PRIVACY POLICY

PhiAcademy Open Day-MeetPhiAcademy

With this information, PhiAcademy doo Beograd-Vozdovac (hereinafter “PhiAcademy“ or “we“) informs you about the processing of your personal data (“Data“) as well as your Data protection claims and rights in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Serbian Personal Data Protection Act, in regard to the following:

1.Which Data are processed?

We process the Data that we receive from you when you register on our website www.phiopen.com (hereinafter “Website“) and when you attend a PhiAcademy Open Day-Meet PhiAcademy Event (hereinafter “Event”).

These Data include:

• Your personal details: name and surname*, city*,age*, e-mail address* and phone number*
• Your occupation (optional)
• Your answers (optional)
• Your image and sound (recordings are made at each Event)

We do not collect or process any special categories of personal Data. Sole exception to this is whenever you voluntarily provide on an Event’s photos or videos some indication of special categories of Data (= personal data which reveals a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health condition, sex life or sexual orientation). We do not wish to process this type of Data and will make every effort to prevent this. In addition, we ask you, if possible, not to take any actions or make any statements that could lead to the processing of special categories of personal Data.

2.For what purposes are Data processed?

We process your Data in accordance with applicable data protection law and for specific purposes and for a specific period. The most important purposes and duration of the processing are listed below. If we collect Data from you for other purposes, we will inform you separately before collecting that Data.

2.1.Registration and participation

We process your Data to register your attendance at an Event and to inform you about the Event you are registered for (date, time and place of the Event, what you can expect and learn at the Event you are registered for, place and time of the next Event, etc). We also process your Data to prepare personalized training material.

2.2.Further information

If you have registered for an Event, we will contact you via e-mail or phone about similar future Events (in the same state), our products and services if we think they are of interest to you.

2.3.Advertising the Event

We also process video/photos that we take during an Event. These videos/photos are made to show future participants and interested parties what to expect of an Event. Therefore, we take pictures of the participants, for example a group photo with trainers or if they try out new treatment methods. We always make sure that participants are shown in an advantageous and never in a compromising or degrading way. We process these videos/photos for the preparation of reports on the Event, for providing information about the Event on our Website and for performing direct marketing and advertising via electronic and non-electronic means.

2.4.Newsletter

We process the Data you provided when you signed up for the Newsletter for the purposes of direct marketing. We will send you personalized newsletters via e-mail and inform you about offers, services and events of PhiAcademy and our partner companies if, based on your Data, we assume that this information is particularly relevant and interesting for you. These partner companies are: PhiAcademy GmbH and Craftmaster GmbH.

3.What is our legal basis for processing the Data and for how long do we process them?

3.1.On the basis of your consent (article 6 (1) (a) GDPR):

If you have given us your consent to the processing of your Data – for example to receive the Newsletter – this processing will only be carried out in accordance with the purposes specified in the respective declaration of consent and to the extent agreed therein.

You can withdraw your given consent at any time with effect for the future by sending us an e-mail to info@phiopen.com or  if you click on the unsubscribe link in every Newsletter mail . The withdrawal of consent does not affect the lawfulness of the processing of your Data based on your consent before its withdrawal.

3.2 To fulfill our contractual obligations (article 6 (1) (b) GDPR)

We process these Data for the purpose of fulfilling our contractual obligations when you participate in an Event. We process the Data provided for this purpose only as long as it is necessary for the organization of an Event.

3.3.To fulfill our legal obligations (article 6 (1) (c) GDPR)

The processing of your Data may be required to fulfill our legal obligations. Such obligations may arise from the legal norms applicable in the country where an Event takes place. If such legal obligations no longer require the processing of Data, we will delete your Data unless there is another legal basis for its processing.

3.4.For the purpose of our legitimate interest (article 6 (1) (f) GDPR)

We process these Data on the basis of our overriding legitimate interest when we provide you with further information in order to achieve the purposes mentioned in section 2.2. You can object to receiving this further information at any time – there is for example in every information sent by e-mail an “unsubscribe” link or you can write to info@phiopen.com

We also process the Data mentioned in section 2.3 on the basis of our overriding legitimate interest in order to achieve the purposes mentioned in this section. The Data provided by you will be deleted when you object to further information. If you object, we will either delete your Data or make you unrecognizable on the photos and videos.

Beyond that, we process your Data only as long as there is a legal obligation to do so or we need Data for the exercise or defence of legal claims.

4.Who receives your Data?

Within PhiAcademy and our affiliates PhiAcademy GmbH and CraftMaster GmbH, those employees will receive your Data, who need them for the purposes outlined above. If we are legally obliged to do so, we will also transfer your Data to public bodies and authorities. In addition, companies commissioned by us (in particular IT or back office providers) will receive your Data if they need them to fulfill their respective tasks. These providers are obliged to treat your Data confidentially, to process them only to the extent necessary for their service provision and they provide their processing activities within the European Economic Area. If these companies provide their processing activities outside the European Economic Area, there are appropriate safeguards according to Art 46 GDPR in place to ensure an adequate level of data protection.

We will transfer your Data to the following recipients:

5. Are you obliged to provide Data?

As a attendee, you are obliged to provide us with Data that are marked with (*) as mandatory in order to participate in an Event or to o receive a service –newsletter – it is necessary that you provide the Data we need to perform our voluntary service. . Unless you provide those mandatory Data, you will not be able to participate and we will generally be unable to provide our services.

6.Cookies

6.1.Technically required Cookies

We use cookies on our Website, which are small files stored on your device (web browser). On your next visit to our Website using the same device, the information stored in cookies will subsequently be returned to our Website. We use the Data collected through these cookies to better represent our Website and to make our offers user-friendly, for example to evaluate the use of our Website. Some cookies remain stored on your device until you delete them. They allow us to recognize your browser on your next visit. Other cookies are only stored on our Website for the duration of your visit.

The following cookies are used:

All these cookies are technically necessary for the presentation of the Website. You can deactivate the setting of cookies in the settings of your browser. Please note that a general deactivation of cookies may possibly lead to functional limitations of our Website.

6.2.Google Analytics

Furthermore we use the Cookies of Google Analytics, a web analysis service provided by Google LLC (hereinafter “Google”). These cookies transmit data about your usage of the Website to a Google server in the USA. However, your IP address will be shortened by Google prior to transmission and the transmitted data can no longer be associated with your person. Google will use this information to evaluate general usage data of our Website and to compile reports on Website activities.The collection of data only takes place with your consent. This consent can be withdrawn by you at any time. The withdrawal of this consent does not affect the lawfulness of processing based on the consent before its withdrawal. If you want to prevent the use of Google Analytics cookies in general, you can either do this through your browser settings or you can install the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout. Your Data will be processed until you withdraw your consent. Beyond that, we will process the Data only as long as there is a legal obligation to do so or we need the Data for the exercise or defense of legal claims.

For information about how Google and its affiliates use data and storage practices, please visit Google’s Privacy Policy, currently available at: https://policies.google.com/privacy .

6.3.FACEBOOK AUDIENCE PIXEL

We also use the Facebook Audience Pixel analysis tool from Facebook Ireland Limited to measure the effectiveness of our advertising. All data collected by this pixel is encrypted by Facebook using “hashes”.

The collection of data by Facebook Pixel only takes place with your consent. This consent can be withdrawn by you at any time. The withdrawal of this consent does not affect the lawfulness of processing based on the consent before its withdrawal. The comparison of the data with the data stored by us is based on our legitimate interest in marketing and customer loyalty. We store your data only as long as it is necessary for the purposes for which we have collected your data, we are legally obliged to do so or we have a corresponding overriding interest in the storage. Beyond that data processed on your consent will no longer be stored if you withdraw your consent unless there is a legal obligation to do so or we need the data for the exercise or defense of legal claims.

Additional information about the tool can be found here   https://www.facebook.com/policy.php

7.Your rights in the context of the processing of your Data

You have the right

• to request information about which of your personal Data we process (article 15 GDPR);
• to rectify or erase your Data (article 16 GDPR);
• to restrict the processing of your Data (article 18 GDPR);
• to withdraw your consent (article 7 GDPR);
• to object to the processing of your Data (article 21 GDPR);
• to Data portability (article 20 GDPR).

If you believe that we violate your rights under the GDPR or national data protection law when processing your Data, please contact us. This is the only way we can treat your concerns as quickly as possible. You also have the right to lodge a complaint with a supervisory authority (in Serbia: www.poverenik.rs and in Austria: www.dsb.gv.at ).

8.Automated decision-making

We do not use automated decision-making or profiling.

9.Who can you contact?

If you have any requests or concerns, you can contact us directly by e-mail, by phone or by post to the following address:

PhiAcademy doo Belgrade-Voždovac

Bulevar Oslobodjenja 137, Belgrade, the Republic of Serbia

e-mail: info@phiopen.com