Related documents
Privacy Policy
1. About this Privacy Policy
This Privacy Policy explains how personal data is collected, used, stored and protected when you visit nlp.mihaivasilescu.com, contact me, subscribe to my communications, register for a programme, make a payment or take part in one of my NLP training programmes, workshops or related learning and personal-development services.
In this Privacy Policy, ‘I’, ‘me’ and ‘my’ refer to Mihai Vasilescu, trainer and organiser of the programmes, acting on behalf of Enhance Solutions SRL.
For the purposes of applicable data-protection legislation, including Regulation (EU) 2016/679, the General Data Protection Regulation (‘GDPR’), the data controller is:
Enhance Solutions SRL
Registered office: Str. Gheorghe Țițeica, Nr. 142, Et. 1, Sector 2, Bucharest, Romania
Email: hello@mihaivasilescu.com
Telephone: +40 741 772 885
This Privacy Policy applies to nlp.mihaivasilescu.com. The main website, mihaivasilescu.com, presents a distinct range of services and is governed by its own Privacy Policy. If you follow a link from this website to the main website or another external platform, please read the privacy information provided there.
2. The personal data I collect
The personal data I collect depends on how you interact with me.
When you send a message, complete a form or book a preliminary call, I may receive your name, email address, telephone number, organisation, job title, the programme you are interested in and any information you choose to include in your message.
If you register for a programme or enter into a contract with me, I may also process your personal numeric code (CNP) and identity card series and number, billing information, transaction information, contractual correspondence, programme selection, registration status and information necessary to organise and deliver the service. CNP and identity card data are accessed only by me and my accountant and are never sent to the certification bodies.
Where a programme has entry requirements, I may ask for information about previous NLP training, qualifications, the training organisation or association, the year of completion and documentary evidence needed to verify eligibility.
When you take part in a training programme, workshop or learning event, I may process attendance information, learning objectives, feedback, evaluation responses, assessment results, completion status, certification records and relevant professional information. During exercises or discussions, you may choose to share personal experiences, challenges, decisions, behaviours, relationships, goals or other circumstances relevant to the learning process. I process only information that is relevant to the programme and that you choose to share.
For some programmes, you may be invited to complete an optional, confidential suitability questionnaire, which may include information about your health. You may also choose to provide an emergency contact for in-person programmes. This information is collected only through the Privacy Notice and Consent Form for Course Participants, with your explicit consent where required. Please do not include medical records, detailed diagnostic information or other unnecessary sensitive information in general website forms.
When you subscribe to my newsletter or request a resource, I process your email address, subscription preferences and information about the way you interact with my communications, to the extent permitted by law and by the technologies you have consented to.
The website may also collect limited technical information, such as your IP address, browser type, device information, pages visited, approximate location, referral source and the date and time of your visit. Some of this information is collected through cookies or similar technologies, as explained in the Cookie Policy.
3. How I obtain personal data
Most personal data is provided directly by you, for example when you contact me, subscribe, register, make a payment, sign a contract or take part in a programme.
Where an organisation purchases a programme for one or more participants, certain information may be provided by the organisation or another contracting party. This normally includes your name, professional contact details, role, participation status and information required to organise the programme. I ask organisational clients to provide only information they are entitled to share and that is necessary for the agreed purpose.
I may also receive limited information from service providers used for scheduling, email delivery, video conferencing, payment processing, website administration or analytics.
4. Why I use personal data and the legal bases
I process personal data to respond to enquiries, arrange preliminary calls, manage registrations, confirm eligibility, conclude and perform contracts, deliver programmes, manage attendance, assessments and certification, issue invoices, keep business records and support participants. This processing is necessary to take steps at your request before entering into a contract or to perform a contract with you or the organisation you represent.
I process accounting, invoicing and transaction information where necessary to comply with my legal and financial obligations.
With your consent, I may send newsletters, educational content, invitations and commercial communications. You can withdraw that consent at any time by using the unsubscribe link in any email or by contacting me. Withdrawing consent does not affect processing that took place lawfully before withdrawal.
Suitability information, including any information about your health, is processed only on the basis of your explicit consent, given separately through the Privacy Notice and Consent Form for Course Participants. You may withdraw it at any time, although withdrawal may affect my ability to assess or support your participation safely. Emergency contact details are processed on the basis of my legitimate interest in protecting your safety and, in an emergency, your vital interests.
With your consent, given through the website’s cookie banner, I use analytics and marketing technologies, including Google Analytics and Meta Pixel, to understand how the website is used and to measure the effectiveness of my communications.
I may process limited personal data on the basis of my legitimate interests in operating and improving my business, maintaining professional relationships, protecting the website and systems, establishing or defending legal claims and communicating with existing contacts where permitted by law. I use this basis only where my interests are not overridden by your rights and reasonable expectations.
Where I ask for consent to use non-essential cookies, publish a testimonial or use your image or voice, refusing or withdrawing consent will not affect your access to a service.
5. Programme confidentiality and professional boundaries
Information shared privately with me is treated as confidential within the limits described in the programme documentation and applicable law.
Training programmes may include discussions, demonstrations, exercises, reflection and practice involving real experiences or situations. Participants are expected to protect information shared by other members of the group. These expectations are explained in the Participation Guidelines and, where applicable, the Participant Agreement.
Although confidentiality expectations are established and reinforced, I cannot guarantee that every participant will comply with them. Participants should therefore consider carefully what personal information they choose to disclose in a group setting.
The NLP training, workshops and personal-development services presented on this website are educational and developmental services. They do not constitute psychotherapy, psychiatric care, medical advice, diagnosis or treatment and are not intended to replace assistance from an appropriately qualified healthcare or mental-health professional.
Methods, models or structured exercises may be used to support reflection, communication, learning, decision-making and behavioural experimentation. They are not used to diagnose a medical or psychological condition. My role is to facilitate a structured learning process in which participants can examine their experience, reach their own conclusions and make informed choices. Participants remain responsible for their decisions and actions.
If information disclosed before or during a programme suggests that participation or the requested support falls outside the professional scope of the service, I may discuss pausing or ending participation and recommend seeking an appropriately qualified professional. This is a professional-boundary decision and does not involve making a clinical diagnosis.
Confidentiality may be limited where disclosure is required by law, necessary for the establishment or defence of legal claims or necessary to address a serious and imminent risk, to the extent permitted by applicable law. Any such situation will be handled with care and with disclosure limited to what is reasonably necessary.
6. Organisation-sponsored programmes and participant information
When an organisation contracts me to deliver a programme, the organisation and Enhance Solutions SRL may each act as an independent controller for the personal data they process for their own purposes. In other circumstances, the contractual documentation may assign different data-protection roles.
Before collecting evaluations, structured feedback, assessment information or other individual learning data, participants will be told what information is being collected, why it is needed, who will have access to it and whether individual or aggregated results will be shared with the sponsoring organisation.
Individual results, comments, suitability information or personal-development information will not be disclosed to an employer merely because the employer has paid for the programme. Any reporting arrangement that goes beyond attendance, logistics, completion status and aggregated programme information will be communicated in advance.
7. Photographs, recordings and testimonials
Participants may not photograph, film, audio-record, video-record or transcribe the sessions, programme materials or other participants using telephones, computers, cameras, artificial-intelligence transcription services or any other device or application.
I do not routinely photograph or record sessions. Where I occasionally take photographs or video, for an internal programme archive or for promotional purposes, I do so only with the separate consent of the people concerned, given through the Privacy Notice and Consent Form for Course Participants. Refusing consent does not affect participation in the programme.
Participation in a programme or event is not treated as automatic permission to use a person’s name, image, voice, story or testimonial for marketing.
Testimonials, case examples and personal stories are published only with consent. Where possible, identifying details will be removed or changed. A testimonial describes one person’s experience and does not represent a promise that another person will obtain the same outcome.
8. Who may receive personal data
I do not sell or rent personal data.
Personal data may be accessed by me and, where they support a programme, by my assistants, on a need-to-know basis. It may also be processed by carefully selected service providers that support the website and the delivery of my services, including:
- website hosting: Romarg (Romania);
- newsletter and email communications: currently Mailchimp;
- call scheduling: Calendly;
- messaging: WhatsApp;
- online sessions: Zoom or Microsoft Teams;
- international card payments: Stripe;
- website analytics and advertising measurement, with your consent: Google (Google Analytics) and Meta (Meta Pixel);
- email, document storage, accounting and invoicing services.
These providers receive only the data reasonably necessary to perform their services and process it under appropriate contractual and confidentiality obligations. If I change a provider, this Privacy Policy will be updated.
Where certification applies, ARONLP, EANLP and IANLP receive your name, the programme, level, dates and certificate series and number, so that your certification can be issued and registered.
I may also disclose personal data to accountants, auditors, legal advisers, public authorities, courts or other competent bodies where this is required by law or necessary to protect my legitimate legal interests.
9. International transfers
The certification bodies that receive your data are based in the European Union. Some service providers, such as Google, Meta, Mailchimp, Calendly, Zoom, Microsoft, Stripe and WhatsApp, may process personal data outside the European Economic Area (EEA).
Where this happens, the transfer takes place on the basis of a lawful mechanism recognised under the GDPR, such as an adequacy decision, including the EU–US Data Privacy Framework where the provider is certified, or the European Commission’s Standard Contractual Clauses, together with supplementary safeguards where necessary.
Information about a specific transfer or the safeguards used may be requested at hello@mihaivasilescu.com.
10. How long I keep personal data
I keep personal data only for as long as it is reasonably necessary for the purpose for which it was collected, including the fulfilment of contractual, accounting and legal obligations.
- General enquiries that do not lead to a registration are kept for up to 24 months after the last meaningful contact.
- Registration, proposal and participant-relationship records are kept for up to 5 years after the end of the relationship, unless a longer period is required by law or justified by an ongoing contractual or legal matter.
- Accounting, invoicing and transaction records, together with CNP and identity card data included in contracts, are kept for the period required by Romanian accounting law.
- Participation and certification records are kept for 5 years after the programme ends, so that certificates can be verified.
- Suitability information and emergency contact details are kept for the duration of the programme and deleted no later than 3 months after it ends, or sooner if you withdraw your consent.
- Photographs, video and testimonials are kept until you withdraw your consent.
- Feedback used for service improvement may be anonymised and kept without information that directly identifies the participant.
- Newsletter information is kept until you unsubscribe or the communication is discontinued. A minimal suppression record may be kept after you unsubscribe, so that you are not added back to the mailing list by mistake.
- Analytics data is kept according to the settings described in the Cookie Policy.
- Technical and security records are kept for limited periods determined by the purpose of the relevant system and the requirements of the service provider.
When data is no longer required, it is deleted, anonymised or securely archived where a legal retention obligation continues to apply.
11. Security
I use reasonable technical and organisational measures designed to protect personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures may include access controls, strong authentication, secure service providers, restricted permissions, backups, software updates and confidentiality obligations.
No website, transmission method or storage system can be guaranteed to be completely secure. If I become aware of a personal-data breach, I will assess it and take the steps required by applicable law, including notifying the competent authority or affected individuals where required.
12. Your rights
Under the GDPR, you have the right to ask whether I process your personal data and to receive a copy of it; to correct inaccurate or incomplete information; to request deletion or restriction of processing in applicable circumstances; to object to processing based on legitimate interests; and to receive certain information in a structured, commonly used and machine-readable format.
Where processing is based on consent, you may withdraw your consent at any time. Where direct marketing is concerned, you may object at any time and I will stop using your personal data for that purpose.
These rights are not absolute, and certain legal exceptions may apply. For example, I may need to keep information required for accounting purposes, contractual obligations, certification records or the establishment, exercise or defence of legal claims.
To exercise a right, contact me at hello@mihaivasilescu.com. I may need to ask for reasonable information to verify your identity and ensure that personal data is not disclosed to an unauthorised person. I will respond within the period required by applicable law.
13. Complaints
If you have a concern about how your personal data is processed, I invite you to contact me first at hello@mihaivasilescu.com, so that I can investigate and respond.
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)
B-dul General Gheorghe Magheru nr. 28-30, Sector 1, 010336 Bucharest, Romania
Email: anspdcp@dataprotection.ro
Website: www.dataprotection.ro
14. Cookies and website analytics
The website uses cookies and similar technologies that are necessary for its operation and, subject to your choices, additional technologies for analytics and marketing, such as Google Analytics and Meta Pixel.
Non-essential cookies are not placed before you have given the consent required by law. You may accept, refuse or change your choices at any time through the website’s cookie banner. Further information about the cookies used, their providers, purposes and duration is available in the Cookie Policy.
15. External websites and platforms
This website may contain links to scheduling platforms, video-conferencing services, social networks, payment services, the main website mihaivasilescu.com or other external resources.
Those services operate under their own terms and privacy notices. I encourage you to review them before submitting personal data. I am not responsible for the privacy practices of an independent third-party website or platform.
16. Children’s data
The services presented on this website are intended for adults. I do not knowingly collect personal data from children through the website.
If a programme is specifically designed to include participants under the age of 18, separate information and appropriate consent arrangements will be provided before personal data is collected.
17. Automated decision-making
I do not use personal data collected through this website to make decisions based solely on automated processing that produce legal effects or similarly significant effects concerning you.
If this changes, I will provide the information required by law before such processing takes place.
18. Changes to this Privacy Policy
I may update this Privacy Policy when my services, technology providers or legal obligations change. The current version is always published on this page, with the date of its latest revision.
Where a change materially affects the way personal data is processed, I will take reasonable steps to bring it to the attention of the people concerned.
19. Contact
Questions, requests or concerns about this Privacy Policy or the processing of personal data may be sent to:
Enhance Solutions SRL
For the attention of: Mihai Vasilescu
Postal address: Str. Gheorghe Țițeica, Nr. 142, Et. 1, Sector 2, Bucharest, Romania
Email: hello@mihaivasilescu.com
Telephone: +40 741 772 885
