Privacy policy

Information on the processing of personal data

1. Introduction
   This document has been drawn up in accordance with and for the purpose of implementing the provisions of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the „Regulation”);
   The purpose of this document is to inform you, in accordance with the provisions of the Regulation, about the processing of your personal data by Addictive Design SRL.
   In accordance with the provisions of Art. 13 of the Regulation, we hereby bring the following information to your attention:

2. Identity and contact details of the Controller
   Your personal data is processed by: ADDICTIVE DESIGN S.R.L., with its registered office at B-dul Carol I no. 68, 3rd floor, Sector 2, Bucharest, Romania, registered with the Trade Register under no. J40/5290/2018, tax identification code 39201638, represented by Ana Stan, in her capacity as administrator. The Grey Matter HUB premises operate at the same address, on the 1st and 3rd floors.
   Under the Regulation, Addictive Design SRL acts as Controller, i.e. the legal entity that determines the purposes and means of processing your personal data.

3. The personal data we process
   We may process the following personal data relating to you, as the case may be: surname, first name, email, telephone, IP address, the organisation you belong to, the reason why you wish to be part of the Grey Matter HUB community, the membership requested, as well as any other data you enter in the application form on the Grey Matter HUB website.

4. The purposes for which your personal data is processed
   As the case may be, we process the data referred to in Art. 3 for the following purposes:
   a) to carry out the steps necessary for concluding the membership chosen at Grey Matter HUB, and to respond to requests submitted through the forms on the website (visit, event);
   b) to send you our newsletter, if you have subscribed;
   c) to understand, in aggregate form, how the website is used (traffic statistics), if you have accepted the „Analytics” category in the cookie banner;
   d) to measure the performance of our advertising campaigns and to display relevant ads to you, if you have accepted the „Marketing” category in the cookie banner;
   e) to ensure the security of the website and to prevent abuse of the forms.
   We do not process your data for other purposes; should we intend to process your personal data for other purposes as well, we will inform you and/or, as the case may be, obtain your consent, in accordance with the applicable legal provisions.

5. The legal bases on which we process your personal data
   We process your personal data referred to in Art. 3 as follows:
   – for the purpose under Art. 4 letter a): Art. 6(1)(b) of the Regulation (pre-contractual steps and performance of the contract);
   – for the purposes under Art. 4 letters b), c) and d): Art. 6(1)(a) of the Regulation (your consent, expressed through subscribing, or through the cookie banner). You may withdraw your consent at any time, without affecting the lawfulness of the processing carried out before the withdrawal;
   – for the purpose under Art. 4 letter e): Art. 6(1)(f) of the Regulation (our legitimate interest in keeping the website functional and protected against abuse);
   – where we have a legal obligation: Art. 6(1)(c) of the Regulation.

6. The storage period of your personal data
   We will store your personal data, as the case may be: until the conclusion of the contract corresponding to the membership requested at Grey Matter HUB, or, if you decide not to conclude the contract, until the moment you inform us of this.
   Data submitted through the contact forms is kept for the period necessary to resolve your request and thereafter, where applicable, for the duration of the contractual relationship.
   Newsletter subscription data is kept until unsubscribing.
   Data collected through cookies is kept for the lifetime of each cookie, as indicated in the cookie table below, or until the withdrawal of consent, if this occurs earlier.
   Upon expiry of the period for which your data is stored, it will be deleted.

7. Recipients of the personal data
   We will not disclose your personal data to third parties, with the following exceptions: we may transmit your data to the competent authorities where we have a legal obligation to do so; we may transmit your data to our suppliers who provide us with services such as: invoicing services, accounting services, security services, marketing/newsletter and user interaction services, hosting services.
   If you accept the corresponding cookie categories, the data collected through the analytics and advertising tools is also processed by:
   – Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) — measurement of traffic and advertising campaigns;
   – Meta Platforms Ireland Limited (Merrion Road, Dublin 4, Ireland) — measurement of advertising campaigns.
   If you choose to load the map on the contact page, your IP address is transmitted to Google for the purpose of displaying the map.

8. Where we store your personal data
   The data you send us directly (forms, newsletter, contract) is stored within the territory of the European Union.
   The suppliers referred to in Art. 7 (Google, Meta) may, however, transfer the data collected through cookies to the United States of America. These transfers are based on the European Commission's adequacy decision regarding the EU–U.S. Data Privacy Framework and/or on the Standard Contractual Clauses adopted by the European Commission, accompanied by supplementary measures, in accordance with Chapter V of the Regulation.
   If you do not want these transfers, do not accept the „Analytics” and „Marketing” categories in the cookie banner, or withdraw your consent from „Cookie settings”, in the footer of the page.

9. Security measures
   We process your personal data in accordance with our internal data security policy. In this respect, we assure you that we have implemented all the security measures required by the legislation in force to ensure the security of your data.
   In the event of a breach of the security of your personal data likely to result in a high risk to your rights and freedoms, we will inform you of that breach without delay and will take all necessary measures to remedy the problem and/or to mitigate its adverse effects.

10. Automated decision-making
    We do not take decisions producing legal effects concerning you or similarly significantly affecting you, based solely on automated processing, within the meaning of Art. 22 of the Regulation.
    If you accept the „Marketing” category in the cookie banner, the advertising tools of Google and Meta may, however, build interest profiles based on your browsing, in order to display relevant ads to you. This processing takes place only with your consent and you may object at any time, by refusing the „Marketing” category or by withdrawing your consent from „Cookie settings”, in the footer of the page.

11. Your rights11.a. Right of access.
    You have the right to obtain confirmation of the processing of your personal data and to obtain access to that data. To the extent that you send us a request to this effect, we will provide you with a copy of the personal data we process about you, together with all the information we are required to provide to you, in accordance with the provisions of the Regulation.11.b. Right to rectification and erasure.
    You have the right to request the correction of incorrect, inaccurate or incomplete personal data. You also have the right to request the erasure of personal data where it is no longer necessary in relation to the purposes for which it was processed, or where its processing is unlawful.11.c. Right to restriction of processing
    You have the right to request the restriction of the processing of your personal data in the following cases: you contest the accuracy of the data, in which case you may request the restriction of processing for the period during which we verify the accuracy of the data; the processing is unlawful and you oppose the erasure of the data; we no longer need your personal data, but you require it for the establishment, exercise or defence of a legal claim.
    
    11.d. Right to object
    You have the right to object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation. In such a case, we will no longer process your personal data, except in the situations in which, under the Regulation, we may continue processing your data.
    
    11.e. Right to data portability
    You have the right to receive the personal data which you have provided to us and which concerns you, in a structured, commonly used and machine-readable format. You also have the right to transmit that data to another controller.
    
    11.f. Right to withdraw your consent
    Where the processing is based on your consent (newsletter, analytics and marketing cookies), you have the right to withdraw your consent at any time, as easily as you gave it, without affecting the lawfulness of the processing carried out before the withdrawal. For cookies, use the „Cookie settings” link in the footer of every page. For the newsletter, use the unsubscribe link in each message or write to us at info@greymatterhub.ro.

12. Exercising your rights
    In order to exercise any of these rights, please send us your request in writing, to the email address: info@greymatterhub.ro
    We will respond to your request without undue delay, within one month at the latest, except where, due to the complexity or the number of requests, we are obliged to extend the response period by a maximum of 2 months, in accordance with the Regulation.
    We also anticipate that we may ask you to provide information in order to confirm your identity (for example, to click a verification link, to enter a user name or a password) in order to exercise your rights.

13. Lodging a complaint with the Supervisory Authority
    If you consider that your rights have been infringed, you may lodge a complaint with the competent Supervisory Authority, namely the National Supervisory Authority for Personal Data Processing (ANSPDCP), with its registered office at B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucuresti, Romania; telephone: +40.318.059.211; email: anspdcp@dataprotection.ro; web: www.dataprotection.ro.

14. Contact details
    For any request you may contact us at the email address: info@greymatterhub.ro

Privacy policy

This website uses cookies. The information presented below is intended to give the user more details about the placement, use and administration of the „cookies” used. A few useful links related to this subject are also provided. If you need more information and it is not to be found below, you may contact us using the details on the contact page.

Please read the following information carefully:

This website may use both its own cookies and cookies originating from third parties, in order to provide visitors with a much better browsing experience and services tailored to the needs and interests of each of them.

In what we call „web 2.0”, „cookies” play an important role in facilitating access to and delivery of the many services the user enjoys on the internet, such as:

• Personalisation of certain settings such as: the language in which a website is viewed, the currency in which certain prices or rates are expressed, keeping the options for various products (sizes, other details, etc.) in the shopping basket (and remembering these options) – thereby generating the flexibility of the „shopping basket” (accessing previous preferences by using the „forward” and „back” buttons)
• Cookies give website owners valuable feedback on how their websites are used by users, so that they can make them even more efficient and more accessible to users.
• They allow multimedia or other types of applications from other websites to be included in a given website in order to create a more valuable, more useful and more pleasant browsing experience;
• They improve the effectiveness of online advertising.

What is a „cookie”?

An „Internet Cookie” (a term also known as „browser cookie” or „HTTP cookie” or simply „cookie”) is a small file, made up of letters and numbers, which will be stored on the computer, mobile terminal or other equipment of a user from which the Internet is accessed.

The cookie is installed by a request issued by a web server to a browser (e.g. Internet Explorer, Chrome) and is completely „passive” (it contains no software programs, viruses or spyware and cannot access the information on the user's hard drive).

A cookie consists of 2 parts: the name and the content or value of the cookie. Moreover, the lifetime of a cookie is determined; technically, only the web server that sent the cookie can access it again at the moment a user returns to the website associated with that web server.

Cookies in themselves do not require personal information in order to be used and, in most cases, do not personally identify internet users.

There are 2 broad categories of cookies:

• Session cookies – these are stored temporarily in the web browser's cookie folder so that it remembers them until the user leaves that website or closes the browser window (e.g. at the moment of logging in/out of a webmail account or on social networks).
• Persistent cookies – These are stored on the hard drive of a computer or equipment (and generally depend on the preset lifetime of the cookie). Persistent cookies also include those placed by a website other than the one the user is visiting at that moment – known as „third party cookies” – which may be used anonymously to remember a user's interests, so that advertising as relevant as possible is delivered to users.

What are the advantages of cookies?

A cookie contains information that links a web browser (the user) to a particular web server (the website). If a browser accesses that web server again, it can read the information already stored and react accordingly. Cookies ensure users a pleasant browsing experience and support the efforts of many websites to offer users convenient services: e.g. – online confidentiality preferences, website language options, shopping baskets or relevant advertising.

What is the lifetime of a cookie?

Cookies are administered by web servers. The lifetime of a cookie may vary significantly, depending on the purpose for which it is placed. Some cookies are used exclusively for a single session (session cookies) and are no longer retained once the user has left the website, and some cookies are retained and reused each time the user returns to that website („permanent cookies”). Nevertheless, cookies may be deleted by a user at any time through the browser settings.

What are third party cookies?

Certain content sections on some websites may be supplied through third parties/suppliers (e.g. a news box, a video or an advertisement). These third parties may also place cookies through the website and they are called „third party cookies” because they are not placed by the owner of that website. Third party suppliers must also comply with the law in force and with the privacy policies of the website owner.

How cookies are used by this website

The complete list of the cookies this website may place, with the provider and the duration of each, is in the table above. In short, we use three categories:

• Strictly necessary – they make the website usable: they remember your choice in the cookie banner and ensure the security of the forms. They cannot be disabled and they do not track your browsing.
• Analytics – they show us, in aggregate form, how many visitors we have and which pages are read, so that we can improve the website. They are placed only with your consent.
• Marketing – they measure the performance of our ads and allow relevant ads to be displayed. They are placed only with your consent.

This website does not use registration or authentication cookies (there are no user accounts), shopping basket cookies (we do not sell online) and it does not display ads on its pages.

You may change your choice at any time from the „Cookie settings” link, located in the footer of every page.

Other third party cookies

If you choose to load the map on the contact page, Google may place cookies through it. The map does not load automatically: it appears only after you press the dedicated button.

Likewise, when you open one of our links to the social networks, that network will record your activity on its own website, in accordance with its own privacy policy.

What type of information is stored and accessed through cookies?

Cookies keep information in a small text file that allows a website to recognise a browser. The web server will recognise the browser until the cookie expires or is deleted. The cookie stores important information that improves the Internet browsing experience (e.g. the language settings in which a website is to be accessed; keeping a user logged in to a webmail account; online banking security; keeping products in the shopping basket).

Why are cookies important for the Internet?

Cookies are central to the efficient functioning of the Internet, helping to generate a browsing experience that is friendly and adapted to the preferences and interests of each user. Refusing or disabling cookies may make some websites impossible to use.

Refusing or disabling cookies does not mean that you will no longer receive online advertising – only that it will no longer be able to take into account your preferences and interests, as revealed by your browsing behaviour.

Examples of important uses of cookies (which do not require the authentication of a user through an account):

• Content and services adapted to the user's preferences – categories of news, weather, sport, maps, public and government services, entertainment websites and travel services.
• Offers adapted to users' interests – remembering passwords, language preferences (e.g. displaying search results in Romanian).
• Remembering child protection filters regarding content on the Internet (family mode options, safe search functions).
• Limiting the frequency with which ads are served – limiting the number of times an advertisement is displayed to a given user on a website.
• Providing advertising that is more relevant to the user.
• Measurement, optimisation and analytics features – such as confirming a certain level of traffic on a website, what type of content is viewed and how a user reaches a website (e.g. through search engines, directly, from other websites, etc.). Websites carry out these analyses of their use in order to improve the websites for the benefit of users.

Security and confidentiality issues

Cookies are NOT viruses! They use plain text formats. They are not made up of pieces of code, so they can neither be executed nor auto-run. Consequently, they cannot duplicate or replicate themselves on other networks in order to run or replicate again. Since they cannot perform these functions, they cannot be considered viruses. Cookies may nevertheless be used for negative purposes. Since they store information about users' preferences and browsing history, both on a particular website and across several other websites, cookies may be used as a form of Spyware. Many anti-spyware products are aware of this fact and constantly flag cookies to be deleted as part of anti-virus/anti-spyware deletion/scanning procedures.

In general, browsers have built-in confidentiality settings that provide different levels of cookie acceptance, validity period and automatic deletion after the user has visited a given website. Other security aspects related to cookies

Since the protection of identity is very valuable and is the right of every internet user, it is advisable to know what problems cookies might create. Because information is constantly transmitted through them in both directions between the browser and the website, if an attacker or unauthorised person intervenes in the course of the data transmission, the information contained in the cookie may be intercepted. Although very rare, this may happen if the browser connects to the server using an unencrypted network (e.g. an unsecured WiFi network).

Other cookie-based attacks involve incorrect cookie settings on servers. If a website does not require the browser to use only encrypted channels, attackers may use this vulnerability to trick browsers into sending information through unsecured channels. Attackers then use the information for the purposes of gaining unauthorised access to certain websites. It is very important to be careful in choosing the most appropriate method of protecting your personal information.

Tips for safe and responsible cookie-based browsing

Due to their flexibility and to the fact that most of the most visited and largest websites use cookies, they are almost unavoidable. Disabling cookies will not allow the user access to the most widespread and used websites, among which Youtube, Gmail, Yahoo and others. Here are a few tips that can ensure you browse without worries but with the help of cookies:

• Customise your browser settings regarding cookies to reflect a level of security in the use of cookies that is comfortable for you.
• If you do not mind cookies and you are the only person using the computer, you may set long expiry periods for storing the browsing history and personal access data.
• If you share access to the computer, you may consider setting the browser to delete individual browsing data each time you close the browser. This is one way of accessing websites that place cookies and of deleting any visit information when the browsing session is closed.
• Install and constantly update anti-spyware applications.

Many of the applications for detecting and preventing spyware include the detection of attacks on websites. In this way, they prevent the browser from accessing websites that could exploit the browser's vulnerabilities or download dangerous software. Make sure that your browser is always updated. Many of the cookie-based attacks are carried out by exploiting the weak points of old versions of browsers.

Cookies are everywhere and cannot be avoided if you wish to enjoy access to the best and largest websites on the Internet – local or international. With a clear understanding of how they operate and of the benefits they bring, you can take the necessary security measures so that you can browse the internet with confidence.

How can I stop cookies?

Disabling and refusing to receive cookies may make certain websites impractical or difficult to visit and use. Likewise, refusing to accept cookies does not mean that you will no longer receive/see online advertising.

It is possible to set the browser so that these cookies are no longer accepted, or you can set the browser to accept cookies from a particular website. But, for example, if you are not registered using cookies, you will not be able to leave comments.

All modern browsers offer the possibility of changing the cookie settings. These settings are usually found in the „options” or in the „preferences” menu of your browser. In order to understand these settings, the following links may be useful; otherwise you can use the „help” option of your browser for more details.

• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari

For the settings of cookies generated by third parties, you may also consult the website:

• http://www.youronlinechoices.com/ro/

Useful links

If you would like to find out more information about cookies and what they are used for, we recommend the following links:

• Microsoft Cookies guide
• All About Cookies
• http://www.youronlinechoices.com/ro/