Protection of personal data

The Association Education for Real Life (AEVR), a non-profit organization registered with the National Register of Associations and Foundations under no. 10061/A/2013, Unique Tax Identification Code 32120145, with mailing address Bulevardul Dacia, no. 102, Sector 3, Bucharest, postal code 020054, email address contact@aevr.ro, telephone 0723 681 502, processes personal data in accordance with the provisions of the General Data Protection Regulation (GDPR) and Law 190/2018 on the application of GDPR in Romania.

The programs we run are educational in nature, and one of the specific elements of any such approach – when done seriously – is the need to evaluate the effectiveness of the program in order to improve it permanently. And this evaluation is most correctly done through regular feedback on how the beneficiaries of these programmes apply and use the acquired knowledge and skills. In addition, due to the specific nature of the educational programmes we run, the data we collect often includes data in the category considered by the GDPR as special data: income level, education level, psycho-socio-behavioural skills and characteristics, etc.

For these reasons, we considered it useful – and necessary, due to the legal obligation imposed by Article 37 of the GDPR, that the processing of personal data is carried out under the coordination of a Data Protection Officer, who can be contacted for any issues related to the processing of your data at dpo@aevr.ro.

From whom we collect data

The activities carried out by AEVR are aimed at individuals aged 18 or over who may be, are, or have been beneficiaries of the educational programmes we organise. In addition, we also collect data from collaborators or potential collaborators, as well as from representatives of organisations with which we also have or may initiate collaboration contracts. 

We also collect specific web traffic data from visitors to aevr.ro.

Type of data collected, purpose, duration and lawfulness of processing

From the categories of persons mentioned above, we primarily collect contact data – in order to be able to relate to each other, data that we process in accordance with the provisions of Article 6 (1) (f) of the GDPR, for as long as the Purpose of the Association remains unchanged. When a legally regulated relationship (employment contract, collaboration contract, enrolment in our programmes, etc.) arises as a result of the relationship between us and these persons, we will request, in addition to the contact data, only the data required by the legislation governing the activity in which the persons concerned are to participate. These data will be processed for the duration mentioned in the documents legally governing the partnership relationship or in the legislation which may also mention the period during which the data must be kept, plus the limitation period for rights arising from these collaborations, which is usually three years for most commercial contract relationships. 

The data collected from visitors to the site is anonymous, i.e. it only refers to the IP address used to access Internet services, the type of equipment used (PC, tablet, phone), the type of browser, the most frequently accessed pages, etc., – elements that cannot by themselves identify the persons from whom we collect this data, but which help us to constantly improve the content of the site, according to the interests of visitors. The processing of this type of data is done on the basis of Article 6 (1) (f) of the GDPR, for a maximum period of 3 years. 

In addition, also for the purpose of optimizing the content of our website but also to facilitate your navigation on subsequent visits, we also use cookies. The processing of this type of data is carried out in accordance with the provisions of art. 4 – par. (5) of Law 506/2004, based on your consent which can be given or refused in accordance with the provisions of art. 5 par. (5^1) of the said law. For more details on cookies and the ways in which you can give your consent or reject their use, please refer to the end of this notice or to https://aevr.ro/politica-de-utilizare-a-modulelor-cookie.

How we collect data

We obtain your data via the registration forms for our financial education programmes, via the data collection forms on the website pages, from written or telephone messages you send us using our contact details on the website, or from the websites or social media pages where you have deliberately chosen to make this data public and which we may find when looking for collaborators or potential collaborators who may be interested in our programmes.

Obligation to provide data

Before joining our programs as a beneficiary or collaborator, you are under no obligation to provide us with any data about yourself. 

However, if you choose to benefit from our programmes, we will ask for a range of personal data and information that will help us to guide you as accurately as possible towards achieving the objectives that led you to choose our educational services. Of course, you will not be obliged to respond to all of our requests, but please understand that the less information we ask for, the less we will be able to tailor the educational programme to your needs, in which case there is a risk that we will not be able to achieve the objectives you set out to achieve when you contacted us. 

If you choose to collaborate – either as a representative of a legal entity or as an employee of the AEVR, the data required by the legislation governing the agreed form of collaboration will be necessary, without which it will be impossible to start the collaboration relationship.

Data security

Having a legal obligation, but above all out of respect and care for the beneficiaries and partners of our programmes, EDUCATION FOR REAL LIFE ASSOCIATION undertakes to apply all the technical and organisational measures necessary to protect personal data processed through computer and communication systems and other electronic systems, as well as those processed in any other form. Thus, in order to protect such data against threats and any actions that may harm the confidentiality, integrity, availability and authenticity of the data, we have developed and comply with security procedures and policies designed to ensure the physical protection of areas where equipment or documents through which personal data are processed are located, limiting access to these areas and to such equipment or documents only to personnel authorized to have access to such data, without neglecting either the rules established for situations in which data are transferred to/from our computer systems, or those applicable in the event of the identification of security incidents.

Data made available to third parties

The data you make available to us will not be disclosed to a third party for use for purposes other than those for which it is collected. With strict reference to the purposes for which the personal data were collected, the personal data processed by the REAL LIFE EDUCATION ASSOCIATION may be made available to intermediaries specialized in providing services related or complementary to the activities we carry out (such as electronic payment services, courier services, accounting services, educational services, etc.). However, even in these situations, we will not make your data available to a third party, unless the third party undertakes, on the basis of a legal commitment concluded in accordance with Article 26 or Article 28 of the GDPR, that they will process your personal data in compliance with both the relevant legal rules and the obligations assumed by this information.

Do we transfer personal data outside Romania?

We do not process or transfer your data outside Romania.

Do we use automated decision-making or profiling processes?

No, we do not use decision-making or profiling processes based solely on automated data processing, and are thus not in the situation provided for in Article 22 of the GDPR, concerning the production of legal effects or which may similarly affect the persons from whom we collect data.

Your rights regarding processed data

In accordance with the provisions of Articles 13-22 of the GDPR, you may exercise your rights in relation to data collected and directly concerning you at any time by contacting us using the contact details set out in the first paragraph or directly to the email address of the Data Protection Officer, dpo@aevr.ro. 

The rights you can exercise in this way relate to:

  • the right to information and access – you can obtain from the REAL LIFE EDUCATION ASSOCIATION confirmation as to whether or not personal data concerning you is being processed and, if so, access to that data;
  • the right of intervention or rectification of data – refers to the right to obtain the completion of personal data that is incomplete, including by providing additional data or by modifying/deleting information that is no longer up to date.
  • the right to erasure of data – you may request the deletion from our records and systems of personal data directly concerning you, and we will respect this right without undue delay, if the grounds set out in Article 17(1) of the GDPR apply and none of the situations set out in Article 17(3) of the GDPR apply;
  • the right to restrict processing – when the accuracy of the data processed, the lawfulness of the processing, the period or purpose for which the data were collected has been exceeded, the period of restriction of processing being at least equal to the period necessary to resolve the objection lodged;
  • the right to data portability – when the personal data was in a structured, commonly used and machine-readable format, one may request, in the cases provided for by Article 20 of the GDPR, the transmission of such data to another controller, without obstacles from the ASSOCIATION OF EDUCATION FOR REAL LIFE.;
  • The right to withdraw consent – at any time, without affecting the lawfulness of the processing carried out on the basis of consent prior to the withdrawal of consent.

 

  • The right to lodge a complaint with the National Supervisory Authority for Personal Data Processing – when you consider that your rights regarding the processing of data directly concerning you have been violated and you also consider that the response we have given to your complaint is not correct, you have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing. 

 

The Authority’s contact details are as follows:

B-dul G-ral. Gheorghe Magheru nr. 28-30, Sector 1, postal code 010336, Bucharest, Romania

Telephone: +40.318.059.211 or +40.318.059.212;

E-mail: anspdcp@dataprotection.ro

Web address: https://dataprotection.ro

Changes to the general Terms and Conditions

AEVR reserves the right to periodically modify the content of this document, as well as the content of any section of the website it hosts, without prior notice to the user.

You as a user/visitor understand, accept and agree to periodically review this document as well as to periodically review any policy for the operation of the website whenever you access the website or provide personal data to us through the website.

Cookies

Cookies are small files that are stored on a user’s computer. They are designed to store a small amount of data specific to a particular visitor and the website they are visiting, and are accessible both to the person who owns the computer on which they were automatically saved and to the website that sent the file. This type of processing allows the server to provide a web page tailored to a specific user, or perhaps even to transmit information from a visit to one site to another similar site with the same owner.

How do I know if cookies are enabled in my browser?

To check whether your browser is configured to allow cookies, you will need to look in your browser settings options for the section dedicated to cookies, usually under the heading “privacy and security options”. Also in this section you will find information on enabling or disabling cookies, deleting cookies. You can also view the content of these files.

What data is contained in a cookie?

Each cookie file is actually a small table or line of text containing pairs of values (key, data) – for example (name, John) (name, Smith). Once the cookie file has been read by the code on the client server or computer, the data can be retrieved and used to personalise the web page accordingly.

When are cookies created?

Writing data to a cookie is usually done when information is sent to the website being accessed – for example, after pressing a ‘submit’ button, the data handling page could be used to store the values in a cookie. If the user has chosen to disable cookies, the write operation will fail and subsequent visits that might retrieve the information already submitted, from the cookie, will either work according to the default algorithm for new visitors or will ask the user to re-enter the information that would have been stored in the cookie.

How are cookies used by this site?

A visit to this site may place cookies on your system for the following purposes:

  • Site performance cookies
  • Visitor analytics cookies
  • Geotargeting cookies
  • Registration cookies

 

Do cookies contain personal data?

Cookies themselves do not contain or require personal information to be used and, in most cases, do not personally identify Internet users. Personal data obtained indirectly through the use of Cookies may be collected only to facilitate certain functionalities for the user. Such data is encrypted in a way that makes it impossible for unauthorised persons to access it.

Why are cookies used?

Cookies are central to the efficient functioning of a website, helping to generate a user-friendly browsing experience tailored to each user’s preferences and interests. Refusing or disabling cookies can make some sites very difficult or even impossible to use. Refusing or disabling cookies does not mean that you will no longer receive online advertising – it just means that it will no longer be able to take into account your preferences and interests as evidenced by your browsing behaviour. Here are some examples of facilities that can be implemented using cookies:

  • Content and services tailored to user preferences – categories of products and services
  • Offers tailored to user interests – password retention
  • Retention of child protection filters on Internet content (family mode options, safe search functions)
  • Limiting the frequency of ads – limiting the number of times an ad is shown to a particular user on a site
  • Providing more relevant advertising to the user
  • Measurement, optimisation and analytics features – such as confirming a certain level of traffic to a website, what type of content is being viewed and how a user gets to a website (e.g. via search engines, directly, from other websites etc). Websites run these analytics on their usage to improve their sites for the benefit of users.

 

What are tracking cookies?

Some commercial websites include embedded advertising material that is served by a third party website and it is possible that such ads will store a cookie for that website. This cookie will store information that could include the name of the site, certain products visited, pages visited, etc. When the user later visits another site that contains a similar embedded ad from the same third-party site, the advertiser will be able to read the cookie and use it to determine some information about the user’s browsing history. This allows publishers to serve ads targeted to a user’s interests, so in theory they have a better chance of being relevant to the user. However, many people see such “tracking cookies” as an invasion of privacy because they allow an advertiser to build user profiles without their consent or knowledge.

How can cookies be managed or deleted?

Where a site does not provide mechanisms for selecting or rejecting cookies, the storage of cookies on your computer can be controlled by a browser option that allows you to refuse cookies. Thus, through your browser settings, you can choose not to accept cookies or you can set your browser to accept cookies only from certain sites. However, you should bear in mind that disabling or deleting certain cookies may adversely affect or limit some of the functionality of websites. To control from your browser how you accept cookies, you can access one of the links below – depending on your browser:

  • Google Chrome ( https://support.google.com/chrome/answer/95647?hl=en-GB )
  • Mozilla Firefox (https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox?redirectlocale=en-US&redirectslug=delete-cookies-remove-info-websites-stored )
  • Internet Explorer (https://support.microsoft.com/ro-ro/help/17442/windows-internet-explorer-delete-manage-cookies )
  • Safari ( https://support.apple.com/ro-ro/guide/safari/sfri11471/mac )
  • Opera ( https://help.opera.com/en/latest/security-and-privacy/ )
  • Edge ( https://support.microsoft.com/ro-ro/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy )

The European Commission support does not constitute an endorsement of the contents which reflects the views only of the authors, and the National Agency and Commission cannot be held responsible for any use which may be made of the information contained therein