Through this privacy policy, CODALITY L.T.D. (hereinafter referred to as the Company) is committed to protecting the privacy of the personal data of users of the website https://www.codality.eu.

By using this website you consent to the processing of your personal data as described in this privacy policy.

This Privacy Policy is an integral part of the set of procedures and rules that the Company has implemented in order to comply with the requirements of the General Data Protection Regulation (EU) 2016/679 regarding the protection of natural persons concerning the processing of personal data and regarding the free circulation of these data and repealing Directive 95/46/EC. By accessing and browsing our website, it also means that you have become aware of the content of the Privacy Policy, and at the same time you consent to the processing of personal data with the specifications specified below.

The Company may modify this privacy policy when necessary. If any changes are introduced, they will be updated via the web page so that you can effectively become aware of the new privacy conditions. If you continue to use the functionalities made available by CODALITY L.T.D., by accessing the website, it will be assumed that you agree with them, except in cases where your express consent is required.

A. Who are we?

Website https://www.codality.eu (hereinafter referred to as the website) belongs to and is managed by CODALITY L.T.D.

Trade Registry registration number: J12/1388/2023

Tax registration number: RO47885189

Address of the registered office: Dezmir village, Apahida commune, Trandafirilor street, no. 61B, Cluj county, Romania

Email: adrian@codality.eu

Phone: 0773397537; 0752413407

B. What is personal data?

"Personal data" is any information by which you can be identified. This includes data such as first and last name, telephone number, email, postal address, user name, location data, an online identifier, one or more specific elements of physical, physiological, genetic, mental, economic, cultural or social, personal preferences and browsing habits, the content generated, the IP address of your computer, the MAC address of your device, as well as information from cookies, as regulated by the General Data Protection Regulation which aims to protect all citizens EU on privacy and data breaches.

C. What is the scope of this privacy policy?

This privacy policy applies to your personal information collected or processed through the websites, mobile applications, and other services and products with which you come into contact and which belong to CODALITY L.T.D. This privacy policy does not apply to other entities websites, mobile applications, and other services and products that do not display or include a link to this privacy policy or have their own privacy policy.

The personal data provided by the users of the website may be processed by the Company depending on the type of data provided by the user, as well as the interactions between the user and the Company through the web page.

D. What type of data do we process and from what sources?

The data that the Company can process as a result of the interaction with the user through our website comes from the following sources:

• When using the website https://www.codality.eu, we automatically process the following data: the IP address of the device used by you; the type of internet browser used; the operating system used; the number of visits and the average time spent on the website; the time and date of accessing the website; your activities on the website (including pages viewed); We use this data to monitor the attractiveness of our web pages and to improve their performance and content.

• When completing the data when placing the order and paying the amounts for each service purchased on the website https://www.codality.eu, we collect the following data: name and surname; email address; billing address; chosen payment method.

• When visiting our website, we collect and store information in cookies and similar technologies, according to the cookie policy contained in the "Terms and conditions" section.

• When registering for our newsletter, we process your personal data, namely your e-mail address.

• When registering in the “Let's work together” section, we collect the following personal data: name, surname, phone number, and email address.

Exclusively, if the user of our web page provides other types of data in interactions with the Company, these data will be processed by the Company only if their processing is necessary to achieve the intended purpose. Otherwise, the data will be destroyed without having been previously saved by us.

E. The legal basis for processing your data

The Company processes the personal data provided by the users of its web page in accordance with the following legal grounds, depending on the type of data provided by the user, as well as the interactions between the user and the Company:

• Contractual obligations - data processing is necessary in order to perfect or execute the contract between us and you as a customer so that the Company can provide services to you, to fulfill the obligations related to providing online courses to you, under the conditions agreed.

• Consent - in certain situations, personal data can be processed and collected only based on your consent, for one or more specific purposes, such as to ensure communication between the Company and you, through the communication channels you have consented to (i.e. e-mail, notifications), consent for the use of cookies that monitor your behavior on the website, consent for the publication of your name on the websites, social networks belonging to the Company, for advertising and marketing purposes. We also inform you that the data provided through the Google Forms platform will remain stored exclusively on this platform, not on our platform, in the sense that we provide you with information related to the processing of personal data by this platform: https://policies.google.com/privacy?hl=ro#inforetaining.

• Legal obligations – in certain situations, the collection and processing of your personal data is necessary for the fulfillment of a legal obligation incumbent on the Company, for example, protection against criminal activities/fraud, for the fulfillment of obligations in fiscal matters, etc.

• Legitimate interest – the processing of your personal data may be necessary for the purposes of the legitimate interests pursued by the Company or a third party. In any case, your fundamental interests or rights and freedoms, which require the protection of personal data, will always prevail.

F. Purpose of processing your personal data

The purpose of data processing consists of:

• Offering visitors the possibility to access the website https://www.codality.eu, to consult its content and analyze the services made available by the Company.

• Fulfilling the contractual obligations assumed towards you, namely the provision of online courses and mentoring services in the IT field, carried out through the https://www.codality.eu website.

• Your information about the packages purchased on https://www.codality.eu.

• Promotion of https://www.codality.eu services.

• Conducting market research and analyzing the behavior of our customers;

• Improving the services related to the https://www.codality.eu website.

• The realization of marketing services.

• Ensuring the implementation and maintenance of business/website security measures https://www.codality.eu and its visitors/users;

• Communication/notification to public bodies/authorities/institutions or institutions of public interest when required by law;

• Compliance with specific legal obligations for protection against fraud, money laundering, and terrorism.

G. What do you have to guarantee when providing personal data?

The user guarantees that the data provided is real, accurate, complete, and up-to-date, being responsible for any damage, direct or indirect, that may result from the violation of this obligation.

If the user provides data belonging to a third party, he guarantees that he has informed that third party of all aspects contained in this privacy policy and that he has obtained consent to provide us with its data for the purpose of the processing in question. All of this must take place prior to providing data to a third party through our Website.

The Company informs you that in order to provide your personal data, in any way, through our Site, you must be over 18 years old. The User who provides data to the Company through this Site represents and warrants that he is over 18 years of age and is being fully responsible for this statement. The use of the systems, as well as the results of the processing, is prohibited with regard to children who have not reached this age, without the consent of their parents/legal representatives. If, despite our reasonable prevention efforts, such processing still takes place, we will stop it once we notice that the users have not reached the age mentioned above.

H. Measures to protect personal data

In response to our concern to guarantee the security and confidentiality of your data, the necessary security levels for the protection of personal data have been adopted and the available technical measures have been installed to prevent the loss, misuse, modification, unauthorized access, and theft of data with personal information provided through the website. In any case, you should know that Internet security measures are not infallible.

Among the security measures implemented, we indicate the following:

• Your data is stored on secure servers owned by https://www.squarespace.com; https://stripe.com; https://calendly.com; https://www.google.com/drive; access to the database is made only based on a user and password assigned to the employees of the Company.

• The Company's employees undertake to use the personal data to which they have access exclusively for the exercise of their duties.

• Personal data are accessed only from the company's equipment.

• Personal data are printed in physical format only from the company's equipment.

• All users undertake to maintain the confidentiality of the personal data to which they have access;

• Periodically, a back-up is made to the database of https://www.squarespace.com,  https://stripe.com, https://calendly.com , https://www.google.com/drive;

• In the case of online payments with your credit/debit card, provide information about your card by completing the form on the secure page of the payment processor. Credit/debit card payments issued under the Visa and/or MasterCard logo (Visa/Visa Electron, MasterCard/Maestro) are made through the "3-D Secure" system developed by organizations that ensure online transactions the same level of security as those made at the ATM or in the physical environment/at the merchant; "3-D Secure" ensures that no information related to your card is transferred or stored, at any time, on the servers of the store or on the servers of the payment processor, these data being directly entered into the Visa and MasterCard systems.

I. Your rights regarding personal data

We inform you that you have the right to obtain a confirmation as to whether or not personal data concerning you is being processed.

Similarly, you have the following rights regarding your personal data:

• To access your data: You have the right to access your data to know which of the personal data we process concern you and the conditions under which they are processed.

• To request the rectification or deletion of your data: In certain circumstances, you have the right to rectify personal data that you consider to be inaccurate and that concern you, and which are subject to processing by the Company, as well as the right to request the deletion of the data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.

• To request the restriction of the processing of your data: In certain circumstances, you have the right to request us to restrict the processing of your data, in which case we inform you that we will keep the data concerning which you have requested the restriction of processing only for the exercise or defense of a legal right.

• On the portability of your data: In certain circumstances, you will have the right to receive the personal data concerning you, which you have provided to us, in a commonly used and machine-readable structured format, as well as such to be transmitted by the Company to another operator.

• To object to the processing of your data: In certain circumstances and for reasons related to your particular situation, you have the right to object to the processing of your data, in which case the processing will stop, unless we must continue to do so for compelling legitimate reasons or for the exercise or defense of a legal right.

• Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly affects him in a significant way.

• To file a complaint at the Data Protection Authority (ANSPDCP) and the right to address it to the competent courts.

• We also remind you that you have the right to withdraw any consent you have provided for the processing of your data, without this affecting the legality of the processing based on the consent before its withdrawal.

The company informs you that you can exercise your rights over your personal data through any of the following channels:

• Through a letter addressed to CODALITY L.T.D. with headquarters chosen for communications and correspondence in Dezmir village, Apahida commune, Trandafirilor street, no. 61B, Cluj county. Please include the mention "Data Protection".

•  Through a request addressed to CODALITY L.T.D. to the e-mail address adrian@codality.eu.

In both cases, the Company has the right, following the legal provisions, to request the provision of additional information necessary to confirm the identity of the person concerned, when it has reasonable doubts about the identity of the requesting natural person.

The company will provide the requested information within a maximum of one month after receiving the request. This term can be extended by another two months if necessary, depending on the complexity of the applications and their number.

The company informs you that you can file a complaint with the competent data protection supervisory authority. However, we encourage you to submit your complaint to the Company in the first instance, so that it can be resolved amicably.

Supervisory authority:

The National Authority for the Supervision of the Processing of Personal Data

G-ral Blvd. Gheorghe Magheru 28-30

Sector 1, postal code 010336

Bucharest Romania

Phone: +40.318.059.211; +40.318.059.212

Fax: +40.318.059.602

Email: anspdcp@dataprotection.ro

www.dataprotection.ro

J. Management and treatment of requests and requests from users

The personal data of users who contact the Company through any of the contact channels made available through the Website will be processed for the purpose of maintaining contact between the parties, managing Website users, providing support services for customers or users, and the handling and resolution of such requests and requests.

We will process your personal data when you provide us with feedback about our products and services. Such personal data will be processed for the above purpose only based on your consent, also taking into account our legitimate interest in helping us to understand the needs and expectations of our customers regarding our products and services. Accordingly, it is your choice whether or not to provide us with personal data (such as name and surname, e-mail, telephone number or the like).

K. Receivers of your data

The data collected by the Company through this web page may be communicated to the following recipients in Romania, depending on the legal basis of the communication and only if necessary:

• To our collaborators for the provision of contracted services, such as, for example, courier companies, and companies providing marketing and advertising services/payment services.

• To public authorities or institutions (for example, if the communication is necessary for the management of complaints, for the fulfillment of legal and fiscal obligations, or when the Company is obliged by virtue of a legal provision to provide information to the authorities or institutions having powers to carry out inspections and controls on the activity and assets of the Company or the courts, to protect the rights and assets of the Company).

• Companies that provide hosting services for the Company's platforms and companies that provide technical maintenance of the website.

• Financial or legal auditors, potential third party acquirers, to the extent that the Company's activity would be transferred (in whole or in part), and the data of the persons concerned would be part of the assets that are the subject of such a transaction.

Regarding the other purposes of data processing detailed in this privacy policy, the Company informs users that these purposes do not involve the Company communicating their data to third parties.

L. Retention time of your data

The company will keep your personal data as long as necessary to provide the requested service and/or to achieve the proposed purpose of the processing.

Afterwards, your data will be deleted.