Privacy Policy – Collective Shift Academy

**Last updated:** 12.05.2026

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## 1. Who We Are

This website is operated by LEADERSHIP IDENTITY ON SRL, a company registered in Romania under registration number 46989548, with its registered office at Str. Cremenita 88 Ap. 1 Cod 022814, Bucuresti, Sectorul 2, Romania.

For all privacy-related matters, you can contact us at:
– Email: contact@csacademy.com

We are the **Data Controller** for the personal data collected through this website in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and Romanian Law no. 190/2018.

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## 2. What Data We Collect and Why

### 2.1 Qualification & Contact Form

When you submit our qualification form or any contact form on this website, we collect:
– Full name
– Email address
– Phone number (if provided)
– Professional background and role
– Answers to qualification questions

**Legal basis:** Legitimate interest (Art. 6(1)(f) GDPR) in evaluating program fit, and pre-contractual steps (Art. 6(1)(b) GDPR).

**Retention:** We retain this data for **24 months** from the date of submission, or until you request deletion.

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### 2.2 Email Newsletter & Marketing Communications

If you subscribe to our newsletter or download a lead magnet, we collect:
– Full name
– Email address

**Legal basis:** Consent (Art. 6(1)(a) GDPR). You may withdraw your consent at any time by clicking the unsubscribe link in any email or contacting us directly.

**Retention:** Until you unsubscribe or request deletion, plus an additional **6 months** for suppression list purposes.

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### 2.3 Program Enrollment

If you enroll in the Collective Shift program, we collect:
– Full name and contact details
– Billing and invoicing information
– Professional credentials and background
– Communications during the program

**Legal basis:** Contract performance (Art. 6(1)(b) GDPR) and legal obligation (Art. 6(1)(c) GDPR) for accounting/invoicing purposes.

**Retention:** Invoicing and contractual records are retained for **10 years** as required by Romanian fiscal law (Legea nr. 82/1991).

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### 2.4 Website Analytics

We use **Google Analytics 4** (operated by Google LLC) to understand how visitors use our website. This collects:
– Pages visited and time spent
– Approximate geographic location (country/city level)
– Device and browser type
– Referring sources

**Legal basis:** Consent (Art. 6(1)(a) GDPR). Analytics cookies are only activated after you accept them via our cookie banner.

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### 2.5 Advertising & Remarketing

We use the **Meta Pixel** (operated by Meta Platforms, Inc.) to measure the effectiveness of our advertising and show relevant ads to people who have visited our website.

**Legal basis:** Consent (Art. 6(1)(a) GDPR). The Meta Pixel only loads after you accept marketing cookies via our cookie banner.

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## 3. Third-Party Data Processors

We share your data only with trusted third-party service providers acting as **data processors** under written agreements. These include:

We do **not** sell your personal data to any third party.

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## 4. International Data Transfers

Some processors listed above are located outside the European Economic Area (EEA), specifically in the United States. All such transfers are safeguarded by **Standard Contractual Clauses (SCCs)** approved by the European Commission under Art. 46(2)(c) GDPR.

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## 5. Your Rights Under GDPR

As a data subject, you have the following rights:

– **Right of access** (Art. 15): Request a copy of the data we hold about you.
– **Right to rectification** (Art. 16): Request correction of inaccurate data.
– **Right to erasure** (Art. 17): Request deletion of your data (“right to be forgotten”).
– **Right to restriction** (Art. 18): Request that we limit how we process your data.
– **Right to data portability** (Art. 20): Receive your data in a structured, machine-readable format.
– **Right to object** (Art. 21): Object to processing based on legitimate interest.
– **Right to withdraw consent** (Art. 7(3)): Withdraw any consent you have given at any time.

To exercise any of these rights, contact us at **[PRIVACY@YOURDOMAIN.COM]**. We will respond within **30 days**.

You also have the right to lodge a complaint with the Romanian supervisory authority:

> **Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP)**
> Bulevardul General Gheorghe Magheru 28-30, Sector 1, 010336 București
> Website: [www.dataprotection.ro](http://www.dataprotection.ro)

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## 6. Cookies

For detailed information on the cookies we use and how to manage them, please see our [Cookie Policy](#).

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## 7. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These include encrypted connections (SSL/TLS), access controls, and regular security reviews.

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## 8. Children’s Data

Our website and services are intended for professionals aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently collected such data, please contact us immediately.

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## 9. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last updated” date at the top of this page reflects the most recent revision. Continued use of the website following any changes constitutes your acknowledgment of the updated policy.

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## 10. Contact

For any questions or concerns regarding this Privacy Policy:

LEADERSHIP IDENTITY ON SRL
Str. Cremenita 88 Ap. 1 Cod 022814, Sectorul 2.
BUCURESTI ROMANIA
Email: contact@csacademy.com