Privacy Policy

1. Identity of the controller

The controller of personal data processed under this Privacy Policy is Neophron International SRL, the owner of the European Trade Academy brand.

For all GDPR, compliance, and accountability purposes, references in this Privacy Policy to “European Trade Academy”, “the Academy”, “we”, “us”, or “our” mean Neophron International SRL acting through the European Trade Academy brand.

2. Categories of personal data

Depending on the context, Neophron International SRL may process identification data, contact data, application and admissions data, programme-related records, employer liaison information, technical website data, communications content, and consent records.

These categories may include full name, date of birth, nationality or citizenship, postal address, email address, phone number, education history, ID or passport details, language ability, application form contents, assessment or certification records, employer-facing profile data, and information contained in correspondence or support requests.

For website visitors, the controller may also process IP-related data, cookie identifiers, consent preferences, browser and device metadata, pages viewed, timestamps, referral source, interaction events, and other website usage information generated through logs, analytics tools, and consent technologies.

3. Sources of personal data

Personal data may be collected directly from the data subject, from forms submitted through the website, from email or messaging communications, from telephone interactions documented by staff, from uploaded documents provided during admissions, and from technical systems used to operate the website.

In limited cases, personal data may also come from employer contacts, authorised representatives, or public authorities where necessary for admissions, certification, compliance, or placement-related verification.

4. Purposes of processing

Neophron International SRL processes personal data to respond to enquiries, manage admissions, assess eligibility, communicate with applicants and employer contacts, deliver institutional information, administer programmes, maintain educational and certification records, support employer liaison functions, protect website security, comply with legal obligations, and improve the website and communications systems.

Personal data may also be processed to issue official qualification documentation, maintain records required by ANC and other Romanian authorities, manage invoicing and accounting obligations, and send marketing or informational communications where the relevant legal basis applies.

5. Legal bases for processing

Depending on the activity, processing may be based on the performance of a contract, steps taken at the request of the data subject before entering into a contract, compliance with legal obligations, the legitimate interests of Neophron International SRL, or the data subject’s consent.

Contractual and pre-contractual necessity may apply to admissions handling, applicant communications, enrolment preparation, and programme administration. Legal obligation may apply to certification, archiving, tax, accounting, and regulatory record-keeping. Legitimate interests may apply to security, fraud prevention, internal administration, limited service improvement, and carefully configured analytics. Consent may apply to optional marketing, certain cookies or analytics technologies, photography, employer introductions, or other optional processing activities.

Where consent is the legal basis, consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

6. GA4, GTM, tracking and website analytics

European Trade Academy, as a brand owned by Neophron International SRL, may use website measurement and tag management technologies including consent management tools, cookies, Google Tag Manager, Google Analytics 4, and server-side or browser-side diagnostics to understand how users interact with the website and to improve performance, usability, and communications.

Google Tag Manager may be used to deploy or manage scripts, consent-aware triggers, analytics tags, conversion-related events, and other website technologies. Google Tag Manager does not ordinarily act as an independent storage system for personal data, but it may trigger technologies that do process data according to their own configuration.

Google Analytics 4 may be used to collect or receive information relating to website activity, such as page views, session and engagement data, event parameters, approximate location, device attributes, browser details, traffic source information, and form interaction events, subject to the chosen configuration and applicable legal rules.

Where non-essential analytics or advertising-related technologies require prior consent under applicable ePrivacy or data protection rules, Neophron International SRL will rely on the website’s consent mechanism before enabling them.

7. Automated decision-making

Neophron International SRL does not state on the current website that it uses fully automated decision-making producing legal or similarly significant effects in relation to website visitors or applicants.

If this changes, the relevant notice and safeguards will be updated in accordance with applicable GDPR requirements.

8. Sharing of personal data

Personal data may be shared with competent public authorities, the National Qualifications Authority (ANC), the Romanian tax authority (ANAF), accountants, legal advisers, IT and hosting providers, communications providers, and other processors or recipients where disclosure is necessary for the relevant processing purpose or legal obligation.

Where a data subject opts into employer liaison or placement support, relevant data may also be shared with identified or appropriate employer partners to support recruitment, compliance checks, and onboarding discussions, subject to the applicable legal basis and any required consent.

Neophron International SRL does not state on the current website that it sells personal data to third parties, and the current draft Privacy Policy expressly says it does not sell data to third parties.

9. International data transfers

The current website states that personal data is not transferred outside the European Economic Area.

If any future transfer outside the EEA becomes necessary, Neophron International SRL will implement an appropriate transfer mechanism recognised by applicable data protection law and will update this Privacy Policy accordingly.

10. Retention periods

Retention periods depend on the category of data and the legal or operational purpose for which the data is processed.

The current website states that unsuccessful applicant files are retained for 12 months, student records including enrolment, attendance, assessment, and certificate copies are retained for 50 years in line with Romanian certification archival obligations, and marketing subscribers may unsubscribe at any time with removal from active lists within 30 days.

Where different retention obligations arise under law, contract, litigation hold, or regulatory instruction, Neophron International SRL may retain data for the longer mandatory period.

11. Data subject rights

Under GDPR, data subjects may have rights of access, rectification, erasure, restriction, objection, data portability, and withdrawal of consent, subject to the conditions and limitations provided by law.

Data subjects also have the right to lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP). The current website identifies www.dataprotection.ro as the authority’s website.

12. Security measures

Neophron International SRL applies technical and organisational measures appropriate to the risks associated with the processing activities described on the European Trade Academy website and in its related operations.

No website, database, transmission channel, or storage environment can be guaranteed to be fully secure, and users should avoid sending unnecessary sensitive data through insecure channels unless specifically instructed to do so through a secure process.

13. Children’s data

The current website presents the programmes as intended for adult applicants and states eligibility information based on adult participation in vocational training.

The website is not designed as a children’s service, and any accidental collection of children’s personal data should be reviewed and handled in accordance with applicable law and internal deletion or remediation procedures.

14. Changes to this Privacy Policy

Neophron International SRL may amend this Privacy Policy from time to time to reflect changes in law, website technologies, institutional operations, data flows, processor relationships, or regulatory requirements.

The updated version becomes effective when published on the website unless another effective date is stated.

15. Contact details

Neophron International SRL

Owner of the European Trade Academy brand

Bulevardul Unirii 27, 030828 Bucharest, Romania

Email: eta@neophroninternational.ro

Privacy contact: privacy@european-trade-academy.com

Phone: +40 21 200 1995