GPDR & Cookies Policy

GENERAL TERMS AND CONDITIONS

The identity and contact data of the seller
The owner of the brainovate.com (the „Website”) is the company The Training Boutique SRL, with headquarters in Ostratu Village, Corbeanca Commune, 30D Hipodromului Street, Ilfov County, Romania, registered with the Trade Registry under no. J23/1727/2006, unique identification number 14823562, as the seller (the“Seller”).

The products sold on the Website are usually end-goods meant for end consumers (the„Buyers”) who use the Website to launch purchase orders / purchase offers (the „Order”). The present Terms and Conditions do not apply to cases where the entity intends to buy the goods from the Seller in wholesale, for the purpose of resale or distribution.

The proposal for the conclusion of the purchase contract is the placement of the offered goods by the Seller on the Website (the “Offer”). The sale-purchase contract (the “Contract”) is concluded when the Seller responds to an Order through an order confirmation on a durable support, usually through a confirmation e-mail sent to the Buyer (the „Confirmation”).

The products
All products presented on the Website are new. The displayed pictures are for information purposes only – the colour and some of the details might be different from those in the displayed images.

Some of the products displayed on the Website might not be in stock at certain times. The Seller reserves its right to refuse a certain Order in case the respective product is no longer in the store’s stock or is not available due to reasons independent of the Seller.

The Seller reserves the right to cancel the Order or part thereof before the purchase Contract is concluded in the following cases: the goods are no longer manufactured or delivered or the price of the goods supplier has changed significantly. If the Buyer has already paid a portion of the purchase price or the full purchase price, this amount will be refunded.

Placing a product in the basket, in the absence of the Order completion and of Confirmation, does not mean the registration of an Order, nor the reservation of the product until the Confirmation is made.

Prices
The price displayed on the Website is the final price of the product. To it the Seller shall add delivery costs, which vary depending on the delivery area and on the chosen delivery service. The Seller shall try, to the largest extent possible, to offer the Buyer an estimation of delivery prices, before the Order is launched.

The Seller reserves their right the change the price of products, without any previous notification. The Seller shall not modify the value of the Order after Confirmation by e-mail.

Commitment of Orders
The Seller undertakes to fulfil any Confirmed Order within the term displayed [or within 30 days] from the Confirmation.

The Seller can cancel or delay the delivery of a Confirmed Order only in case of exceptional justified reason, or in case of a fortuitous or force majeure case.

The Seller shall not be held liable for delays due to the transportation services, from the moment when the latter have taken possession of the products.

By completing the Order, the Buyer confirms that all the data the Buyer has supplied, necessary for the fulfilment of the sale Contract, are correct, complete and true, on the date the same had launched the Order. The Buyer shall be held liable for any damages caused by incorrect information supplied.

Payments
The Seller has the obligation of providing only the payment means displayed on the Website at the moment the Order is launched.

In case of online payments through credit cards or other similar instruments, the Seller is not/cannot be held responsible for any additional cost undertaken by the Buyer, including, but without being limited to currency conversion fees applied by the bank issuing his/her card, any payment service taxes and fees, etc. The responsibility for such taxes and rates are the sole responsibility of the Buyer.

Additional information
The Seller shall try to provide Buyers with additional information regarding the products sold on the Website but does not undertake to answer all questions or provide all requested information.

Intellectual Property
The content of the Website, including, but without being limited to logos, stylized representations, commercial symbols, static images, dynamic images, multimedia text and/or content presented on the Website, are the exclusive property of the Seller, if they do not belong to other manufacturers or distributors, all the rights to such materials, whether obtained directly or indirectly (through user and/or publishing licenses), belonging to the respective rightsholders („Intellectual Property”).

The Seller or the respective rightsholders reserve all Intellectual Property related rights, while the Website visitors are not allowed to copy, distribute, publish, transfer towards third parties, modify and/or otherwise alter, use, connect to, expose, include any element of the Intellectual Property.

Contact
The Buyer agrees that the Seller can contact him/her, through any of the means available / accepted by the Seller, in any situation which requires contacting the Buyer including for Order related notifications.

Modifications of the document
The present General Provisions are updated periodically; anytime the Seller makes an update, the Seller will display the same on its Website.

The date of the last update: November 2018

 

COOKIE POLICY

Identity and contact data of the operator
All personal data processing activities performed through the website revealingtheleaderwithin.com (the „Website”) are performed by the company The Training Boutique SRL, with headquarters in Ostratu Village, Corbeanca Commune, 30D Hipodromului Street, Ilfov County, Romania, registered with the Trade Registry under no. J23/1727/2006, unique identification number 14823562 (the“Operator”). The representative of the Operator is Oliver Perkins, Director.

This Cookie policy should be interpreted alongside the more general Notice regarding website personal data processing [link to the Notice regarding website personal data processing].

Contact data for any personal data protection related requirement
Any complaints or requests related to the protection of personal data can be sent to the e-mail address [oliver@brainovate.com] or through mail at the address [Ostratu Village, Corbeanca Commune, 30D Hipodromului Street, Ilfov County, Romania] in the attention of the data protection representative.

What is a cookie?
A cookie is a small text file that is stored in your web browser that allows the Operator or a third party to recognize you. Cookies might be used for the following purposes: (1) to enable certain functions; (2) to provide analytics; (3) to store your preferences; and (4) to enable ad delivery.

Cookies can either be session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years. Cookies placed by the website you’re visiting are sometimes called “first party cookies” while cookies placed by other companies are sometimes called “third party cookies.”

What cookies are used when I use the Website?
When you use the Website or visit a Website page with a video, the Operator or a third party may place a number of cookies in your browser. Some of the cookies will only be used if you use certain features or select certain preferences, and some cookies will always be used.

Each cookie serves different purposes:

Analytics cookies
This Website uses Google Analytics, a web page analysis service offered by Google Inc. (“Google“). The service uses cookies installed by Google. The information generated by these files refers to how the User navigates on the Website, including their IP address, and is transmitted to Google, which can store such data on servers United States. Google will use this information to evaluate how the Website is used, to generate reports on the activity on the Website (intended for its operators) and to provide other services related to the activity on the Website and t Google may also transfer this information to third parties if the law so requires or if the third parties process the information on Google’s behalf.

Google may use that data for its own research and statistics, in accordance with the currently available Google privacy policy.

The operator believes that the Google Analytics service is generally a service compliant with personal data protection legislation. The Operator undertakes to activate or alter those settings that lead to Google Analytics being compliant with applicable law in the field of personal data protection.

Cookies data can be transferred to Google Inc. in the United States, the adequacy of data protection being met by the accession of Google Inc. to the EU-US privacy shield system.

Preference Cookies
These first party cookies store your Website preferences, such as login status, order basket, etc.

What are my cookie options?
If you don’t like the idea of cookies or certain types of cookies, you can change your browser’s settings to delete cookies that have already been set and to not accept new cookies. To learn more about how to do this, visit the help pages of your browser. We do our best to limit the number of cookies on the Website. Please note, however, that if you delete cookies or do not accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, you may not login and some of our pages might not display properly.

You can also turn off all cookies but the strictly necessary cookies here [GDPR cookie plugin link]

Do you use any other user tracking technologies?
We use additional technologies to help track user activities and preferences. For example, we use web beacons (also known as clear gifs, pixel tags or web bugs). Web beacons are tiny graphics (about the size of period) with a unique identifier that are embedded invisibly on web pages or emails. They are used to track user activities and communicate with cookies. You cannot opt out of web beacons used in webpages, but you can limit their use by opting out of the cookies they interact with. You can opt out of web beacons used in emails by setting your email client to render emails in text mode only. Finally, we use local storage to facilitate certain functions, but we do not retain the data captured via local storage.

Where can I find more information about cookies?
You may learn more about cookies and how to opt out of them by visiting the following third party websites:

About.com Browser Guide

All About Cookies.org

Network Advertising Initiative

 

NOTICE REGARDING WEBSITE PERSONAL DATA PROCESSING

Identity and contact data of the operator
All personal data processing activities performed through the website revealingtheleaderwithin.com (the „Website”) are performed by the company The Training Boutique SRL, with headquarters in Ostratu Village, Corbeanca Commune, 30D Hipodromului Street, Ilfov County, Romania, registered with the Trade Registry under no. J23/1727/2006, unique identification number 14823562 (the“Operator”). The representative of the Operator is Oliver Perkins, Director.

Contact data for any personal data protection related requirement
Any complaints or requests related to the protection of personal data can be sent to the e-mail address [oliver@brainovate.com] or through mail at the address [Ostratu Village, Corbeanca Commune, 30D Hipodromului Street, Ilfov County, Romania] in the attention of the data protection representative.

The purpose of data processing
The information that the Operator collects with respect to the Website’s users mainly consist of:

the electronic identification details of the website users along with any information provided by cookies and beacons as per our Cookie Policy [link to cookie policy] (IP address, browser type, time of browsing, browsed pages, any other information as per the Cookie Policy, etc.);
the identification details and contact data of actual and potential clients (including name, address, e-mail address, telephone number, etc.);
payment data, including those of debit cards (if applicable – includes credit card no. expiration date, CVV, name on credit card, withdrawn amount);
information on any purchased products and unsubmitted orders, usage of the Website and Website browsing habits;
information on any other submitted claims, requests or questions (including name, address, e-mail address, telephone number, query text etc.).
The purposes for which personal data is collected include:

the remote conclusion of a contract (letters b) and c) above);
the delivery of products (letter b) above);
answering any support, return or warranty request (letters b), c), and e) above);
direct marketing (letter b) above);
statistics related to the user activity performed within the Website (letters a) and d) above);
accounting and reporting (letters b), c) d), and e) above).
The Operator processes personal data based on the following legal grounds:

the preparation of execution and actual execution or conclusion of the contract with potential clients – letters (i), (ii) and (iii) above;
the legitimate commercial interests of the Operator, for example, preventing and preventing frauds improving services and products; the Operator shall evaluate its commercial interests depending on the case, in order to ensure that they do not prevail over the rights of the data subject – letter (v) above;
compliance with an imperative legal requirement, including, for example, accounting and legal requirements, which are subject to a strict internal policy (such as retention periods) – letter (vi) above;
the consent that data subjects give when the Operator – letter (iv) above.
Personal data recipients or recipient categories
Customers (members and guests) can pay by bank card via NETOPIA mobilpay. Bank card details (shopping value, card number, card name, expiration date, CVV code) and customer identification data (extracted from the Website) are processed – name, surname, phone, e-mail address, code the customer assigned by the merchant.

The purpose of processing is to make online payments through the NETOPIA mobilpay payment processor.

The legal basis is the execution of the contract in accordance with Article 6 (1) (b) of the GDPR.

The Operator’s customers are hereby informed that at the time of payment they will navigate to NETOPIA mobilpay’s website. The terms and conditions under which NETOPIA mobilpay processes payments are available here: https://www.mobilpay.ro/public/politica-de-confidientialitate/

Personal data recipients or recipient categories
The Operator may transfer the personal data belonging to data subjects towards partners and collaborators only for performing its commercial activity. Third parties and processors that can receive personal data include:

delivery services;
the manufacturers, importers and suppliers of the products and services distributed by the Operator;
payment operators (e.g. Netopia Mobipay);
accounting firms, legal services suppliers;
e-mail marketing agencies and mass e-mail services (e.g. MailChimp);
website traffic monitoring services (e.g. Google Analytics);
other subcontractors.
The Operator will make sure that it concludes contracts with third parties that ensure an appropriate level of personal data protection.

The operator will not transfer personal data to a third country. As an exception, certain data on direct marketing or Website trafic may be transferred to third-country processors offering an equivalent level of protection or to the United States of America (EU-US Privacy Shield companies only).

If the Operator proceeds through a reorganization procedure (including merger, division, dissolution or liquidation) or sale to another organization, it will communicate the person’s information to the successor organization. Also, the Operator may transfer the data to a third person if an imperative requirement of the law so requires.

The personal data storage period
The Operator shall store the information belonging to data subjects for as long as required by the applicable legal provisions. If there is no applicable regulation, or if the mandatory legal term has passed, the Operator shall store the data only for as long as necessary, depending on the purpose they were collected for.

The data collected for direct marketing purposes shall be processed until the exercise of the withdrawal right.

The rights of the data subject
The data subject shall have the right to request the Operator, in relation to the personal data regarding the data subject, to grant the data subject access to them, to rectify or delete them, or to restrict their processing, or the right to oppose the processing, in compliance with the applicable regulations. The Operator shall ensure the right to data portability.

When the processing is based on the consent of the data subject, the data subject shall have the right of withdrawing their consent at any moment, without affecting the legality of the processing performed based on the consent given before the respective withdrawal.

The data subject has the right of filling a complaint at the competent National Supervisory Authority for Personal Data Processing or at any other competent authority, in case the data subject considers that the data subject’s data processing related rights have been breached.

Mandatory supply of personal data
The supply of certain personal identification data, such as name, e-mail address, physical address and telephone number, as well as the data corresponding to payment instruments or requested by payment processors are essential for concluding a remote contract and for the delivery of products.

Modifications of the document
The present information on personal data processing is periodically updated; every time the Operator makes a change it shall be updated on the Website.

Date of the last updated: November 2018

 

CONFIDENTIALITY, MARKETING AND COMMERCIAL COMMUNICATIONS POLICY

The identity and contact data of the operator
All marketing activities performed regarding the data collected from users (the “Users”) of the website revealingtheleaderwithin.com (the „Website”) are performed by the company The Training Boutique SRL, with headquarters in Ostratu Village, Corbeanca Commune, 30D Hipodromului Street, Ilfov County, Romania, registered with the Trade Registry under no. J23/1727/2006, unique identification number 14823562 (the“Operator”) duly represented by Oliver Perkins.

This Confidentiality, marketing and commercial communications policy should be interpreted alongside the more general Notice regarding website personal data processing [link to the Notice regarding website personal data processing].

Confidentiality
The Operator has the obligation of maintaining the confidentiality of any information related to the orders and to the Users.

The Operator can disclose such information to its affiliated entities, subcontractors and partners with whom it collaborates with the purpose of performing its commercial or marketing activity, within the applicable legal limits and in equivalent confidentiality conditions.

Commercial communications
By ticking the „I agree to be contacted for various offers or updates from revealingtheleaderwithin.com” box or any similar description, the User expressly accepts the possibility of receiving by e-mail or any other similar communication means offered, a newsletter and other commercial communications.

The User can modify at any time their option regarding the consent granted to the Operator for commercial communications containing general and thematic information, including information with regard to offers or promotions, by accessing the unsubscribe link displayed in the commercial communications received from the Operator or by contacting the Operator directly with an express request on the matter.

Transfer to third countries
Some data on direct marketing campaigns may be transferred to third-country processors offering an equivalent level of protection or to the United States of America (only EU-US Privacy Shield companies).

One of those third party empowered could be the MailChimp email marketing service, which also carries out processing activities in the US. The User or the Customer expressly accepts the possibility of transferring email marketing data to the US and the MailChimp Privacy Policy, available on the date hereof, at https://mailchimp.com/legal/privacy/#contacts

Marketing
In order to improve the offer of goods and services and the User experience, the Operator can use the data belonging to Users in order to perform market research and analysis on the effectiveness of commercial communications. The information obtained from these activities shall not be used for advertising purposes.

Modifications of the document
The present confidentiality, marketing and commercial communications policy is updated periodically; every time the Seller makes a modification, this policy will be updated on the Website.

Date of the last update: November 2018

 

Privacy Policy

GDPR Privacy Policy for Brainovate and Personal Strengths Romania

  1. Who are WE?
  2. Who You are!
  3. How We collect Your personal Information?
  4. How We use Your personal information?
  5. How We secure Your personal information?
  6. How long do We keep Your personal information?
  7. With whom do We share Your personal information?
  8. What are Your rights over Your personal information?
  9. Who do you contact if You feel Your personal information has not been handled correctly?
  10. What if, You have further questions and queries?
  1. Who are WE?

 Under the legal entity, The Training Boutique S.R.L , we have reunited 2 brands: Brainovate (www.brainovate.com) and Personal Strengths (www.personalstrenghts.ro). Both provide solutions that don’t come “off-the-shelf”, as we work with you to find and tailor the right programme for your organization.

 As the official distributor for Personal Strengths in Romania and Moldova for the complete suite of motivational and strengths-based assessments, we also provide the global SDI (Strength Deployment Inventory) qualification and access to the SDI assessments. You can see Personal Strengths’ Romania privacy policy on our website www.personalstrengths.ro .

 In broad strokes, as creative leadership consultants, WE at Brainovate offer organizational, team and leadership development, training and coaching. Our main focus areas are:

  • Leadership
  • Coaching and mentoring
  • Leadership Wellness and personal development
  • Team Building
  • Team and motivational profiling
  • Organizational culture

 Since We like to stay up to date, we are also active on social media, and you  can read up on our news and interests both on LinkedIn and Facebook. (LinkedIn Brainovate page, LinkedIn Personal Strengths Romania page, Brainovate Facebook page; Personal Strengths Romania Facebook page).

  1. Who You are! 

In the past 16 years, You have probably been one of our clients or participantsYou have been recommended to us as someone with both an interest and a decision power over people development issues. WE have probably spoken or met to discuss personal development, leadership trainings or WE have crossed paths at different job fairs or diverse training conferences and networking events.

You have made decisions that have engaged your teams and brought forward new breath within your organization.

If this is not the case, You have definitely received, along the years, our tailored email communications in the form of our Open Workshop announcements or tailored meeting invitation emails. For us, You are a decision maker, for both your own personal development, as well as your team’s and organization’s development.

  1. How We collect Your Personal Information?

First of all, we would like to define, what is Your Personal Information. We collect Your: full name, contact details (email and contact number), company name and position held.

We search all available public online records (Social Media Profiles: Facebook, LinkedIn, etc., Google Search, etc.) and collect this information into our HubSpot CRM Cloud AccountWehave been informed about their own GDPR compliance and You can read up on it here.

We also collect and store all physical and electronic transactional records pertinent to service purchases (Purchase Orders, Contracts, Receipts, Course Attendance Sheets, etc.).

  1. How We use Your personal information?

 We use Your Personal Information to send legitimate business interest emails pertinent to the universe of Personal and Organizational Development. (i.e. – Training Announcements, Meeting Invitations, Course Curriculums, Class Enrollment Lists, Team and Company Updates, etc.).

Your Personal Information may be used, depending on Your specific training offer, in conjunction with other online tools (Personal Strengths Internationally, Internal Wellness Program and Audit, etc.) You can read about the global privacy policy for Personal Strengths here.

We do not take SPAM lightly, and We consider Your time as well as ours valuable.

  1. How We secure Your Personal Information?

We are geared towards personal development and as such We are not interested in making a profit from Your Personal InformationWe do not sell, nor do We purchase mailing lists from 3rd parties. This is one of our promises!

Since all Your Personal Information resides within our HubSpot Cloud Account, this is not stored or saved on any other devices. When we require an overview, we will make sure the data downloaded is deleted.

 We would also like to promise, that We will ensure our full compliance with the legislation, should this change in the future and require further security steps.

  1. How long do We keep Your Personal Information?

After the 25th of May 2018, this will be totally up to you! Since Your Personal Information has been collected from previously attended workshops, team development or coaching programmes under our brands legal umbrella, be them individual or company wide, or from all available public records, meetings we’ve had, recommendations or events we’ve attended together, direct requests from or on your behalf, this data has been stored and used from our personal fully licensed hardware and software (i.e. – desktops, laptops, mailing and security software, etc.).

No data will be kept longer than necessary for the legitimate business interests. We consider reasonable to approach our clients many years after they have attended our programmes.

Should You not, please let us know by emailing us at letstalk@brainovate.com.

  1. With whom do We share Your personal information?

As promised above, We do not share Your Personal Information with any 3rd party.

We analyze this data internally and organize it, in order to be able to subtract information pertinent to our own organizational development (i.e. – improved facilitation, tailored developmental programmes, etc.).

This organized information may be used between the two brands as demonstration of our experience and expertise. (i.e. – anonymized company case studies).

  1. What are Your rights over Your personal information?  
  • Your identity is protected at all timesIf You have authorized a 3rd party to submit any type of requests on Your behalf, we will ask them to provide Your consent. 
  • You have the right to request all details that are pertinent to Your Personal Information. These will be provided in an email once you’ve sent us your request at letstalk@brainovate.com .
  • You have the right to ask for the correction of Your Personal Information, if incorrect, out of date or incomplete.
  • You have the right to unsubscribe from our email communications. We will stop any further emails from being sent out.
  • You have the right to the deletion of Your Personal Information from our records by letting us know through an email sent to letstalk@brainovate.com requesting us to delete your personal records.
  1. Who do you contact if You feel Your personal information has not been handled correctly?

If You feel that Your Personal Information has not been handled correctly or You are unhappy with our response to any requests You have made to us, regarding the use of Your Personal Information, You have the right to lodge a complaint with the National Authority in Data Protection and Use (http://www.dataprotection.ro/?page=Modele_de_plangere).

  1. What if, You have further questions and queries?

 We hope this Privacy Policy has been helpful in setting out the way We handle Your Personal Information and Your rights to control it.

 If you have further questions and queries, that have not been covered, please just get in touch:

  • Email as us at letstalk@brainovate.com;
  • Tel: +40 722 311 878;
  • Write to us at: Str. Hipodromului 30D, Ostratu, Ilfov, Romania;