1. Identity and contact details of the Controller.

Personal data is processed by “The Mark Twain International School” Foundation, headquartered in Voluntari town, 25B Erou Iancu Nicolae Street, Ilfov County, tax registration number 11677489, email: contact@marktwainschool.ro, phone: 0724 000 900, according to the provisions of the EU Regulation no. 679 of 2016 on the Protection of Personal Data (GDPR) and Law no. 190 of 18.07.2018, on measures for the implementation of GDPR in Romania.

2. Contact details of the Data Protection Officer.

The processing of personal data is performed under the coordination of a Data Protection Officer. Any claim regarding your rights with respect to processed personal data may be addressed through the contact details given in section 1 or directly to the Personal Data Protection Officer via the email address dpo@marktwainschool.ro .

3. Categories of data subjects and types of data processed.

The processing of personal data by “The Mark Twain International School” Foundation targets the following categories of people:

• natural persons who are the representative of the companies with which it exists, may exist or is in preparation, a partnership regarding the products and services offered by our institution.
• natural persons who may become, are or have been contractual or commercial partners of “The Mark Twain International School” Foundation.
• minors who are willing to participate, participate or participated in forms of training, education or educational programs and / or related activities organized by “The Mark Twain International School” Foundation as well as their parents and / or their guardians;
• parents or legal guardians of minors who may participate in forms of training, education or educational programs and / or related activities organized by “The Mark Twain International School” Foundation;

The personal data of the categories of people listed above can be retrieved directly from them, from the messages (sent by telephone, FAX, email or through instant messaging applications or social networks) through which we are asked about the educational services delivered. These data can also be retrieved during direct meetings between “The Mark Twain International School” representatives and potential beneficiaries of our activities that we carry out. Later contact details may be supplemented with other information related to the person’s identity, such as home address or residence address, job address, national identification numbers, health data, and other data with special character, depending on the necessities imposed by the commercial, financial law rules or by the norms governing the activities carried out for the benefit of the persons whose data we process.

Also, personal data that is anonymous (cannot directly identify the data subjects by such processing) can also be automatically retrieved from those who visit the websites or the online services of “The Mark Twain International School” Foundation. Such data is used to optimize and adapt the content of online services, according to the requirements and interests of those accessing them.

Depending on the needs deriving from the legitimate interests or legal obligations stemming from the partnership relations concluded with the individuals concerned, the types of personal data that we process are:

1. Anonymous data associated with web traffic: IP address, computer system type (desktop, tablet, PC, smartphone), browser type, cookies modules;
2. Identification data: Last name, first name, telephone or FAX number, email address, home address, residence address, or address used for delivery of documents, products or services.
3. National identification numbers: Personal Identification Number (CNP) ID series and number, driving license number, passport number, health insurance number.
4. Data of a special nature that allow the individualization of a natural person through: profession, occupation, job, religious confession, health data, and criminal record data.
5. Purpose, duration and legal basis of the processing of personal data.

 

As regards non-commercial partners or legal (contractual) beneficiaries of the activities carried out by “The Mark Twain International School” Foundation, we only process contact data in order to pursue legitimate interests derived from the Foundation’s objectives. These interests may include processing for statistical purposes or direct marketing. The length of time during which this data is processed will be the same as the length of time during which “The Mark Twain International School” Foundation has its legal status unchanged from the moment of taking / obtaining the data or until exercising a right of the data subject that requires the processing to be suspended or these data erased.

When a legally valid partnership relationship exists between “The Mark Twain International School” Foundation and the data subjects by processing, to the contact details we can also add the identification or individualisation data required by the legal rules governing the contractual relationship occurred. These data are processed for a period identical to the prescription period for the legal obligations assumed (typically this period is 3 years) or the period required by law for certain categories of documents (for example, the retention period for the personnel file is for 75 years).

5. The obligation to provide data.

When contacting us directly (by email or telephone) for obtaining information, the provision of your data is not a legal or contractual obligation or obligation required to conclude a contract. On the other hand, however, please note that in the absence of such data, we will not be able to send you information about the activities of “The Mark Twain International School” Foundation for which you have expressed interest at a given moment.

When between you and “The Mark Twain International School” Foundation a legally regulated partnership relationship occurs, you will need to provide us with the data required by the legal rules governing the activities we carry out for your benefit in addition to contact data, as in the absence of such data, it is impossible for us to provide you with the services or products requested.

6. Legitimate interests.

The data provided by you is processed in order to meet the objectives of “The Mark Twain International School” Foundation regarding the activities it is authorized to carry out. These interests may include, but are not limited to, contacting partners to promote our services or products, transferring personal data to companies with which we have partnership relationships when their activity requires access to such data, preventing fraud, abusive use of our services and products, monitoring of premises in order to ensure their physical security, protection of their own IT systems, processing for historical, scientific and statistical purposes, processing for research purposes (including marketing studies).

7. The security of personal data processed by “The Mark Twain International School” Foundation

“The Mark Twain International School” Foundation undertakes to apply all technical and organizational measures in order to ensure the protection of personal data that is processed through computer and communications systems and other electronic systems as well as those processed in any other forms, against threats and any actions that may affect the confidentiality, integrity, availability, authenticity of data, and non-repudiation of processing operations, as well as the impairment of the operation of computer systems, whether occurring accidentally or intentionally.

8. Data made available to third parties.

Personal data processed through activities targeting natural persons will not be disclosed to a third party for use for purposes other than those in which they are retrieved.

With strict reference to the purposes for which personal data has been retrieved, personal data processed by “The Mark Twain International School” Foundation can be made available to intermediaries specialized in providing related or complementary services to our activities (such as be electronic payment services, courier services, accounting services, etc.). Any provision of personal data to a third party will be made only on the basis of a legal commitment by which the legal person authorized by “The Mark Twain International School” Foundation to process personal data, undertakes to comply with the provisions of the GDPR as well as the national rules in the matter.

9. Transferring data to a third country or an international organization outside the European Union

We process data together with partners in the European Union. These data are processed in accordance with mandatory corporate rules established by the competent supervisory authority (from the EU Member State in which the partner who has developed the training rules is headquartered).

We do not transfer data to entities outside the EU except to the extent that those countries are on the list of countries considered by the EU as presenting adequate conditions for the protection of personal data or only with the fulfilment of the conditions described in Chapter V of the GDPR on transfers of personal data to third countries or international organizations.

10. Rights of data subjects regarding the processing.

For the natural persons concerned by the processing of personal data, “The Mark Twain International School” Foundation assures the exercise of all rights provided by Article 13 – Article 22 of the GDPR, as follows:

1. The right to information and access to processed personal data. When personal data is retrieved or within 30 days if it is obtained indirectly, the data subject by the processing is informed of the identity and contact details of “The Mark Twain International School” Foundation, the contact details of the Data Protection Officer (where applicable), the purposes and legal basis in which personal data are processed, recipients or categories of recipients of personal data, the intention of “The Mark Twain International School” Foundation to transfer personal data to a third country or an international organization (if applicable), the period for which the personal data will be stored or the criteria used to determine that period, the existence of an automated decision-making process including the creation of profiles and, at least in the cases concerned, relevant information on the logic used and concerning the importance and expected consequences of such processing for the data subject.
2. The right of access to personal data. Natural persons subject to the processing of personal data are entitled to obtain from “The Mark Twain International School” Foundation a confirmation that personal data concerning them are processed or, if so, access to the data and to the information listed in point a.
3. The right to rectification or deletion. Natural persons subject to data processing have the right to obtain from “The Mark Twain International School” Foundation, without undue delay, the rectification of inaccurate personal data that concern it. Taking into account the purposes for which the data were processed, the data subject has the right to obtain the supplementing of incomplete personal data, including the provision of additional statements. The data subjects also have the right to obtain from “The Mark Twain International School” Foundation the deletion of their personal data without undue delay, if the reasons set out in Article 17 paragraph (1) of GDPR apply.
4. The right to restrict the processing. Natural persons subject to data processing have the right to obtain from “The Mark Twain International School” Foundation the restriction of the processing of personal data in the cases described in Article 18 of GDPR.
5. The right to oppose processing. Natural persons subject to data processing by “The Mark Twain International School” Foundation have the right to oppose, for reasons related to their particular situation, to the processing out of marketing purposes, to profile creation, or to be subject to a decision based solely on automatic processing and which produces legal effects concerning the data subject and affecting it similarly to a significant extent.

With regard to the processing of anonymous data automatically retrieved when accessing our online services, you can always oppose this type of processing by enabling the privacy settings of your browser or by selecting applications that offer anonymous browsing facilities on the web.

With regard to cookies, by means of the settings that your application you use to browse the Internet offers you, you can view these modules, delete them, and block these modules from being saved on your computer system. Keep in mind, however, that most websites often use these cookies to optimize the content of the site you access, depending on the preferences and settings you make when you first visit the site. So, on the next visits, restoring these settings will no longer be necessary. By deleting or blocking cookies, whenever you revise an Internet site, you may be prompted for some content display setting operations. More details about cookies are provided in section 11.

1. The right to data portability. When personal data has been provided by a natural person in a structured format that is currently used and that can be automatically read in order to be processed by “The Mark Twain International School” Foundation, the natural person subject to this type of processing, has the right, in the cases provided by Article 20 of the GDPR to transmit this data to another operator without any hindrance from the “The Mark Twain International School” Foundation.
2. The right to withdraw consent at any time without affecting the lawfulness of the processing performed based on consent prior to its withdrawal.
3. The right to lodge a complaint with the National Supervisory Authority for Personal Data Processing where a natural person concerned by the processing of personal data by “The Mark Twain International School” Foundation believes that his / her rights have been breached. The National Authority for the Supervision of Personal Data Processing can be contacted at phone +40.318.059.211, email anspdcp@dataprotection.ro or through www.dataprotection.ro.
4. If the provision of personal data is a legal or contractual obligation or an obligation required to conclude a contract, then the data subjects have the right to know the possible consequences of non-compliance with this obligation.

The exercise of any of the rights listed in sections a.-i. can be done by making a request through the contact details presented under section 1 or using the contact information presented on the https://marktwainschool.ro/ contact-us /

11. Cookies.

What are cookies? What is a cookie?

Cookies are small files that are saved on a user’s computer. They are designed to store a small amount of data specific to a particular visitor and website accessed by it, being accessible to both the person holding the computer in which these modules were automatically saved and to the website that submitted this file. This type of processing allows the server to provide a web page tailored to a particular user, or even to transmit information from a visit to a site to another similar site with the same holder.

Are cookies enabled in my browser?

To check if your browser is configured to allow cookies, you’ll need to look into your browser’s setting options, the section dedicated to these modules, usually under the “privacy and security options.” Also, in this section you’ll find information on enabling or disabling cookies, deleting cookies. You can also view the contents of these files.

What data can be found in a cookie module?

Each cookie file is actually a small table containing values (key, data) – for example (name, Ion) (name, Ana). Once the cookie file has been read by the code on the server or client computer, the data can be retrieved and used in order to customize the web page accordingly.

When are the cookies created?

Writing data to a cookie module is usually done when information is sent to the visited website – for example, after pressing a ‘submit’ button, the data handling page could be used for Storing values in a cookie. If the user chose to disable cookies, the writing operation will fail and subsequent visits that could retrieve the information already transmitted from the cookies will either work according to the default algorithm for new visitors, or require the user to reintroduce the information that would have been stored in the cookie.

Why are cookies used?

Cookies are a convenient way to associate information about how to use a site without the need to store massive amounts of data per visitor within the site. In addition, storing data on the server without the use of cookies would require that each user’s recognition to be made only by their authentication, based on username and password. Last but not least, the use of cookies reduces the amount of personal data processed in controllers’ own systems, given that a cookie module is saved in the computer system owned by the natural person subject to this type of processing.

What is the duration of processing a cookie?

The expiration date of a cookie module can be set when the cookie is created. By default, the cookie is “destroyed” when the browser window is closed but can be designed to persist for a period of time after accessing a site.

Who can access cookies?

When creating a cookie, it’s possible to control its visibility by setting the primary domain of the site that uses it. Then this file will be accessible to any site belonging to this domain. For example, the domain could be set to “numedomeniuprincipal.ro”, and the cookie will be available for sites from “numedomeniuprincipal.ro” or “xyz numedomeniuprincipal.ro” or “numedomeniuprincipal.ro”. This could be used to allow related pages to “communicate” with each other.

How secure are the cookies?

There are many concerns about privacy and security on the internet. Cookies do not in themselves pose a threat to privacy because they can only be used to store information the user has voluntarily provided or that the web server already has. Although this information may be made available to certain third-party sites, this does result into risks additional to those specific to data storage in a central database. If you are concerned that the information you provide to a web server are not treated as confidential, then you should ask whether you really need to provide this information or not.

What are tracking cookies?

Some commercial websites include embedded advertising materials that are provided by a third-party site, and it is possible that such ads may store a cookie for that site. In this cookie information that could include the name of the site, certain products visited, visited pages, etc will be stored. When the user later visits another site containing a similar embedded ad from the same third-party site, the advertiser will be able to read the cookie module and use it to determine some information about the user’s browsing history. This thing allows publishers to serve targeted ads in the interest of a user so that in theory these have a greater chance of being relevant to the user. However, many people see such “tracking cookies” as an invasion of confidentiality because they allow an advertiser to build user profiles without their consent or knowledge.

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