Privacy policy

Data protection policy

Last update: 02 February 2024

This policy details the Company's practice with regard to the processing of personal data of users of www.johnmaxwell.ro (hereinafter referred to as the Site) as persons interested in purchasing tickets for the Step up and take the lead event (hereinafter referred to as the Event), with the aim of informing users about this subject.

Following the purchase of tickets to the Event, as detailed in the Terms and Conditions and within the limits indicated therein, the user will be entitled to access the https://www.johnmaxwellacademy.ro/ platform where he/she will be able to access various materials, depending on the type of ticket paid for, according to the information on the Event website. The way in which his/her personal data will be processed on that platform, as well as on any other related online platforms, is set out in the policies therein. Thus, this present Data Protection Policy, Cookie Policy and Terms and Conditions relate strictly to the Event page.

By using the Site further, you acknowledge that you have read and agree to this Data Protection Policy, the Cookie Policy, and the Terms and Conditions, all of which are posted on the Site.

CONTENTS:

1.Identification of the data controller

2.Processing of personal data

3.The person concerned

4.Personal data processed

5.Processing of personal data

6.Purpose

7.Recipients of processing

8.Legal basis of processing

9.Type of processing

10.Data processing and storage time

11.Rights of the data subject with regard to the processing of personal data

12.Obligations of the Company. Security measures for processed data

13.Liability of the Company

14.Transfer to third countries/international organisations

15.Final provisions

1. Identification of the data controller

Highlife Mentoring SRL (hereinafter referred to as the Company or HM)

Registered office: Romania, Timișș county, Timișoara, str. Gheorghe Lazăr nr. 24, et. 4, ap. SAD 29 (Fructus Plaza)

Registered at the Trade Register of the Timis Court under no. J35/1290/2010

Unique registration code RO46231968

Email: office@maxwellleadership.ro

Tel: +40.771.706.337

2. Processing of personal data

HM collects information from users of the Site in the following ways: directly from the user, from traffic reports recorded by the servers hosting the Site, and through cookies.

Information provided directly by the user:

1. When the user of the Site sends messages using the "Contact" box or has a telephone conversation with a representative of HM after completing the aforementioned box, he/she indicates: his/her first and last name or only one of them, respectively his/her email address if messages are sent or telephone number if the latter information is also desired.

Other personal data may be processed by the Company in case they are included in the information/request submitted by the user (e.g. additional contact data, data on the persons who will be able to access the user's account, etc.). Thus, HM has not requested such data, but to the extent that they are necessary to be able to respond to what has been transmitted, the processing of personal data will be carried out at the request of the Site user.

Using the email address or phone number in the "Contact" form is not mandatory for visiting the Site or purchasing tickets for the Event. Moreover, all this information can also be submitted in other ways (e.g. by asking a question at the Company's location or on HM's social media profiles).

2. When a person purchases one or more tickets to the Event (general/VIP ticket), by filling in the "I register now" box, he/she indicates: first name, last name, an e-mail address and a phone number, address (country, county, city) and optionally personal number code. In the case of tickets purchased by a legal entity, the name and surname of the representative of that legal entity must be indicated as personal data, and in addition the name of the purchasing company, telephone number, email address, ORC registration number, tax identification code, registered office address and possibly bank account and IBAN must be filled in on the order form.

In order to complete the purchase of the tickets, the data necessary for the payment of the price will be filled in (it is possible to pay by card or by bank transfer, in full or in instalments - see the Terms and Conditions for details on this subject), i.e. holder name, card number, bank - all of which may be personal data processed after pressing the "Register" button.

The purchase of tickets requires acceptance of the three check boxes at the end of the account creation form, related to the Terms and Conditions and Data Protection Policy, as well as the minimum age limit for Event participants.

3. When HM draws up and sends the invoice for the ticket purchased by the user and for the fulfilment of any other legal or contractual obligations as agreed by the parties, it shall indicate: name; surname; address, and for buyers who are legal entities it shall also indicate the registration number and tax identification code.

4. When a user consents to the use of his/her email address for marketing purposes by HM (newsletters), for receiving information related to the Event, but also other current or future Maxwell events/programs or the like (personal data that will be processed after the user ticks the box related to his/her consent and fills in the email address).

You can choose to be added to the list of recipients of newsletters sent by HM by ticking the appropriate box at the end of the "Let's connect" section or on the first page of the Website by clicking the "Send" button.

The user who has chosen to receive newsletters from HM will be able to unsubscribe at any time by simply clicking on the active "Unsubscribe" link at the end of each communication received from the Company.

5. When a user consents to the use of his/her image, voice, name and surname/nickname chosen for social media platforms and links to them for marketing purposes by HM, for the display of photos and/or videos obtained at the Event, on the Site, on the associated Maxwell websites or on the Company's social media pages (personal data that will be processed after obtaining the data subject's consent).

Information from the server traffic report:

When a website is visited or an application is used, users reveal certain information about themselves, such as IP address, time of visit, location from which the Site was accessed. HM, like other companies, records this information.

If a visitor to the Site has not completed a ticket order but has provided an email address or telephone number, the Company may email or contact the user for further information in this context.

Information obtained through the use of cookies:

Full details of how data is processed in this context are set out in the Cookie Policy on the Site.

The contact details that the user can use to submit any requests, notifications or complaints regarding this Data Protection Policy, the Terms and Conditions and the Cookie Policy, as well as any other information published on the Site, policies or operations carried out by the Company, are indicated in point 1 above.

The deadline for the Company to send a response is no later than 30 days after receipt of the request.

The company confirms that none of the personal data indicated above will be used for purposes other than those expressly indicated without complying with the legal provisions.

3. The person concerned

Since the Company processes personal data of the users of the Site, they are considered as Data Subjects. In the case of users who are legal entities, certain personal data of their representatives who are natural persons will be processed in accordance herewith.

By using the Site, each user assumes that he/she can take the steps required when filling in forms, purchasing tickets to the Event and generally using the Site, as well as sending messages, being over 18 years of age and can express his/her valid consent (where applicable) freely and without the need for prior approval from a third party that has not been obtained by that user.

In the event that the information/requests/forms submitted by users also contain personal data relating to other persons (and they thus acquire the status of data subject), the Company will process their data strictly in order to be able to respond to that information/request and does not assume any liability in addition to that provided for herein, in the Terms and Conditions or in the applicable legislation.

4. Personal data processed

Any information relating to an identified or identifiable natural person, i.e. the Data Subject, may be personal data.

With regard to the purposes of the data processing indicated herein, the Company seeks to minimize the personal data processed.

Thus, according to the Cookie Policy, the Data Subject will be able to tick the applicable types of cookies where their use is not automatic, in order to ensure him/her a more complete and better experience when browsing the Site.

In order to send answers to requests/submissions communicated by users using the "Contact" form or telephone discussions with HM representatives by users, to purchase tickets to the Event via the "I register now" section or to send information for marketing purposes via the "Let's connect" or "Register now" sections, the Company processes the following personal data:

• User:

• Through the Contact section and phone conversations with HM representatives by users: user's first and last name, email address and phone number

• By Event ticket order form: name, surname, an e-mail address and a phone number, address (country, county, city) and optionally your personal number, payment details. In the case of ticket purchase by legal entity, the name and surname of the representative of that legal entity shall be indicated as personal data, and in addition the name of the purchasing company, telephone number, email address, ORC registration number, tax identification code, registered office address and possibly bank account and IBAN shall be filled in the order form.

• When dealing with cancellation/refund requests by HM in accordance with the Terms and Conditions: name, surname, email, telephone, any other relevant details in the context of the ticket purchased 

• In fulfilling HM's legal and contractual obligations such as the preparation of invoices

• By the user's express confirmation by ticking the box corresponding to the consent to data processing for marketing purposes at the end of the order form, or on the first page of the Site by clicking on the "Let's connect" or "Register now" button: e-mail address

• By displaying testimonials in the form of photos and text or videos from the Event, on the Site, on Maxwell associated sites or on HM social media pages: image, voice, first and last name/nickname chosen by the user for the social media platforms and links to them 

• User IP

Depending on the cookie settings, other data may also be processed (in particular data related to user preferences and behaviour on the Site).

• Of persons other than the user:

each user who sends a message can indicate there personal data of other persons. The company did not request them.

Depending on the content of the messages sent by users using the "Contact" form, other data may be processed to the extent indicated, although not requested.

The company undertakes to comply with the legislation on the protection of personal data also in relation to these third parties, without, however, being obliged to obtain any separate consent in this regard. It is the user who has transmitted such information who assumes full responsibility in this respect and declares that they have agreed to the processing carried out by HM and have been fully informed in this respect.

5. Processing of personal data

Processing is the carrying out of any operation or set of operations on personal data or on sets of personal data, whether or not by automatic means.

The Company accesses, collects, stores, uses and performs any other steps permitted by applicable law on personal data provided by users as indicated in point 4 above.

6. Purpose

The Company processes the data of the users of the Site according to the purposes described below:

• For data provided directly by the user:

• providing answers, clarifications and remedying problematic situations (including order cancellations and refunds), in relation to requests and complaints submitted by the user or in subsequent discussions with the HM representative. In this context, data of other persons who have knowledge of the state of affairs may also be processed, which could help HM in making a decision under the Terms and Conditions;
• providing additional information related to the Event;
• conclusion of the ticket sales contract for the Event, following the completion of the order form and the preparation and submission of the corresponding invoices;
• sending information for marketing purposes;
• ensuring compliance with this Data Protection Policy, the Terms and Conditions and the Cookie Policy, and applicable legal provisions to protect the rights, property or safety of the Site.

• In the case of data obtained through traffic reports:

• identification of the relevant sections of the Site;
• more secure management of the IT system

• In the case of data obtained through cookies:

• Site operation
• depending on the settings set by the user, the data may be used for the proper functioning of the Site, obtaining statistical information to improve the services offered, saving preferences, etc. All the details related to this type of data processing can be found in the Cookie Policy.

If the Company intends to further process the personal data for a purpose other than those indicated above, it will provide the Data Subject prior to such further processing with additional relevant information on the secondary purpose, subject to completion of the formalities required by law.

7. Recipients of processing

Personal data of the Data Subject are processed by:

• administrators and employees/collaborators of the Company who are in charge of the administration of the Site and who are involved in the activities in relation to which the user registers an account or has questions/questions submitted - will process the name, surname and e-mail address of the user as well as any other personal data submitted by the user by message;

• the Company's associates and employees/collaborators who are involved in the organisation of the Event - will process the data indicated by the user in the I register now form, namely: name, surname, email, telephone, address.

• Company associates and employees/collaborators who are involved in the process of invoicing, cancellation of access to Maxwell resources after payment, refunds, order cancellations - will process all personal data filled in the order form and any other information necessary to make the cancellation/refund decision (if applicable);

• Company associates and employees/collaborators who are involved in the marketing process - will process email address for newsletters, image, voice, name, first name, nickname on social media and link to user's social media platforms for testimonials;

• support service providers contracted by the Company to fulfil its contractual or legal obligations, such as:

• hosting/IT company - can access all data recorded in the Company's online records, including those of users;
• accounting firm - will process the name, surname and address indicated on the invoices, as well as any other bank details;
• the Company's lawyers - can access all data recorded in the Company's records in the event of legal issues arising that require their involvement;
• advertising, PR and communication companies for marketing activity. These companies may collect anonymous data via cookies or event registration or feedback forms, and to the extent that this is done, HM will provide this information to data subjects in advance.

The above list of suppliers is not exhaustive, but indicates the main such collaborating companies. They will be independent operators, associated operators or processors in relation to the Company. Regardless of their capacity, they are obliged to maintain the confidentiality and security of the data subject's personal data by taking appropriate technical and organisational measures.

Although they are not recipients according to legal interpretations, public authorities (including ANPC and ANAF) and courts may process any/all of the user data obtained through the Site.

8. Legal basis of the processing

• Art. 6 lit. a GDPR - processing is carried out on the basis of the user's consent -> applicable situation when data processing is done in the context of cookies accepted by the user and which are not necessary for the functioning of the Site, as well as when user data is processed for marketing purposes e.g. using data from the "Contact" or "Let's connect" form;

• Art. 6 lit. b GDPR - processing is necessary for the performance of a contract to which the user is a party or for taking steps at the user's request prior to the conclusion of a contract -> applicable situation when data processing is done in the context of filling in data using the "Contact" or "Let's connect" form; when filling in the "I'm signing up now" form including other activities related to the purchase of the ticket desired by the user (such as dealing with complaints or requests to cancel the order or refund the price);

• Art. 6 lit. c GDPR - processing is necessary for compliance with a legal obligation incumbent on HM -> situation applicable in the context of data processing in relation to invoicing, collection or reimbursement of the price, and in relation to competent authorities;

• Art. 6 lit. f GDPR - processing is necessary for the purposes of the legitimate interests pursued by the Company or a third party, provided that the fundamental rights and freedoms of the data subject are not violated -> situation applicable in the context of data processing for the purposes of the ordinary operation and administration of the Site.

9. Type of processing

The data processing activities carried out by the Company mainly concern:

• collection of data indicated by the user using the data filled in the "Contact" or "Let's connect" form;
• using data to provide answers and feedback;
• using the data for the conclusion and execution of the contract with the user who purchased the ticket to the Event;
• the use of data for the purpose of each category of cookie agreed by the user;
• the collection of other unsolicited data provided by the Data Subject in a communication, request or complaint to the Company or in a response to the Company's inquiries, in order for the Company to respond to and resolve the request or remedy the incident;
• storing the aforementioned data in accordance with the law and within the limits necessary to achieve the purpose in the Company's secure electronic database;
• allowing access to data to certain employees and external collaborators providing support services whose activity involves processing of data under the condition that they assume the obligation of confidentiality and standard contractual clauses agreed by the European Commission (in the case of collaborators from EU third countries);
• allowing access to data to the competent authorities to the extent required by law;
• the transfer of the entire set of data kept on the Site by a user to the destination indicated by the user based on the user's right to data portability.

10. Data processing and storage time

The storage period of personal data collected is:

• until consent is withdrawn or the right to erasure or erasure is exercised by the user - for data processing based on the data subject's consent;
• for 3 (three) years from the receipt of the message using the "Contact" or "Let's connect" form or from the purchase of the ticket using the "I'm signing up now" box (if the telephone will be used, the data will be kept for 3 years from the date of the telephone conversation, with prior registration consent). The data is kept after the termination of the contract in order to be able to prove the measures taken by the Company in consideration of the contract, in relation to the duration of the general limitation period of the right of action before the Romanian Civil Code;
• a longer period of time than those mentioned above, where the law so provides or where there is a well-founded reason for doing so (e.g. for the exercise of a right before a court in a dispute which started before the expiry of the storage period indicated herein).

Upon expiry of the above-mentioned periods, all data will be deleted from the Company's records.

11. Rights of the data subject with regard to the processing of personal data

1. Right to information

The Company's internal rules and policies are available to the Data Subject at all times and are posted on the Website. See in this respect this Policy, the Cookie Policy and the Terms and Conditions.

The Company reserves the right to modify/update the content of the Site, including the policies referred to, at its sole discretion, at any time and for any reason (including but not limited to the occurrence of legislative or case law changes that may affect the consequences of what is published on the Site). Future revisions to this policy will be indicated by a change to the "Last Updated" date at the top. After the date on which the updated policy is published, access to the Site will constitute the user's acceptance of those updated terms.

However, if there will be significant changes that could affect the rights and freedoms of users or it is mandatory to obtain their consent, informing them of such changes will be done by easily visible indications posted on the Site (pop-ups) or by sending e-mails to the addresses provided if applicable. Such significant changes will take effect for users within 15 days from the time of display of the pop-up in question or transmission of the e-mail by the Company (the manner in which the information will be provided will be decided by HM on a case-by-case basis).

Regardless of the extent of the change, however, the responsibility for checking the content of the Site to keep up to date with the latest versions will rest entirely with the user. Thus, STUDYING THIS DATA PROTECTION POLICY, TERMS AND CONDITIONS AND COOKIE POLICY IS A MUST FOR USERS EVERY TIME THE SITE IS ACCESSED AND BEFORE ANY RECORDS OR DATA SUBMISSIONS ARE MADE WHEN CHANGES MAY OCCUR.

Upon request, the Data Subject will be informed of the substance of the contracts concluded with the above recipients where possible and of the source of the data.

2. Right of access to data

If the Data Subject would like information about the processing, he or she may send a request to the Company, which will reply within 30 days of receipt.

3. Right to rectification of data

If the Data Subject wishes to rectify/complete the data, he or she may submit a request to the Company, which will respond within 30 days of receipt.

4. Right to erasure of data

If the data subject wishes to have his/her personal data deleted, this is possible:

• at the end of the processing period;
• if the data are no longer necessary for the purpose of processing;
• if consent is withdrawn and there is no other basis for the processing;
• if he/she objects to the processing and there are no overriding legitimate grounds;
• if the processing is illegal;
• if deletion is required by law.

The cases of exception provided for in Article 17(1)(a) and (b) shall be excluded. 3 of European Regulation No 679/2016 are applicable.

Some data are part of the Company's records, which it keeps in relation to its legal obligations or legitimate interest. Therefore, not all data can be deleted, according to the law. However, any refusal to delete will be justified by the Company and will be based on a clear legal ground.

5. Right to restrict processing or object to processing

The restriction of processing may apply if the Data Subject finds that:

• the data are not accurate;
• the processing is unlawful and the Data Subject objects to the erasure;
• The company no longer needs the data but the data subject requests it for a court action and it has not yet been deleted;
• The data subject objects to the processing.

The Company may continue to process the restricted data if it is necessary for the establishment, exercise or defence of legal claims or the protection/defence of a person but only with the consent of the Data Subject.

The Company will communicate to recipients the rectification, erasure or restriction of data unless this is impossible or involves disproportionate effort.

6. The right to data portability

The data subject or the person indicated by him may receive, upon request, the data processed by the Company. HM does not assume responsibility for the processing of the data by that recipient.

The obligation to ensure the right to portability is incumbent on the Company only if the processing of those data is based on the consent of the Data Subject or on the conclusion and performance of the contract. The steps shall be taken within a maximum of 30 days of receipt of the request.

7. Right to object

If possible, the Company will stop the processing of the Data Subject's data who objects to the processing based on HM's legitimate interest or circumstances arise that give rise to the exercise of this right (including profiling).

However, the legitimate reason of fulfilling the Company's legal obligations or processing for the purpose of establishing, exercising or defending a right in court shall prevail.

8. Right to complain

The person concerned may submit:

• complaint/application to the address of the Company indicated in point 1 above;
• action in the competent court;
• complaint to the National Authority for Personal Data Protection (www.dataprotection.ro).

However, the company wants any conflict/difference to be resolved amicably and is willing to do so.

1. Right to withdraw consent

The data subject may withdraw his or her consent at any time, without however affecting the lawfulness of the processing prior to the withdrawal or that based on another ground.

10. The right not to be subject to a decision based solely on automatic processing

The company does not practice decision making based on automated data processing.

12. Obligations of the Company. Security measures for processed data

The company complies with the provisions of data protection legislation and has implemented appropriate technical and organisational measures to ensure the security of personal data processed and respect for the rights of Data Subjects. Thus, the Company has implemented measures such as:

• the conclusion of contracts with collaborators in which they have assumed the obligation of confidentiality of the information concerning the personal data processed, as well as the obligation to comply with the applicable legislation in the field of personal data protection;
• training employees and collaborators on the importance of personal data protection and limiting their access to data according to their duties;
• establishing internal procedures to protect personal data;
• a contact address for matters relating to personal data (i.e. the one indicated in point 1 of this policy);
• the Unsubscribe button on all marketing communications;
• implementing information security measures;
• not installing structures that allow access to the Site and the purchase of a ticket only on condition that a user account is created;
• not setting cookies in addition to those necessary for the operation of the Site, without giving the user a choice that is permanently available.

The Company will also inform the competent data protection authority in the event of a data security incident without undue delay and, if possible, no later than 72 hours after becoming aware of it, unless it is unlikely to result in a risk to the rights and freedoms of individuals. If the notification to the authority is not made within 72 hours, it shall be accompanied by a reasoned explanation for the delay.

In the event of an incident involving the security of personal data, HM will also inform the Data Subject without undue delay if the breach of security of personal data is likely to result in a high risk to his/her rights and freedoms. However, the aforementioned information to the Data Subject is not required if any of the following conditions are met:

• The Company has implemented appropriate technical and organisational safeguards and these safeguards have been applied to personal data affected by the personal data breach;
• The Company has taken subsequent measures to ensure that the high risk to the rights and freedoms of Data Subjects is no longer likely to materialise;
• would require a disproportionate effort. In this situation, public information or a similar measure is carried out instead, whereby the data subjects are informed in an equally effective way.

Any HM user traffic statistics that we provide to third party advertising networks or partner sites are provided only as aggregate data and do not include any identifiable information about any individual user.

Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. Accordingly, despite HM's efforts to protect users' personal data, it cannot ensure or warrant the security of any information transmitted by users through or uploaded to the Site. Users are therefore advised that any information submitted or uploaded to the online environment will be done so at their own risk.

In order to reduce this risk, HM offers all interested parties the possibility of sending requests/applications/addresses/messages in physical form to the Company's premises and not necessarily by electronic means.

13. Liability of the Company

The liability of the Company in relation to the Data Subject shall be determined in relation to the capacity held in the respective data processing operation, the reason and place of the incident, the security measures taken, the steps taken to avoid incidents and the compliance with the other legal obligations.

14. Transfer to third countries/international organisations

The Company does not transfer outside the EU personal data of the Data Subject collected through the Site.

15. Final provisions

This policy applies to the Company and users of the Site (whether registered or not).

The Company reserves the right to modify/update the content of the HM, including the policies referred to, at its sole discretion, at any time and for any reason (including but not limited to the occurrence of legislative or case law changes that may affect the consequences of what is published on the Site). Revisions to this policy in the future will be indicated by a change to the "Last Updated" date at the top. After the date on which the updated policy is published, access to the Site will constitute the user's acceptance of those updated terms.

However, if there are any significant changes that may affect the rights and freedoms of visitors, they will be informed of such changes by easily visible indications posted on the Site (pop-ups) or by sending e-mails to the addresses provided if applicable. Such significant changes will take effect for visitors within 15 days from the time of the display of the pop-up in question or the transmission of the e-mail by HM (the manner in which the information will be provided will be decided by HM on a case-by-case basis).