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Learngate SRL Privacy Policy
By using the website www.emotopics.com, you express your agreement with this document regarding the Privacy Policy of Learngate SRL, headquartered in Bucharest, str. Șiragului no. 20, Romania, acting as the data controller. We understand the importance of the privacy and security of your personal data and take all steps to provide you with a safe and transparent online experience.
This document is intended to inform you, in accordance with art. 13 and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as “GDPR”), regarding how we collect, use, store, and protect your personal data.

Processing of Minors’ Data
The products offered through the website www.emotopics.com are not directly addressed to minors. In accordance with art. 8 of the GDPR and Law no. 190/2018, the processing of personal data of a minor who has not reached the age of 16, in the context of information society services, is legal only if and to the extent that consent is given or authorized by the holder of parental responsibility. Therefore, the registration on the site of minors under the age of 16 will be carried out exclusively by a parent or legal representative, who will accept the Terms and Conditions of use of the site on behalf of the minor and will be responsible for supervising the use of the site. If we become aware that we have collected data from a minor without the valid consent of the holder of parental responsibility, we will delete this data without delay.

Definitions
The following terms shall have the following meanings:
(a) Personal data: any information relating to an identified or identifiable natural person.
(b) Processing of personal data: any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
(c) Personal data controller: 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.
(d) Data subject: the natural person whose personal data are being processed.

What kind of personal data we collect

If you are a visitor to the website www.emotopics.com, we process the following personal data:

Data provided directly by you in the “Contact” section, by addressing questions, suggestions, or complaints, using various means of communication (e.g., telephone, email). This data is collected and used exclusively for the purpose of managing your requests and providing you with appropriate and personalized answers.
Data collected automatically when you browse the site: IP address, browser used, duration of navigation, history of searches on the site, operating system used, language and pages viewed, full URLs, clickstream to, through, and from our site, information or products viewed/searched for, duration of visits to certain pages, information regarding interaction with the pages (such as scrolling, clicks, mouse-overs), and data about user behavior. These data are collected to improve the user experience, to analyze, and to optimize the performance of our site. Collection through cookies and similar technologies that are not strictly necessary for the functioning of the site is carried out only based on your consent (see the “Cookies” section).
Data provided upon subscribing to the www.emotopics.com newsletter: name and email address. Subscription to the newsletter is carried out only based on your previously expressed consent, which can be withdrawn at any time, free of charge, including by accessing the unsubscribe link included in each communication. In case of withdrawal of consent, your data collected for the newsletter subscription will be deleted. These data are used exclusively by us and our email distribution service provider.

For activities related to purchasing products sold through the website www.emotopics.com, the data we process directly regarding you may include:

First and last name;
phone number;
Email address and other similar contact information;
Billing address;
Data necessary for issuing the invoice;
Data necessary for fraud prevention;
Data regarding the products you purchase through the website (e.g., order history, payment history, preferences, and other relevant information), for the purpose of administering and optimizing our products;
Personal data from Learngate SRL’s social media pages, if you choose to communicate with us or access our products and information through these platforms. We recommend that you also familiarize yourself with the privacy policies of these platforms before interacting with them, as they have their own practices for managing personal data;
Personal data that you provide by addressing questions, suggestions, or complaints regarding participation in our promotions, either directly on the site or using other means of communication (phone, email);
Any other categories of data that you provide directly in the context of creating a user account, in the context of placing an order through the website, or in any other way resulting from the use of the website.

Note regarding payments: payments are processed through an authorized payment service provider. Learngate SRL does not store and does not have access to your full credit card details.
You are not obliged to provide us with personal data, but refusal to provide data marked as mandatory will, in certain cases, make it impossible to provide our products or resolve your requests. Mandatory fields in forms are marked accordingly.
We do not collect or process special categories of personal data (data regarding health, racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data, or data regarding sexual life). Please do not send us such data.

How we collect your personal data
You directly provide us with most of the data we collect. We collect and process data when you:

Register online or place an order for any of our products;
Voluntarily complete a customer survey or provide feedback on any of our forms or via email;
Request to sign up for our newsletter;
Address questions, suggestions, or complaints using the communication means provided on the site (phone, email);
Use or view our website through cookies in your browser, under the conditions described in the “Cookies” section.

We may also receive your data indirectly from social media platforms used by Learngate SRL, from security service providers, and from payment service providers for the purpose of providing products sold through the website www.emotopics.com, preventing fraud, and personalizing the user experience.

Purposes of processing your personal data
We process your personal data for the following purposes:

Providing our products: creating and managing the user account, taking, processing, and delivering orders, billing, processing payments;
Communicating with you: resolving questions, suggestions, complaints, and grievances, as well as providing complete answers to requested information;
Marketing: sending the newsletter and offers regarding the products sold by Learngate SRL via email or other electronic communication means, under the conditions described in the “Legal bases for processing” section;
Improving the site and products: analyzing and optimizing the site’s performance, the user experience, and our product offering;
Fulfilling legal obligations: maintaining financial-accounting documents, responding to requests from public authorities in accordance with applicable laws;
Protecting our legitimate interests: preventing fraud, ensuring the security of the site and computer systems, establishing, exercising, or defending our rights in court.

Legal bases for processing
We process your personal data only based on one of the legal grounds provided in art. 6 of the GDPR, as follows:

Execution of the contract (art. 6 para. (1) letter b GDPR) — for processing data necessary to place and honor orders, create and manage the user account, process payments and deliver products, as well as for steps taken at your request before entering into a contract (for example, responding to inquiries about products).
Legal obligation (art. 6 para. (1) letter c GDPR) — for issuing and keeping invoices and financial-accounting supporting documents, according to applicable fiscal and accounting legislation, as well as for disclosing data to public authorities when the law obliges us.
Your consent (art. 6 para. (1) letter a GDPR) — for subscribing to the newsletter, for direct marketing communications sent to individuals who are not customers, in accordance with Law no. 506/2004 on the processing of personal data and the protection of privacy in the electronic communications sector, as well as for the use of cookies that are not strictly necessary for the site’s functioning (analysis, personalization, and advertising cookies). Consent can be withdrawn at any time, without affecting the legality of the processing carried out before withdrawal.
Our legitimate interest (art. 6 para. (1) letter f GDPR) — for preventing fraud, ensuring the security of the site and computer systems, improving products and the user experience, resolving complaints and grievances, establishing, exercising, or defending our rights in court, as well as for direct marketing communications addressed to our existing customers regarding products similar to those purchased, under the conditions of art. 12 para. (2) of Law no. 506/2004, ensuring a simple and free unsubscription possibility with each communication. When we base processing on legitimate interest, we ensure that your fundamental interests or rights and freedoms do not prevail over it.

Principles of processing your personal data
In accordance with art. 5 of the GDPR, Learngate SRL processes your data ensuring conditions of transparency, security, and fairness. Personal data are:

Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes shall not be considered incompatible with the initial purposes;
Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
Accurate and, where necessary, kept up to date; we take all reasonable steps to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; data may be stored for longer periods insofar as they will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes;
Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.

How we protect your personal data
The technical and organizational measures, proportional to our activity, that we apply include, but are not limited to:

Pseudonymization and encryption of personal data, where applicable;
The ability to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services;
The ability to restore the availability of and access to personal data in a timely manner in the event of a physical or technical incident;
A process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

How long we store your personal data
We store your personal data only as long as necessary to fulfill the purposes mentioned above, for the conduct of the contractual relationship in the case of Learngate SRL customers, and for other essential purposes, such as fulfilling legal obligations and resolving disputes.
The data storage period may vary depending on the type of data and the purpose of the processing. For example:

Financial-accounting supporting documents and accounting registers are kept for 5 years calculated from the date of the end of the financial year during which they were drawn up, in accordance with the Accounting Law no. 82/1991, as amended by Law no. 36/2023; annual financial statements are kept for 10 years;
Data processed based on consent (for example, for the newsletter) are kept until the withdrawal of consent;
User account data are kept for the duration of the account’s existence and, subsequent to its closure, for the duration necessary to fulfill legal obligations and defend our rights;
Data related to requests and complaints are kept for the duration necessary to resolve them and, subsequently, for the duration of the applicable legal limitation periods.

Upon expiration of storage periods, data are deleted or anonymized.

How we share your personal data
In order to provide our products, as well as for the operation and maintenance of our site, we share your personal data with trusted third parties who perform functions on our behalf. These third parties are selected based on strict confidentiality and security criteria and are obliged, through data processing agreements concluded according to art. 28 of the GDPR, to comply with all legal provisions regarding the protection of personal data and to use the data exclusively for the purposes specified by us.
Categories of recipients include:

Service providers: web hosting and cloud service providers, database management providers, business communication providers, email distribution providers, marketing service providers, data storage and analysis providers, customer service support providers, courier service providers;
Authorized payment service providers, for processing payments;
Business consultants and professional advisors, including lawyers and accountants;
Public authorities, when disclosure is required by law or necessary for the protection of our legitimate rights.

The functions performed by these third parties may include, but are not limited to: processing payments, analyzing data, providing marketing and support services, delivering products, and technically operating the site’s infrastructure. Sharing of data is carried out only to the extent necessary to perform the respective functions.

Transfers outside the European Economic Area
As a rule, your data are processed within the territory of Romania, the European Union, and the European Economic Area (EEA). To the extent that certain service providers (for example, cloud, analysis service providers, or social media platforms) process data outside the EEA, we ensure that the transfer is carried out only with adequate guarantees, in accordance with Chapter V of the GDPR: based on an adequacy decision of the European Commission or based on standard contractual clauses approved by the European Commission, accompanied, where necessary, by additional protection measures. You can obtain additional information about these guarantees by contacting us at the contact details indicated below.

Corporate Operations
In the event of corporate operations, such as mergers, acquisitions, demergers, or restructuring of activities, personal data may be transferred to the entities involved in these operations, in accordance with applicable legal requirements. You will be notified of any such transfer and will have the opportunity to exercise your rights in accordance with the applicable data protection regulations. Your data will be treated with the same care and the same respect for privacy, regardless of the company’s corporate developments.

Cookies
When you visit our site, we may automatically collect information through cookies or other similar technologies.
Cookies are text files placed on your device to collect standard internet log information and visitor behavior information. Cookies strictly necessary for the site’s functioning are used based on our legitimate interest; all other categories of cookies (analysis, personalization, advertising) are used only based on your consent, expressed through the cookie banner displayed at the first visit.
For more information, please consult our Cookie Policy.

Your data protection rights
Learngate SRL wants to ensure that you are fully aware of all your data protection rights. According to the GDPR, you benefit from the following rights:

Right of access (art. 15 GDPR) — you have the right to obtain confirmation as to whether or not personal data concerning you are being processed and, if so, access to the respective data and information regarding the processing, as well as a copy of these data. The first copy is provided free of charge; for additional copies, we may charge a reasonable fee based on administrative costs.
Right to rectification (art. 16 GDPR) — you have the right to obtain the rectification of inaccurate data concerning you, as well as the completion of incomplete data.
Right to erasure (“right to be forgotten”, art. 17 GDPR) — you have the right to obtain the erasure of your personal data under the conditions provided by the GDPR (for example, when the data are no longer necessary for the purposes for which they were collected or when you withdraw your consent and there is no other legal basis for processing).
Right to restriction of processing (art. 18 GDPR) — you have the right to obtain the restriction of processing of your data under the conditions provided by the GDPR.
Right to data portability (art. 20 GDPR) — you have the right to receive the personal data concerning you which you have provided to us, in a structured, commonly used, and machine-readable format, as well as the right to request the transmission of these data to another controller, under the conditions provided by the GDPR.
Right to object (art. 21 GDPR) — you have the right to object, on grounds relating to your particular situation, to processing of data based on our legitimate interest. When the processing is for direct marketing purposes, you have the right to object at any time, free of charge and without any justification, in which case your data will no longer be processed for this purpose.
Right to withdraw consent (art. 7 para. (3) GDPR) — when the processing is based on your consent, you have the right to withdraw it at any time, free of charge and without needing to state a reason. Withdrawing consent does not affect the legality of the processing carried out before the withdrawal. You can withdraw your consent by sending a request to the contact details indicated below or, in the case of the newsletter, by accessing the unsubscribe link included in each communication.
Right not to be subject to a decision based solely on automated processing (art. 22 GDPR) — you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Learngate SRL does not currently use such automated decision-making processes.
Right to lodge a complaint with the supervisory authority — if you consider that the processing of your personal data violates legal provisions, you have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP), headquartered at B-dul G-ral. Gheorghe Magheru no. 28-30, Sector 1, postal code 010336, Bucharest, Romania; phone: +40.318.059.211; email: [email protected]; website: www.dataprotection.ro. You also have the right to appeal to the competent courts. We nevertheless encourage you to contact us first, to try to amicably resolve any dissatisfaction.

How you can exercise your rights
To exercise any of the rights above, you can contact us:

by email, at: [email protected];
by phone, at: 0751 188 752;
by mail, at the address: Bucharest, str. Șiragului no. 20, Romania.

We will respond without undue delay and, in any case, within at most one month of receiving the request. This period may be extended by two months when necessary, taking into account the complexity and number of the requests, in which case we will inform you of the extension and the reasons for it within one month of receiving the request. To protect your data, we may request additional information necessary to confirm your identity before acting on the request.

Privacy policies of other websites
Our site may contain links to other websites. Learngate SRL is not responsible for the privacy policies or practices of these external sites. We encourage you to carefully read the privacy policies of these sites before providing any personal information, as we have no control over their content or privacy practices and cannot guarantee the security of your data on these sites.

Changes to our privacy policy
We regularly review this privacy policy and publish any updated version on this page, indicating the date of the last update. In case of significant changes affecting the way your data are processed, we will inform you through appropriate means (for example, by email or through a visible notification on the site) before the changes take effect.

How to contact us
If you have questions regarding this privacy policy, the data we hold about you, or if you wish to exercise one of your data protection rights, do not hesitate to contact us:

Email: [email protected]
Phone: 0751 188 752
Postal address: Learngate SRL, Bucharest, str. Șiragului no. 20, Romania

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