INFORMATION NOTICE

ON THE PROCESSING OF PERSONAL DATA

            UTOPIC BRAIN S.R.L., having its registered office in Romania, Bucharest, Bd. Hristo Botev nor. 5 bloc 1, scara 1, etaj 1, ap. 2, sector 3, registered with the Trade Register under no. J40/9963/2018, tax identification code: RO 39612552, phone: (+40)728.886.742, e-mail: utopicbrain@gmail.com, hereinafter referred to as "Utopic Brain" or "We", legally represented by Mrs. Raluca MIHĂILĂ, has the capacity of personal data controller whenever we interact with you to offer you and, where appropriate, provide coaching and personal development services, maintaining this quality even after termination of contractual relations.

            Through this document we provide you with information on how we, as a data controller, process your personal data ("Data") and your legal rights in relation to the processing operations of such Data, as governed by Regulation (EU) No 2016/679 of the European Parliament and of the Council (hereinafter referred to as "GDPR").

1. Source of Data

            Utopic Brain processes Data that it receives directly from you.

1. Categories of Data Processed

Utopic Brain processes only that Data in the categories listed below:

1. a) Identification Data: first and last name, home/residence address, date of birth, signature, data relating to the client's legal representatives, shareholders and beneficial owners (as required by law to identify them);
2. b) Contact details: mobile and landline number, e-mail address;
3. c) Payment details: bank account;
4. d) Data that you share with the coach in the working sessions, which may include health data.

III.        Purposes and legal ground of Data processing

One of the principles relating to the processing of personal data requires that Data be collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with those purposes. In compliance with this principle, Utopic Brain collects and processes your Data for the following purposes:

1. a) Conclusion, performance and termination of the Agreement between you and Us respectively: we collect and process Data in order to inform you as fully and completely as possible about the nature of the services we can offer you, to negotiate and sign the agreement, and to be able to offer you our services in the best conditions;
2. b) Compliance with any legal obligation imposed on Utopic Brain: drafting accounting records; fulfilling tax obligations; archiving documents; application by Utopic Brain of the legal requirements concerning the prevention and fight against money laundering, know-your-customer and identification of the beneficial owner of the clients;
3. c) Fulfilling the legitimate interests of Utopic Brain: sending materials of a commercial nature or with the aim to promote Utopic Brain's services to potential clients and persons who are or have been our clients; training and specialising Utopic Brain's staff; organising the recovery of debts and settling any legal situations in connection with the performance of the Agreement concluded between you and Us.

            The Processing of Data for the above purposes will be carried out based on one or more of the following legal grounds:

1. a) On the basis of the consent you have given us to process your Data for certain specific purposes (Art. 6(1)(a) GDPR);
2. b) The processing is necessary for the conclusion, performance and termination of the agreement respectively (Art. 6 (1) (b) GDPR);
3. c) The processing is necessary for compliance with a legal obligation incumbent on the controller (Art. 6 (1) (c) GDPR);
4. d) The processing is necessary for the purposes of the legitimate interests of Utopic Brain (Art. 6 (1) (f) GDPR);
5. Categories of Data recipients

            In order to achieve the purposes described above, we may grant access to your Data: (i) to the Institute of Psychosynthesis / Middlesex University, based in London, United Kingdom, (ii) to our email service providers, as well as (iii) to our collaborators or partners, having the same field of activity (e.g. a substitute coach, if you have given your consent for the replacement of Mrs Raluca Mihăilă, during her rest period).

            The data that we disclose to these recipients are limited to the minimum personal data necessary for the provision of those services or for carrying out specific activities (e.g. carrying out the process of professional supervision of Raluca Mihăilă). The transfer of Data to entities located in the United Kingdom is considered by the European Commission as ensuring an adequate level of protection of personal data falling within the scope of the GDPR.

            Personal Data may also be transmitted to the following categories of third parties (in each of these cases, third parties may have access to the Data for the performance of their tasks or in interactions with Us, without them seeking to process the Data obtained for personal purposes): (i) public authorities, financial or legal auditors or institutions with powers to carry out inspections and controls on our business and assets, which request Utopic Brain to provide information, by virtue of the latter's legal obligations. These public authorities or institutions may be: National Supervisory Authority for the Processing of Personal Data, National Agency for Fiscal Administration; (ii) legal consultants, courts, bailiffs, etc., for compliance with a legal requirement or to protect our legitimate rights and interests.

1. Data Storage Period

            Utopic Brain will store your Data for as long as necessary to fulfil the purpose for which it was collected, in accordance with the provisions of the GDPR and applicable national law. The storage periods are determinable by reference to the Data storage obligations and records of economic operators, as well as by reference to applicable limitation periods and time limits for compliance with archiving obligations imposed by national law. Once the processing period indicated above expires and Utopic Brain no longer has legal or legitimate grounds to process the Data, the Data will be deleted in accordance with existing internal procedures, which may involve archiving, anonymization or destruction of the Data.

1. YOUR RIGHTS
2. a) right of access to your Data - the right to obtain confirmation as to whether or not personal data is being processed by Utopic Brain and, if so, access to that data and certain relevant information;
3. b) the right to rectification of Data - the right to obtain rectification of inaccurate personal data or completion of incomplete personal data;
4. c) the right to erasure of Data - the right to obtain the erasure of personal data, to the extent that the legal conditions laid down in Article 17 of the GDPR are met;
5. d) the right to restrict the processing of Data - the right to obtain the restriction of further processing of personal data concerning you, insofar as the legal conditions laid down in Article 18 of the GDPR are met;
6. e) the right to Data portability - the right to receive your personal data that you have provided to us in a structured, commonly used and easily readable format, as well as the right to have such data transferred by Utopic Brain to another data controller, insofar as the legal conditions set out in Article 20 of the GDPR are met;
7. f) the right to object - the right to object at any time, on justified and legitimate grounds relating to your particular situation, to your Data being processed, insofar as the legal conditions laid down in Article 21 of the GDPR are met;
8. g) the right to withdraw the consent you have given, if your consent was necessary for the processing of certain Data. In such a situation, the withdrawal of consent will not affect the lawfulness of the Data processing operations carried out prior to the withdrawal.

            In order to exercise any of these rights, you must send us a written request, dated and signed, to the e-mail address utopicbrain@gmail.com or by post, to the address in Bucharest, Bd. Hristo Botev nr. 5 bloc 1, scara 1, etaj 1, ap. 2, sector 3. Utopic Brain will treat any request concerning your personal data with celerity, and we will reply to you within one month of receiving your request.

            You also have the right to lodge a complaint with the National Supervisory Authority for the Processing of Personal Data and the right to apply to the courts of jurisdiction.

VII.       Absence of automated individual decision-making

            Utopic Brain does not use automated decision-making processes to process your Data.

This information notice is provided in printed or electronic format prior to the conclusion of the Agreement. Certain aspects that we have presented above can and will be changed whenever there are changes in the way the Data is processed. In the latter case, we will send you an information message reflecting the updates made.