Privacy Policy

We guarantee that:

  • We process your data exclusively for the delivery and our improvement, and guarantee of the services we offer.
  • Your data is securely stored in a protected environment.
  • Personal data is strictly confidential and will not be transmitted to third parties.
  • We use the data we collect for:

Providing and managing services, including displaying personalized content and facilitating communication with other users;

Facilitating the technical operation of the services, including resolving and addressing issues, ensuring services, and preventing fraud and abuse;

Processing enrollments and orders for courses, products, services, etc., and communicating with you to respond to your questions and requests.

Sending administrative messages and information, including messages from trainers and facilitators, notifications about changes to our services, and updates to our agreements;

Sending information and messages about benefits, new services, new features, promotions, informational messages, and other available courses (from which you can unsubscribe at any time);

Requesting feedback and understanding your needs through the use of analytics service providers;

Identifying unique users;

Improving our services and developing new products, services, and features;

Analyzing trends and traffic on websites or promoting our services on websites and applications.

The European Union law on personal data protection, the “General Data Protection Regulation” (hereafter referred to as “GDPR”), came into effect on May 25, 2016, and began to apply from May 25, 2018.

Protecting your personal data is important to us, therefore, we pay special attention to the privacy of visitors accessing any of the sites of S.C. ACCESS2ACCESSIBILITY MOVEMENT S.R.L., (hereinafter “APASS”), in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter “GDPR”).

Please pay special attention to reading the following Policy (hereinafter referred to as “DPP”) to understand how your information (“personal data”) will be treated.

The DPP explains APASS’s practices regarding the application of GDPR provisions, as well as your rights regarding how your information is used through APASS applications.

The processing of personal data by APASS will always be carried out in accordance with the provisions of the GDPR, as well as with the regulations on personal data protection specific to each country in which APASS operates.

Through the DPP, APASS intends to inform visitors about the nature of the personal data we collect and process, as well as the purposes of the processing. In addition, visitors to the sites are informed through the DPP about the rights they enjoy.

We are S.C. ACCESS2ACCESSIBILITY MOVEMENT S.R.L., a company with its registered office in Romania, Jud. PRAHOVA, Mun. CAMPINA, Blv. CAROL I, Nr.65, Cam.6, Bl.17C, Et.2, Ap.6, registered at the Trade Registry under Tribunalul Prahova with no. J29/2454/2020, fiscal registration code 43501587.

S.C. S.C. ACCESS2ACCESSIBILITY MOVEMENT S.R.L. is also known under the trade names: APASS.

The collection of this data is done only with your consent.

“Personal data” means any information or details that can identify you directly (for example, your name) or indirectly (for example, through pseudonymous data such as a unique identification number).

This means that personal data includes things like your address, first and last name, gender, date and place of birth, civil status documents, phone/fax, address (home/residence), email, profession, place of work, vocational training, family situation, economic-financial situation, information on owned goods, habits/preferences/behavior, image, voice, personal preferences and shopping habits, user-generated content, financial information, and financial status.

This may also include unique numeric identifiers, such as your computer’s IP address or your mobile device’s MAC address, as well as cookies.

“Processing” refers to any operation or set of operations performed on personal data or on sets of personal data, with or without the use of 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.

  • For the purpose of concluding and executing contracts – According to Art. 6 para. 1 lit. b) of the GDPR, personal data may be processed for the purpose of concluding or executing the contract. In order to offer you our products and services, we need to process personal data that belongs to you.
  • For the purpose of fulfilling legal obligations – According to Art. 6 para. 1 lit. c) of the GDPR, personal data can be processed in order to fulfill legal obligations. We require a range of personal data, including, in certain situations, the personal numeric code, to fulfill the obligations imposed by tax authorities in connection with billing and reporting to tax authorities.
  • For marketing purposes – According to Art. 6 para. 1 lit. a) of the GDPR, personal data can be processed if the person concerned has given their consent to the processing of their personal data for one or more specific purposes. Thus, if you have subscribed to the Newsletter section, your personal data will be used for the purpose of sending you marketing messages, offers, news, upcoming campaigns, invitations to various events. Your personal data will be deleted when you cancel your subscription from the Newsletter section. You can unsubscribe at any time through the link attached to communications received or through a written request addressed to contact@apass.ro.

APASS is committed to respecting the principles of personal data protection (hereinafter “Principles”) provided by the GDPR, to ensure that all data is:

  • Processed fairly, legally, and transparently;
  • Collected for specified, explicit, and legitimate purposes;
  • Adequate, relevant, and limited in relation to the purposes for which they are processed;
  • Accurate and up-to-date;
  • Kept in a form that does not allow the identification of the data subjects longer than is necessary for the purposes of processing;
  • Processed in a manner that ensures appropriate security of the processing, so that data are complete, confidential, and available.

Personal data means any information about you that allows us to identify you, such as your name, contact details, booking reference number, payment details, and information about your access to our websites.

We may collect personal data from you when you book a place to participate in events (directly or indirectly through our trusted partners), when you create an account, when you use the websites and/or applications and other sites accessible through the website and/or application, when you participate in a survey or contest, or when you contact us.

More specifically, we may collect the following categories of information:

  • Names, home address, email address, telephone number, city;
  • Detailed participant information, which includes names, date of birth, gender, identification card number;
  • Medical conditions for participants who have special medical needs and/or dietary requirements;
  • History of participation, including information related to your courses and services booked in connection with your courses;
  • Information you provide about your and your companions’ participation preferences in APASS programs and courses;
  • Information about your purchases of products and services;
  • Information about your use of our sites and/or our applications;
  • Communications you make with us or direct towards us via letters, emails, chat services, calls, and social networks.
  • Location, including the real-time geographic location of your computer or device through GPS and your IP address, along with Wi-Fi hotspot and GSM locations, if you use location-based features and activate Location Services settings on your device and computer.
  • Personal details about physical or mental health are considered “sensitive” personal data under applicable data protection laws. We will process such data only if you have given your explicit consent or it is necessary (for example, if you request special assistance) or you have deliberately made this data public.

The payment card data of the Client/User/Buyer will not be accessible and nor stored by APASS, but only by the transaction authorization institution or another entity authorized to provide card identification data storage services, about which entity the Client/User/Buyer will be informed prior to entering the data.

3D Secure means a new global approach to authenticating buyers and sales in secure Internet transactions. This security measure involves redirecting the user at the time of payment to a secured page where the registration of each cardholder is done by assigning an authorization code for each online transaction. Cards accepted for payment are those issued under the VISA (Classic and Electron) and MASTERCARD (including Maestro, if they have a CVV/CV2 code) logos.

Your data may be used for the following purposes:

  • For providing the products and services you request: we use the information you provide to perform the services you have requested;
  • To contact you in the event of a schedule change or cancellation: we send you information regarding the services you have requested and any changes to these services. The information is not for commercial purposes, and you cannot unsubscribe from them;
  • We use your payment information for accounting, billing, and auditing purposes and for detecting and/or preventing any fraudulent activities;
  • For administrative or legal reasons: we use your data for statistical and marketing analysis, system testing, customer satisfaction surveys, maintenance, and development, or to deal with a dispute or claim. Note that we may perform profiling based on the data we collect from you, for statistical analysis and marketing purposes. Any profiling will be conducted only with your prior consent, and making all efforts to ensure that all data on which it is based are accurate. By providing any personal data, you explicitly agree that we may use it to perform profiling activities in accordance with this Privacy Policy;
  • Security, health, administration, crime prevention/detection: we may transmit your information to government authorities or law enforcement bodies to comply with legal requirements;
  • For customer support communications: we use your data to manage our relationship with you as a customer and to improve our services and your experience with us;
  • To provide personalized services: we use your data to provide information we think you would find interesting before, during, and after your participation and to personalize the services we offer to you;
  • Marketing: from time to time, we will contact you with information regarding promotional offers and ancillary products through e-communications. However, you will have the option to subscribe or unsubscribe from such communications by indicating your preference at the booking stage. Also, in any online communication from us or our trusted partners, you will have the opportunity to indicate that you no longer wish to receive our direct marketing materials.

We will process your personal data only if we have a legal basis for doing so. The legal basis will depend on the reasons we collected and need to use your personal data.

We may also process your personal data in one or more of the following cases:

  • To comply with a legal obligation (for example, accounting requirements);
  • You have given your consent to use your personal data (for example, for commercial purposes);
  • To protect your vital interests or those of another person (for example, in a medical emergency);
  • It is part of our legitimate interests in operating (for example, for administrative purposes).
  • Only children aged 16 or above can give their consent. For children under this age, the consent of the parents or legal guardians of the children is necessary.

We will not keep your data longer than necessary to fulfill the purpose for which it is processed. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process them, and whether we can achieve those purposes through other means.

We must also consider periods for which it might be necessary to retain personal data to meet our legal obligations or to deal with complaints, queries, and to protect our legal rights in the event of a claim.

When we no longer need your personal data, we will delete or destroy them safely. We will also consider whether and how we can minimize over time the amount of personal data that we use and whether we can ensure the anonymity of your data, so they can no longer be associated with you or identify you, in which case we may use that information without further notice to you.

APASS may retain processed data for various periods of time deemed reasonable, in accordance with the purposes outlined above. We keep your data only for the period necessary to achieve the purpose for which we hold the data, to meet your needs, or to perform our legal obligations.

To determine how long your data may be retained, we use the following criteria:

When you purchase products and services, we keep your personal data for the duration of our contractual relationship;

If you participate in a promotional offer, we keep your personal data for the duration of the promotional offer;

If you contact us with a query, we keep your personal data for the duration necessary to process your queries, but not more than 5 years from the last correspondence sent;

If you create an account, we keep your personal data until you ask us to delete them or after a period of inactivity (without active interaction with our brands) defined in accordance with local regulations and guidance. In this regard, we mention that the data processed for this purpose will be deleted 5 years after the last interaction with the account user (such as, login to your account);

If you have given your consent for marketing, we keep your personal data until you unsubscribe or ask us to delete them or after a period of inactivity (without active interaction with our brands), defined in accordance with local regulations and guidance. In this regard, we mention that the data stored in our databases for the purpose of direct marketing communications are deleted from the records of these databases 5 years after the last interaction with you;

If cookies are stored on your computer, we keep them as long as necessary for them to achieve their purposes (for example, during a session for shopping cart cookies or session ID cookies) and for a period defined in accordance with local regulations and guidance. In this regard, we mention that data processed through cookies used to provide online behavioral advertising, to personalize our services for you, and to allow the sharing of our content on social media sites (sharing buttons intended to display the site), will be kept for a maximum period of 5 years from their collection, based on your consent.

APASS has adopted technical and organizational data processing measures, updated in accordance with GDPR requirements, with the aim of protecting your personal data against any unauthorized access, improper use or disclosure, unauthorized modification, accidental destruction, or loss. All APASS employees and collaborators, as well as any third parties acting in the name and on behalf of APASS, are obliged to respect the confidentiality of your information and the requirements of the GDPR, in accordance with the provisions of this Policy.

We follow strict security procedures in the storage and disclosure of your personal data, and to protect them against loss, destruction, or accidental damage. The data you provide is protected using SSL (Secure Socket Layer) technology. SSL is the standard industry method of encrypting personal information and data so that they can be securely transferred over the internet.

All registration details are transmitted through an SSL connection using dedicated network infrastructure (Multiprotocol Label Switching-MPLS) and are stored in accordance with Data Security Standards.

We may disclose your information to trusted third parties for the purposes set out in this Privacy Policy. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in accordance with Irish and EU law on data protection standards.

APASS will use the information you provide in the relevant contact section on the site exclusively for the purpose of processing your request.

By providing any personal data through the APASS sites, you understand and agree that your data will be processed in accordance with the provisions of the DPP of APASS.

Please be aware that in order to process your requests submitted in the registration section, we may have the obligation, under certain circumstances, to transmit your data to partners with whom APASS collaborates and/or other third-party service providers of APASS.

However, APASS has adopted appropriate technical and organizational measures to ensure the security of data transfer, as well as processing in accordance with GDPR requirements of your data, by the entities mentioned above.

APASS commits not to process the personal data provided for any other purpose than that for which they were transmitted, except where there is your express consent to use them for other purposes.

Some of the personal data processed through the APASS site may be transferred to third parties only if there is your express consent to proceed in this manner, except where there is a legal obligation for APASS to proceed in this way.

The APASS site may contain, at times, access links to other sites whose data processing policies may be different from those of APASS.

Please consider and consult the personal data protection policies of other sites, APASS cannot assume responsibility for the information collected by these third parties.

Depending on the context, we may find ourselves in the absolute necessity of providing information at a higher level, both globally and internally or externally, to our partners and those with whom we transfer data while respecting the aforementioned Regulation, in virtue of providing the most professional services possible. Information controlled by APASS may be transferred, transmitted, or stored and processed in the EU or in other countries than the country where you live, for the purposes described in this policy. These data transfers are necessary to be able to provide services at the highest level, as well as to continue to provide you with our materials at the highest professional standard. We use standard contractual clauses approved by the European Commission and rely on adequacy decisions issued by the European Commission, regarding certain countries, as appropriate, regarding data transfers from the EEA to the United States and to other countries.

The APASS site uses Cookie-type identifiers. In this regard, you can consult our Cookie Policy below and you can exercise your right to deactivate Cookies.

In accordance with GDPR, you have a number of rights concerning the personal data that APASS processes:

  • The right to access processed data – You have the right to access the personal data that we hold. The first provision of information will be made without charging any fee. If you need copies of the information already provided, we may charge a reasonable fee taking into account the administrative costs of providing the information. Vexatious, excessive, or repetitive requests may not receive a response.
  • The right to rectify data – You have the right to request that your Data be rectified if it is inaccurate or outdated and/or to have it completed if it is incomplete. If you have an account, it may be easier to correct your own data via the “My Account” function or by email at contact@apass.ro.
  • The right to data erasure (“right to be forgotten”) – In some cases, you have the right to obtain the erasure or destruction of your Data. This is not an absolute right, as sometimes we may be required to retain your Data for legal or statutory reasons.
  • The right to restrict processing – You have the right to request the restriction of the processing of your Data. This means that the processing of your Data is limited so that we can keep the Data, but not use or process it. This right applies in specific circumstances set out by the General Data Protection Regulation, namely:

– the accuracy of the Data is contested by the data subject (i.e., you), for a period enabling the controller (i.e., APASS) to verify the accuracy of the Data;

– the processing is unlawful and the data subject (i.e., you) opposes the deletion of the Data and requests the restriction of their use instead;

– the controller (for example, APASS) no longer needs the Data for processing, but they are required by the data subject (i.e., you) for the establishment, exercise, or defense of legal claims;

– the data subject (i.e., you) has objected to processing based on legitimate grounds on the part of the controller (in this case APASS), pending the verification whether the legitimate grounds of the controller (APASS) override those of the data subject (i.e., you).

  • The right to data portability – You have the right to move, copy, or transfer data that concern you from our database to another one. This only applies to data you have provided, where processing is based on your consent or on a contract and is carried out by automated means.
  • The right to object – You can object at any time to the processing of your data when such processing is based on a legitimate interest.
  • The right to withdraw consent at any time – You can withdraw your consent regarding the processing of your data when such processing is based on consent. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
  • The right to lodge a complaint with a supervisory authority – You have the right to lodge a complaint with the data protection authority of your country of residence or domicile to challenge the data protection practices provided by APASS.
  • The right to object to the processing of your data for direct marketing purposes – You can unsubscribe or opt out of our direct marketing communication at any time. It is easier to do this by clicking on the “unsubscribe” link in any email or communication we send you.
  • The right to object to the processing of your data by us when we perform actions in the public interest or in our own legitimate interests or those of a third party – You can object at any time to the processing of your data when such processing is based on a legitimate interest.
  • The right to deactivate Cookies – you have the right to deactivate cookies. Internet browser settings are usually programmed by default to accept cookies, but you can easily adjust this by changing your browser settings.

You can exercise these rights, either individually or cumulatively, very easily, by simply sending a request to our headquarters in Jud.PRAHOVA, Mun.CAMPINA, Blv.CAROL I, Nr.65, Cam.6, Bl.17C, Et.2, Ap.6, or by email at: contact@apass.ro.

We access, retain, and provide your information to regulatory authorities, law enforcement bodies, or other entities:

In response to a legal request, when we believe, in good faith, that the law requires us to do so. We may also respond to legal requests when we believe, in good undecaffeinated coffee Faith, that the response required by the laws of the respective jurisdiction affects users in that jurisdiction and is in accordance with internationally recognized standards.

When we believe, in good faith, that it is necessary to: detect, prevent, and respond to fraud, unauthorized use of any material that belongs to us, violations of conditions or policies, or other harmful or illegal activities, to protect us (including our rights, property, or materials), you and others, including during investigations or inquiries by regulatory authorities or to prevent imminent death or physical harm. For example, if relevant, we provide information to and receive information from third parties about the reliability of your account, to prevent fraud, abuse, and other harmful activities inside and outside our materials.

The information we receive about you may be accessed and stored for a longer period when it is subject of a legal request or a legal obligation, a government investigation, or investigations concerning possible violations of our conditions or policies, or in other cases to prevent harm.

The APASS site may contain links to other sites and/or other web pages that are not owned by APASS. APASS assumes no responsibility for the content of these sites and therefore cannot be held liable for the content, advertising, goods, services, software, information, or other materials available on or through these sites. APASS will not be responsible for the loss of personal data, any adverse effects on visitors’ personal data, or other moral and/or material damage caused by access to those sites.

Please be aware that this Policy may be subject to periodic content changes by updating the APASS site.

We will send you a notification before making any changes to this Policy and will provide you with the opportunity to review the revised DPP before you choose to continue using our materials.

Please do not continue to use the APASS sites if you do not agree with such changes. Also, we recommend that you check this page for any updates.

The terms of the DPP are interpreted in accordance with applicable law.

If you have questions or concerns about how we treat and use your personal data, or if you want to exercise any of your rights, please contact us at contact@apass.ro.

Shopping Cart
Scroll to Top