Privacy policy

1. INTRODUCTION

We treat the confidentiality of personal data seriously and responsibly, and their security is a priority for us.

Therefore, we undertake to comply with the new rules imposed by the European Regulation 2016/679 called "Regulation" (supplemented by Law 190/2018) regarding the processing of personal data and the free movement of such data.

Through this policy we explain what personal data we process, how we collect it, how we use it and, above all, how we protect this data.

We also inform you about your rights and guide you on how to exercise them.

2.ABOUT US

CENTRUL DE INDRUMARE MEDICALA DRHC SRL is a Romanian legal entity, with registered office in B-dul Mărășești, nr. 34, Et. subsol, Ap. 1, Camera 3, București, Sect 4, CUI RO30799679, J40/2104/2021.

The legal representative of the company is Carmen Păducel and can be contacted at B-dul Mărășești, nr. 34, Et. subsol, Ap. 1, Camera 3, București, Sect 4, and at the e-mail address pericleanu.carmen@gmail.com.

In terms of the EU Regulation 679/2016, CENTRUL DE INDRUMARE MEDICALA DRHC SRL is a controller of personal data and has designated Carmen Păducel as the responsible person who can be contacted:

• by email to pericleanu.carmen@gmail.com ;
• by mail to: B-dul Mărășești, nr. 34, Et. subsol, Ap. 1, Camera 3, București, Sect 4, for the attention of the PERSON RESPONSIBLE FOR PERSONAL DATA.

3. WHAT DATA WE COLLECT AND HOW WE COLLECT IT

We use only that information that is strictly necessary and relevant to our business and your needs as a consumer and we collect it through our website which is hosted and administered in Romania.

We come into possession of your data, mainly as a result of the fact that you voluntarily choose to disclose it to us, but also by automatic capture at the time you access our site, as a result of the use of specific technology and software.

Although you can visit our site without having to reveal your identity, you can directly provide us with your personal data when you use:

1. Newsletter form*

* Available in the website footer https://www.neurofeedback-bucuresti.ro/

Through which we send you marketing and advertising materials using your identification data.

Data collected:

• Email address;

We will only send you communications about news from our offer if you have opted in.

You can always choose to change your mind and withdraw your consent by ticking the unsubscribe button, according to the instructions included in the e-mail.

2. Program contact formări

* Available at: https://www.neurofeedback-bucuresti.ro/contact/

We use your personal data for the purpose of taking your request, in order to have all the necessary information to schedule you for a discussion with one of our specialists.

Data collected:

• Name;
• First name
• E-mail;
• Phone;

If you do not agree to disclose this information, we will be unable to honor your request.

Automatic data capture is realized through:

• cookie technology; cookie is a piece of information transmitted from the web page, saved by the browser on your computer's hard disk and that we can access later. It retains statistical information necessary for a web page to personalize the browsing session (e.g. by displaying dynamic images of products of interest) such as web pages previously visited, downloads made, the internet provider used, the country of origin of the site visitor.

The most common cookies are:

• Technical: they are absolutely necessary to ensure the efficiency of the site from a technical perspective,
• Functional: remember your choices and help us improve your experience on our website,
• Performance: helps us measure site performance by using information about how visitors navigate the site,
• Redirection: helps us to place advertisements on other websites you use
• Social media plug-in: to connect our customers to different social media channels.

We collect and process data provided by cookie technology only if you allow us to do so.

• standard web server log files, provide us with statistical information about the number of visitors and allow us to evaluate the technical capacity of our website.

Through them we collect some information about your IP address, but they are not able to identify you directly but to provide us with statistical data about the traffic on the page.

Google Analytics

Our website uses the web analytics service "Google Adwords/Analytics" of Google Inc. for statistical purposes.

This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"), which in turn uses cookies. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States.

If IP anonymization is enabled, your IP address will be shortened within the European Union Member States or other third party members of the European Economic Area. Only in exceptional cases, the entire IP address will be transmitted to a Google server in the USA and shortened there. IP anonymization is enabled for this website. Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

The IP address transmitted by your browser will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, if you do this you may not be able to use the full functionality of this website. You can also opt-out of using Google Analytics in the future by downloading and installing the Google Analytics Opt-out Browser Addon for your browser: https://tools.google.com/dlpage/gaoptout?hl=en.

To agree or withdraw your consent to automatic processing by means of the above-mentioned programs or technologies, set this option in the welcome message you receive when accessing the site / make the appropriate settings in your browser. For more details please visit our cookies policy.

If you choose to browse without these technologies or programs, some site functions or features may not work.

If you accept the full use of automatic capture programs and technologies, we will collect the following data:

• contact details: e-mail address
• technical data: connection data, including IP, operating system and platform, browser identification, location, technologies used on the devices used to access the site
• usage data: of the website, of our services,

4. PURPOSE OF COLLECTION and LEGAL BASIS

We collect information containing personal or technical data mainly for:

1. Improving our services and your browsing experience on our website.

In order to carry out this activity we rely on our legitimate interest to carry out commercial activities but we are also attentive to the respect of your rights and freedoms so we offer you the possibility to easily unsubscribe from the use of the programs and technologies we use in the process of data collection and processing.

2. Direct marketing

We base our marketing communications on your prior consent. You can opt-out at any time by clicking the unsubscribe button within the messages you receive from us.

3. Security reasons for our hardware and software infrastructure.

The basis for collection and processing for this purpose is both a legal one, namely the obligation to safeguard our assets, and one based on our legitimate interest to protect our business.

To the extent that we use your information for purposes other than those stated above, we will expressly ask for your consent and explain to you what new rights you have in this situation.

5. INABILITY/REFUSAL TO PROVIDE US WITH CERTAIN PERSONAL DATA

If you do not provide us with the requested information it is very likely that you will not be able to use our website in normal parameters and also that we will not be able to accept and process your request and will not be able to provide you with the products or services of interest to you.

6. USERS

Your data is used by CENTRUL DE INDRUMARE MEDICALA DRHC SRL (https://www.neurofeedback-bucuresti.ro/ ) and we will never share your personal information with a third party for purposes other than those described in this Privacy Policy.

We may transmit your personal information to our trusted partners who are able to provide guarantees about the security and confidentiality of your data and who process the data only in accordance with our instructions.

Our partners are in general third party service providers with whom we collaborate and who operate in areas such as IT services and maintenance, database hosting internally and within the EU, behavioral analytics services (Google Analytics,), accounting and tax, consulting and legal assistance, marketing, finance, advertising, public authorities.

7. PLACE OF STORAGE

Both the web page and the physical and electronic database containing personal information are hosted/stored on secure servers in Romania.

To the extent that we transfer certain personal data to entities located inside or outside the European Union, including to countries where the European Commission has not recognized an adequate level of protection of personal data, we will take measures to protect your rights and interests.

Transfers will be protected by contractual clauses or other safeguards such as the certification schemes of which the Privacy Shield for the protection of personal data transferred from within the EU to the United States is a part.

8. SECURITY MEASURES

Although your data is collected online, some of it is also stored on paper (e.g. invoices).

CENTRUL DE INDRUMARE MEDICALA DRHC SRL (https://www.neurofeedback-bucuresti.ro/ ) is especially and constantly concerned with the implementation of efficient security measures to protect your personal data and to avoid security breaches both in terms of information stored online and on physical media.

Regardless of the method of storage, your data is stored in secure environments that benefit from safeguards to protect against unauthorized access, use, disclosure, alteration or destruction.

Also, we have implemented special measures regarding network and data transfer security, infrastructure auditing and testing, trained staff, data transfer outside Romania only to entities that can ensure similar protection, etc.

9. STORAGE PERIOD

Where we process your data for the performance of pre-contractual/contractual obligations we will store the data for as long as necessary for the performance of the contract and for an additional period thereafter.

If we process your data by virtue of a legal obligation or in the public interest, we will store the data for as long as it is necessary to comply with the legal obligation or as long as the interest is qualified as being in the public interest.

Where we process your data for the protection of our legitimate business interests, we will store the data until you ask us to stop unless we can demonstrate that the reason for collecting and storing it overrides your interests, rights and freedoms.

If we process your data on the basis of your express consent, we will store the data until you ask us to stop.

If we process your data by virtue of a legal obligation or in the public interest, we will store the data for as long as it is necessary to comply with the legal obligation or as long as the interest is qualified as being in the public interest.

Where we process your data for the protection of our legitimate business interests, we will store the data until you ask us to stop unless we can demonstrate that the reason for collecting and storing it overrides your interests, rights and freedoms.

If we process your data on the basis of your express consent, we will store the data until you ask us to stop.

We store the personal data collected through the offer request form for 12 months

We store personal data collected through the contact form for 12 months

10. AUTOMATING DECISION-MAKING

CENTRUL DE INDRUMARE MEDICALA DRHC SRL (https://www.neurofeedback-bucuresti.ro/ ) does not use automated processes that may generate legal effects that concern you or that may affect you to a significant extent.

You may at any time ask not to be subject to a decision based solely on automated processing, if that decision produces legal effects on you or otherwise affects you in a similar way and to a significant extent.

You may not benefit from this right to opt-out if the decision taken as a result of our automated data processing is necessary for us to enter into or perform a contract or is permitted by law and there are adequate safeguards for your rights and freedoms.

If you have given us your consent to automatic processing and then you change your mind, you can withdraw this consent at any time by formulating a written request that you communicate to us using the data mentioned in the Contact section of the website.

11. RIGHTS
12. Right to information -you have the right to know whether your personal data are processed; what data are collected, where they are obtained and why, by whom they are processed, for what period of time and whether these data are subject to automated processing likely to produce legal effects or significantly affect you.
13. Right of access -you have the right to access, free of charge and at reasonable intervals, data collected from/about you. This includes your right to request and obtain a copy of the personal data collected.
14. The right to update/rectification -you have the right to request the rectification or updating of your personal data that is inaccurate or incomplete.
15. Right of erasure -if you have withdrawn your consent, object to the processing, the processing does not comply with the provisions of the Regulation or is no longer necessary for the purposes for which the data was collected and processed, you may request that your personal data be deleted from our records.
16. Right to restrict processing -where certain conditions apply, you have the right to restrict the processing of your personal data.
17. Right to object -in certain cases you have the right to object to the processing of your personal data, for example in the case of direct marketing.
18. The right to object to automated processing -where your personal data is subject to automated processing, including profiling, which may produce legal effects or affect you in a significant way, you are entitled to ask us to exclude your data from any automated individual decision-making process.
19. The right to data portability -you have the right to obtain your personal data in an appropriate format or, where possible, by direct transfer from one processor to another.
20. Right to help from the supervisory authority -you have the right to seek help from a supervisory authority and the right to other remedies, such as claiming damages.
21. The right to withdraw consent -you have the right to withdraw your consent at any time Withdrawal of consent does not affect the lawfulness of the processing prior to its withdrawal.
22. Right to lodge a complaint -if you want to make a complaint about the way we process your personal data, we invite you to contact us:

• by email to pericleanu.carmen@gmail.com
• by mail to: B-dul Mărășești, nr. 34, Et. subsol, Ap. 1, Camera 3, București, Sect 4, for the attention of the PERSON RESPONSIBLE FOR PERSONAL DATA.

We assure you that all your complaints will be treated with seriousness, professionalism and complete confidentiality.

If you are still dissatisfied with the way we have responded to your complaints, you can contact the authorities that have a supervisory role over our personal data activity.

In Romania, this authority is represented by the National Supervisory Authority for the Processing of Personal Data, whose contact information is:

• Address. Gheorghe Magheru nr. 28-30, Sector 1, postal code 010336, Bucuresti, Romania
• Phone: +40.318.059.211 or +40.318.059.212;
• E-mail: anspdcp@dataprotection.ro