We, at [Hospitality Culture Institute], have committed to maintaining the accuracy, confidentiality and security of your personal data. This Privacy Policy describes how [Hospitality Culture Institute] collects personal information from or about you, and how we use, share and protect that information.

This Privacy Policy is intended to cover all data processing activities related to the educational program “Horeca Business Accelerator” developed and managed by [Hospitality Culture Institute], including any personal information collected via our dedicated application form on our website https://accelerator.hospitalityculture.ro/. (“Website”). Furthermore, this Privacy Policy applies to any personal data that [Hospitality Culture Institute] can collect (i) when you interact with us other than via de Website or during the Horeca Business Accelerator educational program, for example, personally, by telephone or e-mail or (ii) from the companies that you work for or collaborate with and other business partners or suppliers (collectively referred to as “Business Partners”)

Throughout this Privacy Policy, we will refer to you as “you”, and we will refer to [Hospitality Culture Institute] as “we”, “us” or “[Hospitality Culture Institute]”.

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Personal Data We Collect

[Hospitality Culture Institute] collects and processes the following types of personal data:

1. Personal data provided directly by you:
   • Personal details: first name, last name, e-mail address, phone number;
   • Work details: job title, company name, company e-mail address, company mobile number;
   • Professional details: trainings, qualifications, personal developments and achievements;
   • Payment details: fee amount, bank account, amount paid, type of payment.

How We Use Your Information

Purpose: Collecting and Managing Your Application on the Website

Personal Data: 1. Personal details: 2. Work details, 3. Professional details

Legal Basis: our legitimate interests to enable us to effectively manage the process of application collecting for the Horeca Business Accelerator;

Purpose: Evaluating Your Applications and Selecting the Candidates

Personal Data: 1. Personal details: 2. Work details, 3. Professional details, 4. Data from External sources and Derived data

Legal Basis: our legitimate interests to ensure the strategic and deliberate selection of the most suitable candidates for the Horeca Business Accelerator educational program;

Purpose: Registration Process and Payment of Registration Fees

Personal Data: 1. Personal Details: 2. Work Details 3. Payment details

Legal Basis: 1. performance of the agreement concluded with us 2. compliance with our legal obligations related to invoice issuing and tax matters, 3. our legitimate business interests regarding fee collection for the Horeca Business Accelerator;

Purpose: Organizing and Managing the Educational Program

Personal Data: 1. Personal details: 2. Work details, 3. Professional details, 4. Data from External sources and Derived data

Legal Basis: our legitimate interests to enable us to effectively organize and manage the Horeca Business Accelerator, including performance of mentorship trainings ;

Purpose: Defending any Legal Interest / Rights / Claims before Official Competent Bodies.

Personal Data: 1. Personal details: 2. Work details, 3. Professional details, 4. Data from External sources and Derived data, 6. Payment Details,

Legal Basis: 1. our legitimate interests to obtain the satisfaction of our interest / rights / claims deriving from or in connection with the Horeca Business Accelerator educational program or to defend ourselves where you would initiate legal proceedings against us, 2. our legal obligation to keep/disclose specific data for such purpose.

When We Share Your Information

[Hospitality Culture Institute] will not disclose your personal data except as described here:

• We may share your personal information with third parties we engage to perform support services for us. Examples include companies that provide software tools we use within [Hospitality Culture Institute]; companies that help us protect [Hospitality Culture Institute] and your personal information; service providers, banks or other financial companies to allow us to invoice and receive your payments. These third parties are required to use the personal information we share with them only to perform services on our behalf and to treat your personal information in compliance with all applicable privacy and data protection laws.
• We may also share your personal data with third parties when we have a good faith belief that disclosure is necessary: (i) to comply with a law, regulation, court order, or other legal process; (ii) to detect, prevent, and respond to fraud, intellectual property infringement, violation of our contracts or agreements, violation of law, or other misuse of [Hospitality Culture Institute] property; (iii) to protect [Hospitality Culture Institute] rights or property or (iv) under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal data.
• We may share your personal data with third parties (Business partners or other investor) in connection with the Horeca Business Accelerator. If such an event occurs, we will take appropriate steps to protect your personal data.
• We may share your information with your permission or at your request.

Whenever we will disclose your personal data these other third parties will use your personal data in a manner consistent with this Privacy Policy, any applicable specific privacy statements, and all applicable privacy and data protection laws.

Security of Your Personal Data

[Hospitality Culture Institute] maintains reasonable safeguards to protect the confidentiality, security and integrity of your personal data. Your personal data will be stored in [Hospitality Culture Institute] databases or databases maintained by our service providers, located within. the European Economic Area (EEA). Where we will need to transfer or store your personal data outside the EEA, we will take appropriate measures, by contract or otherwise, to provide adequate protection for the personal data that will be disclosed or otherwise transferred.

Retention of Personal Data

Your personal data will be retained for a period of [6 months] unless any other applicable legal requirements (for example, in accordance to tax regulations) imposes longer retention periods or your personal data is needed for the exercise any legal interest / rights / claims before official competent bodies, in which case the data will be kept for the duration of the respective legal proceeding.

Your Individual Rights

• Right of Access: You may ask [Hospitality Culture Institute] to confirm whether your personal data is processed and to be provided with access to any data held about you by us.
• Right to rectification: You have a right to have [Hospitality Culture Institute correct your personal information if it is inaccurate. Taking into account the purposes of the processing, you may also have the right to have incomplete personal information about you completed, including by providing supplementary information.
• Right to object to processing of your personal data for our legitimate business interests: You have the right to object to processing of your personal information when that data is processed on the basis of [Hospitality Culture Institute]’s legitimate business interests. We will address your objection and stop processing the relevant personal information unless: (i) there are compelling legitimate grounds for the processing that override your interests, rights and freedoms; or (ii) we need to continue processing your personal information to establish, exercise or defend a legal claim.
• Right to restrict the processing: You can require certain personal data to be marked as restricted whilst complaints are resolved and also restrict processing in certain other circumstances. If following your request, we restrict the processing of your personal data, we will store your personal data, and otherwise process it only with your consent; to establish, exercise, or defend a legal claim; to protect the rights of another natural or legal person; or for reasons of important public interest. We will also inform you before lifting the restriction of processing.
• Right to erasure (“right to be forgotten”): You can ask us to erase personal data in certain circumstances listed in Art 17 GDPR and we will take reasonable steps to inform other controllers that are processing the data that you have requested the erasure of any links to, copies or replication of it.
• Right to data portability: You can ask us to transmit the personal data that we hold about you to you or to a third party electronically (I.e., in a structured, commonly used and machine-readable format), whenever we process your data based on contract/consent and via automatic means.
• Right to lodge a complaint with a supervisory authority: We will use our best efforts to address and settle any requests or complaints brought to its attention. In addition, you have the right to approach the competent data protection authority with requests or complaints. This can be the supervisory authority in the jurisdiction where you live or another supervisory authority. The overall competent supervisory authority for [Hospitality Culture Institute] in Romania is:

National Authority for Supervision of Personal Data Processing

B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, cod postal 010336, Bucharest, Romania

www.dataprotection.ro

You also have the right to lodge specific requests relating to your personal data processing with competent jurisdictional authorities.

Data Controller and Contact Information

We are [Hospitality Culture Institute].

Our registered office is in Bucharest. We are registered in Romania under company number RO38641681

For any details on the above as well as exercising your specific rights you may contact us at:

Post address: Nicolae Iorg 5, camera 5, etaj 2;

E-mail address: contact@hospitalityculture.ro;

Phone number: 0731144133

Changes to this Privacy policy

This Privacy Policy gets updated from time to time, so we encourage you to check it regularly. If we make a major change, we’ll post this on the Website and inform you via e-mail on the update.