Privacy Policy

Identity and contact details of the seller
The owner of https://www.culturaemotionala.ro/ (hereinafter referred to as the “Site”) is the company The Training Boutique SRL, headquartered in Ostratu, Corbeanca, 30D Hipodromului St., Ilfov County, Romania, registered with the Trade Register under no. J23/1727/2006, unique registration code 14823562, acting as seller (“the Seller”).

GDPR Privacy Policy for The Training Boutique Sites

Who are WE?

Who are YOU!

How do we collect YOUR personal information?

How do we use YOUR personal information?

How do we secure YOUR personal information?

How long do we keep YOUR personal information?

With whom do we share YOUR personal information?

What are YOUR rights regarding YOUR personal information?

Whom do you contact if you consider that YOUR personal information has not been managed correctly?

What happens if you have additional questions?

Who are we WE?

Under the legal entity The Training Boutique S.R.L, we have brought together 4 brands: Brainovate (www.brainovate.com), Personal Strengths (www.personalstrenghts.ro), EIROMANIA (www.eiromania.com) and Revealing the leader within (www.revealingtheleaderwithin.com). All offer customized solutions because we work together with you to find and adapt the right program for your organization.

As the official distributor for Personal Strengths in Romania for the entire suite of motivation and strengths-based assessments, we also offer the SDI (Strength Deployment Inventory) global qualification and access to SDI assessments. You can consult the Personal Strengths privacy policy on our website www.personalstrengths.ro.

As the official distributor for Personal Strengths in Romania for the entire suite of motivation and strengths-based assessments, we also offer the SDI (Strength Deployment Inventory) global qualification and access to SDI assessments. You can consult the Personal Strengths Romania privacy policy on their website https://totalsdi.uk/privacy/.

As the official distributor for GENOS INTERNATIONAL in Romania for the entire suite of emotional intelligence assessments, we also offer the GENOS global practitioner qualification and access to GENOS assessments. You can consult the GENOS International privacy policy on their website https://www.genosinternational.com/privacy-policy/ .

Broadly speaking, as creative leadership consultants, WE, at Brainovate, provide organizational, team, and leadership development, training, and coaching. Our main areas of focus are:

Leadership

Coaching and mentoring

Leadership Wellness and personal development

Team Building

Team and motivational profiling

Organizational culture

GENOS Certifications (as official distributor)

SDI Certifications (as official distributor)

Because we like to stay up to date with the news, we are also active on social networks, where you can read about our news and interests on both LinkedIn and Facebook. (Brainovate LinkedIn page here, Personal Strengths Romania LinkedIn page here, Brainovate Facebook page here; Personal Strengths Romania Facebook page here).

Who are YOU!

Over the last 16 years, you have likely been one of our clients or participants, or you have been recommended to us as someone with an interest and decision-making power regarding people development issues. We have likely spoken or met to discuss personal development, leadership training, or crossed paths at various job fairs or training conferences and networking events.

You have made decisions that involved your teams and brought a new breath of life into your organization.

If this is not the case, you have certainly received, over the years, our email communications in the form of announcements for Open Workshops or personalized invitations to meetings. To us, you are a decision-maker, both for your own personal development and for the development of your team and organization.

You might also be someone who has actively searched for resources or information in the professional development fields we cover and, therefore, came into contact with our offers through social networks, Google, or our website.

How do we collect Your Personal Information?

First, we would like to define what constitutes Your Personal Information. We collect: full name, contact details (email and contact number), company name, and job title.

We search all available online public records (Social Media Profiles: Facebook, LinkedIn, etc., Google Search, etc.) and collect this information in our HubSpot Cloud CRM account. You can read Hubspot’s Privacy Policy here.

We also collect and store all physical and electronic transactional records pertinent to service purchases and participation (Purchase Orders, Contracts, Receipts, course attendance sheets, etc.).

How do we use your personal information?

We use Your Personal Information to send emails of legitimate business interest pertinent to the universe of Personal and Organizational Development. (e.g., – Training announcements, Meeting invitations, Course programs, Course registration lists, Team and company updates, etc.).

Your Personal Information may be used, depending on the specific training offer, together with other online tools (Personal Strengths International, Internal Wellness Program and Audit, Genos Surveys, etc.)

We do not take the phenomenon of SPAM lightly and we consider your time, as well as ours, to be valuable.

How do we secure Your Personal Information?

We are oriented towards personal development and, as such, we are not interested in profiting from Your Personal Information. We do not sell or buy email lists from third parties. This is one of our promises!

Since all Your Personal Information resides in our HubSpot Cloud account, it is not stored or saved on other devices. When we need an overview, we will ensure that downloaded data is deleted.

We also want to promise that we will ensure full compliance with the law, should it change in the future and require additional security steps.

How long do we keep Your Personal Information?

After May 25, 2018, this will depend entirely on you! Since Your Personal Information was collected from previous workshops, team development or coaching programs under the legal umbrella of our brands, whether individual or company-level, or from all available public records, meetings we have had, recommendations or events we participated in together, direct requests from or on your behalf, this data has been stored and used on our own fully licensed hardware and software (e.g., – desktops, laptops, email and security software, etc.).

No data will be kept longer than is necessary for legitimate business interests. We consider it reasonable to approach our clients many years after they have participated in our programs.

If you do not wish for this, please let us know by sending an email to letstalk@brainovate.com.

With whom do we share your personal information?

As promised above, we do not share Your Personal Information with any third party.

We analyze this data internally and organize it so we can extract pertinent information for our own organizational development (e.g., – improved facilitation, customized development programs, etc.).

This organized information may be used between the two brands as a demonstration of our experience and expertise (e.g., – anonymized company case studies).

What are your rights regarding your personal information?

Your identity is protected at all times. If you have authorized a third party to send any type of request on your behalf, we will ask them to provide us with your consent.

You have the right to request all details that are pertinent to Your Personal Information. These will be provided in an email after you have sent us the request at letstalk@brainovate.com .

You have the right to request the correction of Your Personal Information, if it is incorrect, outdated, or incomplete.

You have the right to unsubscribe from our email communications. We will stop sending any future emails.

You have the right to the erasure of Your Personal Information from our records, by notifying us via an email sent to letstalk@brainovate.com requesting the deletion of your personal data.

Whom do you contact if you consider that your personal information has not been managed correctly?

If you consider that Your Personal Information has not been managed correctly or you are dissatisfied with our response to any request you have addressed to us regarding the use of Your Personal Information, you have the right to file a complaint with the National Supervisory Authority for Personal Data Processing (http://www.dataprotection.ro/?page=Modele_de_plangere).

What happens if you have additional questions?

We hope that this Privacy Policy has been helpful in establishing how we manage Your Personal Information and your rights to control it.

If you have additional questions that have not been covered, please contact us:

Email: letstalk@brainovate.com;

Tel: +40 722 311 878;

Address: 30D Hipodromului St., Ostratu, Ilfov, Romania;

ADDITIONAL INFORMATION

GENERAL TERMS AND CONDITIONS

The products sold on the Site are, as a rule, final goods intended for final consumers (“Buyers”) who use the Site to place purchase orders / purchase offers (“Order”). These Terms and Conditions do not apply in cases where the entity intends to buy the goods from the Seller on a wholesale basis for the purpose of resale or distribution.

The proposal for concluding the purchase contract is the placement of the goods offered by the Seller on the Site (“Offer”). The sales-purchase contract (“Contract”) is considered concluded when the Seller responds to an Order with an order confirmation on a durable medium, usually via a confirmation email sent to the Buyer (“Confirmation”).

Products
All products presented on the Site are new. Displayed images are for informational purposes only – color and some details may differ from those in the displayed images.

Some of the products displayed on the Site may not be in stock at certain times. The Seller reserves the right to refuse a certain Order if the respective product is no longer in the store’s stock or is unavailable for reasons beyond the Seller’s control.

The Seller reserves the right to cancel the Order or part of it before concluding the Purchase Contract in the following cases: the goods are no longer manufactured or delivered, or the supplier’s price for the goods has changed significantly. If the Buyer has already paid part of the purchase price or the full purchase price, this amount will be refunded.

Placing a product in the cart, in the absence of completing the Order and the Confirmation, does not represent the registration of an Order nor the reservation of the product until the Confirmation is made.

Prices
The price displayed on the Site is the final price of the product. To this, the Seller will add the delivery costs, which vary depending on the delivery area and the chosen delivery service. The Seller will attempt, as far as possible, to provide the Buyer with an estimate of the delivery prices before the Order is placed.

The Seller reserves the right to change the price of products without any prior notice. The Seller will not change the value of the Order after the email Confirmation.

Order Fulfillment
The Seller undertakes to honor any Confirmed Order within the displayed period [or within 30 days] from the Confirmation.

The Seller may cancel or delay the delivery of a Confirmed Order only in case of justified exceptional reasons, or in case of a fortuitous event or force majeure.

The Seller shall not be held liable for delays caused by transport services from the moment the latter have come into possession of the products.

By completing the Order, the Buyer confirms that all data provided, necessary for honoring the sales Contract, are correct, complete, and true at the date the Order is placed. The Buyer will be held liable for any damages caused by the incorrect information provided.

Payments
The Seller is obliged to provide only the means of payment displayed on the Site at the time the Order is placed.

In the case of online payments by credit cards or other similar instruments, the Seller is not/cannot be held liable for any additional costs incurred by the Buyer, including but not limited to currency conversion fees applied by the card-issuing bank, any fees and commissions of payment services, etc. Responsibility for such fees and tariffs belongs exclusively to the Buyer.

Additional Information
The Seller will try to provide Buyers with additional information regarding the products sold on the Site, but does not undertake to answer all questions or provide all requested information.

Intellectual Property
The content of the Site, including but not limited to logos, stylized representations, commercial symbols, static images, dynamic images, text, and/or multimedia content presented on the Site, are the exclusive property of the Seller, if they do not belong to other manufacturers or distributors, all rights to these materials, obtained directly or indirectly (through use and/or publishing licenses), belonging to the respective owners (“Intellectual Property”).

The Seller or the respective owners reserve all rights related to Intellectual Property, while Site visitors are not allowed to copy, distribute, publish, transfer to third parties, modify, and/or otherwise alter, use, link to, display, or include any element of the Intellectual Property.

Contact
The Buyer agrees that the Seller may contact them by any of the means available / accepted by the Seller, in any situation that requires contacting the Buyer, including for notifications related to the Order.

Document Amendments
These General Provisions are updated periodically; whenever the Seller makes an update, it will display it on its Site.

Last update date: November 2018

NOTICE REGARDING THE PROCESSING OF PERSONAL DATA ON THE SITE

Identity and contact details of the controller
All personal data processing activities carried out through the website https://www.culturaemotionala.ro/ (“the Site”) are performed by the company The Training Boutique SRL, headquartered in Ostratu, Corbeanca, 30D Hipodromului St., Ilfov County, Romania, registered with the Trade Register under no. J23/1727/2006, unique registration code 14823562 (“the Controller”). The representative of the Controller is Oliver Perkins, Director.

Contact data for any request related to personal data protection
Any complaints or requests related to personal data protection can be sent to the email address [letstalk@brainovate.com] or by mail to the address [Ostratu, Corbeanca, 30D Hipodromului St., Ilfov County, Romania] for the attention of the data protection representative.

Purpose of data processing
The information the Controller collects regarding Site users consists mainly of:

electronic identification details of site users together with any information provided by cookies and beacons according to our Cookie Policy [link to cookie policy] (IP address, browser type, browsing time, pages browsed, any other information according to the Cookie Policy, etc.);

identification details and contact data of current and potential customers (including name, address, email address, phone number, etc.);

payment data, including those of debit cards (if applicable – includes credit card no., expiration date, CVV, name on credit card, amount withdrawn);

information about any products purchased and unsent orders, use of the Site, and browsing habits on the Site;
information about any other complaints, requests, or questions sent (including name, address, email address, phone number, text of the request, etc.).

The purposes for which personal data are collected include:

concluding a contract at a distance (letters b) and c) above);

product delivery (letter b) above);

responding to any support, return, or warranty request (letters b), c), and e) above);

direct marketing (letter b) above);

statistics related to user activity carried out within the Site (letters a) and d) above);

accounting and reporting (letters b), c), d), and e) above).

The Controller processes personal data based on the following legal grounds:

preparation for execution and the actual execution or conclusion of the contract with potential customers – letters (i), (ii), and (iii) above;

legitimate commercial interests of the Controller, for example, preventing fraud and improving services and products; The Controller will assess its commercial interests case by case to ensure they do not override the rights of the data subject – letter (v) above;

compliance with a mandatory legal requirement, including, for example, accounting and legal requirements, which are subject to a strict internal policy (such as retention periods) – letter (vi) above;

the consent that data subjects give to the Controller – letter (iv) above.

Recipients of personal data or categories of recipients
Customers (members and guests) can pay by bank card via NETOPIA mobilpay. Bank card details (purchase value, card number, name on card, expiration date, CVV code) and customer identification data (extracted from the Site) are processed – name, surname, phone, email address, the code assigned to the customer by the merchant.

The purpose of processing is to perform online payments through the NETOPIA mobilpay payment processor.

The legal basis is the execution of the contract in accordance with Article 6 (1) (b) of the GDPR.

The Controller’s customers are hereby informed that, at the time of payment, they will navigate to the NETOPIA mobilpay site. The terms and conditions under which NETOPIA mobilpay processes payments are available here: https://www.mobilpay.ro/public/politica-de-confidientialitate/

Recipients of personal data or categories of recipients
The Controller may transfer personal data belonging to data subjects to partners and collaborators only for the performance of its commercial activity. Third parties and proxies who may receive personal data include:

delivery services;
manufacturers, importers, and suppliers of products and services distributed by the Controller;
payment operators (e.g., Netopia Mobipay);
accounting firms, legal service providers;
email marketing agencies and mass email services (e.g., MailChimp);
site traffic monitoring services (e.g., Google Analytics);
other subcontractors.
The Controller will ensure it concludes contracts with third parties that provide an adequate level of personal data protection.

The Controller will not transfer personal data to a third country. As an exception, certain data regarding direct marketing or Site traffic may be transferred to processors in third countries that offer an equivalent level of protection or to the United States of America (only companies in the EU-US Privacy Shield).

If the Controller goes through a reorganization procedure (including merger, division, dissolution, or liquidation) or sale to another organization, it will communicate the person’s information to the successor organization. Also, the Controller may transfer data to a third person if a mandatory requirement of the law requires it.

Personal data storage period
The Controller will store information belonging to data subjects as long as required by applicable legal provisions. If there is no applicable regulation, or if the mandatory legal term has passed, the Controller will store data only as long as necessary, depending on the purpose for which they were collected.

Data collected for direct marketing purposes will be processed until the right of withdrawal is exercised.

Rights of the data subject
The data subject has the right to request from the Controller, in relation to personal data concerning them, access to them, their rectification or erasure, or restriction of their processing, or the right to object to processing, in accordance with applicable regulations. The Controller will ensure the right to data portability.

When processing is based on the data subject’s consent, they have the right to withdraw their consent at any time, without affecting the lawfulness of the processing carried out based on the consent given before that withdrawal.

The data subject has the right to file a complaint with the competent National Supervisory Authority for Personal Data Processing or any other competent authority if they consider that their rights related to data processing have been violated.

Mandatory provision of personal data
The provision of certain personal identification data, such as name, email address, physical address, and phone number, as well as data corresponding to payment instruments or requested by payment processors, are essential for concluding a remote contract and for product delivery.

Document amendments
This information regarding personal data processing is updated periodically; every time the Controller makes a change, it will be updated on the Site.

Last update date: November 2018

PRIVACY, MARKETING AND COMMERCIAL COMMUNICATIONS POLICY

Identity and contact details of the controller
All marketing activities carried out regarding the data collected from the users (“Users”) of the site https://www.culturaemotionala.ro/ (“the Site”) are performed by the company The Training Boutique SRL, headquartered in Ostratu, Corbeanca, 30D Hipodromului St., Ilfov County, Romania, registered with the Trade Register under no. J23/1727/2006, unique registration code 14823562 (“the Controller”) legally represented by Oliver Perkins.

This Privacy, Marketing and Commercial Communications Policy should be interpreted together with the more general Notice regarding the processing of personal data on the site [link to Notice regarding processing of personal data on the site].

Confidentiality
The Controller has the obligation to maintain the confidentiality of any information related to orders and Users.

The Controller may disclose such information to its affiliated entities, subcontractors, and partners with whom it collaborates for the purpose of carrying out its commercial or marketing activity, within applicable legal limits and under equivalent confidentiality conditions.

Commercial communications
By checking the box “I agree to be contacted for various offers or news from https://www.culturaemotionala.ro/” or any similar description, the User expressly accepts the possibility of receiving by email or any other similar means of communication offered, a newsletter and other commercial communications.

The User can change their option at any time regarding the consent given to the Controller for commercial communications containing general and thematic information, including information regarding offers or promotions, by accessing the unsubscribe link displayed in the commercial communications received from the Controller or by contacting the Controller directly with an express request to this effect.

Transfer to third countries
Some data regarding direct marketing campaigns may be transferred to processors in third countries that offer an equivalent level of protection or to the United States of America (only companies in the EU-US Privacy Shield).

One of these authorized third parties could be the email marketing service MailChimp, which also carries out processing activities in the USA. The User or Client expressly accepts the possibility of transferring email marketing data to the USA and the MailChimp Privacy Policy, available at the date hereof, at https://mailchimp.com/legal/privacy/#contacts

Marketing
To improve the offer of goods and services and the User experience, the Controller may use data belonging to Users to conduct market research and analysis regarding the effectiveness of commercial communications. Information obtained from these activities will not be used for advertising purposes.

Document amendments
This privacy, marketing and commercial communications policy is updated periodically; every time the Seller makes a change, this policy will be updated on the Site.

Last update date: January 2020