
Privacy Policy
GENERAL PRIVACY POLICY
We take outmost care to process personal data in accordance with the principles of the data protection legislation, including, but not limited to the Regulation (E.U.) 2016/679 on the protection of natural persons, with regard to the processing of personal data and on the free movement of such data. (“GDPR”).
Your rights to privacy and protection of personal data are among our fundamental commitments at LinguaNova. This Policy aims to provide you with information about the personal data LinguaNova and its Affiliates collect from you and/or that you make available to us and how it will be processed by us in the context of interacting with you in any context specific to our business.
1. WHO IS THE CONTROLLER RESPONSIBLE FOR PROCESSING YOUR DATA?
LinguaNova is a software company with its main offices in Romania. The data controller responsible for the processing of your personal data is OWLCRAFT SRL., a Romanian company registered under Registrul Comertului with registration number J40/22716/2023 and Unique Identification Code 49196997, having its registred office at Spl. IndependenÅ£ei 202 B, Camera 42, BucureÅŸti, District 6, Romania, (hereinafter the "Provider" or “ “LiguaNova”)
As per their agreement, LinguaNova. will have access to the data collected via the Website as the administrator. Also, any data collected in the context of surveys/marketing campaigns/events via the Website shall have the same regime. Once the data is shared with the relevant LinguaNova entity, such shall be deemed as independent controller for that data.
LinguaNova cares about protecting the right to privacy of individuals and, while we may rely on local laws, we aim to uphold the Personal Data protection standards of the GDPR even for non-EU LinguaNova’s entities, as possible. If you disclose data to us or share data with us about other individuals, such as family members, co-workers, etc., we assume that you are authorized to do so, and that the relevant data is accurate. Please make sure that these individuals have been informed about this Policy.
2. CATEGORIES OF DATA SUBJECTS
This Policy refers to:
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business clients: legal entities or individuals operating within a profession (for example, authorized natural persons, liberal professions, individual enterprises, etc.), as well as any potential Business Client to whom we address our commercial offers or communications, respectively former clients.
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Clients Representatives: natural persons acting as legal or, as the case may be, conventional representatives, as well as contacts within potential, current or former Clients;
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users of the https://www.linguanova.live/ website (“the Website”);
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collaborators and / or business partners of LinguaNova and/or their staff involved in the performance of the contractual obligations assumed by LinguaNova; and
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persons attending events organized by or with the involvement of LinguaNova.
collectively referred to as "Data Subjects").
3. WHAT ARE THE CATEGORIES OF PERSONAL DATA WE PROCESS?
Your personal data is usually collected directly via our Website, by e-mail, through social media accounts, through our call center, through the platforms & applications used by us, through the contracts signed with us and through the post / courier. Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all the categories of data listed below:
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Identification data, for example: your name and surname, nationality, and signature, data regarding the capacity of representative / authorized representative of the Client, image, voice; Tax identification and similar unique identifiers – if you act as a Business Client; for example, the tax identification code;
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Contact Details, for example your e-mail address, your domicile or residence, your number; landline and/or mobile phone as well as your I.P. address; e-mail;
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Account data, for example the Client number, the invoices issued, the payments made and the payment history, the date of signing the contract, offers, returns, expressed permissions, benefits and advantages, etc.;
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Qualification data, for example, profession or occupation (for example, in cases where you are acting as a representative or contact person for a Business Client);
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Data collected by cookies and similar technologies. For details please visit the cookie policy of LinguaNova, at https://www.LinguaNova.net/cookies-policy/.
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Data related to your device (to access the Website): device type, I.P.;
Client Relationship Data, e.g. (i) notes or records of a phone call with customer service, or a live chat/e-mail correspondence, (ii) details of your complaints, questions, contract requests or feedback, (iii) requests for access to your personal data, personal and other requests to exercise your rights, according to the legislation on the protection of personal data, (iv) other records of your interactions with us, regardless of the medium (notes, records, etc.), including their average duration, (v) information regarding your level of satisfaction with our services and/or other services suppliers on the market, (vi) video recordings of your interaction with our agents, if the case;
4. WHERE DO WE GET YOUR DATA FROM?
We may obtain your personal data:
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directly from you, i.e. (i) when you directly provide us with the information, either in writing (e.g., by filling out a form) or verbally (e.g., as a result of your telephone conversation) or (ii) by examining the interaction we have with you. For example, we will obtain your personal data when: (i) you buy any of our services, (ii) you enter into a service contract with us, (iii) you subscribe to receive commercial communications or other offers and information from us or our partners, (iv) you contact us through various channels or request information / offers regarding a service; (v) you participate in promotions, contests, sweepstakes, promotional lotteries, or various studies and analyses organized or sponsored by Softellingece or in partnership with us, (vi) visit or browse our Website.
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from sources other than directly from you, namely: (i) from external sources, or (ii) Inferred data that we generate based on the data we hold about you.
The external sources from which we can obtain your personal data Include: Public sources, for example websites or social media pages, public databases (including the trade register database, the database of the Ministry of Finance, the Official Gazette for partners who are legal entities, etc.). Third private entities, namely: (i) our suppliers or contractors (including financial service providers – for example, the status of a payment), (ii) Business Clients – when you act as their representative or contact person; (iii) survey and market research agencies, e.g., your telephone and feedback on our services; (iv) our business partners, when you act as their representative/employer/collaborator. Public authorities or institutions, for example in the context of judicial investigations, requests of courts of trial, requests related to your complaints (in which case we may find out certain information about you). People who represent you or contact us on your behalf Inferred data that we generate based on the data we hold about you, such as: the level at which you benefit from the services – for example, failures in the context of delivery or other events that trigger service termination/suspension; details of your use of certain services;
5. WHAT ARE THE PURPOSES AND GROUNDS FOR WHICH WE PROCESS YOUR PERSONAL DATA?
5.1. We collect and use your Personal Data as a Business Client (acting within a proffession as individuals), including a Prospective Client for the following purposes:
A. Conclusion and management of Clients’ contracts
To facilitate the provision of services online (including the execution of the contract and the completion of the specific order, communication with the user of the Website and sending information messages about the stages of the contract, providing clarifications related to the order and, in general, information on the purchases made). For this purpose, we may collect the following data, within the limits of the needs: Identification data: name and surname, the company you represent, industry, you position; Contact details: phone number/e-mail address, delivery address, billing address, Financial data: payment data, Account data: services history, favorite services, Client relationship data and Services interaction data.
Legal grounds: conclusion and execution of the contract with you when we talk about processing operations that have a close connection with our contractual relationship and our legitimate interests: to prove the performance of our contractual obligations or the imputation of non-performance of the contract; to ensure the quality of our services and proper management of the relationship with Clients; to keep adequate records of the orders placed and/or the instructions specific to the related contractual relationships; proper communication with you to ensure the proper delivery of services and adequate information on our services; facilitating the placement of orders, their tracking and their modification/ cancellation; providing benefits for Clients loyalty.
How long do we keep your data (depending on the specific situation): the data closely related to the contract and the customer account will be kept for the entire duration of the contractual relationship, plus at least another 3 years after the termination; in the event of disputes/investigations/procedures, the data and documents will be kept for the duration of their development, and for a period of 3 years from the final settlement.
What happens if you do not provide us with the data from the standard forms / or requested by our colleagues: the data we ask you for is mandatory for the proper conclusion / modification and execution of the contract. The refusal to provide those data marked by us as mandatory may prevent the conclusion of the contract, affect its proper performance, lead to the cancellation or suspension of the services, as the case may be.
B. Billing and payment processing
Such includes: (i) processing the payments you make - payment to our bank accounts or reimbursements made by us; (ii) issuing invoices for the services purchased, collecting the correct amounts, or repaying the correct amounts on request; (iii) communicating with you to ensure the correct payment of the services/clarify the status of a payment;
We use the following categories of data: Identification data (such as your first and last name), position; Contact details (such as business address, e-mail address, telephone number); Account data (such as invoices, payment history, history of any other information related to the payment of the services, gift cards); Financial data, as well as any other information you request/provide to us or the person acting for you.
Legal grounds: our legitimate interests: to ensure the payment in good conditions of the services, validate payments with errors, facilitate the delivery of orders on time in case of erroneous payments, ensure the processing of payments in an efficient and easy way for Clients; the conclusion and execution of the contract with you; our legal obligations: to include certain information in invoices or to request certain information in case of reimbursement of amounts of money, to keep records of orders and related payments, to make available information and report to public authorities.
How long do we keep your data (depending on the specific situation): billing-relevant information (including contracts), payment records and documents relating to the settlement of payments, will be kept for 10 years from the time of the end of the financial year in which it was issued/concluded; correspondences with you related to the above purpose will be kept for the duration of the relationship with you (as long as you have an active account with us), for a maximum of 10 years after creation;
What happens if you do not provide us with the data from the billing order forms or requested by our colleagues: the requested data is mandatory for the proper processing of the payment and the issuance of invoices to you; without them we cannot issue you the invoices according to the law, respectively the payments cannot be processed properly and thus we will not be able to provide the services to you/the company you represent, your services being suspended/terminated, as the case may be.
C. Assistance and management of the relationship with Clients, respectively:
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informing about the amounts owed to us, the status of payments and / or consequences of non-compliance with the contracts you have concluded with us;
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managing any questions or requests, including complaints you or other persons may have regarding our services/contractual relationship with us, including to provide you with any information required by law;
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sending messages about services purchased or benefiting from free of charge (so-called 'functional messages').
We would like to keep you informed about various aspects related to the services you have bought, for example regarding the modification of our terms and conditions or the removal of some services from the Website, the termination of the contract, or other accessories for the services necessary for their operation.
We use the following data: Identification data (such as name, surname); Contact details (such as e-mail address, telephone number, home address, mailing address); Client relationship data (such as delaying services delivery, services defects, payment errors and any other issues raised by you); any other data provided by you by means of the requests and documents submitted in support thereof; any other data in the categories listed above related to the relationship with you necessary for the settlement of requests.
Legal grounds: conclusion and execution of contract for orders placed by you or for you, in relation to activities closely related to the contract; our legitimate interests to ensure the proper performance of the contract and a good relationship with you and to defend our rights and interests in judicial, administrative or similar proceedings, or to properly manage any request you submit to us and to improve our services; specific legal obligations in the field (e.g., the processing of certain data on a mandatory basis in the form dedicated to the complaint and for settlement, the obligation to send you the invoice for your order, etc.); your consent if you contact us by phone and the call is recorded.
How long do we keep your data (depending on the specific situation): during the resolution of your request and after the settlement for a duration of 3 years for the solved claims, respectively for the duration of any disputes / procedures and for a duration of 3 years after their final settlement, or, as the case may be, for other durations imposed according to our legal obligations.
What happens if you do not provide us with the data from the standard forms / or requested by our colleagues: the data we request from you is mandatory for the proper resolution of your requests. Your refusal to provide that data may prevent or affect the full resolution of your request. (e.g., refusal due to lack of sufficient information, delays, partial settlement, etc.), and implicitly the services, if they depend on the resolution of your request. If you choose to contact us through another communication channel operated by a third party (e.g. WhatsApp, Facebook) we will share your personal data with the owner of this channel to confirm that you are a user of this service. We recommend that you check your privacy settings and read the privacy policy of the respective operators to obtain more detailed information on how they use the personal data of users of the services they provide. If you do not agree to the recording of calls, you can contact us on the other communication channels.
D. Promoting our image and services. Improving the relationship with Clients
For the purpose of communicating commercial materials, newsletters and / or alerts from LinguaNova, consisting of information on service offers, invitations to participate in campaigns and lotteries, studies, questionnaires, opinion polls, vouchers and / or gift vouchers offered on birthdays sent by electronic mail (e-mail, SMS, M.M.S.), push notifications, social media platforms on which you have an account and / or phone call, for marketing purposes, respectively to promote LinguaNova services and to improve the experience offered on our Website.
What data we use: Identification data: name, surname; Contact details: e-mail address, telephone number, postal address; Data regarding your qualification; Client relationship data; Account details.
Legal grounds: regardless of the type of services we use:
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calls (human or automated), e-mails, online channels – based on your consent;
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mailing address to promote you our services and our activity (post / courier) – based on our legitimate interest in keeping you up to date about the services that may be of interest to you. If you no longer wish to receive such communications, please send us your opposition at the coordinates at the end of this Policy;
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your choice marketing and respectively the proof of acknowledgment of this privacy policy – based on our legitimate interest in keeping a record of compliance with our specific obligations in the matter and in defending our rights and interests, if any.
You can unsubscribe from these communications at any time by clicking the “unsubscribe” link or button in our messages or by writing to us at info@linguanova.live. If you withdraw your consent or do not provide us with contact details for this purpose from the start, you will no longer receive commercial communications from us by e-mail, telephone (including automated calls) or online channels.
How long we keep your data (depending on the specific situation): we keep your marketing option and respectively the proof of acknowledgment of this privacy policy during the period when it is not withdrawn, respectively for a period of 3 years from the withdrawal, and by way of exception, during any procedures / disputes / controls involving these data.
E. Economic, financial and administrative management.
We process your personal data to optimally organize and streamline our work. In this regard, we can use the data, among others: to improve and optimize the activity of LinguaNova as well as our services; to support our position in various investigations, administrative and judicial procedures, litigations, etc. in which LinguaNova is involved; in the context of various analyses, internal audit procedures and/ or investigations carried out by LinguaNova, on its own initiative or as a result of receiving a referral from a third entity (including public authorities); management of controls/investigations triggered by public authorities.
We use Account Data, Identification Data, Contact Details, depending on the typology of the investigation / purpose pursued; Financial Data, Client Relationship Data.
Legal grounds: our legitimate interest to improve our services and relationship with Clients, to optimize and streamline our activity, including by sharing data with our affiliates, but also to defend our interests and rights, to properly manage the payment process for the services provided, to adequately research the activity and identify potential irregularities, respectively to comply with the requirements of public controls; our legal obligations, such as to issue invoices in a certain format, to transmit them in a certain way, to keep records and supporting accounting documentation.
We can obtain the data from: the competent authorities (for example, the O.P.C.), when circulating with new notifications on complaints / referrals / other aspects; other persons, who may provide us with data according to your request, when acting as your proxies in relation to LinguaNova; our financial and banking service providers, for payments made directly by you to our bank accounts; other service providers, depending on the specifics of the investigation.
How long we keep your data (depending on the specific situation): during the investigations/procedures/audits, including the recovery procedures and after the settlement for a period of 3 years; during any disputes, if any, and 3 years after receipt of a final decision, for the duration imposed by the public authorities, within the limits of their competences.
What happens if you do not provide us with the data: the data we request from you is mandatory for the proper resolution of the investigated situations. The refusal to provide data in line with the legal provisions may affect our contractual relationship.
F. Defending the rights and interests of LinguaNova and our Clients
We use any of the data categories in the LinguaNova systems, appropriate to the type of procedure/investigation/litigation/official audit.
Legal grounds: our legitimate interests to defend our rights and interests in the context of situations in which LinguaNova's image and interests would be exposed or affected, respectively to keep evidence of our rights and interests as well as our compliance with specific legal obligations (for example, solving complaints within the time limit required by law or data protection, the manner of settlement, identification and proof of identification of clients/other individuals before making changes in orders/providing customer account data, etc.); our legal obligations, such as those to comply with the requests of public authorities / courts / other public institutions that have the power to impose certain processing operations on us; the obligation to archive certain documents/information according to the archiving rules or other regulations applicable to LinguaNova; the obligation to notify confidentiality/security incidents to the competent authorities, etc.
From where we may obtain the above data: from any of the sources mentioned in the above purposes, as well as from the authorities, institutions or courts involved.
How long we keep your data (depending on the specific situation): for the duration required by the specific legal provisions; where there are no rules, during the procedure/audit/investigation/dispute, and for a period of 3 years from the end of that procedure, taking into account the limitation period applicable to the specific situation; for the duration imposed by the competent authority/institution/court, according to the legal provisions; for the duration requested by you for the protection of your rights and interests or of a third person who has a legitimate interest in doing so.
What happens if you do not provide us with the data: In certain situations, refusing to provide us with data may result in your contractual or civil liability in relation to LinguaNova, other persons whose rights/interests would be affected.
G. Fulfillment of legal obligations
For the fulfillment of the legal obligations’ incumbent on LinguaNova in the context of the services provided through the Website, including the obligations in tax matters, as well as in archiving matters. (e.g., issuing tax invoices related to the services or granting the guarantee associated with such). Any of your personal data above may be processed.
Legal grounds: The processing of your data for this purpose is necessary based on legal obligations when the law expressly provides for the processing of certain data – e.g. providing the guarantee, the obligation to archive certain documents / information according to the archiving rules or other applicable regulations; the obligation to notify confidentiality / security incidents to the competent authorities, respectively our legitimate interest in complying with legal obligations involving certain processing, where the law does not establish exactly what data will be processed, such as those to comply with the requests of public authorities / courts / other public institutions that have the competence to impose certain processing operations on us; the obligation to notify confidentiality/security incidents to the competent authorities, etc.
What happens if you do not provide us with the data: In certain situations, refusing to provide us with data may result in your contractual or civil liability in the relationship with us, or may even lead to the termination / non-conclusion of the contract with you if we are talking about mandatory data for our relationship.
H. Mergers and Acquisitions
If we are involved in a corporate law transaction (for example, merger, spin-off or sale of the business), we will share or, as the case may be, receive your personal data from the entities involved. We transfer/receive your personal data and for the purpose of integrating databases with the clients of the companies involved in the transaction. For this purpose, we transfer certain Contact Details, Account Details or other data related to you to the companies involved in the transaction as a beneficiary for the integration of customer databases in the transfer in which you are already a client of the other entity involved in the transaction. In the transfer of a planned corporate transaction (e.g., in which our Group or we buy or sell a business), we may use (communicate to the party involved in the transaction) your personal data, personal information to identify and plan the best way to realize any commercial opportunities and possible improvements quickly and efficiently in services in the transfer of that corporate transaction. For example, we may communicate or obtain certain Client data, such as Contact Details, Account Details (e.g., the type of offers/benefits used). As a rule, this information will be transmitted/received in pseudonymized or anonymized form. In all cases, we will additionally communicate or process (as the case may be) personal data only based on an appropriate analysis and risk mitigation measures to ensure that they are not prevalent fundamental rights of the data subjects that could be affected.
Legal grounds: the legitimate interest of us and/or the third-party entity (party to the transaction) to identify, plan and implement the best way to realize any commercial opportunities and database integration when appropriate and possible service improvements, or your consent quickly and efficiently.
How long we will keep the data: the data extracted for this purpose will not be kept separately longer than during the acquisition process and for 3 years after its conclusion. If they are the subject of formal procedures, disputes, the retention periods specific to these purposes will apply.
5.2. We collect and use your Personal Data as a representative/employee of the Business Client (both legal entities and professionals), including a Prospective Client for all the above-mentioned purposes, as the case may be, strictly to allow the fulfillment of such purposes for the Client you act for/legally represent or for which you are the main contact. As a rule, the following data will be processed: Identification Data, Contact Data, Client Relationship Data (including your voice), Inferred data (e.g., the date and hour of the interaction with you).
Legal Grounds: our legitimate interests as described at the above-mentioned purposes and our specific legal obligations, as the case may be. For all the processing operations connected to the contract performance, the corelative legal ground will be instead of contract conclusion and performance our legitimate interest to conclude and ensure adequate performance of the contracts concluded with our clients. In case of recorded call, your consent shall be the legal ground applicable. All the other details described in the Business Clients section above shall apply accordingly.
5.3. If you are a Partner / potential partner of LinguaNova, we process your personal data as follows:
5.3.1. For our partners acting within a profession as individuals:
A. To initiate or carry out the contractual relationship between LinguaNova and Partners or potential Partners and / or through contractual partners expressly mandated to do so.
This purpose also includes any basic checks we carry out – e.g. the capacity of legal representative, public information on partners and their services.
We Use Your: Identification Data, Contact details, Data regarding your qualification, Partner Data – any data relevant to the contract, including minimum data for your assessment in order to conclude the services contract
Legal grounds: our legitimate interest in ensuring a good management of contractual relationships in the context of provision of our services, respectively the legitimate interest in performing a minimum analysis and verification of partners and choosing the most suitable partner or, as the case may be, conclusion and performance of the contract with you, for operations closely related to the contract.
Refusal to provide data for this purpose may result in LinguaNova being unable to sign the contract with you.
How long we keep the data: the data will be kept for the entire duration of the contractual relationship, as a rule, and for 3 years after termination of the contract. If there are open procedures, investigations, disputes, the duration will be extended during them, until the final settlement and for 3 years thereafter.
B. Financial and accounting management. Internal audit/internal/external investigations.
It includes: 1. payment of invoices, purpose which includes: (i) making payments by us for services / products provided / offered; (ii) communicating with you; to ensure correct payment of products/clarify the status of a payment; 2. keeping accounting and tax records, respectively carrying out mandatory internal and external reporting. 3. conducting any internal / external audits / investigations related to payments / invoices, services provided. 4. confirmation of amounts due and fulfilment of performance indicators, if applicable.
We use the following categories of data: Identification data (such as your first and last name); Contact details (such as home address, e-mail address, telephone number); Partner Data (such as invoices, payment history, services rendered, timesheets, performance indicators); Financial data, as well as any other information you provide to us or the person acting for you.
Legal grounds: our legitimate interests: to ensure the payment of invoices in good conditions, to verify their correctness and keep proof of payment, respectively to verify the fulfillment of contractual conditions for payment, to be able to investigate potential errors / incidents / unauthorized payments, to be able to ensure financial management in an optimal way, to organize internal audit; conclusion and performance of the contract with you; our legal obligations: to keep track of invoices received and related payments, to report certain accounting / tax aspects mandatorily, etc.
How much we keep your data (depending on the specific situation): records of payments and documents related to the settlement of payments will be kept for 10 years from the end of the financial year in which they were issued; correspondence with you related to the above purpose will be retained for the duration of the relationship with you (as long as you have an active account with us), for a maximum of 10 years from creation.
What happens if you do not provide us with the necessary clarifications regarding the invoices issued: in the absence of additional data requested, the invoice may be renegotiated or not paid. Without providing payment data in accordance with the contract, we cannot make the payment to you.
C. Partner relationship support and management: handling any questions or requests, including complaints you may have regarding the contract, invoice payment, and the processing of your data, including to provide you with any information required by law, on any communication channel, as well as to check the level of services provided / products offered.
We use the following data: Identification data (such as name, surname); Contact details (such as e-mail address, telephone number, home address, mailing address); Data regarding the relationship with Partners (such as complaint history, correspondence and records with you, agreed performance indicators, documents drawn up, services provided, deliverables including your data); any other data provided by you by means of requests and documents submitted in support thereof; any other data from the categories listed above under Clients related to the relationship with you necessary to resolve requests.
Legal grounds: our legitimate interests in ensuring a good relationship with you and to defend our rights and interests in judicial, administrative or similar proceedings, respectively to properly manage any request you submit to us and to improve our services as well as to verify and ensure the quality of the services / products you provide; specific legal obligations in the field (e.g., the processing of certain data mandatory in the form dedicated to the complaint and for resolution, the obligation to keep certain documents according to the law, etc.); your consent in case you contact us by phone and the call is recorded.
How much we keep your data (depending on the specific situation): for the duration of solving your request and after settlement for a duration of 3 years for settled claims, respectively for the duration of any disputes / procedures and for a duration of 3 years after their final settlement, or, as the case may be, for other periods imposed according to our legal obligations; during the contractual relationship in the case of quality checks, respectively for 3 years thereafter these durations, if there is no need of extension for reasons of formal proceedings, complaints, litigation.
What happens if you do not provide us with the data from the standard forms / or requested by our colleagues: the data we request from you is mandatory for the proper handling of your requests. Your refusal to provide that data may prevent or affect the complete resolution of your request (e.g., refusal due to lack of sufficient information, delays, partial settlement, etc.). Refusal to provide quality/performance information under the contract may result in termination/suspension of the contract with you.
If you choose to contact us through another communication channel operated by a third party (e.g. WhatsApp, Facebook) we will share your personal data with the owner of this channel to confirm that you are a user of this service. We recommend that you check the privacy settings and read the privacy policy of the respective operators to obtain more detailed information on how they use the personal data of users of the services they provide.
If you do not agree to call recording, you can contact us on our other communication channels.
D. Defending our rights and interests and complying with specific legal requirements/obligations
We may process your personal data in the context of official external audits / requests received from public authorities / third parties with legitimate interests, including complaints from Clients / employees, possible litigation or other official procedures, to defend our rights and interests. Also, your personal data may be processed to comply with specific legal standards (e.g., authentication data to secure access to our systems) or legal obligations – mandatory accounting/tax reporting that also includes your data or data included in archiving accounting documents).
The data used may be all data related to you, depending on the context, including Data Inferred by us.
Legal grounds: our legitimate interests to defend our rights and interests, to comply with official requests, the legitimate interests of third parties if justified and do not prejudice your interests, respectively our legitimate interest in complying with legal obligations/legal standards and our specific legal obligations.
6. HOW WE SHARE YOUR DATA
While as a rule we do not disclose your personal data to any third parties, we may disclose your personal data to third parties, if this is needed to perform our services, to observe a legal obligation or if it is in our legitimate interest to do so. In each case, the data strictly necessary for the provision of services or that we are obliged to provide will be disclosed after confirmation of the compliance of the data list by the privacy responsible.
Recipients common to all data subjects (Clients, Website Users, Partners, events Participants):
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audit firms;
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public and regulatory authorities, government bodies, courts – if necessary (including if required by law) or, as the case may be, a third entity or organization – if such disclosure is necessary to comply with any applicable legal provisions, or other legal or regulatory requirements (for example, if we receive such notification and/or address from central or local public authorities or in connection with a dispute in course pending before the Romanian courts, respectively for fulfilling our tax reporting obligations, disclosing data to ANSPDCP / ANPC in the context of a complaint);
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third-party consultants (e.g., external lawyers, auditors, experts), where we involve them in disputes or disputes relevant to us or other activities requiring their professional experience;
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software/hardware service providers and I.T. support;
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providers of equipment / network installation and maintenance services;
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server maintenance service providers – e.g. for storage, I.T. incident remediation; call center service providers – to respond to your questions, requests or complaints;
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archiving service providers;
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our affiliates
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Individuals who complain about certain situations, or incidents concerning you, if there is a justification for receiving access to data and granting access, would not affect your rights.
7. DURATION OF PROCESSING
We intend to keep your personal data for as long as necessary for the purposes detailed in this information notice in accordance with our legal obligations and internal policies.
If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes.
8. AUTOMATED DECISION MAKING
To the extent that the fulfillment of some of the above processing purposes will be achieved by using computer techniques that do not involve the presence of a human factor, which will lead to legal effects on you or which may similarly significantly affect you, the processing will be based on your express consent for this purpose or another legal basis, as required by law. In this regard, this document will be updated whenever necessary to ensure that you are properly informed. We do not use such processes at this time.
9. HOW WE PROTECT YOUR DATA
We take appropriate security measures to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful use, disclosure or access.
Technical and organizational security measures may include encryption and pseudonymization of data, logging, access restrictions, keeping backup copies, giving instructions to our employees, entering confidentiality agreements, and monitoring activities. We protect your data that is sent through our Website in transit by appropriate encryption. However, we can only secure areas in our control. We also require our data processors to take appropriate security measures.
10. YOUR RIGHTS CONCERNING PERSONAL DATA AND HOW TO EXERCISE THEM
You have the following rights in relation to our data processing, depending on the applicable data protection law:
Right of access: Allows you to obtain confirmation that your personal data are being processed by us and, if applicable, the relevant details of such processing activities as described in this Data Protection Notice (including a copy of the data).
Right to rectification: Allows you to rectify your personal data if inaccurate (not up to date or erroneous).
Right to erasure:The right to be forgotten means that you have the right to request that we delete your personal data without undue delay if one of the following reasons applies: (i) they are no longer necessary for the purposes for which they were collected or processed;
(ii) you withdraw your consent and there is no other legal basis for processing; (iii) you oppose the processing and there are no legitimate reasons to prevail; (iv) the personal data have been processed unlawfully; (v) personal data must be deleted for compliance with a legal obligation; (vi) personal data have been collected in connection with the provision of information society services.
In doing so, we will communicate to each recipient to whom personal data has been disclosed any deletion thereof, unless this proves impossible or involves disproportionate efforts and we will inform you about these recipients if you request it.
Important! We will not be able to act on such requests in all cases, such as where the law compels us to keep data for a certain period, or where the data are necessary for a legitimate interest such as the defence of a right before a court of law.
Right to object: aims at the right to object to the processing of personal data when processing is necessary for the performance of a task that serves a public interest or when it considers a legitimate interest of LinguaNova. When the processing of personal data is for direct marketing purposes, you have the right to object to the processing at any time.
Right to withdraw consent: You can withdraw your consent where such is the legal basis for which we process your data anytime, as the case may be: by clicking the “unsubscribe” link or button in our messages for newsletters or similar communications or by writing to us at privacy@LinguaNova.net . If you withdraw your consent, the processing of your data for the past based on such legal grounds will not be affected; only future data processing will usually stop as of the moment of your consent withdrawal but no later than 3 (three) days maximum. 
Right to restriction: Allows you to request us not to use your personal data in any way except to store it until another request from you is resolved, namely: (i) you have requested the rectification of the data.
(ii) you have opposed the erasure of the data in the case of unlawful processing.
(iii) you have required us to provide you with certain data for the defence of a right; (iv) you have objected to the data processing.
The rectification will be communicated to each recipient to whom the data were transmitted unless this proves impossible or involves disproportionate efforts and we will inform you about these recipients, if you request it.
Right to portability: Allows you to receive the personal data concerning you that you have provided to us, in a structured, commonly used, and machine-readable format or to transmit this data to another data controller.
Important! The law compels us to act on such requests only for the data previously processed based on your consent or on the performance of the contract concluded with us and only if the processing is carried out by automated means.
You can exercise the above-mentioned rights in your relationship with any LinguaNova entity if it is concerned by it.
If you wish to exercise the above-mentioned rights in relation to us (or with one of our group companies), please contact us in writing by e-mail at info@linguanova.live.
Please note that conditions, exceptions, or restrictions apply to these rights under applicable data protection law (for example, to protect third parties or trade secrets). We will inform you accordingly, where applicable.
You also have the right to file a complaint with the data protection authority and to defend your rights in front of a competent court. For the Romanian Data Protection Authority, relevant information on the complaint process can be found on their Website (dataprotection.ro).
We are committed to always treat your requests with the utmost attention and address any queries you may have in the shortest time possible.
11. CONTACT
For questions related to protecting personal data, exercising your rights, or registering a complaint, contact LinguaNova by e-mail at info@linguanova.live.
12. UPDATING THIS DATA PROTECTION NOTICE
This privacy policy is not part of a contract with you. We may change it or update it at any time. The version published on this Website is the current version.