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S.C. ACVATIC BEBE CLUB S.R.L.

CONFIDENTIALITY POLICIES REGARDING THE PROTECTION OF PERSONAL DATA

25.05.2018

The purpose of the information

This document contains informative data regarding the protection of personal data and was established by S.C. ACVATIC BEBE CLUB S.R.L. in order to comply with the applicable legal provisions on the protection of personal data imposed by Regulation (EU) 2016/679 (“General Data Protection Regulation”), as well as by any other legislation applicable in Romania.

The document is presenting, in a simple and transparent manner, information about how we collect, use, and protect your personal data when you interact with us in connection with our services and products, through the physical presence inside our club, through our website, or through the applications available on the mobile phone (WhatsUp, Facebook messenger, and SMS).

Any update and modification of the “Privacy Policy” will be displayed on our website, as well as at our headquarters, which is a reason why we ask you to check its content periodically.

Who we are

SC ACVATIC BEBE CLUB S.R.L., a legal person of Romanian nationality, based in Bucharest, Delea Noua street, no. 15, sector 3, registered at the Trade Register Office attached to the Bucharest Tribunal no. J40 / 11799/2012, CUI RO 30782146, legally represented by CARMEN-CRISTINA DUMITRU, having as activity aquatic education for children.

Whom do we address

The purpose of this document is to provide unitary information to individuals whose personal data are processed by S.C. ACVATIC BEBE CLUB S.R.L., including but not limited to the following persons:

What personal data is

According to Regulation (EU) 2016/679 (General Data Protection Regulation), personal data is any information that refers to an identified or identifiable natural person, any information that may lead to the identification of a specific person which also constitutes personal data. Examples of personal data: a name and surname, a home address, personal number code, an identity document number, e-mail address (eg: [email protected]/com), location data, an internet protocol (IP) address, a cookie identifier, etc.

What data processing means

The processing involves performing any operations on personal data: collection, registration, organization, structuring, storage, adaptation, modification, extraction, consultation, use, disclosure by transmission, dissemination, making available in any other way, alignment, combination, restriction, deletion, destruction.

What categories of personal data we process

Your personal data that we collect is provided directly by you, so you always have control over the type of information you provide to us. We receive information from you regarding the name and surname of the parent and child, home address, personal number code, serial number of identity card and birth certificate, date of birth, sex, e-mail address, telephone number, analysis results medical, materials filmed by surveillance cameras (existing in our location), financial information (details about bank cards, bank and bank account).

Additionally, for statistical and marketing purposes, we may collect data on the child’s performance with the aim of improving the activity carried out within the club, as well as individual studies, group studies, and comparative studies. All statistical data collected in connection with the child may be used in statistical studies and scientific communications, the publication of scientific papers or related to national or international meetings, specialized training courses for nurses and physicians, exclusively with your consent and only under the conditions of maintaining total confidentiality on all personal data of the child.

Also, any photos, videos, and images made with children in the club or in other activities made by the club can be used on its own website or in promotional materials.

At the same time, we inform you that there is the possibility to collect other data/information through your interaction with channels and websites that do not belong to us, that does not reveal your specific identity, or are not directly correlated with a person. These may include, but are not limited to:

In certain situations, we may combine the above data with Personal Data, such as the derivation of the geographical location from your IP address and the combination of behavioral data about your use of the Channels with your name. In these cases, we will treat the data/information combined as personal data.

What are the purposes and grounds for processing personal data

We will use your personal data for the following purposes:

The legal bases for the processing of personal data are substantiated:

With whom we share personal data

Your personal data will not be disclosed to other persons, for use in their own marketing or commercial purposes, without your consent, if there is such a situation.

However, we may disclose your information to service providers and/or other companies that provide us with services, such as the companies that manage our financial-accounting and/or invoicing, the companies that maintain the website, or that I send emails on our behalf.

Also, your data can be known by the other companies in our group: ACVATIC CLUB and SALINA BY ABC.

We inform you that based on a legal obligation or to defend a legitimate interest, we may disclose certain personal data to public authorities. We will permanently ensure that access to your data by other legal entities under private law will be made in accordance with the legal provisions on data protection and confidentiality of information, based on contracts concluded with them.

What is the storage period of your personal data

In order to fulfill the mentioned processing purposes, personal data will be processed throughout the contractual relationship, as well as subsequently, after its completion when there is a legitimate commercial need to do so (eg to provide you with the requested information or in order to comply with our legal, fiscal or accounting obligations) or in order to comply with the legal provisions applicable in this matter.

How we protect the security of your personal data

Internally, we apply security policies and standards, we take technical and organizational measures (computer security procedures) to ensure the confidentiality and integrity of personal data and the way they are processed.

Despite all the measures taken to protect your personal data, however, we draw your attention to the fact that the transmission of information via the Internet, in general, or through other public networks, is not completely secure, there is a risk that the data will be seen and used by unauthorized third parties. We cannot be held responsible for such vulnerabilities in systems that are beyond our control.

What are the rights of the person

The general regulation on the protection of personal data provides a number of rights in relation to your personal data. You can request access to your data, correct any mistakes in our records, and/or object to the processing of your personal data. Where applicable, you may also have the right to request the deletion of your personal data, the right to restrict the processing of your data, and the right to data portability. Last but not least, you can exercise your right to complain to the competent supervisory authority (National Authority for the Supervision of Personal Data Processing, 28 – 30 G-ral Gheorghe Magheru Blvd., Bucharest, sector 1, postal code 010336. phone +40.318.059.211, E-mail: [email protected]) or to address the competent court, for situations in which we will not promptly and amicably respond to your requests.

An exhaustive description of your rights can be found in the following:

Right to information: the right of the data subject to be informed about the way in which personal data are processed. Right of access: the right of the data subject to ask the controller if his data is processed, and in case of an affirmative answer to obtain a copy of this data.

Right to rectification: the right of the data subject to request the correction and completion of inaccurate or incomplete personal data on the basis of the information he/she provides.

Right to deletion of data (“right to be forgotten”): the data subject has the right to obtain from the controller the deletion of personal data concerning him, without undue delay if the data are processed illegally, without consent or if the data are no longer necessary for the purpose for which they were initially processed.

The right to restrict the processing – the data subject has this right if: he challenges the accuracy of the data, for a period that allows the verification of the correctness of the data; the processing is illegal and the person objects to the deletion of personal data, instead requesting the restriction; personal data are no longer necessary for the purpose of processing, but the person requests them for the establishment, exercise or defense of a right in court; the person objected to the processing for the period of time in which it is verified whether the legitimate rights of the operator prevail over those of that person.

Right to data portability: the data subject has the right to receive personal data concerning him or her which he has provided to the controller in a structured, commonly used and automatically readable format and has the right to transmit these data. data to another controller, without hindrance from the controller to whom the personal data were provided.

Right of opposition: the data subject has the right to object to the processing based on the legitimate interest of the controller, a third party, or the public interest. If this right has been exercised, the controller must justify the reasons for the processing and suspend it for a certain period. The processing will only operate if the controller demonstrates that he has legitimate reasons justifying it and that the processing prevails over the interests, rights, and freedoms of the data subject or that the purpose is to establish, exercise, or defend a right in court.

Right not to be subject to an automatic decision with significant effect: the data subject has the right not to be subject to an automatic decision, including the creation of profiles if the decision has a significant or legal effect on it. The data subject also has the right to express his / her point of view, to request human intervention, and to challenge the decision.

Any person may exercise in good faith the rights mentioned above, by sending a written request, dated and signed, using the address of our headquarters: Bucharest, Delea Noua Street, no. 15, sector 3 or email address: [email protected], to the attention of Mrs. Carmen Dumitru.