PERSONAL DATA PROTECTION AND PROCESSING POLICY

- PRIVACY POLICY -

 

1. General information

This document governs the terms and conditions for the use of the Primul Milion site (hereinafter referred to as the "Terms and Conditions") and sets out the conditions under which anyone may access and use the content of the site, as well as the conditions applicable to legal relationships arising. between Primul Milion and the User, by placing an Order by the User in order to purchase the products provided by Primul Million.

The terms and conditions below are applicable between the parties and have the value of an agreement between the User and the company Primul Milion S.R.L. or other associated or collaborating companies (hereinafter referred to as the "Primul Million"), the Primul Million being the owner of the Site.

 

Any user of the Site has the obligation, before visiting or using the pages of the Site, to read and carefully study the Terms and Conditions, as well as the Privacy and Privacy Policy (hereinafter referred to as the "Privacy Policy"). confidentiality).

 

If the visitor or user does not agree and does not accept these Terms and Conditions, he / she is asked to leave the Site, to stop using it and not to place an Order. Continuing to browse the Site and placing an Order implies your express, full and unconditional acceptance of these Terms and Conditions and the Privacy Policy, as well as your agreement to their content.

 

Primul Milion assumes and reserves the right to make any changes to the terms and conditions and the Privacy Policy in its sole discretion, as well as to delete or add any information, to suspend or discontinue the use of the Site or any parties, at any time and without prior notice, and the Site Visitor or User agrees and accepts this provision.

Primul Million may publish information about various promotions or discounts during certain periods of time, by him or by any other third party with whom he has entered into partnership agreements or is in a collaborative relationship. Products that are the subject of any promotion or campaign of any kind are subject to the terms and conditions set forth in that promotion and are supplemented by these Terms and Conditions. Any promotions presented are valid only for the duration and within the mentioned limit.

2. Who are we

We are the Primul Milion S.R.L., a Romanian legal entity, with its registered office in Bucharest, Splaiul Independenței no. 332B, sc. 1, et. 8, ap. 79, Sector 6, registered at the Trade Register under no. J40 / 10923/2021, with CUI RO 44488460, e-mail: [email protected]. The notion of Primul Milion may also include other associated or collaborating legal entities.

3. Definitions

Under these Terms and Conditions, unless expressly provided otherwise, the following terms will have the following meanings:

Consent	represents any manifestation of the free will, specific, informed and unambiguous will of the data subject, by which he accepts, by an unequivocal statement or action, that the personal data concerning him be processed
Personal data	represents any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifying element, such as a name, an identification number, location data, an online identifier, or one or more several specific elements, specific to his physical, physiological, genetic, mental, economic, cultural or social identity
Operator	represents the natural or legal person, public authority, agency or other body which, alone or jointly with others, sets out the purposes and means of the processing of personal data
Target person	represents any identified or identifiable natural person whose data is processed by Primul Milion as an operator, such as subscribers, potential customers or visitors to the site
Privacy Policy / Policy	represents the information note that contains the provisions described in this document and is completed with the Terms and Conditions of the site, as well as with the Cookies Policy and can also be identified as the Data Protection Policy
Cookies policy	represents the provision of information about the cookies that our site collects, as well as the communication of the purposes for which they are used and completes this Policy, as well as the Terms and Conditions of the site.
Processing	represents any operation or set of operations performed on personal data or personal data sets, with or without the use of automated means, such as collecting, recording, organizing, structuring, storing, adapting or modifying, extracting, consulting , use, disclosure by transmission, dissemination or otherwise made available, alignment or combination, restriction, deletion or destruction
Primul Milion / us / ours	represents Primul Milion S.R.L. or associated or collaborating companies - Romanian legal entities, established and operating in accordance with the laws of Romania, which provide the Products found on the website and which own the site
GDPR / GDPR Regulation	is Regulation (EU) 2016/679 adopted by the European Parliament and the Council of the European Union on 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95 / 46 / EC, also known as the General Data Protection Regulation
Our site / site	represents the website www.primulmilion.com, any section and subsection of it, as well as the profiles / media pages associated with Primul Milion, including, but not limited to, Instagram, Facebook, Youtube
Terms and conditions	represents the provision of information regarding the use of our site, the relationship with the Primul Milion, the collaboration and agreements concluded between you and the Primul Milion as a result of accessing the site and obtaining products provided, as well as the conditions applicable to legal relations arising between the parties, including by subsequent agreements
Guest	represents any person who visits, views or accesses the site

3. The personal data operator

The personal data operator is Primul Milion S.R.L., a Romanian legal entity, headquartered in Bucharest, Splaiul Independenței no. 332B, sc. 1, et. 8, ap. 79, Sector 6, registered at the Trade Register attached to the Bucharest Tribunal under no. J40 / 10923/2021, with CUI 44488460, e-mail: [email protected]. The notion of Primul Milion may also include other associated or collaborating legal entities.

As a personal data controller, Primul Milion is responsible for the processing of personal data that belongs to you and that it collects directly or from other sources. Please note that in order to ensure the protection and secure processing of your data, Primul Million has made every effort to implement reasonable and appropriate, technical and organizational measures.

4. Data Protection Officer (DPO)

Primul Million has no legal obligation to appoint a personal data protection officer. Accordingly, any request regarding your personal data should be directed to the contact details mentioned above.

If you have any questions, concerns, comments or complaints regarding this Policy or the use of the personal data we process or you wish to exercise any of your rights, you may send us your request at any time. -mail [email protected].

5. What is your personal data that we process?

Depending on the products and features you wish to access or purchase, you will need to collect, use, store and / or transfer certain personal data.

Your personal data that will be processed are the following:

• identification data, such as name and surname, username, date of birth, gender, country, etc .;
• contact details, such as home address, billing address, e-mail address, telephone number;
• financial and trading data, such as information on payments or card or bank account, information on purchased products, details on payments to and from the data subject;
• technical data such as IP address (internet protocol), login data, browser type and version, location and time zone settings, browser plug-ins and their versions, operating system, operating platform and other technologies on the devices which you use to access this site and your user account;
• profile data, such as username, password, placed orders, recorded course regarding the purchased video course, answers offered to various questions or surveys;
• statistical and marketing data, such as information regarding the use of the site and the product provided, preferences regarding the reception of marketing materials and preferred means of communication;
• aggregated data, such as the collection, use and sharing of certain statistical or demographic data. Aggregated data may be derived from personal data, but is not considered "personal data" within the meaning of the law, as this information does not directly or indirectly reveal your identity. Unless aggregated data is combined or linked to personal data so that it is possible to identify it directly or indirectly, the resulting combined data will be treated by Primul Milion as personal data, which will be used as described in this Policy.

If you do not wish to provide us with information about your personal data, please note that there is a possibility that you may not be able to access certain features, may not purchase the products provided, may not subscribe, may not create and / or access user account, we may not be able to conclude any necessary contracts or collaborations later, or we may not be able to respond to your requests.

Primul Milion can hold the personal data of data subjects both as a result of direct interaction and by obtaining them indirectly or through technology.

For example, Primul Milion will receive personal information about you in the following situations:

• placing an order;
• creating a user account;
• subscribe to the newsletter;
• sending an e-mail or a private message on social networks;
• addressing a comment on social platforms, tagging us in posts or distributing our content.

 

6. Principles of data processing

Primul Milion undertakes to comply with the principles of personal data protection set out in the GDPR, in order to ensure that all data are:

•  processed correctly, legally and transparently;
•  collected for specified, explicit and legitimate purposes;
• adequate, relevant and limited in relation to the purposes for which they are processed;
•  correct and up to date;
•  kept in a form which does not allow the identification of the data subjects for longer than is necessary in relation to the purpose of the processing;
•  processed in accordance with the rights of the data subject, in a way that ensures adequate security of processing, so that the data is complete, confidential and available.

 

7. Legal basis and purposes of the processing of personal data

In accordance with 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 be able to offer you our products or to conclude any subsequent collaboration agreements, we need to process personal data that belongs to you, such as name, surname, e-mail address, home or residence address, personal numeric code , series and ID card number.

In accordance with art. 6 para. (1) lit. c) of the GDPR, personal data may be processed for the purpose of fulfilling certain legal obligations, including those of a fiscal nature. In order to fulfill certain obligations imposed by the tax authorities in connection with invoicing, reimbursement of certain amounts, payment of fees for affiliate marketing or reporting certain information to the authorities, Primul Milion may request and process a number of personal data, such as name, surname, home or residence address, personal number code, serial number and ID card.

In accordance with art. 6 para. (1) lit. a) of the GDPR, personal data may be processed if the data subject has given his or her consent to the processing of his or her personal data for one or more specific purposes.

Primul Milion is based on consent only for direct marketing purposes, in which case it is expressly requested. As such, in certain cases, personal data will be used for the purpose of a) potential transmission of newsletters or other marketing, information or commercial messages; b) possible participation in various contests or promotions.

In accordance with art. 6 para. (1) lit. f) of the GDPR, personal data may be processed for the purpose of the legitimate interests pursued by the operator or by a third party for the purpose of carrying out the object of activity. Such a situation will also take into account the analysis of your interest, as well as the fact that fundamental rights and freedoms are not affected. The legitimate interest can be represented by Primul Milion ensuring the correct functionality of the site, as well as a permanent improvement of the experience of the site visitors.

Processing the "Store" product purchase form and free eBook access form

Primul Milion will use the information you provide in the appropriate section to place an order to purchase a product or in the appropriate section to obtain the free eBook on the site for the sole purpose of processing your request.

By providing any personal data through www.primulmilion.com, you understand and agree that your data will be processed in accordance with the provisions of this Primul Milion Data Protection Policy.

Primul Milion undertakes not to process personal data provided for any purpose other than that for which they were transmitted, unless it will reasonably be necessary to use them for another purpose compatible with that of the processing. or if there is your express consent to use them for other purposes.

Processing for billing purposes

Primul Milion will use the information you provide in the ordering section to purchase and pay for the desired product or by sending a subsequent message or email informing the paying company that personal data provided is used solely to process your request. and to send you the invoice for the purchased product.

Payment processor

To make payments on our site, Primul Milion uses external payment processing providers. In connection with the processing of payments in this context, we do not process or retain personal data or information such as credit / debit card data with which the payment is made. This information will be provided directly by you to the Stripe Payment Processor or through your Paypal account, and your use of this data is governed by the data protection policies of the providers, which can be found here and here.

Processing for the purpose of registration as a User

In order to access the Product representing the video course, it is necessary for the User to create an account. In this case, Primul Milion will use the information you provide in the appropriate account creation and login section, such as contact details and credentials, in order to register as a User and allow you to access your account later.

As a User, you have the opportunity to request the deletion of the account and personal data processed by sending a request to Primul Milion, through the agreed and presented means of communication.

Processing for the purpose of sending the Newsletter

If you have given your consent to subscribe to Primul Milion newsletter, please specify that your personal data will be collected, processed and used in order to send you various information in our field of activity, information on possible campaigns. and / or marketing messages.

Please note that Primul Milion reserves the right to select subscribers to whom it will send newsletters, as well as the right to remove from the database any member who has previously given their consent. The exercise of these rights may be carried out without any further commitment from Primul Milion and without any prior notice to that effect.

Processing in order to respond to requests

In the event that you contact us by sending a request, notification, question or message of any kind, Primul Milion will collect and process the personal data you have provided and may request the provision of additional personal data in order to respond. to the request addressed and to resolve any situation or problem exposed.

By contacting Primul Milion in any of the ways provided, through mediated or direct communication, including through the use of social platforms, you understand and agree that your personal data may be processed in accordance with the provisions of this Privacy Policy.

Processing for the purpose of resolving legal claims

Primul Milion may collect, process and transmit information about your personal data to regulators, law enforcement or other entities in the following situations:

• in response to a request of a legal nature, if it can be considered, in good faith, that the law requires it;
• when it can be considered, in good faith, that it is necessary to detect, prevent and respond to fraudulent acts, unauthorized or improper use of any material belonging to us, in case of possible breaches of terms and conditions or policies or in the event of other harmful or illegal activities, in order to protect us (including our rights, property or materials), you and / or others, including in investigations or investigations initiated by regulators.

The personal data we receive from or about you may be accessed, processed and stored for a longer period of time, in the event that it is the subject of a legal request or a legal obligation, a government investigation or other types of investigations into possible breaches of our terms and conditions or policies or in other cases to prevent possible harm.

8. Disclosure of personal data to third parties

Personal data processed through Primul Milion site may be disclosed and / or transferred to third parties only if there is your express consent to do so, unless there is a legal / contractual obligation to do so. Primul Milion to do so.

For example, Primul Milion may provide personal data to various organs of the judiciary, such as prosecutors, police, courts or other competent state bodies, on the basis and within the limits of legal provisions and as a result of an express request.

Please note that in order to be able to process your requests in the ordering and purchasing section of a product or in the free eBook access section of the site, you may, in certain circumstances, we are required to disclose your personal information to Primul Milion partners and / or other Primul Milion third party service providers.

For example, Primul Milion could pass on personal data collected to various partners, such as IT (cloud, hosting) or telecommunications service providers, advertisers, accounting and human resources services, providers of integrated solutions or legal services.

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

Primul Milion ensures, within reasonable limits, that personal data collected will not be transmitted outside the European Economic Area. However, in the event that there is a transfer of data to EEA third countries, Primul Milion will ensure that the transfers are legitimate and will be based on the express consent of the data subject or other legally accepted basis.

Information controlled by Primul Milion may be transferred, transmitted or stored and processed in the EEA or in countries other than the country where you live, for the purposes described in this Policy. In such cases, we note that we use standard contractual terms approved by the European Commission and rely on the European Union's appropriateness decisions regarding certain countries, as appropriate, regarding transfers of data from the EEA to the United States and other countries. countries.

9. Data processing by third parties, other sites and sponsors

The site www.primulmilion.com may at some point contain links to other sites whose data processing policies may differ from those of Primul Milion.

Please consider and consult the privacy policies of the other sites, Primul Milion not assuming responsibility for the information sent or collected by these third parties.

Also, in situations where you interact with Primul Milion via social media, please keep in mind that other third parties may also have access to the personal data provided, such as Facebook or Instagram.

10. Automatic data processing. Cookies

The site www.primulmilion.com uses cookies.

Aspects regarding the use of Cookie identifiers are governed by the Cookie Policy, which is an integral part of and complements this Policy and the Site Terms and Conditions. Please read carefully the entire content of the Cookies Policy, here (https://www.primulmilion.com/milliongame/cookies).

As a data subject, you have the option to exercise your right to disable Cookies, as set out in the Rights section of this cookie.

11. Data storage

• Primul Milion may retain the data processed for various periods of time, necessary for the purposes stated or deemed reasonable, in accordance with the purposes indicated above.
• Other Primul Milion legal obligations, lawsuits and / or inquiries may also require the retention of certain personal data that you have provided to us.
• In general, we keep your personal data only for the time necessary to fulfill the purpose for which you provided it to us, to meet your needs, to respond to requests or to fulfill our legal obligations.
• At this time, we refer to the following criteria for determining the duration of data storage:
• If you have provided us with information to obtain the products provided by Primul Milion, by placing an order, we will collect and process personal data for the purpose of fulfilling the order, as well as fulfilling contractual and / or legal obligations. Such personal data stored in our databases will be deleted from the records within a maximum of 5 (five) years from the date of the last order, except for the necessary personal data from a financial-accounting perspective, which will be processed and stored for the set period. by law.
• If you have provided us with information to create and access your User Account in order to access the purchased product in the form of a video course, we will collect and process personal data in order to recognize and allow access to your account. Given the permanent possibility of accessing the account and watching the video course, granted for an unlimited period, such personal data will be processed and stored in our databases until you decide that you no longer want to hold the account and you will send us a request to delete personal data.
• If you have provided us with information for the conclusion of any contracts or subsequent collaboration agreements, we will collect and process personal data for the purpose of concluding and executing the contract, as well as fulfilling the contractual and / or legal obligations. Such personal data will be processed and stored for the period necessary to fulfill the object of the contract and to fulfill any legal obligations arising from it. For example, in the case of financial-accounting supporting documents, the storage period provided by law is 10 (ten) years from the date of the end of the financial year in which they were drawn up.
• If you have expressed your option to subscribe to Primul Milion newsletter, we will collect and process personal data in order to send you various information in our area of ​​activity, information on possible campaigns and / or messages. marketing. Such data will be processed and stored until you decide to unsubscribe, using one of the options provided for this purpose.
• If you contact us with any questions or requests, we will collect and process personal data in order to respond to your request. Such personal data will be processed and stored for the period necessary to process the request and resolve it, but not more than 5 (five) years from the last correspondence sent.
• In the case of the cookies used, they are stored on your computer for as long as necessary to achieve the purposes for which they are served (eg cookies for the account login) and for a period defined in accordance with the usual rules and guidelines. To find out more about the use of cookies, please read the Cookie Policy on our website.

 

12. The rights of data subjects

The data subjects have the following rights, in accordance with the GDPR, with respect to the personal data that Primul Milion processes:

• The right to access the processed data: you have the right to access the personal data we hold. The first provision of information will be made without charging any fee. If you still need copies of the information already provided, we may charge a reasonable fee, taking into account the administrative costs of providing the information. Clearly unfounded, excessive or repeated requests may not be answered.
• Right to rectify data: You have the right to request that your data be rectified if it is inaccurate or outdated and / or to complete it if it is incomplete.
• Right to have your data erased ("right to be forgotten"): In certain circumstances, you have the right to have your data erased or destroyed. This is not an absolute right, as we may sometimes have to withhold your data for legal or legal reasons.
• 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 store the data but not use or process it. This right applies in specific circumstances provided for in the General Data Protection Regulation, namely:
• the accuracy of the data is contested by the data subject (you), for a period that allows the operator (Primul Milion) to verify their correctness;
• the processing is illegal and the data subject (you) object to the deletion of the data and requests the restriction of their use;
• the operator (Primul Milion) no longer needs data for processing, but these are requested by the data subject (you) to establish, exercise or defend legal claims;
• the data subject (you) raised objections to the lawsuit based on legitimate reasons by the operator (Primul Milion), based on the verification that the legitimate reasons of the operator (Primul Milion) exceed those of the data subject (you).
• Right to data portability: You have the right to move, copy or transfer the data you are interested in from one database to another. This only applies to the data you have provided, when the processing is based on your consent or on the basis of a contract and is implemented by automatic, easily accessible means.
• Right of opposition: You may object to the processing of your data at any time when such processing is based on a legitimate interest.
• Right to withdraw consent at any time: You may withdraw your consent to the processing of your data when such processing is based on consent. Withdrawal of consent does not affect the lawfulness of processing on the basis of consent prior to its withdrawal.
• Right to lodge a complaint with the competent 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 offered by Primul Milion. In Romania, this body is represented by the National Authority for the Supervision of Personal Data Processing (ANSPDCP), which is based in Bucharest, bd. G-ral. Gheorghe Magheru no. 28-30, Sector 1, postal code 010336 and has the following contact details: telephone +40.318.059.211 or +40.318.059.212, e-mail address [email protected].
• The right to oppose the processing of your data by us when we carry out actions in the public interest or in the legitimate interests of ourselves or a third party: you may at any time oppose the processing of your data when such processing is based on a legitimate interest .
• The right to object to the processing of your data for direct marketing purposes (the right to unsubscribe): you have the possibility, permanently and completely, to unsubscribe from our newsletter or to ask us not to send you any marketing messages, either by accessing the unsubscribe link included in the emails, or by sending an email to Primul Milion requesting deletion from the database.
• The right to deactivate cookies: you have the possibility, in part or in full, to deactivate cookies. Settings in Internet browsers are usually set by default to accept cookies, but you can easily change them by accessing and changing your browser settings. For more details, visit the Cookies Policy.

You may exercise any of these rights with respect to the personal data that Primul Milion processes by making a simple request to Primul Milion to the contact details provided. In such a situation, it is very possible to ask for proof of your identity.

Please note that the rights listed above are not absolute. In some cases there may be exceptions, so each request received will be considered to determine whether it is well-founded or not. If the request is well-founded, it will be resolved as requested. If the request is unfounded, we will reject it and, if necessary, we will send you the reasons for the refusal, as well as the rights you still enjoy.

Primul Milion will make every effort to respond to requests within a maximum of 30 (thirty) days. However, in certain situations and taking into account different circumstances, this time limit may be extended, depending on the complexity of the application, the large number of applications received, the inability to identify the applicant in a timely manner or the waiting for responses from other bodies.

In the case of unsubscribing from marketing messages, please note that this unsubscription does not apply to personal data that you have provided to us for any other purpose, such as when you requested a product from Primul Million.

13. Processing security

Primul Milion has adopted technical and organizational data processing measures, updated in accordance with GDPR requirements, in order to protect your personal data against any unauthorized access, misuse or disclosure, unauthorized modification, destruction or accidental loss. All Primul Milion employees and collaborators, as well as any third parties acting on behalf of and on behalf of Primul Milion, are bound by the confidentiality of your information in accordance with the provisions of this Data Protection Policy.

In order to ensure the protection afforded to the personal data we process, Primul Milion has implemented measures such as the adoption of dedicated data processing policies and the protection of systems against unauthorized access, has proceeded to minimize and limit data on processors have restricted access to the data processed, used data security technologies and trained staff and collaborators on applicable law.

However, we point out that unwanted events may also occur which could lead to various security incidents or breaches. In such cases, we will follow the procedure for reporting and notifying security incidents and take all necessary steps to reduce the effects of the incident and to restore the situation to its normal state.

14. Exemption from liability

Primul Milion site may contain links to other sites and / or other non-Primul Milion websites. Primul Milion assumes no responsibility for the content of these sites and therefore cannot be held responsible for the content, advertising, goods, services, software, information or other materials available on or through these sites. -hate. Primul Milion will not be liable for any loss of personal data, for any adverse effects on visitors' personal data or for other non-material and / or material damage caused by access to those sites.

As such, Primul Milion encourages and advises you to read and review the existing Privacy Policies on any site and / or application that you access before providing any personal data.

15. Updating the Personal Data Protection and Processing Policy

Please note that this Policy may be subject to periodic changes to its content by updating Primul Milion website. Therefore, you need to check this page for any updates.

Please do not continue to use Primul Milion website if you do not agree with such changes.

The terms of this Policy shall be construed in accordance with applicable law.