Privacy Policy

Last Updated: 9.02.2021

Your privacy is one of our fundamental commitments, and therefore, we take utmost care to process your personal data in accordance with the principles set forth in the applicable legislation, including without limitation the General Data Protection Regulation no. 679/2016 (“GDPR”). We recognize the importance of maintaining the confidentiality, integrity, and security of your personal information (“Personal Data”) and have written this privacy policy (“Policy”) to explain how your Personal Data is collected, stored, used, and disclosed by SC MR. ADAM TECHNOLOGIES S.R.L., a company incorporated under the Romanian law, having its headquarters at sat Capu Codrului, 773, Comuna Paltinoasa, Postal Code 727415 Romania, fiscal number 38743320, registered with the Trade Registry under no. J33/127/2018 (“WeForReal“, “us”), as a data controller, with respect to your access and use of our website available at the URL www.weforreal.com („Site”).

Each time we are required by the applicable law or, otherwise, want to use this legal basis, we will request your free, informed, specific, and unequivocal consent for the processing of your Personal Data. By expressing your consent, you agree that we can collect, use, reveal, process and transfer your Personal Data in accordance with this Policy.

We reserve the right to amend the provisions of this Policy from time to time. If we make changes to this Policy, we will make the updated version available on the Site and we will update the “Last Updated” date. We will also inform you on the changes that have occurred, to ensure that you are aware of how we use your Personal Data. Any amendments to this Policy will apply on the date that they are made, with the exception of changes that require your prior consent, and which will apply as of the moment when you express such consent.

Welcome to WeForReal! This Privacy Policy has been created to provide information about our website www.weforreal.com (“WeForReal”) and our training services to our users (“you”, “your”). It describes how we collect, use, secure, and share information of our users and individuals whose details are used to purchase WeForReal services. It also describes how to access, update and correct your personal information and the choices available to you regarding your personal information. We encourage you to read this Privacy Policy carefully when attending WeForReal workshops and other events.

1. CATEGORIES OF PERSONAL DATA, PURPOSES OF PROCESSING, AND LEGAL GROUNDS

1.1. Browsing data

Computer systems and software procedures used for the Site’s operation acquire, during their normal operation, some Personal Data (so-called log files), the transmission of which is implicit in the use of internet communication protocols.

This information is not collected in order to be associated with identifying persons, but due to its nature can, by means of processing and integration with data held by third parties, allow users to be identified. Such information includes the IP addresses, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, and other parameters concerning the user’s operating system and computer environment.

Insofar as such information leads to the identification of a user, the provisions of this Policy shall become applicable.

1.2 Contact

You can contact us in different ways: by email, by phone, or by post mail. In this case, we will process the following Personal Data: first name, last name, email, phone number, address and any other information you voluntarily provide when you contact us.

1.3 Marketing messages

You can opt in to receive marketing messages (e.g., newsletter) via e-mail. In this case, we will process your first name, last name, e-mail address. You can revoke your prior consent at all times and without any costs, with altering consequences for the future.

1.4 Attending WeForReal Events (as participants)

WeForReal hosts events throughout the year that can be attended by any person who applies as a participant and is selected by the organizers. These events include meetups, workshops, trainings.

1.5 Registration as participants to the WeForReal events

You can register as a participant in an event organized by us. When you do so, we process the following Personal Data: first name, last name, email address, and personal/office address. We might also use your Personal Data in order to communicate event changes.

1.6 Taking photos and videos during the WeForReal events

During our events, we will take pictures of the audience and trainers. Further, some of the pictures could be published on social media platforms in order to promote our events. In this context, we will use the following Personal Data: images and videos.

If you for any reason do not wish to be included in any photo or video, please inform us at hello[at]weforreal[dot]com.

2. OTHER PROCESSING OPERATIONS

2.1 Contact

You can contact us in different ways: by email, by phone, through feedback or support form. In this case, we will process the following Personal Data: first name, last name, email, phone number, and any other information you voluntarily provide when you contact us.

2.2 Feedback

At the end of the event, we will send you a feedback form. In this case, we will process your email as Personal Data.

2.3 Newsletter/ Marketing Communications

We collect Personal Data when you voluntarily provide such information, such as when you fill out the ‘Request Offer’ and subscribe to newsletter form from our organizer’s website weforreal.com, (for example email address, name, company, phone number), contact us with inquiries, or respond to our surveys.

IP address, date, and time associated with each open and click for an email campaign sent through our email service provider (MailChimp) is stored only in our MailChimp account.

In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us at hello[at]weforreal[dot]com. Note however that as a user of the Service you cannot opt-out of some administrative communications that are reasonably necessary to the Service, such as billing, address account issues, or communication about customer support.

2.4 Analytics and Cookies

When you use our website, you acknowledge that we use third-party analytics to better understand the functionality of our services. These tools may record information about your usage, including how often you use WeForReal, the events that occur within the application, and where the application was downloaded from. This information will not be shared with third-party analytics services without your prior consent.

In operating WeForReal, we may also use a technology called “cookies”. A cookie is a small piece of data that is stored on your computer, mobile phone, or other devices when you access WeForReal. Our cookies help provide additional functionality to WeForReal and help us analyze WeForReal usage more accurately. For instance, our services may set up a cookie to let you navigate between pages efficiently, to store your preferences, or to allow you to access WeForReal without needing to remember and then enter a password more than once during a visit to WeForReal. In all instances in which we use cookies, we will not collect Personal Data without your permission. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file.

3. PROCESSING PERSONAL DATA BASED ON OUR LEGITIMATE INTEREST

When we process on the lawful basis of legitimate interest, we apply the following tests to determine whether it is appropriate:

The purpose test – is there a legitimate interest behind the processing?

Necessity test – is the processing necessary for that purpose?

Balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights, or freedoms?

For more information on how we process the Personal Data on the lawful basis of legitimate interest, please contact us at hello[at]weforreal[dot]com.

4. FAILURE TO PROVIDE PERSONAL DATA

You may refuse to provide certain Personal Data (indicated above) but, in such a case, you may not be able to benefit from certain services and features, including, but not limited to, the creation of an account or contacting you to solve your problem and to provide support.

5. AUTOMATIC PROCESSING OF PERSONAL DATA

Your Personal Data will not be processed for taking decisions based solely on automatic processing that would result in legal effects concerning you or could similarly significantly affect you.

6. SHARING YOUR DATA WITH 3RD PARTIES

We may share your information with certain third parties selected by us to help support our operations. These include, for example, services that help us process payments, analyze web traffic, send emails, and track customer support requests. In addition, we may share limited personal information to third parties that help us market or advertise WeForReal. These third parties may have access to your information only for purposes of performing these tasks on our behalf and we contractually require them to protect your information consistent with this Privacy Policy.

Do take note that the manner in which Third-Party Services use, store and disclose your information is governed solely by the policies of such third parties, and WeForReal shall have no liability or responsibility for the privacy practices or other actions of any Third Party Service that may be enabled within the Service.

7. TRANSFER OF PERSONAL DATA

Your Personal Data is filed and stored on the servers of our contractual partners that are helping us to provide our services to you.

We may transfer Personal Data, as far as necessary, to the following categories of recipients:

• subcontractors;
• contractual partners;
• companies offering courier services;
• companies offering IT services;
• marketing companies;
• public authorities, courts of law or arbitral tribunals, and authorities competent to investigate criminal offenses.

These recipients can be located in the European Union and/or in the European Economic Area. Where recipients are located outside the European Union and the European Economic Area, including in countries not recognized as ensuring an adequate level of protection, the transfer of Personal Data shall be carried out only if there are appropriate guarantees, in accordance with applicable law. In this respect, we rely on several guarantees, such as the Privacy Shield certificate or the standard contractual clauses issued by the European Commission. You may receive from us a list of recipients from third countries, as well as a copy of the agreed provisions that ensure an adequate level of protection of Personal Data. For any request to this effect, please contact us at the contact details mentioned below.

8. RETENTION PERIOD

The retention period of your Personal Data depends on the purpose of processing the respective Personal Data. As a rule, we will retain your Personal Data as follows:

In certain circumstances, we may retain your Personal Data for longer periods of time, for example, if we are obliged to do so in accordance with the legal, regulatory, tax, or accounting requirements.

We may also keep your Personal Data for longer periods of time so that we have accurate records of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

9. SECURITY

The security of your Personal Data is important to us. Your Personal Data will therefore be processed by applying reasonable technical and organizational measures to protect Personal Data, such as limiting access to Personal Data, encryption or anonymization of Personal Data, storage on secure environments. However, despite our efforts, we cannot always guarantee the effectiveness of the security measures implemented, and therefore we cannot guarantee the security of Personal Data at any time.

10. CHILDREN

We do not knowingly collect any personal information from children under the age of 13. If you believe we have mistakenly collected such information, please contact us so we can resolve the issue.

11. RIGHTS IN CONNECTION WITH THE PROCESSING OF YOUR PERSONAL DATA

11.1 Your rights

You have the following rights in connection with the processing of your Personal Data:

Access right: You have the right to obtain from us confirmation that your Personal Data is processed by us, as well as information on the specific processing, such as the purposes of processing, categories of processed Personal Data, recipients of Personal Data, the period for which Personal Data is stored, if we transfer the Personal Data abroad and how we protect it, your rights, the right to lodge a complaint before the supervisory authority, the source of your Personal Data.

Right to rectification: You have the possibility to request rectification of your Personal Data, provided that the applicable legal requirements are met. In the event of errors, after notification, we will immediately correct your Personal Data.

Right to erasure: In certain cases, you have the possibility to request the deletion of Personal Data, namely when: (i) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent on which the processing is based according to and where there is no other legal ground for the processing; (iii) you exercise the right to object to the processing; (iv) the Personal Data has been unlawfully processed. We are not obliged to comply with your request when the processing is necessary (among others) for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims. There are also other circumstances in which we are not obliged to comply with this request for the deletion of Personal Data.

Restriction of processing: You may request us to restrict the processing of your Personal Data in the following circumstances: (i) you contest the accuracy of the Personal Data, for a period enabling us to verify the accuracy of the Personal Data; (ii) the processing is unlawful and you oppose to the erasure of the Personal Data and request the restriction of their use instead; (iii) we no longer need the Personal Data for the purposes of the processing, but you require them for the establishment, exercise or defense of legal claims; (iv) you have objected to processing, pending the verification whether our legitimate grounds override yours. However, we can continue to process your Personal Data (i) when you consent; (ii) for the establishment, exercise, or defense of legal claims, or (iii) for the protection of the rights of another natural or legal person.

Right to data portability: Insofar the Personal Data is processed based on your consent or on the execution of the agreement and the processing is carried out by automated means, you have the right to have your data Personal Data provided to you in a structured format, which is currently used and can be read automatically and you have the right to request us to transfer this Personal Data to another controller. This right shall not adversely affect the rights and freedoms of others.

Right to opposition: In certain situations, such as when we process your Personal Data on the basis of legitimate interest, you have the right to object to the processing of your Personal Data by us. In the event of unjustified objection, WeForReal is entitled to continue processing Personal Data.

Objection to direct marketing: You can also object to the processing of your Personal Data for the purpose of sending marketing messages.

Revocation of consent: Insofar you consented to the processing of your Personal Data, you can at all times revoke your consent, without affecting the lawfulness of processing based on consent before its withdrawal.

Right not to be subject to any automatic individual decisions: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Such right cannot be exercised when the decision: (i) is necessary for entering into, or performing of, a contract between you and us; (ii) is authorized by law which lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (iii) is based on your explicit consent.

Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with The National Supervisory Authority for Personal Data Processing (“DPA”) in relation to any breach of your rights regarding the processing of your Personal Data. The contact details of the DPA are: 28-30 Gheorghe Magheru Boulevard, District 1, Postal Code 010336, Bucharest, Romania; e-mail: anspdcp@dataprotection.ro

11.2 How to exercise your rights

To learn more about the manner in which you may exercise the aforementioned rights, please contact us at hello[at]weforreal[dot]com.

Identity verification: We take utmost care of the confidentiality of all Personal Data and we reserve the right to verify your identity if you make a request in relation to your Personal Data.

Fees: As a rule, you can exercise your rights free of charge. However, we reserve the right to request a reasonable fee if your claims are manifestly unfounded or excessive, in particular, because of their repetitive nature.

Response Time: We make every effort to respond to your request within one month of receiving the request. This period may be extended by two further months where necessary, taking into account the complexity and number of requests, in which case we will inform you of any such extension and of reasons for the delay.

12. CHANGES TO OUR POLICY

Services and our business may change from time to time. As a result, at times it may be necessary for WeForReal to make changes to this Privacy Policy. WeForReal reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

13. CONTACT

We welcome your views about our website and our privacy policy. For any questions and requests regarding this Privacy Policy, you can contact us at hello[at]weforreal[dot]com.