This personal data processing policy explains what we do with your personal data, whether we provide you with services, marketing and informational materials, or use your personal data as part of research conducted for marketing or statistical purposes.

We also inform you that, starting May 25, 2018, Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “Regulation”) will be applied by all European Union member states. The Regulation aims to create a uniform and consistent legal framework across the European Union.

The company ALPHABET KINDERGARTEN aligns with the provisions of the Regulation, and we believe this is an appropriate moment to highlight a few important aspects.

This document describes how we collect, use, and process your personal data and how, in doing so, we fulfill our legal obligations toward you.

Your privacy is important to us, and we are committed to protecting your personal data and safeguarding your rights.

If you are dissatisfied with any aspect of our data processing policy, you may have legal rights, which we have described below where applicable.

We may update this notice from time to time. Please visit this page if you wish to stay informed about the next time we post any changes here.

WHAT PERSONAL DATA DO WE PROCESS?
Your personal data is collected through our website, via email, through the platforms we use, and by phone. Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to assist us in this regard:

Name and surname;
Contact phone number(s);
Sex;
Date of birth;
Contact details: email address;
Identification details;
Correspondence exchanged between us and you; or
Any other additional information that you choose to provide us.

Additionally, when you visit our website, we automatically collect technical information, including the IP address (Internet Protocol) used to connect your computer to the Internet, your login information, browser type and version, time zone settings, types and versions of browser plugins, system and platform details, passwords and hints, and similar security information used for authentication and account access.

Important!

Please note that when you use our website, cookies are stored by your browser on your device. Be aware that if you disable cookies, our website may not function properly in your browser. We aim to ensure that our website provides visitors with what they are looking for and delivers the most relevant information. To achieve this, we may also store and use your data for market research, to improve the quality of our website and services, for service development, to enhance website performance, to measure the success of our promotional campaigns, or to tailor our services to your needs.

HOW DO WE USE YOUR PERSONAL DATA?

We collect and use your personal data for the following purposes:

For registering an information request or enrollment in the services offered by the kindergarten.
For this purpose, we collect the following data: name, surname, email address, IP address, phone number.

To facilitate the provision of information regarding the educational services offered by the kindergarten, as well as for communication with parents or legal representatives.
For this purpose, we collect the following data: name and surname, phone number, email address.

For managing relationships with enrolled children (or those in the enrollment process), including scheduling, notifications, and responses to requests.
For this purpose, we collect the following data: name and surname, phone number, email address.

To send you newsletters or notifications about the kindergarten’s activities and events (if you have given your consent).
For this purpose, we collect the following data: name, surname, email address, IP address.

To provide you with personalized information about the kindergarten’s services and activities, according to your interests.
For this purpose, we collect the following data: name, surname, phone number, email address, preferences.

To communicate with you in order to improve the services offered and to assess beneficiary satisfaction.
For this purpose, we collect the following data: name, surname, phone number, email address.

To send informative materials and/or invitations to events organized by the kindergarten.
For this purpose, we collect the following data: name, surname, phone number, email address.

We may also use your personal data for these purposes if we consider it necessary to safeguard our legitimate interests. For more information, please see the details below.

DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?

Primarily, we will share your personal data with third parties only to ensure the proper management of our contractual relationships, as well as to fulfill specific legal obligations, as follows:

Financial consultants, audit firms, and any public authority, in cases where we are legally required to disclose personal data (for example, if we receive such a notification and/or request from central or local public authorities or in connection with ongoing litigation before Romanian courts).
Service providers acting on our behalf, including, but not limited to, external consultants, lawyers, auditors and/or accountants, and IT consultants and experts.
In the event our company is acquired or merges with another company or group of companies in the future, we may provide your personal data to representatives of the new owners (you will be notified of such action and its implications for your personal data).

HOW DO WE ENSURE THE SECURITY OF YOUR PERSONAL DATA?

We are committed to protecting your personal data. This is why we have implemented, or are in the process of implementing, appropriate measures designed to prevent unauthorized access and misuse of your personal data.

We undertake all reasonable and appropriate steps to ensure the security of your personal data against theft and unauthorized access and make every effort to this end. We achieve this through the implementation of specific technical and organizational measures, including encryption, anonymization, and data recovery/back-up procedures.

Important!

If you suspect unauthorized use or theft of your personal data, please inform us immediately upon noticing such activity. To do this, initially contact us by sending a notification via email to the contact address provided on our website, so that we can investigate the situation and subsequently provide you with updated information regarding the status of the incident resolution, as well as the steps to follow.

FOR HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

We will not retain your personal data in our records for a period exceeding the purposes for which the data was collected, except in cases where legal provisions require us to keep your personal data for a longer, specified period than our intended purpose (for example, if we receive such a notification and/or request from central or local public authorities or in connection with ongoing litigation before Romanian courts).

WHAT ARE YOUR RIGHTS REGARDING THE PERSONAL DATA WE PROCESS?

One of the main objectives of the Regulation is to protect and clarify the rights of individuals regarding the protection of personal data. Therefore, even though we process your personal data, the Regulation recognizes a series of rights you have concerning your personal data.

The Regulation grants several rights to individuals whose personal data is processed. In addition to existing rights, these include the right to data portability and the right to data deletion.

Here is a brief summary of your rights:

Right of access: You have the right to obtain confirmation from us as to whether we process personal data concerning you and, if so, access to that data and information about how it is processed. You also have the right to receive a copy of the personal data you provided to us that is being processed. If your request is made electronically, and unless you request another format, the information will be provided in a commonly used electronic format.

Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and the right to have this data transmitted directly to another controller, if technically feasible.

Right to object: You have the right to object to the processing of your personal data when the processing is necessary for the performance of a task carried out in the public interest or for our legitimate interests. When personal data is processed for direct marketing purposes, you have the right to object at any time.

Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (e.g., direct marketing), you may withdraw your consent at any time, and we will cease that specific activity unless we have another legal basis to continue processing your personal data for that purpose, in which case we will inform you.

Right to rectification: You have the right to have inaccurate personal data corrected without undue delay. Correction will be communicated to each recipient to whom the data has been disclosed, unless this proves impossible or involves disproportionate effort. We will inform you of these recipients upon request.

Right to erasure (“right to be forgotten”): You have the right to request the deletion of your personal data without undue delay if one of the following applies:

The data is no longer necessary for the purposes for which it was collected or processed;
You withdraw your consent and no other legal basis exists for processing;
You object to the processing and no overriding legitimate grounds exist;
The personal data has been unlawfully processed;
The personal data must be deleted to comply with a legal obligation;
The personal data was collected in connection with the provision of information society services.

In this process, we will inform each recipient to whom the personal data has been disclosed of any deletion, unless this proves impossible or involves disproportionate effort, and we will inform you of these recipients upon request.

Right to restriction of processing: You may exercise this right in the following cases:

When you contest the accuracy of the data, for a period allowing us to verify its accuracy;
When the processing is unlawful, and you oppose deletion, requesting restriction instead;
When we no longer need the personal data for processing purposes, but you require it to establish, exercise, or defend a legal claim;
When you have objected to processing for the period during which we verify whether our legitimate grounds override yours, in which case we will provide a full explanation.

In this process, we will inform each recipient to whom the personal data has been disclosed of any restriction of processing, unless this proves impossible or involves disproportionate effort, and we will inform you of these recipients upon request.

Important!

All these rights can be exercised by submitting a written, signed, and dated request to our office or via email, with the necessary contact details available on our website.

Upon request, you will receive a copy of the personal data we process; you may request and receive a response from us in any manner you prefer, including email.

Please note that your right to request a copy, as described above, must not infringe upon the rights and freedoms of others.

Right not to be subject to a decision based solely on automated processing, including profiling.

Right to lodge a complaint with the supervisory authority – If you believe that your personal data rights have been violated, you may also contact and submit a complaint to the local data protection authority:

National Supervisory Authority for the Processing of Personal Data (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal).

Address:
B-dul G-ral. Gheorghe Magheru nr. 28-30
Sector 1, cod poștal 010336
București, România

Email: anspdcp@dataprotection.ro

Telephone switchboard:
+40.318.059.211
+40.318.059.212

WHO IS RESPONSIBLE FOR THE PROTECTION OF YOUR PERSONAL DATA?

Our company, ALPHABET KINDERGARTEN, is responsible for the protection of your personal data. Its headquarters are located at Șoseaua Erou Iancu Nicolae, no. 36, Pipera – Tunari area, Bucharest.
For any comments or suggestions regarding this notice, please contact us using the contact information provided on our website. We are highly committed to the security of your personal data and will respond within a maximum of 5 (five) business days.

TRANSFER OF YOUR PERSONAL DATA: HOW AND TO WHOM?

For the purpose of carrying out one or more of the activities mentioned above, your personal data may be disclosed to external or internal service providers (“Authorized Persons”).

We ensure that our collaboration with authorized persons is based on confidentiality agreements and that they provide sufficient guarantees to implement appropriate technical and organizational measures. This ensures that the processing of your data complies with applicable law and adequately protects your personal data rights.

To ensure the smooth execution of our contractual relationships, your personal data may be transferred:

To third parties (e.g., our company’s consultants);
To a service provider.

The categories of services for which we work with authorized persons and the personal data transferred are as follows:

Newsletter services: email address, name, surname, phone number;
IT and website hosting services: technical data, including IP address;
Communication services: name, surname, email address, phone number;
Comment or contact form services: name, surname, email;
Accounting services: name, surname, identification data, as applicable;
Legal services: name, surname, contact details, identification data, correspondence, audio/video recordings, as applicable.

We ensure that your personal data is stored and transferred in a manner that provides adequate security.

LEGAL BASES FOR THE PROCESSING OF YOUR PERSONAL DATA

The Regulation provides several legal bases that allow us to process your personal data lawfully, as described below:

Processing based on the performance of a contract
Article 6(1)(b) of the Regulation states that “processing is lawful only if and to the extent that at least one of the following applies: […] b) processing is necessary for the performance of a contract to which the data subject is a party, or to take steps at the request of the data subject prior to entering into a contract.”

We rely on this legal basis to process your personal data to enable us to fulfill our contractual obligations, meet obligations to third parties, and ensure that you properly fulfill your obligations toward us.

Processing based on a legal obligation
In addition to our contractual obligations, we are required to comply with certain legal obligations. Article 6(1)(c) of the Regulation states that we may process personal data where such processing “is necessary for compliance with a legal obligation to which the controller is subject.”

An example of a legal obligation we must fulfill is our duty to cooperate with tax authorities.

Processing based on legitimate interests
Article 6(1)(f) of the Regulation explains that we may process your personal data if it “is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.”

Non-exhaustive examples of processing activities based on our legitimate interests include:

For internal administrative purposes;
To prevent unauthorized use of our information and equipment;
To carry out investigations regarding alleged violations; and
To establish, exercise, or defend legal claims.

Processing based on freely given consent
In certain circumstances, we will obtain your opt-in consent before engaging in specific processing of your personal data.

Article 4(11) of the Regulation defines opt-in consent as “any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.”

In simple terms, this means:

Your consent must be given freely, without any pressure;
You must be informed of what you are consenting to, so we provide clear and sufficient information;
You must take a specific action to give your consent—commonly by checking a box—to ensure your agreement is explicit and unambiguous.