Processing of personal data

  1. Purpose and Scope of This Notice

ACCESSOIRES DU LUC SRL, the owner of the website www.thelighthouseproject.rorespects your privacy and is committed to protecting your personal data. This personal data processing notice (hereinafter referred to as the “Notice”) is intended to provide you with relevant information regarding how we process your personal data when you visit our website or when you provide us, by any other means, with your personal data (such as by phone, email, or CV), when you purchase coaching/mentoring/consultancy services, when you subscribe to our newsletter, or when you request a quote from us, etc.

This site is intended only for adults, and the only situations in which we collect data relating to children are those in which you book coaching/mentoring services for your children.

This Notice informs you about the personal data processing operations (as defined by the relevant legislation, including the General Data Protection Regulation 2016/679 – hereinafter referred to as “GDPR”) carried out by ACCESSOIRES DU LUC SRL, in its capacity as a personal data controller.

The controller of your personal data is ACCESSOIRES DU LUC SRL S.R.L. and is responsible for your personal data (hereinafter referred to as “ACCESSOIRES DU LUC SRL”, “we” or “our” in this Notice).

  1. Controller of Your Personal Data and Contact Details of the Data Protection Officer

The controller of your personal data is ACCESSOIRES DU LUC SRL S.R.L., having its registered office in Bucharest, STR. VALIUG No. 32, SECTOR 1, BUCHAREST, Romania, having the unique registration code 36809119 (hereinafter referred to as “ACCESSOIRES DU LUC SRL”, “we” or “our” in this Notice).

If you have any questions regarding this Notice, including any request regarding the processing of your personal data or the exercise of your legal rights, please contact the Data Protection Officer using the following contact details:

  • (1) Email: RALUCA_BRB@YAHOO.COM
  • Postal address: Bucharest, STR. VALIUG No. 32, SECTOR 1, Bucharest, Romania

It is important that the personal data we hold about you is accurate and up-to-date. Please inform us if any of the details you have provided change during your relationship with us.

  1. External Links

This site may include links to third-party websites or applications. If you click on those links or activate such applications, third parties may be able to collect or share data about you. We do not control these third-party websites and are not responsible for their personal data processing policies. When you leave our website, please read the policies of each website you visit.

  1. Personal Data We Collect About You

Under applicable law, “personal data” means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more specific factors related to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
When you access our website, communicate with us, or when we provide you with coaching/mentoring or other services, we may process the following categories of personal data:

  • Contact and/or identification details,including: full name, address (residence or domicile), telephone number, email, ID document series and number (identity card/passport), personal numerical code, as well as information contained in these documents.
  • Data related to the requested services,including: information about the services requested or provided.
  • Data used for advertising, marketing, and publicity purposes, including: full name, image, and social media account images (in the case of IDs and images published on social media accounts, ACCESSOIRES DU LUC SRL through THE LIGHTHOUSE PROJECT accounts will mention the presence of the respective person in the photos and videos posted on social media accounts or on websites belonging to ACCESSOIRES DU LUC SRL).

We collect and process the above data only when strictly necessary to provide the services you have purchased.

You are under no obligation to consent to the processing of special categories of personal data, except when necessary for the provision of the requested services. However, without your consent, we will not be able to take the necessary steps to provide the company’s services you have booked or are trying to book.

Only when this information is necessary for service provision—if you do not provide such data and we do not have your consent—we will not be able to deliver the requested services.

  1. Source of Personal Data

Personal data may be obtained from the following sources:

  • Directly from you when: you request a coaching/mentoring/consultancy offer or benefit from our services, when you subscribe to our newsletter or other publications, send feedback, or participate in contests we organize.
  • Through activities carried out while you benefit from the services we provide, such as photos, conversation history from WhatsApp groups.
  • From third parties, for example when we receive your personal data from third parties requesting coaching/mentoring/consultancy services.
  1. Purpose of Processing Personal Data

ACCESSOIRES DU LUC SRL collects, processes, and uses personal data for:

  • Purposes enabling us to provide an offer or deliver coaching/mentoring/consultancy services.
  • Enabling the initiation or performance of a contractual relationship with you.
  • Advertising, marketing, and publicity purposes.
  • Enabling your participation in contests and events organized by ACCESSOIRES DU LUC SRL.
  • Exercising the rights and obligations of the parties arising from contracts signed between the parties or related to the services provided.
  • Protecting the interests of the parties in promoting legal actions and defending against any claims and lawsuits.
  • Ensuring compliance with legal provisions regarding the retention and archiving of data/documents.
  • Exercising the Company’s rights under applicable law and fulfilling legal obligations.
  • Facilitating financing services made available by ACCESSOIRES DU LUC SRL through partner banking institutions.
  • Purposes related to the general purpose of providing coaching/mentoring/consultancy services.

For the avoidance of doubt, ACCESSOIRES DU LUC SRL will not use your personal data for advertising, marketing, and publicity purposes unless you have given your explicit consent.

Furthermore, ACCESSOIRES DU LUC SRL states that there is no automated decision-making process (including profiling) based on your personal data.

  1. Disclosure of Personal Data

Your personal data will be disclosed within ACCESSOIRES DU LUC SRL only to management personnel and to other individuals who need access to your personal data on a “need to know basis” in order to fulfill their specific duties for the purposes listed in section 6 above, or where such disclosure is necessary or permitted by applicable law.

ACCESSOIRES DU LUC SRL may also provide your personal data to third parties that offer services related to the requested services, IT support services, or technical and organizational services (in connection with the activities of ACCESSOIRES DU LUC SRL), to financial institutions in order to facilitate the financing of coaching/mentoring/consulting services, or to legal, audit, or other consultants or suppliers of the company, solely for the purposes mentioned in this Notice. ACCESSOIRES DU LUC SRL will exercise appropriate due diligence in selecting third-party service providers and will require such providers to maintain adequate technical and organizational security measures to protect your personal data and to process them in compliance with applicable legal provisions.

ACCESSOIRES DU LUC SRL may also disclose your personal data to authorities, as necessary or permitted by law, to insurance entities, external consultants, and/or courts of law. Your personal data will be disclosed to such third parties only to the extent necessary in connection with the performance of contracts.

8. Legal Basis for Processing Personal Data

The legal bases for the processing of personal data described in this Notice are: (i) the performance of a contract to which you are a party or to take steps prior to entering into a contract, (ii) our legitimate interests and/or the necessity to conclude or perform a contract, in compliance with data confidentiality laws, and (iii) your consent.

Our legitimate interests or those of a third party include our requirements to use your personal data in litigation, regulatory investigations, processing for advertising, marketing, or publicity purposes, or for other lawful purposes involving ACCESSOIRES DU LUC SRL.

9. Data Security

ACCESSOIRES DU LUC SRL maintains physical, technical, and organizational security measures to protect personal data against destruction, loss, alteration, disclosure, restriction, or accidental, unlawful, or unauthorized access, regardless of where the data are processed.

10. Duration of Processing/Storage of Personal Data

We aim to keep your personal data accurate and up to date. We also strive to keep your personal data no longer than necessary to fulfill the purposes listed in this Notice or as required by law.

Accordingly, ACCESSOIRES DU LUC SRL will retain your personal data for the entire duration of your contract with ACCESSOIRES DU LUC SRL and for an additional period required by applicable legislation after the end of the relationship between you and ACCESSOIRES DU LUC SRL.

Furthermore, please note that certain personal data may also be included in certain accounting documents of ACCESSOIRES DU LUC SRL, which require an extended retention period in accordance with applicable law.

If you are a candidate for a position offered by ACCESSOIRES DU LUC SRL (without a formalized relationship with the company), your personal data provided to ACCESSOIRES DU LUC SRL will be retained for a period of 1 year.

Regarding personal data obtained through video surveillance, such data will be kept for a maximum of 30 calendar days from the date of recording, except in cases where there are legitimate reasons to store them for a longer period.

In certain circumstances, we may anonymize your personal data (so that they can no longer be associated with you) for research or statistical purposes, in which case we may use such information indefinitely without further notice to you.

11. Processing of Personal Data for Advertising, Marketing, and Publicity Purposes

Capturing an image (photography, video) or using an image (photography, video) is allowed only with your prior consent, and in the case of minors, only with the prior consent of their parents. It should be noted that the right to one’s image is not an absolute right, and photographing and using a person’s image is permitted even without prior consent when done in good faith in the exercise of other fundamental rights, such as the right to freedom of expression or our legitimate interest in ensuring the security and protection of people and property.

If consent is granted, ACCESSOIRES DU LUC SRL will limit the use of the image to its website(s) and only on major social media platforms such as Facebook, Twitter, Instagram, WhatsApp, or on web pages associated with the company, or for display purposes in advertising, marketing, and publicity within premises, events, or presentations.

There are situations, such as trips or group events, where such collection of images or videos is possible. These will be announced in advance, and if you do not wish to have your image collected and processed, you can inform the event organizer or the Data Protection Officer.

12. Your Rights Regarding Personal Data

In accordance with the applicable provisions regarding personal data, we inform you that you have the following rights, which can be exercised by submitting a request using the contact details indicated in Section 2 above:

  • Right of access to processed personal data,meaning your right to obtain from ACCESSOIRES DU LUC SRL confirmation as to whether or not personal data concerning you are being processed and, if so, access to such data and information on the conditions under which they are processed (including the purpose of processing, the categories of data processed, and the recipients of the data);
  • Right to request rectification or deletion of personal data,meaning your right to request that we correct inaccurate personal data or complete incomplete personal data.
  • You may also exercise the right to have your personal data deleted in certain circumstances provided by applicable law, including: when the personal data are no longer necessary for the purposes for which they were collected; when you object to the processing and there are no overriding legitimate grounds for processing; when the personal data have been unlawfully processed;
  • Right to request restriction of processingmeaning your right to obtain from ACCESSOIRES DU LUC SRL the restriction of processing in the following cases: (i) you contest the accuracy of the data (the restriction will last for the period necessary for the Company to verify the accuracy of the personal data); (ii) the processing is unlawful and you oppose the deletion of the data, requesting instead the restriction of their use; (iii) ACCESSOIRES DU LUC SRL no longer needs the personal data for the purposes mentioned above, but you request the personal data for the establishment, exercise, or defense of legal claims; or (iv) you have objected to the processing, for the time necessary for ACCESSOIRES DU LUC SRL to verify whether the Company’s legitimate rights prevail over your rights;
  • Right to object to processingmeaning your right to object, on grounds relating to your particular situation, to processing when: (i) the processing is based on the legitimate interests of the Company or a third party; or (ii) where applicable, the processing is carried out for direct marketing purposes, including profiling;
  • Right not to be subject to automated decision-makingincluding profiling;
  • Right to data portabilitymeaning your right to request the transfer, copy, or movement of your personal data from the Company’s database to another database, in a structured, commonly used, and machine-readable format, where the processing is based on a contract and is carried out by automated means;
  • Right to lodge a complaintwith the National Supervisory Authority for Personal Data Processing and to address the competent courts.
  • 13. Changes to the Notice

If we substantially change our personal data practices or this Notice, we will issue a revised Notice and/or take other steps to inform you of such changes in accordance with applicable law.

The websiteACCESSOIRES DU LUC SRL is operated by S.C. ACCESSOIRES DU LUC SRL, registered under CUI 36809119, with its headquarters in Bucharest, Str. Valiug no. 32, Sector 1, Romania.