Privacy Policy

Privacy Policy regarding the processing of personal data

We regard ensuring the right to the protection of personal data as a fundamental commitment of START ACADEMY, and we therefore devote all the resources and efforts necessary in order to process your data in full accordance with Regulation (EU) 2016/679 (“the General Data Protection Regulation” sau “GDPR”), as well as with any other legislation applicable on the territory of Romania. Since one of the essential principles of this legal framework is transparency, we have prepared this document by which we wish to inform you of the manner in which we collect, use, transfer and protect your personal data when you interact with us in connection with our products and services, including through our website or through the applications available on mobile telephones.

We reserve the right to update and amend this Privacy Policy periodically, in order to reflect any changes in the manner in which we process your personal data or any changes in the legal requirements. In the event of any such amendment, we will publish on our website the amended version of the Privacy Policy, which is why we ask you to check the content of this Privacy Policy periodically.

Who we are and how you can contact us

START ACADEMY is the trading name of S.C. CURSURI ESTETICA S.R.L., a legal person of Romanian nationality, with its registered office in Bucharest, Strada Sfantul Petru Tei nr. 59, sector 2, registered with the Trade Register under number J40/13337/2016, sole fiscal registration code 36621068 (hereinafter “START ACADEMY” sau “noi“). For the purposes of data protection legislation, we are the data controller (in Romanian, operator ) when we process your personal data.

Since we are always open to learning your views, as well as to providing you with any additional information you may need regarding the processing of your data, we encourage you to contact the START ACADEMY Data Protection Officer at the e-mail address data.protection@aesthetic-courses.eu

What categories of personal data we process

In general, we collect your personal data directly from you, so that you have control over the type of information you provide to us. By way of example, we receive information from you as follows:

When you create a START ACADEMY account, you send us: your e-mail address, your surname and first name;

Within your personal page (My account) on the START ACADEMY platform you have the possibility of adding additional information, such as: mobile telephone number, landline telephone number, date of birth, delivery addresses, alternative e-mail address, bank card details, etc.;

When you place an order, you provide us with information such as: the product required, surname and first name, delivery address, invoicing details, payment method, telephone number, bank card details, etc.

We also offer you the possibility of registering on the START ACADEMY platform through your Facebook, Google or Twitter account. If you opt for one of these methods, you will be directed to a page administered by Facebook Inc / Google LLC, where they will inform you of the transfer of your data to START ACADEMY. You may consult the Facebook and Google privacy policies respectively using the following links:

https://www.facebook.com/about/privacy

https://policies.google.com/privacy

https://twitter.com/en/privacy

We may also collect and subsequently process certain information regarding your behaviour while visiting our website or using the smartphone application, in order to personalise your online experience and to make available to you offers adapted to your profile. We invite you to find out more details in this respect by consulting the section on the purposes of processing set out below.

On our website and in the smartphone application we may store and collect information in cookies and similar technologies, in accordance with the Cookie Policy.

We do not collect and do not otherwise process sensitive data, which the General Data Protection Regulation includes within special categories of personal data. Likewise, we do not wish to collect or process data of minors who have not reached the age of 16.

What are the purposes and the legal bases for processing

We will use your personal data for the following purposes:

1. 1. For the provision of START ACADEMY services for your benefit.

This general purpose may include, as the case may be, the following:

a) Creating and administering the account within the START ACADEMY platform;

b) Processing orders, including their receipt, validation, dispatch and invoicing;

c) Resolving cancellations or problems of any nature relating to an order or to the goods or services purchased;

d) Returning products in accordance with the legal provisions;

e) Refunding the value of products in accordance with the legal provisions;

f) Providing support services, including giving answers to your questions regarding your orders or the goods and services of START ACADEMY

The processing of your data for these purposes is in most cases necessary for the conclusion and performance of a contract between START ACADEMY and you. Likewise, certain processing operations falling under these purposes are required by the applicable legislation, including fiscal and accounting legislation.

2. 2. For the improvement of our services

We wish at all times to offer you the best online purchasing experience. To this end, we may collect and use certain information in connection with your behaviour as a purchaser, we may invite you to complete satisfaction questionnaires following the completion of an order, or we may carry out, directly or with the assistance of partners, market studies and research.

We base these activities on our legitimate interest in carrying on commercial activities, always taking care that your fundamental rights and freedoms are not affected.

3. 3. For marketing

We wish to keep you informed of the best offers for the products/services which are of interest to you. To this end, we may send you any type of message (such as: e-mail/SMS/telephone/mobile push/webpush/etc.) containing general and thematic information, information regarding products similar or complementary to those you have purchased, information regarding offers or promotions, information relating to products added in the “Account/My basket” section or the “Account/Favourites” section or in which you have shown an interest in purchasing, as well as other commercial communications such as market research and opinion surveys, and we may display personalised recommendations on the website and in the smartphone application. In order to make available to you information of interest to you, we may use certain data regarding your behaviour as a purchaser (for example, the products viewed / added to the wishlist / purchased) in order to create a profile for you. We always ensure that these processing operations are carried out in compliance with your rights and freedoms and that the decisions taken on the basis of them have no legal effects on you and do not similarly affect you to a significant extent.

In most cases, we base our marketing communications on your prior consent. You may change your mind and withdraw your consent at any time, by:

– Amending the settings in the client account in the “My subscriptions” section;

– Accessing the unsubscribe link displayed in the messages you receive from us; or by

– Contacting START ACADEMY using the contact details described above.

In certain situations, we may base our marketing activities on our legitimate interest in promoting and developing our commercial activity. In any situation in which we use information regarding you for a legitimate interest of ours, we take care and take all necessary measures to ensure that your fundamental rights and freedoms are not affected. Nevertheless, you may at any time request us, by the means described above, to cease the processing of your personal data for marketing purposes, and we will comply with your request.

4. 4. For the defence of our legitimate interests

There may be situations in which we will use or transmit information in order to protect our rights and our commercial activity. These may include:

– Measures to protect the website and the users of the START ACADEMY platform against cyber attacks:

– Measures to prevent and detect attempted fraud, including the transmission of information to the competent public authorities;

– Measures to manage various other risks.

The general basis for these types of processing is our legitimate interest in defending our commercial activity, it being understood that we ensure that all the measures we take guarantee a balance between our interests and your fundamental rights and freedoms.

Likewise, in certain cases we base the processing on legal provisions such as the obligation to ensure the guarding of goods and valuables laid down by the legislation applicable in this matter.

How long we keep your personal data

As a general rule, we will store your personal data for as long as you have an account on the START ACADEMY platform. You may at any time request us to erase certain information or to close the account, and we will comply with such requests, subject to the retention of certain information, including after the closure of the account, in those situations in which the applicable legislation or our legitimate interests so require.

To whom we transmit your personal data

As the case may be, we may transmit or grant access to certain of your personal data to the following categories of recipients:

– companies within the same group of companies as START ACADEMY;

– courier service providers;

– payment/banking service providers;

– marketing / telemarketing service providers;

– market research service providers;

– insurance companies;

– IT service providers;

– other companies with which we may develop joint programmes for offering our goods and services on the market.

Where we are subject to a legal obligation or where it is necessary in order to defend a legitimate interest, we may also disclose certain personal data to public authorities.

We ensure that access to your data by third parties which are private legal persons takes place in accordance with the legal provisions on data protection and the confidentiality of information, on the basis of contracts concluded with them.

În ce țIn which countries do we transfer your personal data

At present, we store and process your personal data on the territory of Romania.

Nevertheless, it is possible that we may transfer certain of your personal data to entities located in the European Union or outside the Union, including in countries for which the European Commission has not recognised an adequate level of personal data protection.

We will always take measures to ensure that any international transfer of personal data is managed carefully with the aim of protecting your rights and interests. Transfers to service providers and other third parties will always be protected by contractual undertakings and, as the case may be, by other safeguards, such as the standard contractual clauses issued by the European Commission or certification schemes, such as the Privacy Shield for the protection of personal data transferred from within the EU to the United States of America.

You may contact us at any time, using the contact details set out above, in order to find out more information about the countries to which we transfer your data, as well as the safeguards we have put in place in respect of these transfers.

Confidentiality and security: how we protect your personal data

We undertake to ensure the security of personal data by implementing appropriate technical and organisational measures, in accordance with industry standards.

The transmission of your personal data is carried out using state-of-the-art encryption algorithms and we store it on secure servers, while at the same time ensuring data redundancy.

For the making of payments we use the services of the payment processor PayU. Any information relating to payments is encrypted, using HTTPS technology with TSL 1.2 encryption.

Despite the measures taken in order to protect your personal data, we draw your attention to the fact that the transmission of information over the Internet in general, or by means of other public networks, is not completely secure, there being a risk that the data may be seen and used by unauthorised third parties. We cannot be held responsible for such vulnerabilities of systems which are not under our control.

What rights you have

The General Data Protection Regulation grants you a number of rights in relation to your personal data. You may request access to your data, the correction of any errors in our files and/or you may object to the processing of your personal data. You may also exercise the right to complain to the competent supervisory authority or to bring proceedings before the courts. As the case may be, you may also benefit from the right to request the erasure of your personal data, the right to restriction of the processing of your data and the right to data portability.

More information about each of these rights may be obtained by consulting the table presented below.

In order to be able to exercise your rights, you may contact us using the contact details set out above. Please note the following aspects if you wish to exercise these rights:

Identity. We take the confidentiality of all records containing personal data seriously. For this reason, please send us your requests regarding such records using the e-mail address associated with the START ACADEMY account. Otherwise, we reserve the right to verify your identity by requesting additional information intended to confirm your identity.

Fees. We will not charge a fee for you to exercise any right in respect of your personal data, save where your request for access to information is unfounded, that is to say repetitive or excessive, in which case we will charge a reasonable amount in such circumstances. We will inform you of any fees applied before dealing with your request.

Response time. We aim to respond to any valid requests within a maximum of one month, save where this is particularly complicated or where you have made several requests, in which case we will respond within a maximum of two months. We will notify you if we need more than one month. We may ask you whether you can tell us exactly what you wish to receive or what specifically concerns you. This will help us to act more quickly and to shorten the response time to your request.

Drepturile terțelor părți. We do not have to comply with a request where it would adversely affect the rights and freedoms of other data subjects.