Privacy Policy

CAPITAL MINDS S.R.L. (hereinafter referred to as ”Capital Minds“ or ”Operator”), attach increased importance to your personal data, constantly applying the necessary due diligence to ensure that the data processing carried out complies with the legal requirements in this area. To this end, we have developed this commitment whereby we undertake to respect the confidentiality of your personal data and through which we explain to you which categories of personal data Kapital Minds processes, how such data are used and the purpose for which they are processed.

This Policy relates only to personal data that we process through our website www.kapitalminds.ro (referred to in the following “Site”or “Platform”)in the context in which you interact with it by filling in the forms available on the platform, by creating a new account, registering a review, placing an order, subscribing to the newsletter, filling out the contact form or if you are just browsing it.

We want to assure you that we have taken all necessary measures to ensure the confidentiality of your data, they are processed only by the personnel of the Controller who have been previously trained in the processing of personal data and authorized in this regard and who comply with firm commitments of confidentiality.

To get to know us virtually, we provide you with our identification data.

The controller who processes your personal data when you browse or interact with the online platform www.kapitalminds.rois CAPITAL MINDS S.R.L., based in Bucharest, str. Tudor Arghezi, no. 21, office 112, Sector 2, registered in the Commercial Register under no. J40/20915/2022 having fiscal code RO38632748.

For any questions/concerns regarding the protection of personal data, you are invited to send a request to the postal address indicated above or to the e-mail address contact@kapitalminds.ro. Persons submitting such requests to Kapital Minds are asked to mention in the subject of the email/on the mailing envelope information such as”data protection“,”GDPR“,”personal data“, in this way there is a guarantee that requests will be treated with priority.

In this capacity, you will receive a response within 30 days of the communication of the document to Kapital Minds, an extension of this deadline which can only operate in exceptional circumstances. In these cases, we ensure that you are properly informed of this deadline.

Through”personal data“ means, within the meaning of national and international legislation in force, any information relating to an identified or identifiable natural person. An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

! For the purposes of this policy, the personal data that will be processed may refer to: name, surname, telephone number, e-mail address, delivery address, etc., as described in the following.

Through”processing of personal data” means any operation or set of operations carried out on personal data, by automatic or non-automatic means, such as: collecting, recording, organizing, storing, adapting or modifying, extracting, consulting, using, disclosing to third parties by transmission, dissemination or in any other way, joining or combining, blocking, deleting or Destruction.

! For the purposes of this policy, data processing refers to those processing carried out at the time of your browsing on the website. www.kapitalminds.ro or interact with it by filling in the forms available on the Platform.
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“Operator” means the person who, alone or jointly with others, determines the purposes and means of processing personal data. For clarity, for the purposes of this Privacy Policy, the Controller of personal data is Kapital Minds.

“Data subject” represents the person whose personal data are the subject of processing.

! For the purposes of this Policy, the data processing data subject is the Internet user browsing the website www.kapitalminds.ro.

Through ”consenting“ of the data subject means any manifestation of the free, specific, informed and unambiguous will of the data subject by which the data subject agrees, by means of an unequivocal statement or action, that personal data concerning him or her will be processed.

“Third Party“ means the natural or legal person, public authority, agency or body, other than the data subject, the controller, the controller and the persons who, under the direct authority of the controller or the controller, are authorized to process personal data.

“Operator Authorized Person“ means the person who processes the personal data on behalf of the controller.

Your browsing on the Site and interacting with it involves the processing of two categories of personal data, namely:

a. personal data that you disclose to the Operator voluntarily (e.g. via the order or contact form, respectively in the case of subscribing to the newsletter), these being collected individually;

b. data that you provide involuntarily, by simply browsing our website. In the event that you opt for billing on a legal entity, we draw your attention to the fact that the data requested and entered in the forms on the website on behalf of a legal entity does not represent personal data (email address of the company as e.g. nickname @office, the company's telephone number such as landline number, etc.) in light of the provisions of the Regulation no. 679/2016 on the protection of personal data (GDPR).

Where they are provided personal data of the representative of the company the natural person(name and surname, telephone number, e-mail address), he/she will be treated as a data subject in accordance with the provisions of the GDPR and all protective measures will apply to him;.

The User is duly informed about the processing of personal data when providing the Controller with his/her data through the forms on the website, thus Kapital Minds fulfils its legal obligation to inform the user.

Kapital Minds collects, on the basis of the voluntary provision of the data subject, the following personal data:
A. In case of a request for an offer:
- name and surname;
- phone number;
- any other information made available to the Operator by filling in the field, "message” or by phone;
- e-mail address, communicated by telephone;
- voice, on the occasion of telephone contact.

‍B. To schedule an appointment:
- name and surname;
- phone number;
- e-mail address communicated by telephone;
- any other data that you provide by telephone to the Telephone Operator; voice (in the context of telephone contact by the Operator).

‍C. To fill in the “HELP” form:
- name and surname;
- telephone number; any other information made available to the Operator by filling in the field,message” or by phone;
- e-mail address, communicated by telephone;
- voice, on the occasion of telephone contact.

‍D. To complete the contact form:
- name and surname;
- telephone number; any other information made available to the Operator by filling in the field,message” or by phone;
- e-mail address, communicated by telephone;
- voice, on the occasion of telephone contact.

‍E. To obtain additional information/submission of referrals via e-mail have a phone call (customer support):
- e-mail address;
- telephone number (in the context in which you contact the Operator by phone);
- any other personal data that you make available to the Controller for the resolution of the complaint/provide the requested additional details;
- voice (in the context of contacting the Operator by phone).

‍F. In the context of inbound/outbound phone calls:
- the voice;
- phone number;
- Other categories of personal data which the data subject makes available in the context of telephone conversations and which may relate to:
- name and surname;
- e-mail address;
- etc.

G. To subscribe to the newsletter
Subscribing to the newsletter is conditional on giving your consent for the purpose of receiving commercial and marketing messages. In this context, they will be processed, as personal data, name, respectively your email address.

‍This data contributes to the provision of the services offered by Kapital Minds, but also to the communication with the Operator or the transmission of marketing communications from the Operator, but with the prior obtaining of the User's consent.

Also The operator also processes marketing and communication data only on the basis of the prior consent of the users, but also technical data and navigation actions through cookies and similar technologies. You can access our cookie policy on the Site.

In the event that you provide us with personal data that is not necessary for the purposes described below, namely for providing Kapital Minds services, resolving your complaints or providing additional information, we reserve the right to remove them from our database immediately.

The controller may involuntarily collect other personal data belonging to you, namely: IP address, browser version, time zone and location setting, operating system, platforms on the devices used to access our sites, etc.This information will not be used to identify natural or legal persons as the case may be, and will not be disclosed otherwise than under the conditions inserted in this Privacy Policy, supplemented with the Cookie Policy.

The Operator reserves the right to request additional information, accompanied by supporting documents, by e-mail, printed or in any other way deemed appropriate for the Operator, if applicable, for the purposes detailed below.

‍! Note: Kapital Minds has entered into data processing agreements with its service providers (for example: IT/online system administration, legal services, payment processing services, etc.), but notResponsible for the processing carried out by these providers on their own behalf, in the event that they would process the data as independent operators, the data subject being duly informed of the processing involving a transfer of data between Kapital Minds and any company providing services to the Operator.

‍Your personal data may be communicated by Kapital Minds, for processing, to persons authorized to process them, including contractual partners, financial authorities and institutions, courts or competent bodies, at their request and for the purpose of providing the services offered by the Operator.

Kapital Minds may store your personal data even after the registration of a request to delete such data, if the storage is done for one of the following purposes, provided for by Art. 13 GDPR, respectively:
a. performance of a contract;
b. fulfilment of a legal obligation providing for processing under European Union law or national law applicable to the controller;
c. exercise of the right to freedom of expression and information;
d. protecting the vital interests of the data subjects;
e. performing a task that serves the public interest;
f. archiving in the public interest, scientific or historical research or for statistical purposes;
g. the protection of the legitimate interests of the Controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject prevail, which require the protection of personal data, in particular when the data subject is a child;
h. to establish, exercise or defend a right in court.

Kapital Minds processes your personal data for the following purposes and on the following legal grounds:
a. processing is necessary for execution of a contract in which the data subject is part or to take steps at the request of the data subject prior to the conclusion of a contract(Article 6 (1) (b) of Regulation (EU) No 679/ 2016 of the European Parliament and of the Council of 27 April 2016), in particular, for the purpose of ensuring the data subject's access to the products marketed on the Platform www.kapitalminds.roand closing the distance sale;
b. processing is carried out on the basis of consent of data subjects(Article 6 (1) (a) of Regulation (EU) No 679/ 2016 of the European Parliament and of the Council of 27 April 2016) in the case of the transmission of commercial and marketing communications;
c. processing is necessary for the purpose legitimate interests pursued by the Operator(Article 6 (1) (f) of Regulation (EU) No 679/ 2016 of the European Parliament and of the Council of 27 April 2016), for the recruitment of competent personnel, for solving problems of any nature relating to the content of the website www.kapitalminds.roor the services offered by the Operator, as well as for actions that involve interaction with the online platform.

Your personal data will be processed in order for Kapital Minds to:
a. improve the Website and the services provided through it;
b. determine the usability/popularity of the web content presented on the site;
c. send technical, assistance or administrative notifications;
d. honor requests and resolve complaints received from users;
e. facilitate the user's access to the services offered by Kapital Minds;
f. communicate the information of interest to the users of the site;
g. protect the rights of Kapital Minds.

Personal data processed at Kapital Minds level through the website www.kapitalminds.ro are retained for a reasonable period of time in relation to the purpose of data processing, in accordance with the legal provisions regarding data archiving.

The operator pays special attention to the data of minors that may be provided by them by filling in the forms available on the online platform www.kapitalminds.roto ensure that any processing of personal data of minors is carried out only in accordance with legal requirements and in strictly defined cases.

Thus, the Operator does not carry out activities of any kind towards minors, including promotional activities of direct marketing. However, if a minor contacts the Operator via the relevant forms or by telephone, the minor will be deemed to have done so with the consent of his legal representative.

Minors who have not reached the age of 14 are not allowed to request services provided by the Operator, unless these operations are carried out on behalf of the minor by his legal representative or guardian, in accordance with the law.

In this regard, any person who provides Personal Data to the Operator through the Website or other applications or devices covered by this Policy guarantees that it is major or has full capacity to exercise it.

Any processing of personal data belonging to minors will be carried out only under the conditions of the law and taking into account the above provisions.

Your data is processed within the European Union via secure internal servers. However, through specific social media plugins (e.g. Facebook, Twitter, Instagram, etc.), acting as third-party recipients, your data processed in this context may also be transferred outside the European Union/European Economic Area and stored on servers in third countries. In this regard, the Controller has implemented a number of necessary and appropriate measures to ensure a consistent data processing.

Kapital Minds undertakes to process the collected data only in accordance with the stated purposes and not to publish, sell, rent, license, transfer, etc. unauthorized database containing information about the data of data subjects to any third party not involved in the fulfillment of the stated purposes, except where the transfer/access/viewing is etc. requested by the competent bodies, in the cases provided for by the regulations in force at the time of the occurrence of the event.

Your data may be disclosed to other companies that provide services to us and act as authorized persons, such as providers that provide website maintenance, IT, legal, etc.

These entities or persons are selected with special care to ensure that they meet specific personal data protection requirements. They have a limited ability to use your information for purposes other than to provide services to us.

In addition to the disclosures described in this Privacy Policy, we may disclose information to third parties to whom you consent or request that we make such disclosure.

Site www.kapitalminds.ro may contain links to third party websites that may in turn collect your personal data, including through cookies or other technologies.

If you connect to a third party website, Kapital Minds's privacy policy will not apply to your browsing on that site.

Any natural person browsing our website, as a data subject, has the following rights in relation to Kapital Minds, as Personal Data Controller:

- Right of access means the right of the data subject to obtain confirmation from the Controller that he or she is processing or not the personal data concerning him or her and, if so, access to such data and to information on how the data are processed;

- Right to rectification refers to the correction, without undue delay, of the inaccurate personal data processed or the completion of them, if they are incomplete. These can be changed by sending an email to: contact@kapitalminds.ro;

- Right to erasure of data/right to erasure (“right to be forgotten”) data from the database means the right of the data subject to request the erasure of his or her personal data without undue delay, if one of the following reasons applies: they are no longer necessary for the purposes for which they were collected or processed, withdraws their consent and there is no other legal basis for the processing; object to the processing and there are no legitimate grounds that prevail, the personal data have been processed illegally, the personal data must be deleted in order to comply with a legal obligation, personal data have been collected in connection with the provision of information society services;

- Right to restriction of processing can be exercised if the data subject requests the restriction of the processing of his personal data, in which case they will be used strictly for the exercise of the other legal rights of the data subject, including to respond to any requests/complaints from the data subject;

- Right to portability refers to the right to receive personal data in a structured, commonly used and machine-readable format and to the right for such data to be transmitted directly to another controller, where the processing is based on consent or performance of a contract and is carried out by automated means, if this is technically feasible;

- Right to opposition concerns the right of the data subject to object to the processing of personal data when the processing is necessary for the performance of a task that serves a public interest or when it concerns a legitimate interest of Kapital Minds;

- Right to object to the processing of data based on automated individual decisions refers to the fact that the data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly affects him to a significant extent. However, it will not be possible to exercise this right if the decision is necessary for the conclusion or performance of a contract between the data subject and Kapital Minds, is authorized by the applicable law of the Controller, provided that adequate protection of the rights, freedoms and interests of the data subjects is ensured or is based on the consent of the data subject obtained with respect implementation of the legislation in force;

- The right to apply to the National Supervisory Authority for the Processing of Personal Data.In the event that the data subject considers that the rights provided for above have been violated, he has the opportunity to apply to ANSPDCP by filing a complaint.
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‍Contact details of A.N.S.P.D.C.P. are the following:

‍Address:  Bucharest, Sector 1, G-ral Blvd. Gheorghe Magheru No. 28-30;
‍Telephone: 0.318.059.211/0.318.059.212;
‍Fax: 0.318,059.602;
‍E-mail: anspdcp@dataprotection.ro;
‍Webpage: www.dataprotection.ro.

‍In order to exercise the rights provided for above, the data subject shall address CAPITAL MINDS by sending a request to the address: Mun. Bucharest, str. Tudor Arghezi, nr. 21, office 112, Sector 2 or the e-mail address mentioned above, within the first section of this Policy.

If Kapital Minds considers that a change in the privacy rules is necessary, the Operator will publish such changes in order to inform the data subjects about the information it collects and how it uses it.

The provisions of the Privacy Policy are supplemented with the provisions Cookie Policy,present on the website www.kapitalminds.ro.