TERMS AND CONDITIONS REGARDING PERSONAL DATA PROCESSING POLICY


I. OUR COMMITMENT TO YOUR PERSONAL DATA

The Personal Data Processing Policy describes the categories of your personal data that we process, the ways and purposes in which we collect them, in which situations we transfer personal data, as well as the rights and options you have in this regard. At the same time, the Personal Data Processing Policy details how we process personal data in the management of the customer relationship, most often to provide you with quality services in accordance with your requirements.

The RITO KIDS platform undertakes to apply, in relation to the personal data of its users, appropriate technical and organizational measures to protect their data against accidental or illegal destruction, loss, modification, disclosure or unauthorized access, especially if the respective processing involves data transmissions in within a network, as well as against any other form of illegal processing.

These policies, together with the General Conditions of Use of the website, apply from the moment you visit the website, as well as when you complete the registration or registration procedure with your contact details within the platform. They remain in effect until you withdraw your consent, at which point your personal data will be deleted from our database, and you will no longer be able to use the account created within the RITO KIDS platform.

The RITO KIDS platform is oriented towards maximizing the protection of its users' data against all types of risks, taking extensive technical and organizational measures for this purpose.

Protection against unauthorized connection or access, unauthorized viewing, modification or distribution, loss, destruction or misuse of data by third parties (privacy of transmitted electronic messages). At the same time, since the Internet connection cannot be completely protected, the possibility of unauthorized access cannot be completely excluded. In this regard, the company asks the user to protect personal data by completing a session before leaving the page.

II. THE OPERATOR OF YOUR PERSONAL DATA

The operator in relation to your personal data is the company MANUSCRITO APP SRL with headquarters in Cluj-Napoca, str. Bld. 1 Decembrie 1918, no. 126, Scara 1, ap. 1, Cluj county, registered in the Commercial Register of next to the Cluj Court under no. J12/4993/2022, having CUI 46646612.

CATEGORIES OF PERSONAL DATA PROCESSED

The personal data we process may include:

Contact information, such as your name, postal address, including home address if provided, telephone number and email address; Data resulting from your browsing on our website collected through cookies and similar technologies;

The data resulting from your navigation, as a user, within the platform: information such as the operating system, the type of browser used, the names and types of applications, files and plugins, as well as unique identifiers, device identifiers, data from cookies stored on your device (see cookie policy), as well as other data on technical means, technical connection data (including IP address of the host, geographical position, Internet service provider.);

III. LEGAL BASIS OF PROCESSING

The data subject's consent is any manifestation of the data subject's free, specific, informed and unambiguous will, by which he accepts, through a statement or an unequivocal action, that the personal data concerning him be processed . Your consent may be revoked at any time under the conditions described herein.

Your freely expressed, specific, informed and unambiguous consent is one of the legal grounds for the processing of personal data for the purposes presented.

Alternatively, another applicable legal basis is the legitimate interest in situations where the data subject's consent cannot be obtained immediately or is extremely difficult, including our legitimate interest which consists in providing an innovative, personalized, secure and profitable for our users and partners, unless these interests prejudice your fundamental interests or rights. In the case of minors (under the age of 18 in most EU countries), who have limited capacity to enter into an exclusively enforceable contract, we may not be able to process personal data on the basis of necessity contractual. However, when these people use our Services, it is in our legitimate interest to:

To fulfill our legal obligations as well as to protect your vital interests. The vital interests we rely on in this processing include protecting the life or physical integrity of you or others, and we rely on these to combat harmful content and promote safety and security, for example when investigating reports of harmful content or when someone needs help.

When the basis for processing is a legal obligation, we generally base our processing on legal provisions, such as obligations under tax and/or accounting legislation, including archiving obligations, as well as fraud protection legislation, money laundering and terrorism.

If we require personal data to comply with legal or contractual obligations, the provision of such personal data by you is mandatory.

IV. DESTINATION OF YOUR PERSONAL DATA

Personal data can be transmitted to our partners both within the EU and outside the EU space, our company imposing on them the obligation to establish appropriate technical and organizational security measures to process and protect personal data. Service providers will be entitled to use subcontractors in providing the services to the company, provided that the subcontractor complies with the same data protection obligations as the service providers.

Specifically, we transmit some data to third parties (our suppliers and partners) for the performance of functions and services necessary for the operation of our company's activities, such as:

• • contractual partners of the operator;
• • for technical support and website maintenance;
• • for hosting and backup services used for the website hosting
• • public authorities, only if they request it for the performance of an administrative or judicial act;
• • IT service providers;

V. DURATION OF PROCESSING YOUR PERSONAL DATA

Your personal data is processed throughout our relationship and, after its termination, at least for the period required by applicable legal provisions in the field, including, but not limited to, archiving provisions.

Thus, we will store your personal data according to the following criteria and the categories of personal data affected:

• • how long we are bound by the relevant legal provisions;
• • during the conclusion and execution of a contract, until the execution of all rights and obligations arising from it;
• • according to the Cookie Policy available on the website;
• • for the period for which you have given us consent, if the processing is based on consent.

VI. DATA SECURITY

For privacy and data security, your account is protected by a password and a username ("user"). Also, the databases are stored on a guaranteed server, protected from fraud attempts. Data transmission over the Internet is not completely secure. Although we will do our best to protect your data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we receive your data, we will use strict procedures and security features to try to prevent unauthorized access.

VII. YOUR RIGHTS REGARDING THE PROCESSING OF PERSONAL DATA

The data subject's right to information and access

According to art. 15 of the Regulation, you, as the data subject, have the right to obtain from the operator a confirmation that personal data concerning you is being processed and, correlatively, you can have access to that data, through a simple request addressed to the operator .

In the situation where your data is processed by the operator, you have the right to request information such as: the purposes of the processing, the categories of personal data targeted, the recipients or the categories of recipients to whom the personal data was or will be disclosed, especially recipients from third countries or international organizations. You can also, where applicable, receive information about the period for which the personal data is expected to be stored or, if this is not possible, the criteria used to determine this period. Last but not least, you have the right to request information regarding the existence of an automated decision-making process including the creation of profiles and pertinent details regarding the logic used and regarding the importance and expected consequences of such processing for the data subject.

The right to rectification

Art. 16 of the Regulation gives you the right, as a data subject, to obtain from the operator, without undue delay, the rectification of inaccurate personal data. Taking into account the purposes for which the data were processed, you have the right to obtain the completion of personal data that are incomplete, including by providing an additional statement.

The right to opposition

It concerns the right to object to the processing of personal data when the processing is necessary for the performance of a task that serves a public interest or when it has in mind a legitimate interest of the operator.

The right to data portability

Specifically, you have the right to receive your personal data in a structured, commonly used and machine-readable format, as well as the right to have this data transmitted directly to another controller, if this is technically possible.

The right to restriction of processing

You have the right to obtain from the operator the restriction of processing if you are in one of the following situations:

Contest the accuracy of the data, for a period that allows the operator to verify the accuracy of the data or in the situation where the processing is illegal and the data subject objects to the deletion of the personal data, requesting instead the restriction of their use.

Another situation in which the restriction of processing can be requested is the case where the operator no longer needs the personal data for the purpose of processing, but the data subject requests them for establishing, exercising or defending a right in court.

Right to erasure (right to be forgotten)

You have the right to request the deletion of personal data from our databases, without undue delay, if one of the following reasons applies: they are no longer necessary to fulfill the purposes for which they were collected or processed; you withdraw consent and there is no other legal basis for the processing; you object to the processing and there are no overriding legitimate grounds; personal data were processed illegally; personal data must be deleted to comply with a legal obligation; personal data were collected in connection with the provision of information society services.

We inform you that we strictly respect and ensure professional secrecy. We only disclose the data to fulfill your interests or fulfill legal obligations. Confidentiality is not only a legal obligation for us, but also an essential value.

VIII. EXERCISE THE RIGHTS PROVIDED BY PERSONAL DATA PROTECTION LAW.

If you wish to exercise some of these rights, you can contact us with a request in this regard, using the following contact details:

• E-mail: contact@ritokids.com

In order to comply with our legal data security and privacy obligations, when you exercise one of your rights as a data subject, we may ask you to prove your identity by providing us with a copy of an identification document or any other information necessary to verify that the request is from the relevant data subject.

We will consider any requests or complaints we receive and provide you with a response within the time limits provided by law. If you are not satisfied with our answer or consider that the processing is done in violation of the applicable legislation, you can file a complaint with the data supervisory authority in Romania: the National Supervisory Authority for the Processing of Personal Data - based in Bd. Gheorghe Magheru no. . 28-30, Bucharest, Romania.

IX. UPDATE OF PERSONAL DATA PROCESSING POLICY

This Privacy Policy was last updated in December 2022. We reserve the right to periodically update and amend this Privacy Policy to reflect any changes in how in which we process your personal data or any changes to legal requirements. In the event of any such change, we will display the modified version of the Personal Data Processing Policy on our website and/or otherwise make it available to you.

We will notify you before making any changes to this policy and give you the opportunity to review the revised policy before choosing to continue using our Products.