Privacy Policy
Global Bridge Education SRL of Calea Grivitei 156 Ap.133, S1 Bucharest 010744, Romania hereinafter: "GBE", "we" or "us") is committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data (as defined in Romania`s Law No. 190/2018 and the General Data Protection Regulation (GDPR)) (the “Personal Data”) we collect from account holders or individual users or visitors to our Platform, or that is uploaded to our Platform, will be processed by us. Account holders, users and visitors of our Platform or owners of Personal Data collected by us (each, “you”) should read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
By providing any Personal Data to us, you consent to the collection, use, disclosure and transfer of such Personal Data in the manner and for the purposes set out below.
Principles of data processing
We process users' personal data only in compliance with the relevant data protection regulations. User data is only processed if the following legal permissions exist:
The above legal bases are set out as follows:
Information we may collect
We may collect and process the following data which may contain Personal Data:
information that you provide by filling in forms on the GBE Platform (“our Platform - QARTHA”), including information provided at the time of registering to use our Platform, subscribing to any services provided by us, posting material, reporting a problem with our Platform, or requesting further services:
Hosting
To provide our Platform, we use a web hosting service, who process the data mentioned below and all other data that is processed in connection with the operation of our Platform on our behalf. Our Platform is hosted using the services of Amazon Web Services, Inc. a subsidiary of Amazon.com, Inc. in their US East (N Virginia) us-east-1 Data Center.
IP Addresses
We may also collect and process information about your device, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our business partners. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
Log Files
We may also collect and process access data that your internet browser automatically transmits to us for technical reasons in order to provide the website. Depending on the access protocol used, the protocol data record contains general information with the following contents: Your session data (usage behavior, length of stay, which links were clicked on, etc.), your abbreviated and unabbreviated IP address, your browser version, your operating system, your website-specific settings, your cookie IDs, your pixel IDs. This data does not allow any direct inference to your person and is processed to improve our website offer and to defend against attempted attacks on our web server.
Cookies
Please refer to our Cookie Policy for more information on how we use cookies.
Registration
If you register on our website, we will request mandatory and, where applicable, non-mandatory data in accordance with our registration form for the purposes stated below. The entry of your data is encrypted so that third parties cannot read your data when it is entered.
Your data will remain stored for as long as the registration lasts, in particular the storage is still necessary for the fulfilment/execution of the contract, for legal prosecution by us or for our other legitimate interests or we are required by law to retain your data (e.g., within the framework of tax retention periods).
Profile
As a registered user, you have the opportunity to create a user profile with just a few clicks and details. If you make use of the option, the relevant profile data you provide will be transferred to your profile. Of course, you can change the information at any time via the settings in your profile. When creating a profile, you can submit personal data. You have choices about the information on your profile. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be available. The legal basis for the processing of your personal data is the establishment and implementation of the user contract for the use of the service. We store the data until you delete your user account. Insofar as legal retention periods are to be observed, storage also takes place beyond the time of deletion of a user account.
Purchases
When ordering services, it is necessary, among other things, to provide your name, e-mail address and postal address. We process the personal data provided when you place an order solely for the purpose of providing you with the ordered service. Payment by credit card and debit card are made via our payment service provider as selected, to which we pass on your mandatory details provided for payment processing. Your data will only be passed on for the purpose of payment processing with the payment service provider and only insofar as it is necessary for this purpose.
Where we store your data
The Personal Data that we collect may be transferred to, and stored at, a destination outside Romania and the EEA. It may also be processed by staff operating outside Romania and the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your services ordered by you, the processing of your payment details and the provision of support services. By submitting any Personal Data to us, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this privacy policy.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Uses made of the information
We use information held, including Personal Data, in the following manner:
Disclosure of your information
We may disclose your Personal Data to any member of our group, which means any corporation deemed to be related to us.
We may disclose your Personal Data to third parties:
We may also disclose your Personal Data to a governmental or regulatory body, law enforcement, or other authorities, in order to enforce our terms of use for the Platform, to cooperate with any direction, request or order from such parties or to report any suspected unlawful activity.
Commercial and business services
We process data of our contractual and business partners, e.g., customers and interested parties in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g., to answer enquiries.
We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organization. We only disclose the data of the contractual partners to third parties within the scope of the applicable law to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the contractual partners (e.g., to participating telecommunications, transport, and other auxiliary services as well as subcontractors, banks, tax and legal advisers, payment service providers or tax authorities).
Unless otherwise specified the purposes of processing are Contractual performance and service, contact requests and communication, office and s procedures, administration, and response to requests, visit action evaluation, interest-based and behavioral marketing. And, the Legal bases are Contractual performance and pre-contractual inquiries, Legal obligation, and our Legitimate interests.
Offering our platform services
We process the data of our customers and Customers in order to enable them to select, purchase or commission the selected services. The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information.
Unless otherwise specified the purposes of processing are Contractual performance and service, contact requests and communication, office and s procedures, administration, and response to requests, visit action evaluation, interest-based and behavioral marketing. And, the Legal bases are Contractual performance and pre-contractual inquiries, Legal obligation, and our Legitimate interests.
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the data mentioned in these processing activities.
In this context, we disclose or transfer data to consultants, such as legal advisors or auditors, as well as other fee offices and payment service providers.
Furthermore, based on our business interests, we store information on suppliers and other business partners, e.g., for the purpose of contacting them at a later date. This data, most of which is company-related, is generally stored permanently.
Consent
By providing your Personal Data to us, you consent to the collection, use and disclosure of your Data by us for the purposes set out in this privacy policy (“Purposes”).
Where any Personal Data relates to a third party, you represent and warrant that the Personal Data is up-to-date, complete, and accurate and that you have obtained the third party’s prior consent for our collection, use and disclosure of their Personal Data for the Purposes. You agree that you shall promptly provide us with written evidence of such consent upon demand by us.
Each use of our services by you shall constitute a fresh agreement for us to collect, use and disclose the Personal Data in accordance with this privacy policy.
You may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all of the Purposes by submitting your request to us in writing. Should you withdraw your consent to the collection, use or disclosure of your Personal Data, it may impact our ability to proceed with your transactions, agreements or interactions with us. Prior to you exercising your choice to withdraw your consent, we will inform you of the consequences of the withdrawal of your consent. Please note that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies) or undertaking any steps as we may be entitled to at law.
What are your rights?
You have the following rights with respect to us processing your personal data:
You have the right to obtain information about whether and which of your personal data is processed by us. In this case, we will also inform you about:
You have a right to rectification and/or completion if your personal data processed by us is inaccurate or incomplete.
You have a right to restriction of processing, provided that:
You have a right to erasure if:
If you have exercised your right to rectification, erasure or restriction of processing, we will inform all recipients of your personal data, of this rectification, erasure of data or restriction of processing.
You have a right to receive your personal data processed by us on the basis of consent or for the performance of a contract in a structured, common and machine-readable format and to transfer it to another controller. If technically feasible, you have the right to have us transfer this data directly to another controller.
You have the right to object to the processing of your personal data in case of special reasons. In this case, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing. In case of processing of your personal data for direct marketing purposes, you have the right to object at any time.
You have the right to revoke any consent given to us at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with the competent supervisory authority if you believe that the processing of your personal data by us violates the law.
The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it.
We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information.
We encourage you to get in touch if you have any concerns with how we collect or use your personal information. If you wish to exercise your right to object, simply send an e-mail to us using support@qartha.com
Access and correction
Applicable Data Protection Law gives you the right to access your Personal Data. Your right of access can be exercised at any time without detriment. Any access request may be subject to a fee of an administrative fee at our rates then in force to meet our costs in providing you with details of the information we hold about you.
In the event that you wish to correct and/or update your Personal Data in our records, you may inform us in writing of the same by contacting us. In certain cases, Personal Data may also be corrected or updated via the Platform.
We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under applicable Data Protection Law).
Accuracy
We endeavour to ensure that all decisions involving your Personal Data are based upon accurate and timely information. However, we rely on you to disclose all relevant information to us and to inform us of any changes in your Personal Data. As such, please disclose all relevant information necessary for us to provide services to you and ensure all information submitted to us is up-to-date, complete, and accurate. Kindly inform us promptly if there are any changes in your Personal Data.
Retention
We may retain your Personal Data for at least five (5) years, or such other longer or shorter period as may be necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We will cease to retain your Personal Data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected and is no longer necessary for legal or business purposes.
Data Intermediary
Where we process your Personal Data as a data intermediary on behalf of a third party, we will process your Personal Data in accordance with the instructions of the third party and shall use it only for the purposes agreed between you and the third party. All such Personal Data will be protected and retained in accordance with this privacy policy.
We will take steps to inform the third party of any requests, complaints or questions that you may have regarding such Personal Data.
Security
State-of-the-art internet technologies are used to ensure the security of your data. During the online enquiry process, your details are secured with SSL encryption. For secure storage of your data, the systems are protected by firewalls that prevent unauthorized access from outside. In addition, technical and organisational security measures are used to protect the personal data you have provided against accidental or intentional manipulation, loss, destruction or access by unauthorized persons.
Data Breaches/Notification
Databases or data sets that include personal information may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, GBE will notify all affected individuals whose personal information data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after the breach was discovered.
Confirmation of Confidentiality
All company employees must maintain the confidentiality of personal information as well as company proprietary data to which they may have access and understand that such personal information is to be restricted to only those with a business need to know. Employees with ongoing access to such data will sign acknowledgment reminders annually attesting to their understanding of this company requirement.
Cooperation with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (order processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g., if a transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract pursuant to Art. 6 para. 1 lit. b GDPR), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g., when using agents, web hosts, etc.). If we commission third parties to process data on the basis of a so-called "processing agreement", this is done on the basis of Art. 28 GDPR.
Existence of automated decision-making
As a responsible company, we do not use automated decision-making or profiling.
External Links
Our platform contains links to the online services of other providers. We hereby point out that we have no influence on the content of the linked online services and the compliance with data protection regulations by their providers.
Personal information and children
Our services are aimed at people aged 18 and over. We will not knowingly collect, use or disclose personal information from minors under the age of 18 without first obtaining consent from a legal guardian through direct offline contact.
Changes and updates to the privacy policy
We kindly ask you to regularly inform yourself about the content of our privacy policy. We will amend the privacy policy as soon as changes to the information processing activities we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or other individual notification.
Concerns and Contact
If you have any concerns about a possible compromise of your privacy or misuse of your personal information on our part, or any other questions or comments, you can contact us using: support@qartha.com
Important Notice!
The information provided on this platform is for educational purposes only and is not to be taken as legal or professional advice on any matter.
