Privacy and personal data protection Policy
is the Policy on the privacy and protection of personal data (hereinafter
referred to as “Policy”), adopted by GLITCH MEDIA SRL (hereinafter referred to
as “GLITCH MEDIA”).
MEDIA respects your privacy and is committed to protecting the personal data
you have provided to us. We undertake to collect and use personal data in
accordance with the General Data Protection Regulation (GDPR).
Policy will inform you of how we handle your personal data and will detail your
rights in relation to your personal data and how the law (including the GDPR)
Policy applies to the personal data of our customers, business partners, other
persons who contact and visit us and their representatives and employees,
potential employees or interns and applies to data collected through our
websites https://photolog.cloud , https://glitch.ro , https://photolog.studio , respectively to
our services and/ or products’ websites, namely PhotoLog, as well as during our
events, respectively personal data collected by e-mail or other offline lines.
1. Important information and details about GLITCH MEDIA
protection of personal data
This Policy is intended to inform you of how GLITCH MEDIA collects and uses
personal data as a result of using our websites, as a result of registering for
any Events (as defined in the Glossary) or courses organized by GLITCH MEDIA,
as a result of subscription to any GLITCH MEDIA publications or newsletter or
as a result of collaboration of any kind, current or potential, with GLITCH
Our website, respectively our ervices
and/ or products’ websites are not
intended for minors and we do not consciously collect personal data of minors.
your personal data together with any other information notice about personal
data or any processing notice that we may provide on certain occasions when we
collect or process personal data about you, so that be fully informed of the
manner and purpose of the use of this data. This Policy complements the other
notifications and is not intended to replace them.
GLITCH MEDIA SRL is the operator for
your personal data (collectively referred to as "Company",
"us", "to us" or "our" in this personal data
It is important that the personal data
we hold is accurate and current. Please let us know if your personal data
changes during your relationship with us.
2. The data we collect
Personal data or personal information means any information about a person
from which that person can be identified. Does not include data in which the
identity was removed (anonymous data).
In order to provide our services, we collect or receive your personal
information in different ways. We often choose what information to provide, but
sometimes we need certain information from you to use so that we can provide
you with these services.
We may collect, use, store and process different types of personal data
about you that we have grouped together (all or any):
• Identity data includes first name, last name, username or similar
identifier, personal numerical code, specialty, professional grade, job, date of
birth and gender.
• Contact details include billing address, delivery address, e-mail address
and phone numbers.
• Financial data includes bank account and payment card details.
• Transaction data includes details about payments to and from you and other
details about the products and services you have contracted from us.
• Technical data includes [IP protocol] address, your connection data,
browser type and version, time zone setting and location, browser plug-in types
and versions, operating system and platform, and other technologies on the
devices you are using for the use of the site.
• Profile data includes your username and password, purchases or orders
made by you, interests, preferences, feedback and survey responses, including
user data for registration on the platforms where webinars are eventually
• Usage data includes information about how you use our website, products
• Marketing and communication data includes your preferences in receiving
our communications from us and our third parties and your communication
• Media data includes audio, video, and photos / pictures.
We also collect, use, and share aggregate Google Analytics data, such as
statistical or demographic data.The aggregated data may be obtained from your
personal data, but is not considered personal data in accordance with
applicable law, as this data does not directly or indirectly reveal your
identity. For example, we may aggregate your usage data to calculate the percentage
of users who access an GLITCH MEDIA’s services and/ or products.
We do not collect any special categories of personal data
about you (this includes details about your race or ethnicity, religious or
philosophical beliefs, sex life, sexual orientation, political opinions,
membership in trade unions / political parties, information about your health
and biometric and genetic data). We also do not collect any information about
criminal convictions and crimes.
If you do not provide us with personal
If we need to collect personal data by law or for the
performance of a contract we have with you or the organizations you are
affiliated with and you are unable to provide such data when requested, we may
not be able to perform the contract we have (for example, to provide you with
goods or services). In this case, it may be necessary to cancel a product or
service that you have with us, but we will notify you, if applicable, at that
3. How is personal data collected?
We use different methods to collect personal data including by:
• Direct interactions. We
collect your data when you voluntarily provide us with contact details by
filling in any forms in digital / physical format provided or by GLITCH MEDIA,
by filling in the data on our website or on our services and/ or products'
websites or by correspondence with us (including mail, telephone, e-mail or
other method of communication). These include personal data that you provide
when, for example, but not limited to:
for our products or services;
account on our website or on our services/ and or products’ websites;
to our services or publications;
MEDIA offers or promotional materials;
an Event or course organized by GLITCH MEDIA;
a contest, competition, survey organized by GLITCH MEDIA;
a position within GLITCH MEDIA;
feedback on our services and products;
offer to provide services for us.
Also, there are situations in which we collect media data at Events
eventually organized by GLITCH MEDIA. For example, (i) if you accept the
invitation to be a speaker at a presentation / workshop, etc.within an GLITCH
MEDIA Event, we will collect media data, respectively: photos and videos if the
event is recorded, (ii) if you choose to ask questions to the panel during a
video recording event, then your intervention will be registered (iii) if
during an Event, there is a photo panel and you will verbally request GLITCH
MEDIA staff or GLITCH MEDIA collaborators to take photos. All media data
collected will be collected during GLITCH MEDIA Events and only if you
voluntarily take action in this regard.
• Automatic technologies or
interactions. As you interact
with our website, we may automatically collect technical data about your
equipment, actions and navigation patterns.We collect this personal data using
• Third parties or public sources. We may receive personal data about you
from various third parties or from public sources (public registries). These
sources also include:
organizations and associations to which you are affiliated and which contract
our services or products;
authorities or institutions of any kind;
institutions (for example, when you make a payment to us by payment order).
4. How we use personal data
We will only use your personal data when the law allows us to. Most often,
we will use your personal data in the following situations:
• If we have to execute a contract concluded with you (or which we are
about to conclude);
• If we need to execute a contract with an organization, association or
company to which you are affiliated; (e.g. participate in a possible event
organized by GLITCH MEDIA)
• If necessary for our legitimate interests (or those of a third party) and
your fundamental interests and rights do not exceed those interests;
• If we have to comply with a legal or regulatory obligation;
• If you provide us with the express prior consent or on the basis of fair
proof of your consent, provided by a third party who communicates this data to
• If we disseminate video or photo content from any GLITCH
MEDIA Events, on the media channels of GLITCH MEDIA or of the partners for
which GLITCH MEDIA organizes any Events, for professional, media communication
or educational and / or scientific purposes.
The purpose for which we use your
We have presented below, in a table format, a description of all the ways
in which we intend to use your personal data and what are the legal bases on
which the processing is based. We have also identified our legitimate
interests, where appropriate.
Please note that we may process your personal data based on several legal
grounds, depending on the specific purpose for which we use the data. Contact
us if you need details on the specific legal basis on which we rely to process
personal data, if several reasons have been set out in the table below.
basis for the processing, including the legitimate interest, where applicable
of a new client / participant / student
or executing a contract
processing and execution, including:
of costs, fees, taxes;
(e) Data for
marketing and communication
performance of a contract
the relationship with you, including:
of changes to policies on terms and conditions, protection of personal data,
other documents as appropriate;
solicit feedback or participate in surveys;
communicate to you requests or other matters relating to our partnership.
Marketing and communication data
performance of a contract
interest (to keep records up to date and to analyze how customers use our
products and services)
the business and this website (including troubleshooting, data analysis,
testing, system maintenance, support)
Necessary for legitimate interest (business administration, IT infrastructure
Necessary for the fulfillment of a legal obligation
of legal reporting obligations to professional organizations and competent
for fulfilling a legal obligation
of suggestions and recommendations about GLITCH MEDIA products and services
that are of interest
for legitimate interest (business administration)
(online / offline)
of a contract
We strive to provide you with options for the use of
personal data, especially in terms of marketing and advertising.
We may use your identity, contact, technical, usage and
profile data to form an image of what we think you would like or need or that
may be of interest to you. This is how we decide what products, services and
offers may be relevant to you.
You will receive marketing communications from us if you
have requested information from us or participated in any Events or courses
organized by us or if you have provided us with your data when you entered a
contest or registered for a promotion and / or you have placed an order for
services and / or products and, in each case, if you have not withdrawn your
You can request that we stop sending you marketing
messages at any time by e-mail to [email protected]
or, if applicable, by unsubscribing via
the UNSUBSCRIBE link in the newsletter.
If you opt out of receiving these marketing messages, we
may continue to process your personal data, based on another legal basis, where
we have at least two legal bases on which we process personal data.
Changing the Purpose
We will use your personal data only for the purposes for
which we collected it, unless we reasonably believe that we must use it for
another reason and that this reason is compatible with the original purpose. If
you would like to receive an explanation of how the processing for the new
purpose is compatible with the original purpose, please contact us.
If we have to use your personal data for undeclared
purposes, we will notify you and explain the legal basis that allows us to do
Please note that we may process your personal data
without your knowledge or consent, in accordance with the above rules, if
required or permitted by law.
5. Disclosure of Personal Data
We may share your personal data with the parties listed
below for the purposes set out in the table in point 4 above.
Internal third parties, as defined in the Glossary.
External third parties, as defined in the Glossary.
Third parties to whom we may choose to transfer or merge
parts of our business or assets. Alternatively, we may seek to acquire or merge
with other businesses. If there is a change in our business, then the new
owners may use your personal data in the same way as described in this Policy.
We ask all our collaborators and partners to respect the
security of your personal data and to treat them in accordance with the
applicable legislation in force. We do not allow employees to use your personal
data for their own purposes. They may use your personal data only if we give
them permission to process it and only for the purposes mentioned by us.
6. Data security
We have implemented appropriate security measures to prevent
accidental loss of your personal data, unauthorized use or access, modification
or disclosure of your personal data. In addition, we limit access to your
personal data to those employees, agents, contractors and other third parties
who are in dire need of such data. They will only process your personal data in
accordance with our instructions and will be subject to confidentiality
obligations in this regard.
7. Data retention
As long as we keep personal
We will retain your personal data for as long as is
necessary to fulfill the purposes for which we have collected it, including for
the purpose of fulfilling any legal, accounting or reporting requirements.
In order to properly determine the retention period for
personal data, we consider the value, nature and sensitivity of personal data,
the potential risk of harm caused by unauthorized use or disclosure of your
personal data, the purposes for which we process your personal data and whether
we can achieve these goals by other means.
8. Your rights
In certain circumstances, you have rights under
applicable data protection law in respect of your personal data. Such rights
• The right to access your personal data.
• The right to rectify your personal data.
• The right to request the deletion of your personal
• The right of the opposition regarding the processing of
your personal data.
• The right to request the restriction of the processing
of your personal data.
• The right to request the transfer of your personal data
• The right to withdraw consent.
• The right not to be the subject of any individual
decision or automated individual decision-making process (including, but not
limited to, automated profiling).
You will not have to pay any fees to access your personal
data (or to exercise any of the rights granted to you in connection with them).
However, we may charge a reasonable fee if your request is manifestly
unfounded, repeated or excessive. Alternatively, we may refuse to comply with
your request in these circumstances.
What we can ask of you
We may request specific
information from you to help you confirm your identity and secure your right to
access your personal data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person who is not
entitled to receive it.
We try to respond to all legitimate requests within
thirty (30) days. Occasionally, it may take more than thirty (30) days if your
request is particularly complex or if you have made several requests. In this
case, we will notify you and keep you informed of the status of the request.
GLITCH MEDIA EVENTS
Event (s) means
any event organized by us, including virtual events, in collaboration with our
customers or partners, regardless of how it is organized, online (virtual),
offline or in any combination of the two variants, respectively: conference,
seminar, congress, webinar, workshop, presentation, conference with speaker in
the hall and participants who connect online etc.
Legitimate interest means
our interest in running and managing our business to enable us to offer you the
best services and / or products, as well as the best and safest experience.We
make sure that we consider and balance any potential impact on you (both
positive and negative), respectively on your rights, before processing your
personal data for our legitimate interests.We do not use your personal data for
activities in which our interests are overburdened by the impact on you (unless
we have your consent or if the
applicable law does not provide otherwise).
Execution of the
Contract means the processing of your data if it is necessary for
the execution of a contract to which you are a party or to which an association
or company to which you are affiliated is a party or to take action at your
request before concluding such a contract.
Compliance with a
legal or regulatory obligation means the processing of your
personal data if it is necessary to comply with a legal or regulatory
obligation to which we are subject.
parties are, as the case may be, other branches/ subsidiaries of GLITCH
MEDIA and/ or other entities that act as operators or processors and that have
their headquarters in Romania, associates, employees or collaborators of GLITCH
External third parties (listing
• Service providers that provide IT systems administration
and management services.
• Professional consultants including lawyers,
accountants, bankers, auditors and insurers providing consulting, banking,
legal, insurance and accounting services.
• Public regulatory authorities and institutions and
other public authorities in Romania or the European Union.
• Collaborators or business partners with whom GLITCH
MEDIA works in order to carry out its activity.
You have the following rights in connection with your
The right to access personal data, which provides that you have the right to a copy
of personal data held by us and to verify that they are legally processed.
The right to
rectification by which you can request the correction of personal data
we hold about you. This allows you to request the correction of any incomplete
or inaccurate data we hold about you. Please note that it may be necessary to
verify the accuracy of the new data you provide to us.
The right to delete
data (“the right to be forgotten”). This allows you to ask us to
delete or remove your data.if there are no longer good reasons to continue
processing. Please note, however, that we may not always be able to comply with
your request of deletion, for specific legal reasons, which will be notified to
you, if applicable, at the time of your specific request.
The right to object
to the processing of personal data when we process data based on
legitimate interest (ours or a third party) and when in your particular
situation you consider that your fundamental rights and freedoms are violated. You
may also object to the processing of your data for marketing purposes. In some
cases we may demonstrate legitimate and compelling reasons justifying the
processing and prevailing over personal interests, rights and freedoms.
The right to
restrict processing. This right allows you to request that we suspend the
processing of your personal data in the following cases: (a) whether you wish
to establish the accuracy and correctness of the data; or; (b) if our
processing of the data is illegal, but you object to the deletion; (c) if you
need to keep the data, even if we no longer process it, because you need it to
establish, exercise or defend rights in court; or (d) you objected to the
processing of your data, but we must verify that we have mandatory legal
reasons to process it.
The right to data
portability. We will provide you or a third party of your choice with
your personal data in a structured, commonly used format that can be read
automatically. Please note that right applies to automatic data processing for
which you have given us your consent or, if we have used the data, to execute a
contract with you.
The right to
withdraw consent when we base our processing on your consent. However,
this right shall not affect the lawfulness of the processing carried out before
the withdrawal of the consent in question.
The right not to be
subject to any individual decision or automated individual decision-making
process, including, but not limited to, the creation of profiles
that produce legal effects that concern or affect you in a similar way.