Privacy Policy
This Privacy Policy describes how Yayafu Nawobo ("we", "us", "our"), operating the website at yayafu-nawobo.info, collects, uses, stores, and protects personal data in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, "GDPR"), Law No. 190/2018 on measures for the implementation of GDPR in Romania, and all other applicable Romanian and European Union data protection legislation.
1. Data Controller Identity
The data controller responsible for personal data collected through this website is:
Yayafu Nawobo
Calea Floreasca Nr. 146, Sc.B, Et.3, Ap.24
Bucharest, Romania
Email: [email protected]
Phone: +40 312 285 574
2. Categories of Personal Data Collected
We collect personal data in the following categories, depending on how you interact with our website:
| Data Category | Specific Data Types | Collection Method | Legal Basis |
|---|---|---|---|
| Contact Information | Full name, email address, telephone number | Contact form submission | Consent (Art. 6(1)(a) GDPR) |
| Communication Content | Message content, subject matter, enquiry details | Contact form submission | Consent (Art. 6(1)(a) GDPR) |
| Newsletter Subscription | Email address | Newsletter subscription form | Consent (Art. 6(1)(a) GDPR) |
| Technical Data | IP address, browser type, device type, pages visited, session duration | Automatic collection via cookies and server logs | Legitimate interest (Art. 6(1)(f) GDPR) / Consent for analytics cookies |
| Cookie Preferences | Consent choices for cookie categories | Cookie consent widget | Legal obligation (Art. 6(1)(c) GDPR) |
3. Purposes of Processing
Personal data is processed for the following specific purposes:
| Purpose | Description | Legal Basis |
|---|---|---|
| Responding to enquiries | Processing and responding to messages submitted through the contact form regarding our educational programme | Consent; Pre-contractual measures (Art. 6(1)(b) GDPR) |
| Newsletter distribution | Sending informational updates and course-related content to subscribers who have explicitly opted in | Consent (Art. 6(1)(a) GDPR) |
| Website analytics | Understanding how visitors use the website to improve its structure and content, using anonymised or pseudonymised data | Legitimate interest / Consent |
| Security and fraud prevention | Protecting the website and its users from malicious activity and abuse | Legitimate interest (Art. 6(1)(f) GDPR) |
| Legal compliance | Fulfilling obligations under applicable Romanian and European Union law | Legal obligation (Art. 6(1)(c) GDPR) |
4. Data Retention Periods
We retain personal data only for as long as necessary for the purposes for which it was collected, subject to applicable legal requirements:
- Contact form data: up to 24 months from the date of last contact, unless a longer retention period is required by law or contract
- Newsletter subscription data: until the subscriber withdraws consent or requests erasure
- Technical and analytics data: typically 13 months, depending on the analytics tool used
- Cookie consent records: 12 months from the date consent was given or last updated
5. Data Recipients and Third-Party Sharing
We do not sell, rent, or trade personal data to third parties for their own marketing purposes. Data may be shared with the following categories of recipients where necessary for the purposes described in this policy:
- Email service providers and hosting infrastructure providers, acting as data processors under written data processing agreements
- Analytics service providers, where consent for analytics cookies has been given
- Competent public authorities or courts in Romania or the European Union, where required by law
Any third-party processors are required to implement appropriate technical and organisational measures to protect personal data and to process it only on our documented instructions.
6. International Data Transfers
Where personal data is transferred outside the European Economic Area ("EEA"), we ensure that such transfers take place only to countries or organisations that provide an adequate level of protection as determined by the European Commission, or subject to appropriate safeguards pursuant to Articles 46-49 of the GDPR, including standard contractual clauses approved by the European Commission.
7. Your Rights Under GDPR
As a data subject under the GDPR and Romanian law, you have the following rights in relation to your personal data:
- Right of access (Art. 15 GDPR): You may request a copy of the personal data we hold about you and information about how it is processed.
- Right to rectification (Art. 16 GDPR): You may request correction of inaccurate or incomplete personal data.
- Right to erasure (Art. 17 GDPR): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent.
- Right to restriction of processing (Art. 18 GDPR): You may request that we restrict processing of your data in certain circumstances.
- Right to data portability (Art. 20 GDPR): You may receive personal data you have provided to us in a structured, commonly used, machine-readable format.
- Right to object (Art. 21 GDPR): You may object to processing based on legitimate interests or for direct marketing purposes.
- Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
- Right not to be subject to automated decision-making: We do not engage in automated decision-making or profiling that produces legal or similarly significant effects.
To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days as required by the GDPR, with the possibility of extension by a further two months where requests are complex or numerous.
8. Right to Lodge a Complaint
You have the right to lodge a complaint with the competent supervisory authority. In Romania, the supervisory authority for data protection is:
Autoritatea Nationala de Supraveghere a Prelucrarii Datelor cu Caracter Personal (ANSPDCP)
B-dul Magheru 28-30, Sector 1, Bucharest, Romania
Website: www.dataprotection.ro
9. Security Measures
We implement appropriate technical and organisational security measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include encrypted data transmission via HTTPS, access controls, and regular review of our data handling practices. In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay in accordance with Article 34 of the GDPR.
10. Children's Data
This website is directed at adult professionals and is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe that a child has submitted personal data to us, please contact us so that we can take appropriate steps to delete it.
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The "Last Updated" date at the top of this page indicates when the policy was most recently revised. Continued use of the website following any update constitutes acceptance of the revised policy.
12. Contact for Privacy Matters
For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact us at:
Email: [email protected]
Postal address: Calea Floreasca Nr. 146, Sc.B, Et.3, Ap.24, Bucharest, Romania