Terms of Use & Privacy Policy These T&C regulate the rules for using our website secureid.ro and POWERKIDS applications in Romania market. More specifically it regulates the access and use by you, an individual, of services made available by POWER DYNAMIC TECHNOLOGY SRL (hereinafter referred to as "POWERKIDS"), a limited liability company, registered in Romania, having registration number J40/15570/2006, fiscal code RO19068945, registered in Bucharest, St Petre Paun 27. YOU MUST CAREFULLY REVIEW THESE TERMS BEFORE CHOOSING TO USE POWERKIDS'S SERVICES MADE AVAILABLE THROUGH ONLINE AND MOBILE DEVICE PLATFORMS. IF YOU DO NOT AGREE WITH THESE TERMS, YOU MUST NOT USE OUR SERVICES. Your access to and use of the services constitutes your agreement to comply with these T&C, which gives rise to a contractual relationship between you and POWERKIDS. If you do not agree to these Terms, you may not access or use the services. The collection and use by us of your personal information in connection with the services is carried out according to the POWERKIDS Privacy Policy, located at https://secureid.ro/#privacy, to which you must also agree before creating the POWERKIDS user account. If after reading this agreement in its entirety you are still unsure of anything or you have any questions, please feel free to contact us at enroll@secureid.ro. SERVICES POWERKIDS services represent a technology platform which helps you, the User, make payments to third parties, the Merchants, through face recognition on top of other multi-factor authentication methods. TAKE KNOWLEDGE THAT: POWERKIDS is only a technology provider and while operating on the POWERKIDS platform, POWERKIDS shall by no means enter into the possession of the funds due to Merchants or Users and there is no actual transfer of funds from Users to POWERKIDS or from POWERKIDS to Merchants during a merchant transaction. The payments and transactions at Merchant locations are performed by using POWERKIDS on-demand distributed biometric payment technology and take place directly between the Users, Merchants, 3rd Party Payment Providers and Banks or, as the case may be in Romania, between Users and Merchants by our 3rd party payment provider euplatesc.ro. POWERKIDS is an independent contractor and is not your agent or trustee. Your POWERKIDS account is not a bank account. POWERKIDS is not an issuing bank, seller, processor or depository institution. You are conducting transactions with third parties using POWERKIDS are between you and that third party's card processing service provider, and not with POWERKIDS or any affiliates. POWERKIDS is the owner of POWERKIDS platform and is not a party to your transactions at participating Merchant locations. Unregistered users are not permitted to use the services and any attempts to do so can trigger legal proceedings against such persons. We only provide our site for domestic and private use. Our services, including creating and using a POWERKIDS User account are made available free of charge for Users. YOUR USE OF SERVICES To use most aspects of the services, you must register and maintain an active personal user account of the Services (the "User Account"). In order to register your User Account, you will need to submit certain personal data (herein inclusive biometric data too) to POWERKIDS. Detailed information related to what personal data you need to share with us and how we manage your personal data you can find at https://secureid.ro/#privacy. You are responsible for all activities carried out through your User Account and you may open only one POWERKIDS account. Payments which are carried out through POWERKIDS platform should be in accordance with applicable laws and regulations. HOW IT WORKS The User uses the POWERKIDS technology to authorise payment at the merchant's point of sale (mPOS) terminal using the POWERKIDS Merchant Kiosk Retail System and app using a face recognition engine. Registered POWERKIDS Users can shop and pay for goods and services using their face/biometric identification only at Merchants enrolled in POWERKIDS who have a POWERKIDS Merchant Kiosk Retail System installed and integrated in their stores. Face detection and face recognition is processed locally on the POWERKIDS Merchant Kiosk Retail System device and your "selfie" photo file is not uploaded or downloaded or saved on any server for our face recognition process to function. Your biometric face template is a unique unidentifiable and encrypted data that we use to match your real-time video capture image with your POWERKIDS account at the point of purchase directly on the POWERKIDS Merchant Kiosk Retail System. Account security settings are also checked against POWERKIDS API for any user or transaction restrictions or fraud alerts on your account or if the face matching service has an issue with accuracy/duplicates. If necessary, the User will need to type in their PIN-ON-GLASS 4-digit secret code into the POWERKIDS Merchant Kiosk Retail System during checkout for manual confirmation and authorization to process the transaction. User gets to visually verify the total purchase price and confirms they want to proceed with the transaction after passing the secret code and face recognition steps from above. POWERKIDS sends the transaction details to the 3rd Party Payment Gateway for processing (in Romania this service is provided by euplatesc.ro). For more details on euplatesc.ro system please view their F.A.Q. webpage located at https://www.euplatesc.ro/faqs.php. New User's can register a new SecureID account through our POWERKIDS SecureID App available for free download on iOS or Android smartphone device from both Google Play Store and Apple App Store. For new users, after they download the app and register, the user receives a welcome e-mail with login details, then users login to manage their account available on both iOS and Android mobile smartphones. Existing User's can manage their digital wallet via the POWERKIDS SecureID smartphone app and add/remove debit or credit cards. Users can add one active card at any time in their POWERKIDS SecureID app, view their profile and add/update/delete their account profile from the app, view transaction history, initiate disputes on transactions with Merchants directly via email, report a fraud alert, update their basic account information and update their biometric face template data. DEFINITIONS User – the person that creates a user account on POWERKIDS platform, meaning the person who is able in certain conditions to buy goods or services from the Merchants enrolled in POWERKIDS without the need to carry cash, cards or their mobile phones when they go shopping. Merchant – the store or vendor who sells goods or services to the User. Participating merchants have our POWERKIDS Merchant Kiosk Retail System installed and integrated in their stores. Merchant's bank – the merchant's bank is the destination account for the payment requested by the mPOS from the User's bank account. User's bank – this is the financial institution that issued the User's bank/credit card and the source of funds involved in the transaction to pay for the goods or services purchased. ACCESS TO NETWORK AND DEVICES It is your responsibility to gain access to the data network required to use the services. The fees and prices charged by your mobile network may be applied for data and message transfer, if you access or use the services on a device that allows wireless communication, you are responsible for paying these rates and prices. You are responsible for obtaining and updating the hardware or devices required to access and use the services, as well as for any updates thereof. POWERKIDS does not warrant that the services or any portion thereof will work on any particular hardware or device. In addition, the services may be affected by failures and delays inherent in the use of the Internet and electronic communications. USER'S RESPONSIBILITIES Transactions are concluded only by and between Users and Merchants. You cannot hold POWERKIDS liable for any financial transaction made through POWERKIDS platform. You will use the POWERKIDS account in good faith and in compliance with all applicable laws and regulations. You will not use our services to defraud POWERKIDS or engage in any other unlawful activities. All the information you provide in connection with the services is true, complete, lawful and accurate. As User you will be sole responsible for payment of any taxes or duties that may be imposed on any products or services purchased through POWERKIDS. You agree to indemnify and hold harmless POWERKIDS and its officers, directors, employees and agents in the event of any claims, claims, losses, damages and expenses (including attorneys' fees) arising out of or in connection with: (i) your use of the services or of the services or goods obtained through your use of the services; (ii) your failure to comply with or breach any of these Terms or (iii) your violation of the rights of any third party. You cannot assign, in whole or part, this agreement to any person or entity. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site, if you are unsure of certain aspects. The User is responsible for updating the data in the user account as soon as changes occur. POWERKIDS assumes no responsibility for any damages of any kind caused by this breach of obligation. Considering the dependence of the services offered by the Internet access, the possible technical and system limitations that may arise, POWERKIDS undertakes only diligence obligations regarding the availability of services provided. No data transmission through the Internet can be guaranteed to be one hundred percent secure. Consequently, despite our efforts to protect your information and use secure information transmission protocols (https), POWERKIDS cannot guarantee the security of the information transmitted by you to us. We therefore warn you that any information sent to us will be done at your own risk. User understands and accepts that POWERKIDS shall transmit its data to the investigating bodies, if it receives a reasoned request from an authorized public institution. JURISDICTION If any dispute, controversy or claim arises out of, in connection with or relating to these Terms, the relevant parties shall first attempt to resolve the dispute through amicable negotiations. If you have a dispute with us, do not hesitate to contact us and we shall aim to solve the matter as soon as possible. You hereby acknowledge that these Terms of use, their subject matter and their formation, are governed by Romanian law. The courts of law from Romania will have exclusive jurisdiction. SUSPENSION OF THE ACCOUNT We may close, suspend, or limit your access to your POWERKIDS Account (or longer if pursuant to a court order or other legal process) if you violate these Terms, or as may be otherwise specified in this Agreement. Temporary suspension is also possible in case of security concerns. If you are unable to use POWERKIDS directly or indirectly due to either system suspension or any Force Majeure as defined below, you agree that to the full extent permitted by applicable law you will not hold POWERKIDS liable for any default, delay or failure in performing its obligations under these Terms. POWERKIDS REGISTERED TRADEMARK "Power Dynamic Technology" is a European registered trademark of POWER DYNAMIC TECHNOLOGY SRL. You are not permitted to use it without our approval. We own all intellectual property rights for POWERKIDS products and services. All such rights are reserved. WE MAY MAKE CHANGES TO THESE T&C AND/OR TO OUR SITE We may amend these T&C from time to time. Every time you wish to use our site, please check these terms to ensure you understand the terms that apply at that time. If you object to the renewed Terms you may stop using our services and terminate this agreement by contacting us at [enroll@secureid.ro]. Also, we may bring changes to our website, or we may suspend or withdraw our site. We will try to give you reasonable notice of any important changes to these Terms. EXCLUSIONS AND LIMITATIONS OF LIABILITY Neither you, nor POWERKIDS shall be held liable for any default, delay or failure in performing its obligations under these Terms resulting directly or indirectly from acts of nature, forces or causes beyond the reasonable control of such party, including (i) a fire, flood, elements of nature or other acts of God, (ii) an outbreak or escalation of hostilities, war, riots or civil disorders, or an act of terrorism; (iii) Internet failures, computer, telecommunications, electrical power failures or any other equipment failures; (iv) a labor dispute, (v) acts or omissions of a government authority prohibiting or impeding the affected party from performing its obligations under these Terms, including orders of domestic or foreign courts or tribunals, governmental restrictions, sanctions, restrictions on foreign exchange controls. If a Force Majeure Event occurs, the non-performing party to these Terms will be excused from any further performance of the obligations affected by the event only for as long as the Force Majeure Event continues, and the party continues to use commercially reasonable efforts to resume performance. POWERKIDS is also exonerated from liability for fortuitous case and events assimilated to such (e.g. technical or security problems etc.). LIMITATION OF LIABILITY The services are provided "as is", "as available" and without any representation or warranty, whether express, implied, or statutory. POWERKIDS, our affiliates, and our respective officers, directors, agents, joint ventures, employees, and suppliers specifically disclaim any implied warranties of title, merchantability, fitness for a particular purpose or non-infringement. POWERKIDS makes no warranty that (i) the services will meet your requirements, (ii) the services will be uninterrupted, timely, secure, or error-free, or (iii) the quality of any products, services, information, or other material purchased or obtained by you will meet your expectations. You expressly understand and agree that POWERKIDS and our affiliates and service providers, and their respective officers, directors, agents, joint ventures, employees, and representatives will not be liable for any indirect, incidental, special, consequential, exemplary damages, or damages for loss of profits including but not limited to, damages for loss of goodwill, use, data, or other intangible losses (even if POWERKIDS has been advised of the possibility of such damages), whether based on contract, tort, negligence, strict liability, or otherwise, resulting from: (i) the use or the inability to use the services; (ii) the cost of procurement of substitute goods and services resulting from any goods, data, information, or services purchased or obtained or messages received or transactions entered into through or from the services; (iii) unauthorized access to or alteration of your transmissions or data; or (iv) any other matter relating to the services. We reserve the right, and by accepting this T&C you expressly agree with our right to freely assign or transfer this agreement and the rights and obligations of this Agreement, to any third party at any time without notice or consent. Except as set forth in this agreement, all payment transactions processed through the services are non-refundable. You may have additional refund or charge-back rights under your agreement with the recipient of such funds, your bank, or applicable law. You should periodically review statements from your bank, which should reflect all applicable payment transactions made using that payment method. You can also always access the record of your POWERKIDS transactions by logging into your account. POWERKIDS does not guarantee or ensure that a complete transaction shall take place between the User and the Merchant. Also, we will not be liable for damage that you could have avoided by following our advice to apply an update offered to you free of charge or for damage that was caused by you failing to correctly follow installation instructions or to have in place the minimum system requirements advised by us. If at a certain moment our site shall contain links to other sites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them. We have no control over the contents of those sites or resources. We make no representations, warranties or guarantees, whether express or implied, that the content on our site is accurate, complete or up to date. The limitations as provided in this section are not intended to modify your consumer rights which cannot be excluded under applicable law. GENERAL PROVISIONS You may terminate this agreement at any time by closing your account and discontinuing use of the services. You may contact us at [enroll@secureid.ro] for more details related to this matter. If any provision of these Terms is held to be invalid or unenforceable, such provisions shall be considered as deleted and the remaining provisions shall be enforced. Any failure by POWERKIDS to exercise any of our rights under these Terms shall not constitute a waiver of such right or a waiver with respect to subsequent or similar breach. A waiver shall be effective only if made in writing. These Terms constitute the entire agreement between the parties regarding their subject matter and cancel and replace all previous or concurrent agreements and commitments regarding the subject matter. PRIVACY POLICY INTRODUCTION As of May 25, 2018, European Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and the free movement of such data ("the Regulation" or "the GDPR") is applicable. Its main goal is to increase the level of protection of personal data and create climate of trust which allows each individual to control their own data. This Privacy Policy contains important information and aims to explain in a simple and transparent way what type of personal data we collect about you, how we process it and your rights regarding the use your personal information. WHO WE ARE POWER DYNAMIC TECHNOLOGY SRL (hereinafter referred to as "POWERKIDS" or "the Controller"), a limited liability company, registered in Romania, having registration number J40/15579/2006, fiscal code RO19068945, registered in Bucharest, St Petre Paun 27, as Operator, processes your personal data when you use: our websites at www.secureid.ro or www.POWERKIDS.ro or power-dynamic.ro the POWERKIDS Merchant Kiosk app; the POWERKIDS SecureID app and/or any of the services you can get access on the POWERKIDS platform (our products and services). As mentioned above, we are the ‘data controller' of your personal information, according to the data protection regulation. Contact data of the person in charge with attributions in the privacy field are; name: Mihai Ungureanu; email: enroll@secureid.ro. You must be at least 18 years of age to enter into this agreement. By accessing and using POWERKIDS platform and becoming a User, it is assumed that you have read the terms of this Privacy Policy and that you give your consent to process your personal information necessary for such services to be provided. For the avoidance of any doubt, by agreeing with this Privacy Policy you acknowledge that POWERKIDS provides through the POWERKIDS platform a service that helps you make payments by facial recognition. Your BIOMETRIC data represents a mathematical model (which allows facial recognition) of your facial characteristics and is encrypted. Biometric data is considered to be sensible/special data which should benefit of an enhanced protection according to GDPR. Read this policy carefully to understand our data practices and how we treat them. If you do not agree to any of these practices, do not access the services provided by this platform. If after reading this agreement in its entirety you are still unsure of anything or you have any questions, please feel free to contact us at enroll@secureid.ro. PRINCIPLES OF PROCESSING Protecting and respecting your privacy is one of our constant concerns. The processing of your personal data will be done in a legal, correct and transparent manner. The purpose for which we collect your personal data are specified, explicit and legitimate and your personal data will not be further processed in a manner that may be incompatible with those purposes. We shall collect your personal data in an appropriate manner; personal data collected shall be relevant and limited to the information required for the purpose of the processing, accurate and, where necessary, updated. We are committed to take all necessary steps to ensure that incorrect data is erased or corrected. Personal data will be retained for a period no longer than the one in which personal data is processed, except for the circumstances imposed by law where retention may be necessary and subsequently. Personal data will be kept confidential; storage of such will be made in a manner that provides the necessary security. Personal data will be shared with third parties only if it is required for the purpose of providing services under agreements. Persons concerned have the right to request access to personal data, rectification and erasure, impediment or restriction of data processing and the right to data portability. We do not trade personal data for commercial purposes, and we don't use cookies. TYPE OF PERSONAL DATA PROCESSED We may process personal data like: Contact details (name, surname, email address, phone number, merchant store address) Biometric data (facial characteristics, images and videos) to generate biometric template. Account login (username and password) Merchant's store profile photo Technical information like the internet protocol (IP) address used to connect your computer to the internet, the browser type and version, your log-in information, the time-zone setting, the operating system and platform, the type of device you use, or the mobile phone number used by the device, mobile network information, your mobile operating system, the type of mobile browser you use and so on; Information about your GPS location PURPOSES OF PROCESSING Our primary goal in collecting personal information is to provide you with a safe, efficient and personalized experience. We use personal information to create, develop, operate, deliver and improve our services as provided in the Terms & Conditions and To create your POWERKIDS platform User account, to identify you as a platform user and give you access to the various features and services available to you as a registered user. Verifying your identity/biometric recognition. Responding to your queries, claims or disputes. Detecting, investigating, preventing or remediating violations of your agreements with us. To comply with legal and regulatory requirements. LEGAL BASIS FOR PROCESSING POWERKIDS processes your personal information on the bases set out below: Keeping to our agreement with you – We need certain personal information (herein included too your Biometric data) to provide our services and cannot provide them without this information. Legal obligations – In some cases, we have a legal responsibility to collect and store your personal information. Legitimate interests – We sometimes collect and use your personal information because we have a legitimate reason to have it and this is reasonable when balanced against your right to privacy. Consent – by accepting this Privacy policy, you grant us your specific consent on the data processing performed for the purposes detailed above. DISCLOSURE OF YOUR PERSONAL DATA It is possible for us to share the required part of your personal data only to the extent that it is necessary for the following third-party categories: (a) Subcontractors – companies that offer us products or services, such as: cloud services providers; (b) Companies involved in the operation of our platform; (c) Other parties such as public authorities and institutions, accountants, auditors, lawyers and other external professional counselors, if their activity requires their knowledge or where the law requires us to divulge them. Data processing may also be performed by companies acting as Merchants (the store or vendor enrolled to POWERKIDS) or Providers (payment gateway and/or banks providing services to Users and enrolled to POWERKIDS). BY AGREEING WITH POWERKIDS'S PRIVACY POLICY YOU CONFIRM THAT YOU SPECIFICALLY AGREE WITH THE DISCLOSURE OF YOUR PERSONAL DATA WITH THE MERCHANTS AND PROVIDERS IN RELATION TO WICH YOU SHALL USE THE POWERKIDS PAYMENTS BY FACIAL RECOGNITION. It is possible that we also disclose your personal information to third parties: (a) In case you request or give us permission to do so. (b) To persons who can demonstrate that they have the legal authority to act on your behalf. (c) If it is our legitimate interest to do so in order to manage, expand or develop the commercial activity: (i) in the case of a transfer of an enterprise (we sell part of the business or certain goods), we may disclose your data to the potential buyer of those commercial or commodity activities to ensure that the activity continues; (ii) if POWERKIDS (or a substantial part of its assets) is acquired by a third party, in which case the personal data held by POWERKIDS will be one of the transferred assets. (d) If we have an obligation to disclose your personal data to comply with a legal obligation, any legal request from governmental or executive authorities and as may be necessary to meet certain national security or enforcement requirements law or to prevent certain illegal activities. (e) To respond to any claim, to protect our rights or a third party, to protect the safety of any person or to prevent any illegal activity. (f) To protect the rights, property or safety of POWERKIDS, its employees, POWERKIDS platform Users, or others. KEEPING PERSONAL DATA POWERKIDS takes all necessary steps to ensure that your personal data is processed only for the minimum period required for the purposes set forth in this Privacy Policy. POWERKIDS will keep copies of your personal data in a form that permits identification only as long as: (i) we maintain an ongoing relationship with you; (ii) your personal data is required in connection with the purposes set forth in this Privacy Policy and we have a valid legal basis. When it comes of your biometric data, we only store biometric templates; such data will be processed for no longer than it is absolutely necessary to achieve the purpose for which the data was collected and processed. In particular, biometric samples used to generate the biometric template may only be processed in the capture and acquisition phases as required for biometric comparison; they may not be stored for longer than it is absolutely necessary to generate the said template. In addition, if relevant legal actions are being formulated, we may continue processing your personal data for such additional time in relation to that claim / action. After the end of the periods in (I), (II) above, each to the extent applicable, we will erase or definitively destroy the relevant personal data, or we will anonymize the relevant personal data. Also, Users can request the deletion of the account at any time. Following such a request, POWERKIDS will delete information that is no longer to be stored and will restrict access or use of any information that is still to be kept. Please bear in mind that your right to erasure of your personal data is not an absolute one. Your personal data will be retained after the period referred to in (I) and (II) above only if it is ordered by internal law and only for the period of time provided for by these regulations, the basis being the legal obligation. SECURITY OF YOUR PERSONAL DATA We use appropriate measures to maintain the confidentiality and security of your personal data and to prevent unauthorized access, use, disclosure, alteration or destruction. Please be aware that these safeguards do not apply to the information you choose to distribute in the public domain, such as social networks owned by third parties. Your personal data will be processed by our authorized staff or agents only to the extent they are required to know, depending on the specific purposes for which your personal data was collected. We use Interactive Biometric system, meaning that the data's subject participation is required to cooperate in the data acquisition phase (as opposed to passive systems which collect data without the data subject's perceiving or being aware of that). We store your personal data in operating environments that use reasonable security measures to prevent unauthorized access. We use device management system for all mPOS devices which allows remote wiping functionalities to be applied in case of loss/theft of the device. We respect adequate standards for the protection of personal data. The personal information you provide when you create an account with POWERKIDS Platform are encrypted and kept in POWERKIDS's cloud accounts in Azure. These have their own Privacy Policies in terms of personal data protection which you can find here: https://azure.microsoft.com/en-in/overview/trusted-cloud/privacy/ https://azure.microsoft.com/es-es/blog/protecting-privacy-in-microsoft-azure-gdpr-azure-policy-updates/ BY AGREEING WITH POWERKIDS'S PRIVACY POLICY FOR THE POWERKIDS PLATFORM YOU CONFIRM THAT YOU ARE ALSO AWARE OF AMAZON'S AND AZURE'S PRIVACY POLICY. It is important for you to play a role in maintaining the security and security of your personal data. You are responsible for maintaining the confidentiality for any use of your account. If you become aware of any unauthorized use of your account or any other breach of security regarding personal data you provided to POWERKIDS, you agree to notify POWERKIDS immediately. POSSIBLE RISK FOR PROVIDING BIOMETRIC DATA Even though we are taking all measure for securing all the personal data provided by Users, there still exist some risks, especially when it comes to sensitive data, such as biometric data. Because we want our Users to be fully informed when it comes to their personal data, in the following we mention by way of example some of such risks: Is not excluded the identity theft regardless the technology used; Publishing of such data in case the servers are hacked and the utilization of the data for unauthorized purposes (e.g. marketing, statistics, social control and discriminatory usage, biometric identity theft, biometric data forgery etc.), loss of such data, their destruction, modification, disclosure or illegal collection; Access to other personal data that may results from the biometric data, such as: race, gender, ethnicity, age, etc. Nevertheless, please note that we implemented methods for securing the personal data we collect, especially the sensitive data by encrypting and storing them in a form where such information cannot be used to render biometric data in its initial form. MINORS Persons who have not reached the age of 18 are not allowed to request services or any communications on the POWERKIDS platform. PERSONAL DATA TRANSFERS Keeping and processing your personal information as described above may require the transfer of such and / or storage to a destination outside your country of residence to countries within the European Union (the " EU ") Or the European Economic Area (" EEA "), for example, service providers. Before transferring your data, we will take the necessary steps to ensure that your personal information will benefit from adequate protection, in accordance with the relevant privacy laws and internal policies of POWERKIDS. Your data may be transferred outside the EEA/EU. Transferring your data outside of the European Union is mainly due to the location of our subcontractors. In order to provide you with safe services, we have decided to outsource certain operations to specialized service providers who have a relevant experience in their areas (for example: IT hosting). Some of these providers are established outside the EEA / EU, for example the United States. By enrolling as a User of the POWERKIDS platform owned by POWERKIDS you expressly and unambiguously give your consent to the transfer and storage of your personal data on servers outside your country of residence, including the US, which may have data protection laws different from those in your country. DATA SUBJECT'S RIGHTS The right to be informed, access (the data subject has the right to obtain from POWERKIDS a confirmation that personal data concerning him / her are processed or not, and, if so, he / she has the right to access the data). This right may be limited or refused, the reason for the refusal or limitation being communicated to the person concerned. Right of rectification (the data subject has the right to obtain, without undue delay, the rectification of inaccurate personal data concerning him / her). Taking into account the purposes for which the data were processed, it is entitled to obtain the completion of personal data that is incomplete, including by providing an additional statement. The right to erase data (in situations where (1) the data are no longer necessary for the fulfillment of the purposes, (2) the consent has been withdrawn and there is no other legal basis for the processing, (3) the person opposes the processing and there are no legitimate reasons (4) personal data have been processed unlawfully, the person has the right to obtain the deletion of the data relating to him / her without undue delay). This right may be limited or refused, the reason for the refusal or limitation being communicated to the person concerned. The right to restrict processing – the data subject has the right to restrict the processing in the following situations: (i) contest the accuracy of the data for a period that allows the operator to verify the accuracy of the data; (ii) the processing is illegal, and the person concerned opposes the deletion of personal data, but instead calls for the restriction of their use; (iii) no personal data is required for processing, but the data subject requests them for the establishment, exercise or defense of a right in court; (iv) the data subject opposed to the processing, for the period of time to verify that the legitimate interests of the operator prevail over the rights of the person. The user has the right to oppose at any time data processing for direct marketing purposes, not to be subject to the automated decision-making process, including profiling – does not have this right if the decision: (i) is required to conclude or execute a contract between the person concerned and POWERKIDS; (ii) is authorized by Union or national law applicable to POWERKIDS and which also provides for appropriate measures to protect the legitimate rights, freedoms and interests of the data subject; (iii) is based on the explicit consent of the data subject. Right to data portability – the data subject has the right to receive the personal data which he/she regards and which he/she has provided in a structured, commonly used and readable form and has the right to request POWERKIDS to transmit this data to another operator, without obstacles from POWERKIDS, if the following conditions are met cumulatively: (i) processing is based on consent or contract and (ii) processing is carried out by automatic means, in particular if this is technically feasible The right to file a complaint with POWERKIDS – the data subject may file a complaint if he / she is unhappy with the processing of his or her personal data or with the way of responding to its request. Right to file a complaint with the Supervisory Authority – the data subject has the right to file a complaint with the National Supervisory Authority for Personal Data Processing if he is dissatisfied with the processing of his personal data. Name: National Authority for the Supervision of Personal Data Processing Address: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania Telephone: +40.318.059.211 or +40.318.059.212 Fax: +40.318.059.602 Email: anspdcp@dataprotection.ro Right to address to justice – the data subject has the right to appeal to competent courts if he is unhappy with the processing of his or her personal data. Data subject enjoys these rights, irrespective of the legal basis of the processing of his data. MISCELLANEOUS It is possible that our site contain links to and from the websites of our partner networks, advertisers and affiliates. If you access a link to any of these websites, please note that these websites have their own privacy policies and that we cannot be held responsible for those policies. Please check the privacy policies of each website before submitting personal data. CHANGES TO THIS POLICY If we make changes to the way we handle your personal information, we will update this privacy policy. We reserve the right to make changes to our practices and policies at any time. Please check our site regularly to see any updates or changes to our confidentiality policy. All the previous versions of this Privacy policy shall be available on our website. If you do not agree with the revised policy, you must change your preferences or not access POWERKIDS. If you continue to access or use the Platform after these changes take effect, you agree to comply with the up-dated Privacy Policy. You are not required to provide us with your personal data (biometric data inclusive). However, if you choose not to provide us your personal data, POWERKIDS app will no longer be accessible to you and / or, as the case may be, we will no longer be able to facilitate and provide the POWERKIDS payment method and you will not be able to interact with these services; however, you shall be able to use the alternative payment methods freely used by each respective vendor/provider. info@powerkids.app Visit our developer page.