SC winsedswiss SRL, headquartered in 12-14 Moliere street, apt. 5, district 1, Bucharest, Romania, registered in the Trade Register under no. J40/4928/2020, Unique Identification Code RO 42487190, is responsible for processing your personal data that we collect directly from you or from other sources.
According to legislation, our company is a personal data controller. In order for your data to be processed safely, we have made every effort to implement reasonable and appropriate, technical and organisational measures to protect your personal information.
According to legislation, you, the individual beneficiary of our products and/or our services, the representative or contact person of a company, the visitor of the website or the person in a relationship of any kind with our company, are a ‘data subject’, i.e. an identified or identifiable natural person. In order to respect the principle of transparency in our reports on data processing and to allow you to exercise your rights easily at any time, we have implemented measures to facilitate this information.
Personal data that you are transmitting to us is very important to us, so we are hereby confirming our complying with European and national data protection legislation, in particular Regulation (EU) 679/2016, also known as GDPR, and also all data processed will take into account the following principles:
a) lawfully processed, fairly and transparently in relation to the data subject (“legality, fairness and transparency”);
b) collected for specified, explicit and legitimate purposes and not subsequently processed in a way incompatible with those purposes; further processing for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes is not considered incompatible with the original purposes in accordance with Article 89(1) (‘purpose limitations’);
c) appropriate, relevant and limited to what is necessary in relation to the purposes for which it is processed (‘data minimisation’);
d) accurate and, where necessary, updated; all necessary measures must be taken to ensure that personal data which in inaccurate, taking into account the purposes for which it is processed, is erased or rectified without delay (‘accuracy’);
e) kept in a form that allows the identification of data subjects for a period not exceeding the period necessary to fulfil the purposes for which the data is processed; personal data may be stored for longer periods to the extent that it will be processed exclusively for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes, in accordance with Article 89(1), subject to the implementation of the appropriate technical and organisational measures provided for in this Regulation to guarantee the rights and freedoms of the data subject (‘storage limitations’);
f) processed in a manner that ensures adequate security of personal data, including protection against unauthorised or unlawful processing and accidental loss, destruction or deterioration, by taking appropriate technical or organisational measures (“integrity and confidentiality”).
We at winsedswiss and our affiliates listed on the website either as Partners, or under the “About US / Our offer” section) are committed to protecting your privacy:
- Fundatia “Didactica” – headquartered in 14 Papiu Ilarian, Sibiu, Romania, Unique Identification Code 12272289;
- winsedswiss SRL - headquartered in 12-14 Moliere street, apt. 5, district 1, Bucharest, Romania, registered in the Trade Register under no. J40/4928/2020, Unique Identification Code RO 42487190;
- winsedswiss talent SRL – headquartered in 12-14 Moliere street, apt. 5, district 1, Bucharest, Romania, registered in the Trade Register under no. J40/4909/2020, Unique Identification Code RO 42486373;
- winsedswiss education group SA – headquartered in 38 Rue du Villars, 1024 Ecublens, Switzerland, identified with no. CHE-392.354.424;
- EHL Advisory Services SA – headquartered in Le Chalet-à-Gobet, 1000 Lausanne, Switzerland, identified with no. CHE-114.708.494.
1. What Information We Collect About You
When You Visit our Websites
You are free to explore the Website without providing any Personal Information about yourself. When you visit the Websites or register for the Subscription Service, we request that you provide Personal Information about yourself, and we collect Navigational Information.
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Website, and information about you that is available on the internet, such as from Facebook, Instagram, LinkedIn, Google, and YouTube.
Personal Information includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual.
Navigational information refers to information about your computer and your visits to the Website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the "Use of Navigation Information" section below.
Payment information includes information we collect and process from you when you buy something from us, that needs completing forms with data including credit card numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect other Sensitive Information from you.
This refers to credit or debit card numbers, personal financial account information, Social Security numbers, passport numbers, driver's license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information.
When you view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by winsedswiss to provide general statistics regarding use of the Website. For these purposes, we do link this automatically-collected data to other Personal Information such as name, email address, address, and phone number.
Information we collect from third parties
From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and sources such as social media websites.
Information About Children
The Website www.ohma.ro is not intended for or targeted at children under 18, and we do not knowingly or intentionally collect personal information about children under 18. If you believe that we have collected personal information about a child under 18, please contact us at [email protected] – directly announcing Alex Baicoana, our Data Protection Officer , so that we may delete the information.
2. How We Use Information We Collect
We Never Sell Personal Information
We will never sell your Personal Information to any third party.
Use of Personal Information
· improve your browsing experience by personalizing the Websites and to improve the Subscription Service;
· send information or ohma by winsedswiss content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
· promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
· provide other companies with statistical information about our users - but this information will not be used to identify any individual user and will only be shared on an aggregate and de-identified basis;
· contact you about billing, account management, and other administrative matters;
· investigate and help prevent security issues and abuse;
· and meet legal requirements.
We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.
Legal basis for processing Personal Information (EEA visitors only)
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so (via cookies, double opt-in forms, or signed forms and agreements), where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.
In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
Use of Navigational Information
We use Navigational Information to operate and improve the Website and to provide you with a better experience when you interact with winsedswiss via www.ohma.ro. We may also use Navigational Information alone or in combination with Personal Information to provide you personalized content. Navigational Information, such as IP address, is used to approximate your location. For example, we may use your approximate location to provide content that has been translated or send emails at certain times using your local time zone.
You may disable the collection and use of your location data through browser-, operating system- or device-level settings.
Consent concerning location data may be withdrawn at any time by emailing [email protected] – contacting Alex Baicoana – our Data Protection Officer.
Customer Testimonials and Comments
We post customer testimonials and comments on our Website, which may contain Personal Information. We obtain each customer's consent via email prior to posting the customer's name and testimonial.
Use of Payment Information
Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.
Social Media Features
Retention of Personal Information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the "How to Access & Control Your Personal Data" below.
If you have opted in to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your ohma by winsedswiss or directly your winsedswiss account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
3. How we Share Information we Collect
We employ other third-party service providers to provide services on our behalf to visitors to our Website and our customers and users of the Subscription Service and may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service or support.
These service providers are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.
In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by winsedswiss on the www.ohma.ro Website and the Subscription Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
4. Rights of the data subject
• Right to withdraw consent
You may withdraw your consent to the processing of your data at any time by submitting a request to this effect at the e-mail address [email protected] Note, however, that insofar as we have identified another legal basis for the processing of your data, we will continue to process your data on that legal basis. We have the legal possibility to use one or more grounds for the processing of your data.
• The right to be informed about the processing of your data
• The right of access to data
You have the right to obtain from us a confirmation that personal data relating to you is being processed or not and, if so, access to the respective data and to the information provided for in Article 15(1) of the GDPR.
• Right to rectify inaccurate or incomplete data
You have the right to obtain from us, without undue delay, the rectification of inaccurate personal data concerning you.
• The right to erase (‘the right to be forgotten’)
In the situations provided for in Article 17 of the GDPR, you have the right to request and obtain the deletion of personal data.
• Right to restriction of processing
In the cases provided for in Article 18 of the GDPR, you have the right to request and obtain restriction of processing.
• “Right to portability” – The right to transmit the data we have about you to another operator
In the cases provided for in Article 20 of GDPR, you have the right to request and obtain data portability.
• The right to oppose data processing
In the cases provided for in Article 21 of GDPR, you have the right to object to data processing.
• The right not to be the subject of a decision based solely on automatic processing, including the creation of profiles with legal effects or similar significant effects on you.
• The right to address a court of justice for the defence of your rights and interests.
• The right of a complaint before a Supervisory Authority
4. Cookies and Similar Technologies
What are cookies?
A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.
Cookies provide a convenience feature to save you time, or tell the Web server that you have returned to a specific page.
Cookies set by the website owner (in this case, winsedswiss) are called "first party cookies". Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognise your computer both when it visits the website in question and also when it visits certain other websites.
We use first party and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Website to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Website and Subscription Service. For example, winsedswiss keeps track of the Website (www.ohma.ro), in order to determine what portion of its content or Subscription Service is the most popular or most used. This data is used to deliver customized content and promotions to customers whose behavior indicates that they are interested in a particular subject area. Third parties serve cookies through our Websites for advertising, analytics and other purposes. This is described in more detail below.
What types of cookies do we use and how do we use them?
· Essential website cookies: These cookies are strictly necessary to provide you with services available through our Website.
· Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our Website but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.
· Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our Website is being used or how effective our marketing campaigns are, or to help us customize our Website for you.
· Advertising cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.
· Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our Website through third-party social networking and other websites. These cookies may also be used for advertising purposes too.
How can I control cookies?
You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links provided below.
Essential website cookies: Because these cookies are strictly necessary to deliver the Websites to you, you cannot refuse them. You can block or delete them by changing your browser settings however, as described above.
What about other tracking technologies, like web beacons?
Cookies are not the only way to recognize or track visitors to a website. We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage the Website and Subscription Service by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on Web pages or in emails and are about the size of the period at the end of this sentence. We use clear gifs or pixels in our HTML-based content to let us know which topics have been accessed by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. We tie the information gathered by clear gifs in emails to our customers' Personal Information.
Where can I get further information?
Third-Party Tracking Technologies
5. How to Access & Control Your Personal Data
Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights
· You can request access, correction, updates, or deletion of your personal information.
· You can object to the processing of your personal information, ask us to restrict the processing of your personal information, or request portability of your personal information.
· (For EU visitors) - If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
· You have the right to complain to a data protection authority about our collection and use of your personal information.
To exercise any of these rights, please contact us at [email protected] – Alex Baicoana Data Protection Officer. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
To Unsubscribe From Our Communications
You may unsubscribe from our marketing communications by clicking on the "unsubscribe" link located on the bottom of our e-mails, updating your communication preferences, or by emailing us at [email protected] – Alex Baicoana, Data Protection Officer.
How We Collect, Use, and Share your Personal Information
· Identifiers, such as name, e-mail address, mailing address, and phone number. We collect this information directly from you.
· Commercial information - We collect this information directly from you.
· Internet or network information, such as browsing and search history. We collect this information directly from your device.
· Geolocation data, such as IP address. We collect this information from your device.
· Financial information, such as Payment Information or financial account numbers in the process of providing you with an ordered service. We collect this information from you.
· Other personal information, in instances when you interact with us online, by phone or mail in the context of receiving help through our help desks or other support channels; participation in customer surveys or contests; or in providing the Subscription Service.
You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.
The right of access means that you have the right to request that we disclose what Personal Information we have collected, used, and disclosed about you in the past 12 months.
The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.
The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
Please use the contact details below, if you would like to:
· Access this policy in an alternative format;
· Exercise your rights;
· Learn more about your rights or our privacy practices; or
· Designate an authorized agent to make a request on your behalf.
E-mail: [email protected] – Alex Baicoana – Data Protection Officer
6. Data Protection Officer