1.Purpose of This Privacy Notice
The confidentiality of your personal data and your confidence are important for FCRO Training SRL. Due to this priority, correlated with the compliance with the EU Regulation no. 679 of April 27, 2016 regarding the processing and free movement of personal data (hereinafter referred to as "GDPR"), applicable starting May 25, 2018, FCRO Training SRL, as "Operator", processes your personal data in good faith and in achieving the goals specified in this policy. This policy regarding the processing of personal data ("Policy") describes what types of data are processed, the principles of processing of personal data, how they are used, what your options are in relation to such processing, and how we will respect the rights you have as a data subject according to the legislation regarding the protection of personal data. It is important that you read this privacy notice, together with any other privacy notice or fair processing notice provided when personal data is collected or processed, so that you are fully aware of how your data is used. This privacy notice is supplemental to any other notice and is not intended to override.
FCRO Training SRL legal entity, with its registered office in str. Emanoil Porumbaru, no. 31, ap. 6, sector 1, Bucharest, identified by J40 / 2796 / 12.02.2007, CUI 21058552, collects and processes personal data of the persons interested in the services offered by the company, as well as the data of the direct beneficiaries of these services (learners), in accordance with the General Regulation on the protection of personal data 2016/679 (GDPR) and the national legislation in force (Law no. 677/2001 amended and completed). Personal data are information about a natural person that can be identified directly or indirectly.By processing, in the sense of the GDPR, is understood the collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, disclosure by transmission, dissemination or making available in any other way, alignment or combination, restriction, deletion or the destruction of your personal data.
Personal data or information means any information about an individual from which that person can be identified. It does not include data where identity is removed (anonymous data).
We may collect, use, store, and transfer a variety of personal data, including:
- Identity Data, including first name, last name, username, or similar identifier, title, date of birth and gender.
- Contact Data, including email address and telephone numbers.
- Technical Data, including internet protocol (IP) address, your login data, browser type and version, time zone and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website and our services.
- Profile Data, including your username and password, preferences, feedback, and survey responses.
- Usage Data, including information on how you use our website and services.
3.Using Your Personal Data
FCRO Training SRL collects and processes your personal data (name, first name, email address, telephone, function) obtained through (i) the contact form and the registration forms for marketing events and public workshops on the website, (ii) direct communication by email, telephone or face-to-face with you and / or with your employer's legal representatives, (iii) networking events, based on freely expressed consent or for legitimate purposes:
- to provide you with information regarding the services we offer;
- to inform you about the marketing projects and events we organize;
- to provide you with training and personal development services, based on the legal execution of a commercial contract;
- to be able to access and offer assistance regarding the use of the online evaluation platform, the online access learning platform or the web-based application for implementing the implementation practice.
Any use of your personal data for purposes other than those listed, will be made only on the basis of your freely expressed consent, except where the law provides otherwise.
Once you have recorded and / or transmitted personal data to us, by the means made available and described above, you have agreed to use the respective data in accordance with this policy.
Your preferred browser can be set to refuse all or some browser cookies, or to alert you when websites set or access cookies. If cookies are disabled or refused, some parts of the website may be inaccessible or fail to function properly.
Change of Purpose
If your personal data must be used for an unrelated purpose, we will notify you and explain the legal basis that allows its use.
We may process your personal data without your knowledge or consent, in compliance with the rules stated above, where required or permitted by law.
4.Disclosure of Personal Data
Access to your personal data is only allowed to partners and employees of FCRO Training SRL. The employees, partners and authorized persons of the company, who have access to your data, fully respect their confidentiality.
The public authorities to whom the personal data may be communicated in a particular investigation in accordance with the legislation in force are not considered as recipients.
Third parties to whom we may choose to sell, transfer, or merge part of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change to our business occurs, new owners may use personal data in the same manner as set out in this privacy notice.
We require all third parties to respect the security of your personal data and treat it in accordance with the law. Third-party service providers are not allowed to use your personal data for their own purposes. Use of personal data is permitted only for specified purposes and must be in accordance with our instructions.
In order to facilitate access to the online assessment platform, the All Access Pass online learning platform or the web-based implementation application of the my4DX execution practice, your personal data is transferred to FranklinCovey Co USA.
The transfer of your personal data is based on the prior signing of an agreement between FCRO Training SRL and FranklinCovey Co, an agreement that fully respects the provisions described in the GDPR. Also, the transferred data is subject to an adequate level of protection by taking appropriate technical and organizational measures.
Whenever your personal data is transferred outside of the European Economic Area, we ensure a similar degree of protection is implemented using at least one of the following safeguards:
- Transfer is only allowed to countries sanctioned by the European Commission to provide an adequate level of protection for personal data.
- Where certain service providers are used, specific contracts provided by the European Commission may be used to ensure personal data will have the same protection as in Europe. For further details, see European Commission: Model Contracts for the transfer of personal data to third parties.
- Data may be transferred to third-party providers in the U.S. who are members of the Privacy Shield, requiring them to provide similar protection to personal data shared between Europe and the U.S. For additional information, see European Commission: EU-US Privacy Shield.
Click https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en to learn more.
Your personal data will be retained only as long as necessary to fulfill the purpose(s) for which it was collected, including legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
The personal data provides uses and contact forms, registration forms for marketing events and public workshops available on the website and will be in effect as long as you express your intent to receive our news, actions, events, services or offering of offers from our company, or until the exercise of one or more rights regarding personal activity.
The personal data provided by you on the 360 degree evaluation platform, the All Access Pass learning platform, or the my4DX execution platform, made available by FCRO Training SRL pursuant to the execution of a commercial contract with you or your employer, will be processed throughout the duration of the use of the services listed above, in order to allow the good execution and performance of the contract.
7.Your Legal Rights
According to the new provisions of the General Regulation on the protection of personal data 2016/679 (GDPR) at any time you can exercise the following rights on your data:
- Right to information - you can request information regarding the activities of processing your personal data;
- Right to rectification - you can rectify inaccurate personal data or you can complete them;
- The right to delete data ("the right to be forgotten") - you can request the deletion of data when (i) they are no longer needed for the purposes for which they were collected and processed; (ii) you have withdrawn your consent for the processing of the data and we can no longer process them on other legal grounds; (iii) the data are processed against the law; respectively (iv) the data must be deleted according to the relevant legislation;
- Right to restriction of processing - you can request the restriction of processing in case you dispute the accuracy of the data, as well as in other cases provided by law;
- The right to data portability - you can request that your personal data collected and processed by us be transmitted to another operator;
- The right to file a complaint - the right to address the National Supervisory Authority for the Processing of Personal Data or the competent courts, if you consider it necessary;
- The right of withdrawal of consent - in cases where the processing is based on your consent, you can withdraw it at any time, with future effects not retroactive.
Other additional rights that reside in the automatic decisions regarding personal data, if any.
8.How you can exercise your rights
You can exercise these rights either individually or in the aggregate, through a written request sent to the firstname.lastname@example.org. We will respond to your request within a maximum of 30 days from the date of receipt of the request. In order to process the application it is possible to request additional information.
For any other questions regarding the way we manage personal data, please contact us at email@example.com or at the postal address: str. Emanoil Porumbaru, no. 31, ap. 6, sector 1, 011422, Bucharest, Romania.