respective user and he/she undertakes to provide such proof immediately upon receipt of the request from the Company.

17. HM liability

• The company ensures that all data protection requirements have been complied with when processing the user's personal data. HM does not assume any additional liability in such cases, except for those mandatory under applicable law

• HM may, but has no obligation to, remove content (such as testimonials or messages) and accounts from the Platform that contain content that the Company deems, in its sole discretion, to be unlawful, offensive, threatening, libelous, defamatory, pornographic, obscene, or otherwise objectionable or that infringes any party's intellectual property or these Terms and Conditions.

• HM makes no warranties and assumes no liability for the following:

• the ability of users to purchase Event tickets, use the Platform, make requests
• satisfaction of the participants with the event (organisation, information obtained, etc.)
• that the Site and the Platform will be available at all times, uninterrupted and error-free.

In the event of an error, the User shall immediately notify HM in writing and describe the error in as much detail as possible. Remediation is conditional on the error being reproduced and demonstrated on the basis of the description provided by the user. The User shall not remove the error by his own means, otherwise he shall be liable for the damage caused to HM (in particular, the Company shall not bear the expenses advanced by the User for the services of third parties offered for the correction of the error).

HM shall not be liable for any limitations of use or errors that have been or may be caused, in whole or in part, by improper use or inadequate infrastructure of the Site or the Platform (faulty hardware and/or software, faulty power supply, faulty internet connection).

• the accuracy of any mathematical calculations, statistics or reports made by the Company or its partners
• that errors or mistakes on the Site or Platform will be corrected

• Use of the Site and the Platform including any content, information or functionality contained therein, is provided "as is" and "as available" without any representations or warranties of any kind from HM, either express or implied, including, but not limited to, the implied warranties of merchantability, fitness for a particular purpose and non-infringement. Therefore, HM is neither responsible nor liable for any direct, indirect, incidental, consequential, special or other damages arising out of or in any way connected with the use of the Site or the Platform. Users assume full responsibility and risk for the use of the Site and the Platform, and the only remedy available to any Users in the event that they have any grievances related thereto is to cease using them or to request cancellation of the order within the limits indicated in art. 9 or art. 10 above.

• HM will not be responsible in any way for the way in which some users use information posted by other users on the Site or Platform (such as testimonials). Data security is an obligation HM undertakes towards buyers only with respect to data processed for the purpose of selling tickets to the Event.

• HM will not be liable for data submitted by the user that may infringe the rights of third parties (intellectual property, data protection, etc.), the user being solely responsible for uploading, managing, processing such data.

• HM shall not be liable for any losses suffered by the User if they were caused by the improper use of the Site, the Platform and/or failure to take measures and to follow instructions communicated by the Company.     

• HM will only be liable to users for damage caused with direct intent, regardless of its cause and nature. The amounts paid by way of compensation shall in no event exceed the amount paid by the user for the purchase of a ticket to the Event, within the limits set out in Article 10 above if applicable. In any case, the User is obliged to notify the Company immediately of the damage suffered (no later than 1 calendar day) from the time the damage occurred, in writing, so that HM can take the necessary measures to mitigate or limit the damage.

18. Modification of the applicable conditions

STUDYING THE TERMS AND CONDITIONS, AS WELL AS THE DATA PROTECTION POLICY AND THE COOKIE POLICY, IS SOMETHING THAT USERS SHOULD DO EVERY TIME THE SITE IS ACCESSED AND BEFORE ANY REGISTRATION OR PROVISION OF DATA IS MADE, AS CHANGES MAY OCCUR.

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 visitor/user's acceptance of the updated terms.

However, if there are significant changes that could affect the rights and freedoms of users, information will be made by publication on the Site (pop-ups) or by sending e-mails to the addresses provided if applicable. Such significant changes will take effect for visitors/users 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 given will be decided by the Company on a case-by-case basis).

Regardless of the extent of the change, however, the responsibility for checking the content of the Site (including the Terms and Conditions and posted policies) to keep up to date with the latest versions remains entirely with the user.

The Company also has the free and exclusive right to limit/refuse access to the Site and implicitly not to honour ticket requests if other tickets have not been paid for by the same purchaser before or in respect of which there are delays in payment of the price (without applying discriminatory measures and only in compliance with legal provisions), and to suspend or even close the Site with immediate effect, as well as to modify any of its functionalities.

19. Third-party websites/applications

The website may contain links or references to other companies' websites/applications. Such websites/applications may contain terms and conditions or policies that differ from those of the Company, or may have reduced security measures. ACCESS TO SUCH LINKS AND THEREFORE TO THIRD PARTY WEBSITES/APPLICATIONS IS AT THE SOLE RISK OF THE VISITOR.

Also, advertising sections may be included in the content of the Site where advertising messages from third parties will be displayed. HM is in no way responsible for the content provided by third parties, whether or not it is advertising, nor for the manner in which such third parties agree to comply with their legal obligations.

20. Security

This Site is protected by competitive security systems. However, like most webistes and applications on the Internet, it cannot be completely free of vulnerabilities.

Therefore, information submitted by visitors using the Site may be subject to privacy and security breaching activities beyond the direct control of the Company (such as the transmission of unsolicited spam messages, viruses on the equipment used, theft of IP addresses, unauthorized access to e-mail) for which HM assumes no responsibility, although it tries to avoid such unpleasant events.

21. Privacy

The privacy of the data of visitors to the Site is an important issue for the Company and is assumed by the Company with regard to the data entered by users in the forms on the Site.

Our Data Protection Policy forms an integral part of these Terms and Conditions and can be consulted by the user at any time.

22. Applicable law and dispute resolution

The rights and obligations of the parties (i.e. visitors/users and the Company), as well as all the legal effects produced by the Company's activity, shall be interpreted and governed by Romanian law and the provisions of European legislation.

All disputes may be settled by mutual agreement within 15 days of HM sending a notice or the Company receiving a notice to this effect under the "Contact" heading or using any other contact details from those indicated in item 1.

If a consensus cannot be reached within the time limit, the common law court at the Company's headquarters will be used or the out-of-court dispute resolution platform offered by the European Commission for consumers who have purchased products online can be used without the need to take legal action (link here:

https://ec.europa.eu/consumers/odr/main/index.cfm?event=main.home2.show&lng=RO and/or https://anpc.ro/formular-sal-anpc/ )

23. Final provisions

If any provision of these Terms and Conditions shall be ineffective (void) either in whole or in part, or if any provision shall in the course of time become invalid or if there are any loopholes, the remaining provisions shall not be affected in any way. For the purpose of replacing the invalid provision, i.e. to close the loophole, the parties shall be deemed to have agreed that the provision in question shall be replaced by the legal regulation which corresponds as closely as possible to the intention of the parties or which would correspond to the intention which the parties would have had, taking into account the purpose and meaning of what is stated herein, in the event that they would have known the invalidity of the provision in question or the loophole.

Section headings are for reference purposes only and shall not affect the meaning or interpretation of these Terms and Conditions in any way.

If a party waives its right to require performance of a contractual provision, such a waiver relates strictly to that situation and does not result in a general waiver of the right to require performance of the contractual provision.

Communication between the Company and the User will take place by email or telephone after the latter has communicated a request on the Site or to HM's email address.

This policy applies to the Company and users of the Site.

This document is part of the Company's set of security policies. Other policies may apply to the topics addressed in this document and will be revised as specific needs arise.

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

2.Processing of personal data

3.The person concerned

4.Personal data processed

5.Processing of personal data

6.Purpose

7.Recipients of processing

8.Legal basis of processing

9.Type of processing

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

13.Liability of the Company

14.Transfer to third countries/international organisations

15.Final provisions

1. Identification of the data controller

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

2. Processing of personal data

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:

1. When the user of the Site sends messages using the "Contact" box or has a telephone conversation with a representative of HM after completing the aforementioned box, he/she indicates: his/her first and last name or only one of them, respectively his/her email address if messages are sent or telephone number if the latter information is also desired.

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).

2. When a person purchases one or more tickets to the Event (general/VIP ticket), by filling in the "I register now" box, he/she indicates: first name, last name, an e-mail address and a phone number, address (country, county, city) and optionally personal number code. In the case of tickets purchased by a legal entity, the name and surname of the representative of that legal entity must be indicated as personal data, and in addition the name of the purchasing company, telephone number, email address, ORC registration number, tax identification code, registered office address and possibly bank account and IBAN must be filled in on the order form.

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.

3. When HM draws up and sends the invoice for the ticket purchased by the user and for the fulfilment of any other legal or contractual obligations as agreed by the parties, it shall indicate: name; surname; address, and for buyers who are legal entities it shall also indicate the registration number and tax identification code.

4. When a user consents to the use of his/her email address for marketing purposes by HM (newsletters), for receiving information related to the Event, but also other current or future Maxwell events/programs or the like (personal data that will be processed after the user ticks the box related to his/her consent and fills in the email address).

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.

5. When a user consents to the use of his/her image, voice, name and surname/nickname chosen for social media platforms and links to them for marketing purposes by HM, for the display of photos and/or videos obtained at the Event, on the Site, on the associated Maxwell websites or on the Company's social media pages (personal data that will be processed after obtaining the data subject's consent).

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.

3. The person concerned

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.

4. Personal data processed

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:

• User:

• Through the Contact section and phone conversations with HM representatives by users: user's first and last name, email address and phone number

• By Event ticket order form: name, surname, an e-mail address and a phone number, address (country, county, city) and optionally your personal number, payment details. In the case of ticket purchase by legal entity, the name and surname of the representative of that legal entity shall be indicated as personal data, and in addition the name of the purchasing company, telephone number, email address, ORC registration number, tax identification code, registered office address and possibly bank account and IBAN shall be filled in the order form.

• When dealing with cancellation/refund requests by HM in accordance with the Terms and Conditions: name, surname, email, telephone, any other relevant details in the context of the ticket purchased 

• In fulfilling HM's legal and contractual obligations such as the preparation of invoices

• By the user's express confirmation by ticking the box corresponding to the consent to data processing for marketing purposes at the end of the order form, or on the first page of the Site by clicking on the "Let's connect" or "Register now" button: e-mail address

• By displaying testimonials in the form of photos and text or videos from the Event, on the Site, on Maxwell associated sites or on HM social media pages: image, voice, first and last name/nickname chosen by the user for the social media platforms and links to them 

• User IP

Depending on the cookie settings, other data may also be processed (in particular data related to user preferences and behaviour on the Site).

• Of persons other than the user:

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.

5. Processing of personal data

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.

6. Purpose

The Company processes the data of the users of the Site according to the purposes described below:

• For data provided directly by the user:

• providing answers, clarifications and remedying problematic situations (including order cancellations and refunds), in relation to requests and complaints submitted by the user or in subsequent discussions with the HM representative. In this context, data of other persons who have knowledge of the state of affairs may also be processed, which could help HM in making a decision under the Terms and Conditions;
• providing additional information related to the Event;
• conclusion of the ticket sales contract for the Event, following the completion of the order form and the preparation and submission of the corresponding invoices;
• sending information for marketing purposes;
• ensuring compliance with this Data Protection Policy, the Terms and Conditions and the Cookie Policy, and applicable legal provisions to protect the rights, property or safety of the Site.

• In the case of data obtained through traffic reports:

• identification of the relevant sections of the Site;
• more secure management of the IT system

• In the case of data obtained through cookies:

• Site operation
• depending on the settings set by the user, the data may be used for the proper functioning of the Site, obtaining statistical information to improve the services offered, saving preferences, etc. All the details related to this type of data processing can be found in the Cookie Policy.

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.

7. Recipients of processing

Personal data of the Data Subject are processed by:

• administrators and employees/collaborators of the Company who are in charge of the administration of the Site and who are involved in the activities in relation to which the user registers an account or has questions/questions submitted - will process the name, surname and e-mail address of the user as well as any other personal data submitted by the user by message;

• the Company's associates and employees/collaborators who are involved in the organisation of the Event - will process the data indicated by the user in the I register now form, namely: name, surname, email, telephone, address.

• Company associates and employees/collaborators who are involved in the process of invoicing, cancellation of access to Maxwell resources after payment, refunds, order cancellations - will process all personal data filled in the order form and any other information necessary to make the cancellation/refund decision (if applicable);

• Company associates and employees/collaborators who are involved in the marketing process - will process email address for newsletters, image, voice, name, first name, nickname on social media and link to user's social media platforms for testimonials;

• support service providers contracted by the Company to fulfil its contractual or legal obligations, such as:

• hosting/IT company - can access all data recorded in the Company's online records, including those of users;
• accounting firm - will process the name, surname and address indicated on the invoices, as well as any other bank details;
• the Company's lawyers - can access all data recorded in the Company's records in the event of legal issues arising that require their involvement;
• advertising, PR and communication companies for marketing activity. These companies may collect anonymous data via cookies or event registration or feedback forms, and to the extent that this is done, HM will provide this information to data subjects in advance.

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.

8. Legal basis of the processing

• Art. 6 lit. a GDPR - processing is carried out on the basis of the user's consent -> applicable situation when data processing is done in the context of cookies accepted by the user and which are not necessary for the functioning of the Site, as well as when user data is processed for marketing purposes e.g. using data from the "Contact" or "Let's connect" form;

• Art. 6 lit. b GDPR - processing is necessary for the performance of a contract to which the user is a party or for taking steps at the user's request prior to the conclusion of a contract -> applicable situation when data processing is done in the context of filling in data using the "Contact" or "Let's connect" form; when filling in the "I'm signing up now" form including other activities related to the purchase of the ticket desired by the user (such as dealing with complaints or requests to cancel the order or refund the price);

• Art. 6 lit. c GDPR - processing is necessary for compliance with a legal obligation incumbent on HM -> situation applicable in the context of data processing in relation to invoicing, collection or reimbursement of the price, and in relation to competent authorities;

• Art. 6 lit. f GDPR - processing is necessary for the purposes of the legitimate interests pursued by the Company or a third party, provided that the fundamental rights and freedoms of the data subject are not violated -> situation applicable in the context of data processing for the purposes of the ordinary operation and administration of the Site.

9. Type of processing

The data processing activities carried out by the Company mainly concern:

• collection of data indicated by the user using the data filled in the "Contact" or "Let's connect" form;
• using data to provide answers and feedback;
• using the data for the conclusion and execution of the contract with the user who purchased the ticket to the Event;
• the use of data for the purpose of each category of cookie agreed by the user;
• the collection of other unsolicited data provided by the Data Subject in a communication, request or complaint to the Company or in a response to the Company's inquiries, in order for the Company to respond to and resolve the request or remedy the incident;
• storing the aforementioned data in accordance with the law and within the limits necessary to achieve the purpose in the Company's secure electronic database;
• allowing access to data to certain employees and external collaborators providing support services whose activity involves processing of data under the condition that they assume the obligation of confidentiality and standard contractual clauses agreed by the European Commission (in the case of collaborators from EU third countries);
• allowing access to data to the competent authorities to the extent required by law;
• the transfer of the entire set of data kept on the Site by a user to the destination indicated by the user based on the user's right to data portability.

10. Data processing and storage time

The storage period of personal data collected is:

• until consent is withdrawn or the right to erasure or erasure is exercised by the user - for data processing based on the data subject's consent;
• for 3 (three) years from the receipt of the message using the "Contact" or "Let's connect" form or from the purchase of the ticket using the "I'm signing up now" box (if the telephone will be used, the data will be kept for 3 years from the date of the telephone conversation, with prior registration consent). The data is kept after the termination of the contract in order to be able to prove the measures taken by the Company in consideration of the contract, in relation to the duration of the general limitation period of the right of action before the Romanian Civil Code;
• a longer period of time than those mentioned above, where the law so provides or where there is a well-founded reason for doing so (e.g. for the exercise of a right before a court in a dispute which started before the expiry of the storage period indicated herein).

Upon expiry of the above-mentioned periods, all data will be deleted from the Company's records.

11. Rights of the data subject with regard to the processing of personal data

1. Right to information

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.

2. Right of access to 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.

3. Right to rectification of data

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.

4. Right to erasure of data

If the data subject wishes to have his/her personal data deleted, this is possible:

• at the end of the processing period;
• if the data are no longer necessary for the purpose of processing;
• if consent is withdrawn and there is no other basis for the processing;
• if he/she objects to the processing and there are no overriding legitimate grounds;
• if the processing is illegal;
• if deletion is required by law.

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.

5. Right to restrict processing or object to processing

The restriction of processing may apply if the Data Subject finds that:

• the data are not accurate;
• the processing is unlawful and the Data Subject objects to the erasure;
• The company no longer needs the data but the data subject requests it for a court action and it has not yet been deleted;
• The data subject objects to the processing.

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.

6. The right to data portability

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.

7. Right to object

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.

8. Right to complain

The person concerned may submit:

• complaint/application to the address of the Company indicated in point 1 above;
• action in the competent court;
• complaint to the National Authority for Personal Data Protection (www.dataprotection.ro).

However, the company wants any conflict/difference to be resolved amicably and is willing to do so.

1. Right to withdraw consent

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.

10. The right not to be subject to a decision based solely on automatic processing

The company does not practice decision making based on automated data processing.

12. Obligations of the Company. Security measures for processed data

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 conclusion of contracts with collaborators in which they have assumed the obligation of confidentiality of the information concerning the personal data processed, as well as the obligation to comply with the applicable legislation in the field of personal data protection;
• training employees and collaborators on the importance of personal data protection and limiting their access to data according to their duties;
• establishing internal procedures to protect personal data;
• a contact address for matters relating to personal data (i.e. the one indicated in point 1 of this policy);
• the Unsubscribe button on all marketing communications;
• implementing information security measures;
• not installing structures that allow access to the Site and the purchase of a ticket only on condition that a user account is created;
• not setting cookies in addition to those necessary for the operation of the Site, without giving the user a choice that is permanently available.

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:

• The Company has implemented appropriate technical and organisational safeguards and these safeguards have been applied to personal data affected by the personal data breach;
• The Company has taken subsequent measures to ensure that the high risk to the rights and freedoms of Data Subjects is no longer likely to materialise;
• would require a disproportionate effort. In this situation, public information or a similar measure is carried out instead, whereby the data subjects are informed in an equally effective way.

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.

13. Liability of the Company

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.

14. Transfer to third countries/international organisations

The Company does not transfer outside the EU personal data of the Data Subject collected through the Site.

15. Final provisions

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).

INFORMATION NOTE on the processing of personal data for marketing purposes
This information note (briefly referred to as the Note) is intended to clarify the ways in which Highlife Mentoring SRL, based in Timis County, Timisoara, str. Gheorghe Lazăr nr. 24, et. 4, ap. SAD 29 (Fructus Plaza), with registration number ORC J35/2476/2022, CUI RO46231968 (hereinafter referred to as HM or the Company) processes the personal data of the natural person who participates in the Step up and take the lead event (hereinafter referred to in short as the Event) and/or who wishes to subscribe to the information sent by HM regarding the Event or other Maxwell programs/events carried out (hereinafter referred to as the Participant).
NR	SECTION	DETAILS
1.	Definitions	Data controller - the notion includes the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of processing personal data - in this case HM Data Subject - the natural person who is or can be identified, directly or indirectly, by reference to an identifier, whose personal data are processed - in this case the Participant or other persons included in the testimonial provided by the Participant (including minors) Personal data - any information relating to an identified or identifiable natural person Processing of personal data - any operation or set of operations which is performed upon personal data, whether or not by automatic means Regulation or GDPR - EU Regulation 679/2016
2.	Personal data protection contact person (PCPD)	The Data Protection Contact Person has been instructed by HM to deal with any requests, notifications, information, petitions, requests for information made or transmitted by any natural or legal person. The contact person will also mediate communications with the competent supervisory authorities in the field of personal data processing. The contact details of the EDPS that can be used for the communication of addresses, requests, notifications and referrals are indicated below:
		Phone		+40.771.706.337
		E-mail		office@maxwellleadership.ro
3.	Purpose of processing and source of data	In order to promote the Event and its subsequent editions, for and to promote the activity of the Company, on the occasion of the Event, photographs will be taken with the participants, testimonials and promotional and presentation videos of the HM will be recorded and broadcast, on which occasions personal data of the Participant will be processed. Also, if the Participant wishes to subscribe to HM's newsletter list, he/she will sign up for it. Personal data is submitted to HM directly by the Participant by attending the Event and completing the newsletter subscription forms.
4.	Legal basis	The processing of personal data is done on the basis of Article 6 para. 1 lit. a GDPR processing with the consent of the Participant - when the processing of the Data Subject's data is done for marketing purposes (e.g. when recording testimonials and presentation/promotional videos with their display on the chosen social media channels and on the Site/Platform).
5.	Personal data	The data that HM processes is mainly information that the Participant has provided directly, but also through the actual conduct of the activity of promoting HM services, respectively: first and last name/nickname chosen on the Participant's social media platforms Participant image Participant voice email of the newsletter subscriber
6.	Recipients	The recipients of the personal data processed may be: some employees/associates of HM performing an activity requiring the processing of the Participant's personal data in the framework of the preparation and promotion of the Events and other services of the Company - all/any of the data indicated in point 5; people accessing the Site, Platform or social media pages - name, first name, chosen nickname, image and voice; Social media platforms, participating in the promotion of the HM or the Event - name, first name, nickname, image and voice; service providers contracted by HM (e.g. IT, marketing and PR firms) - all/any of the data indicated in point 5, depending on the specific activity of each provider; Although they are not recipients according to legal interpretations, public authorities (including ITM, PCA and ANAF) and courts may process all/any of the data indicated in point 5. HM ensures that the disclosure of data to third parties is done in compliance with the legal provisions for all categories of recipients and if possible, with their contractual obligation to maintain confidentiality and with the proper implementation of the GDPR.
7.	Data storage period	HM retains personal data for as long as necessary for the purpose, i.e.: until the moment of exercising the right to erasure of the processed data by sending a request using the contact details of the DPOCP indicated in point 2 above/ until the withdrawal of the consent in case of processing based on this ground, unless there is another ground justifying the continuation of the processing and without affecting the validity of the processing carried out until that moment on this ground. Thus, the Participant understands that the right to erasure of data (like all other rights concerning the processing of personal data) is a fundamental, but not absolute, right and therefore HM may refuse to erase his/her data for good reason; a longer period of time where the law so provides or where there is a well-founded reason for doing so (e.g. for the exercise of a right before a court in a dispute which started before the expiry of the storage period indicated in this Notice). Upon expiry of the aforementioned time periods/withdrawal of consent under the above conditions, all data will be deleted from HM's records and HM will make every effort to delete the data also from the platforms with which the Company has collaborated.
8.	Participant's rights from the perspective of GDPR	Right to information	At the Participant's request, the Participant will be informed of how HM ensures the security of his or her personal data, as well as of the substance of the contracts concluded with the recipients under point 5 and the source of the data. In the event of restrictions/modifications being established by the legislation applicable to the Notice, the Data Subject shall be duly informed by posting on the Website, by posting at the Company's registered office and/or by e-mail or by drawing up an additional document hereto.
		Right of access to data	If the Participant would like information about the processing, he/she may submit a request to HM using the contact details of the PCPD indicated in point 2 above, which will be answered within 30 days.
		Right to rectification of data	Should the Participant wish to rectify/complete the data, he/she may submit a request to HM using the contact details of the PCPD indicated in point 2 above, which will be responded to within 30 days.
		Right to erasure of data	If the Participant wishes to delete data, this is possible: at the end of the processing period if the data are no longer necessary for the purpose of processing if consent is withdrawn and there is no other basis for the processing if he/she objects to the processing and there are no overriding legitimate grounds if the processing is illegal if deletion is required by law. The cases of exception provided for in Article 17(1)(a) and (b) shall be excluded. 3 of the GDPR are applicable. Some data are part of HM files (name, address, payment documents, etc.), which it keeps in relation to its legal obligations or legitimate interest, therefore not all data may be in disposal, according to the law.
		Right to restrict processing or object to processing	Restriction of processing may apply if: The participant notes that the data are not accurate, the processing is unlawful and the Participant objects to deletion, HM no longer needs the data, but the Participant is requesting it for legal action and it has not yet been deleted, The participant objects to the processing. HM may continue to process the restricted data if this is necessary for the establishment, exercise or defence of a legal claim or the protection/defence of a person but only with the consent of the Participant. HM will communicate to recipients the rectification, erasure or restriction of data unless this is impossible or involves disproportionate effort.
		The right to data portability	The participant or the person indicated by the participant as recipient may receive, upon request, the data processed by the Company. HM does not assume responsibility for the processing of data by that recipient. The obligation to ensure the right to portability is incumbent on HM if the processing of those data is based on the Participant's consent or on the conclusion and performance of the contract. The request shall be made within 30 days of the request.
		Right to object	If possible, HM will stop the processing of the data of the Data Subject who objects to the processing based on the legitimate interest of the Company or circumstances arise that give rise to the exercise of this right (including profiling). However, the legitimate reason of fulfilling HM's legal obligations or processing for the purpose of establishing, exercising or defending a right in court shall prevail.
		Right to complain	The data subject may lodge a complaint using the contact details of the DPO indicated in point 2 above, a court action or a complaint to the National Authority for Personal Data Protection (ANSPDCP). However, HM wants any conflicts/differences that arise to be resolved amicably and is willing to do so.
		Right to withdraw consent	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 right not to be subject to a decision based solely on automatic processing	HM does not practice decision making based on automated data processing.
9.	Main obligations of the HM	HM declares that it complies with all the obligations laid down by the applicable legislation on the protection of personal data and that it has implemented appropriate technical and organisational measures to ensure the security and confidentiality of the personal data of individuals and is responsible according to the quality and involvement it has. The Company undertakes to keep all personal data and information that comes to its knowledge in complete confidence (this shall not affect the right to broadcast testimonials and to promote the Event or the HM). Regardless of the above: HM appoints a personal data protection contact person who can be contacted by the Data Subject. The contact details are set out in point 2; HM will take all necessary steps to reduce the risk of data breach or eliminate negative consequences in the event of a data security incident; HM will inform the competent data protection supervisory authority in the event of a data security incident without undue delay and, if possible, at the latest within 72 hours of becoming aware of the incident, unless the breach is unlikely to result in a risk to the rights and freedoms of Data Subjects. Where the notification is not transmitted to the competent authority within 72 hours, it shall be accompanied by a justified explanation for the delay; In the event of a data security incident, HM will inform the Data Subject concerned without undue delay (e.g. by email), if that incident may result in a high risk to his/her rights and freedoms. However, the aforementioned notification of the Data Subject is not necessary if at least one of the following conditions is met: the controller has put in place appropriate technical and organisational safeguards and these safeguards have been applied to the personal data affected by the data breach; the controller has taken additional measures to ensure that the risk to the data subject's rights and freedoms is no longer likely to occur; would require a disproportionate effort. In this situation, HL issues a public notice or will take similar measures by which Data Subjects are informed in an effective manner (such as posting information on the Company's Website or social media pages, being prominently marked for example by a pop-up).
10.	Transmission of data to third countries	HM does not transmit Data Subjects' data outside the EU.