Privacy Policy

1. INTRODUCTION

AETERNA COACHING S.R.L., headquartered in Romania, Bucharest, 1st District, 19 Gheorghe Simionescu Street, ap. B26, trade registry registration number J2025004220001, sole identification code 51169684, represented by legal representative Iolanda Kim, phone number +40 730 586 421, email address aeternacoaching@gmail.com, in its capacity as “Provider” or “Coach”, “Controller” (also “Company” or “we” or “us”).

Our website, aeternacoaching.com (“Website”), is intended to provide a presentation of our coaching services and to allow you to communicate with us and eventually sign a coaching agreement in order to benefit from our coaching services.

In the above-mentioned context, we process personal data. This privacy policy (“Privacy Policy”) applies to Personal Data Processing (as defined below) and addresses natural persons whose personal data are processed (Data Subjects, as defined below) in the context of providing coaching services. 

AETERNA COACHING S.R.L. is the Controller of Personal Data (as defined below) of your Personal Data (as defined below), according to the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and any other applicable regulations at European or national level adopted in the context of such regulation (“GDPR”). This Privacy Policy informs you on the Personal Data we collect and process, the purposes and the legal basis of the Processing, and any other relevant information according to the GDPR. 

Please carefully read this Privacy Policy, and if you do not agree with the provisions herein, we might not be able to respond to your inquiries, but in any case, you will not incur any negative consequences. 

By ticking the box regarding this Privacy Policy before contacting us via the Website, you agree that you have read, understood, and agree that your Personal Data will be processed in accordance with this Privacy Policy. Nevertheless, there are certain Processing operations requiring your explicit consent, such as for sessions recording purpose, and you will be duly informed in this respect before giving your consent.

2. DEFINITION OF TERMS

“Personal Data” means any information relating to an identified or identifiable natural person.

“Data Subject” means an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

“Special Categories of Personal Data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation;

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller;

“Sub-processor” means the processor engaged by the Processor for carrying out specific Processing activities on behalf of the Controller; 

“Recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;

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

“Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements;

“Pseudonymization” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;

“Third Country” means any country located outside of the European Economic Area.

3. PRINCIPLES OF PERSONAL DATA PROCESSING 

The Personal Data are processed in accordance with legal principles, as follows:

  • Personal Data shall be processed in a lawful and transparent manner, guaranteeing loyalty to the persons whose Personal Data are processed (“lawfulness, loyalty and transparency”);
  • there shall be specific purposes for Processing the data and the Controller shall indicate these purposes to the Data Subjects when collecting their Personal Data (“purpose limitation”);
  • the Company can only collect and process Personal Data that is necessary to achieve these purposes (“data minimization”);
  • the Company shall ensure that Personal Data are accurate and kept up to date with regard to the purposes for which they are processed, and correct them where necessary (“accuracy”);
  • the Company can no longer use Personal Data for other purposes which are not compatible with the purpose for which they were initially collected;
  • the Company shall ensure that Personal Data is not kept longer than necessary to achieve the purposes for which they were collected (“limitation of conservation”);
  • the Company shall put in place technical measures and appropriate organizational structures that ensure the security of Personal Data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technology (“integrity and confidentiality”). 

4. PERSONAL DATA THAT WE PROCESS, PURPOSES AND LEGAL BASES

CONTEXTTYPE OF PERSONAL DATAPURPOSELEGAL BASIS
When you are requesting our coaching services and during the performance of the coaching agreement– name, given name and postal address (for invoicing);
– e-mail address (for communicating with you);
– phone number (for providing our services, where applicable);
– user names on Internet applications (for providing our services, where applicable);
– payment details (for payment of our services);
– any personal data that you provide us through survey tools (for providing our services);
– any personal data that you provide us through e-mail or other messaging services (for providing our services);
– any personal data that you provide us during our meetings or coaching sessions (for providing our services).		The performance of the contract concluded with you, including the activities performed by us in your interest under the contract between us or in order to take steps at your request prior to entering into the contract.Article 6 (1) (b) of the GDPR.
You are not obliged to provide these data, but if you decide not to do so, we will not be able to enter or to perform the coaching agreement.
During the performance of the coaching agreement or within maximum 3 years as of its termination– name and given name;
– address;
– e-mail address;
– phone number;
– user names on Internet applications;
– payment details;
– personal data provided during our coaching sessions. 		To exercise the right of defence whether in court proceedings or in an administrative or out-of-court procedures, as the case may be.Our legitimate interest
– Article 6 (1) (f) of the GDPR.
Our legitimate interest in processing these data arises from the interest to exercise the right of defence whether in court proceedings or in an administrative or out-of-court procedures, as the case may be.
When you contact us via the scheduling tool on the Website, or by e-mail– first name, last name;
– e-mail address, and any other data you provide us with.		In order to communicate with you and to solve your requestsOur legitimate interest
– Article 6 (1) (f) of the GDPR.
Our legitimate interest in processing these data arises from the interest in communicating with you and in solving your requests and thus in ensuring and increasing customer satisfaction.
You are not obliged to provide these data, but if you do not provide these data, we will not be able to solve your requests.
Processing is required for compliance with applicable lawsIf required by the applicable law, we may process Personal Data which is required for compliance with the respective legal obligation, such as first name, last name, address, payment details.To comply with our legal obligations, for example for information archiving, reporting towards public authorities/ institutions (such as tax authorities).Processing is necessary for compliance with a legal obligation to which the Controller is subject
– Article 6 (1) (c) of the GDPR.
If required by relevant applicable law, you must provide us with your Personal Data.
Not providing Personal Data for this purpose may entail certain legal consequences, as provided by relevant legal provisions.
After our coaching agreement is terminated– name, given name;
– personal information related to your experience with our coaching services.		To request for your feedback through a feedback form after our coaching agreement is fulfilled, and to improve our services.Our legitimate interest
– Article 6 (1) (f) of the GDPR.
Our legitimate interest in processing these data arises from our interest to request for your feedback through a feedback form after our coaching agreement is fulfilled, and to improve our services.
You are not obliged to provide these data, but if you do not provide these data, there are no negative consequences whatsoever. 
When you browse our Website (information collected through cookies or similar technologies)For the use of cookies, please read our Cookies Policy (for EU) / Cookies Policy (for UK) / Opt-Out Preferences (for US).

We also use third party technologies where website data are securely backed up, provided by UpdraftPlus. For additional information, please refer to https://teamupdraft.com/privacy/

When visiting our website, you may be redirected to our social media platforms, such as Facebook, Instagram, Pinterest, where their privacy policies apply:
– https://www.facebook.com/privacy/policy/
-https://privacycenter.instagram.com/policy
-https://policy.pinterest.com/en/privacy-policy		Please read this Privacy Policy and our Cookies Policy (for EU) / Cookies Policy (for UK) / Opt-Out Preferences (for US).Your consent – Article 6 (1) (a) of the GDPR.
Depending on the types of cookies, your consent may or may not be required – please carefully read the Cookies Policy. For the use of cookies that require your consent, if you do not express your consent, those cookies will not be used, without negative consequences for you. 
You may express your consent by ticking the boxes on the Website for each type of cookie and data as you will be informed upon and only the cookies you expressed your consent for will be placed on your computer/ device.
We rely on Article 6(1)(f) of the GDPR for our legitimate interest when we use third party technologies for securely backing up our website data with UpdraftPlus, respectively when using social media platforms.

5. We will take appropriate security measures and safeguards for your rights and freedoms, as provided by the GDPR, including pseudonymisation. 

6. We will not process Personal Data for automated individual decision-making, direct marketing and advertising profiling without your express prior consent for such purposes.

7. Our coaching services are not intended for minors below the age of 18 years and we do not knowingly collect Personal Data relating to minors.

8. TO WHOM IS YOUR PERSONAL DATA DISCLOSED

We are committed to ensure confidentiality of Personal Data at all times. Nevertheless, there are circumstances when we will disclose Personal Data, as applicable, to certain Recipients as follows:

  • In your interest, for the purpose of performing the contract with you or taking the steps to conclude the contract with you – we will disclose your data to the following recipients: our employees, collaborators, service providers, such as lawyers, accountancy services providers, website hosting providers (SiteGround) – located within the European Union, and consent management providers (Complianz), security providers (Wordfence), data processors (Google Workspace, UpdraftPlus), survey providers (Qualtrics), communications providers (Zoom), and payment service providers (Stripe and Paypal) – located outside the European Union.
  • If we have legal obligations in this respect – for example, we can disclose personal data to the Romanian National Agency for Tax Administration and other authorities/ institutions requiring them.
  • For the purpose of exercising or defending our legitimate rights and interests – for instance, to enforce our contract: lawyers, accountants, experts.
  • You have given your consent for this purpose, if applicable.

9. THE PERIOD FOR WHICH PERSONAL DATA WILL BE PROCESSED AND STORED AND THE CONDITIONS THEREOF

Data will be stored for the period required for the performance of the contract with you or for the storage period provided by law. During the performance of the contract and after the termination of the contract, there may be legal obligations for our company to keep records, in which case your data will be stored for the period provided by law, which can vary, up to 5 years.

When we process personal data based on your consent – Personal Data are retained until the consent is withdrawn, unless there are legitimate reasons justifying further processing (including a legal obligation in this respect) and prevailing over your interests, rights and freedoms or if this is necessary in order to establish, exercise or defend a right in court, but not later than 3 years from the date when such right could have been exercised.

Data processed under the legitimate interest basis – during the existence of the legitimate interest, but not more than 3 years from the date when such legitimate interest could have been exercised.

10. YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM

In relation to your Personal Data Processing, you have the following rights:

  • The right to access – You can request information related to the Personal Data that we process;
  • The right to rectification – You can request the rectification of the data if the information is inaccurate;
  • The right to the erasure of the data (“right to be forgotten”) – You can request the erasure of the data, in certain conditions (specified in the GDPR), namely: 
    • if personal data are no longer necessary for the purposes for which they were collected or processed;
    • if you withdraw your consent and there is no other legal ground for the processing;
    • if you object to the processing and there are no legitimate reasons to prevail;
    • if the personal data have been unlawfully processed;
    • if personal data must be deleted in order to comply with a legal obligation.      
  • The right to the restriction of the processing – You can request the restriction of your Personal Data Processing, when one of the following applies:
    • the accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of the Personal Data;
    • the processing is unlawful and you oppose the erasure of the Personal Data and request the restriction of their use instead;
    • we no longer need the Personal Data for the purposes of the processing, but these are required by you for the establishment, exercise or defence of legal claims;
    • you have objected to processing pending the verification whether our legitimate grounds override yours.     
  • The right to oppose – You can oppose to the Processing, in certain conditions (specified in GDPR), namely and where applicable, when we process Personal Data based on our legitimate interest.
  • The right to the portability of your Personal Data – You can request a copy of your data in a structured, commonly used and easy-to-read format, and you can receive it in an electronic format, respectively the right for these data to be transmitted by us to another data controller, insofar as the conditions provided by law are met. The data to which the right to portability applies are either those obtained by your consent or by a contract with us.
  • The right to oppose to an automatic individual decisional process, including profiles creation – as applicable and in other cases than based on your consent, you can oppose to any automatic individual decisional process including profiles creation.
  • The right to withdraw consent – Where applicable, namely where Personal Data Processing is based on the legal basis of consent provided at Article 6 (1) (a) of the GDPR, you have the right to withdraw consent at any time, as easy as you originally gave it, without prejudice to the lawfulness of the processing carried out on the basis of the consent before its withdrawal.
  • The right to file a complaint with the supervisory authority – You can file a complaint with the Romanian National Supervisory Authority for the Processing of Personal Data – https://www.dataprotection.ro.

The above rights may be exercised by submitting a request in this respect to the following e-mail address: aeternacoaching@gmail.com

The answer to your request will be communicated in accordance with the GDPR provisions, in not more than 1 (one) month as of the receipt of the request. This period of 1 (one) month can be prolonged with 2 (two) months if the complexity of the request and/or if the number of requests are imposing it. 

We review the data collected each year, analyzing the extent to which their retention is necessary for the purposes mentioned, your legitimate interests or the fulfillment of legal obligations by our company. Data that are no longer needed will be erased.

11. AMENDMENTS OF THE PRIVACY POLICY

We may change this Privacy Policy and we will publish the new version on the Website. 

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