Privacy Policy – Parents / Legal Guardians / Legal Representatives
Last updated: June 20, 2025
Through this Privacy Policy, we inform you about how we collect, use, transfer, and protect your personal data. The processing of such data is carried out in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (hereinafter referred to as the “General Data Protection Regulation” or “GDPR”), as well as the applicable national legislation on personal data protection.
WHO ARE WE?
UPGRADE EDUCATION SRL provides educational counseling and mentoring services for students who wish to study abroad. We support and guide young people through the academic exploration process, the selection of suitable programs, and the preparation of their applications to top universities around the world. In this document, we will refer to the company using the terms “we”, “the Company”, or “Upgrade Education”.
Our contact details are:
Company address: Bulevardul Dimitrie Pompeiu no. 10A, Conect 1 Building, 1st Floor, Office 10
Email address: gdpr@upgrade.education
Phone number: +40 31 630 5013
HOW DO WE PROCESS YOUR PERSONAL DATA?
Personal data are:
- processed lawfully, fairly, and in a transparent manner in relation to the data subject;
- collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes;
- adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and kept up to date;
- stored in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
WHAT TYPES OF PERSONAL DATA DO WE PROCESS AND FOR WHAT PURPOSES?
For parents/guardians/legal representatives, we process the following personal data: full name, ID series and number, personal identification number (CNP), home address, email address, and phone number.
When completing and submitting the “Talk to a Mentor” form on our website – https://upgrade.education/ro/ (hereinafter the “Website”), we process the following types of data: first name, last name, email, phone number, student/parent status, country, city, name of the high school, expected graduation year, school type (public/private), last year’s GPA, preferred study destinations (UK, US, Europe, Canada), confidence in studying in English, family budget for studies, intended major, and reasons for submitting the form.
For the “Register for the Webinar” form, we process: first name, last name, student/parent status, phone number, email address, high school graduation year, confidence in studying abroad, and annual budget for studies.
For the “Access the ICERI 2024 Paper” form, we process: first name, last name, and email address.
For contests/raffles organized through our Website or on social media (Facebook, YouTube, Instagram, TikTok), we may process: full name, home address, email address, phone number, age, date of birth, and signature.
For website visitors, we may collect data through cookies or similar technologies, such as: IP address, browser type, location, web pages visited on our Website, time spent on the Website, internet network, and device used. For more details, please refer to our Cookie Policy. Politica de cookie-uri
For the purpose of purchasing our book “Life After High School” via the website, we process the following personal data: first name, last name, email address, phone number, and delivery address.
We will not use your personal data to send marketing communications (e.g., newsletters) unless you explicitly consent by checking a consent box. In such cases, we process your first name and email address and provide a simple opt-out mechanism at any time.
WHAT ARE THE LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA?
Your personal data may be processed:
- for the conclusion and execution of contracts;
- for compliance with legal obligations that apply to us;
- based on your prior and explicit consent (e.g., in recruitment processes, for receiving marketing communications);
- for the legitimate interests pursued by the Company (e.g., ensuring the protection and security of our employees, exercising legal rights and defending the Company in legal proceedings).
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We store personal data only for as long as necessary to fulfill the purposes set out in this Policy or as required by law (e.g., for accounting, archiving, or regulatory compliance).
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
We do not disclose or transfer your personal data to third parties unless:
- Required by public authorities or institutions under legal obligations or to serve a legitimate interest (e.g., protecting the Company’s legal rights);
- Shared with our contractual partners or collaborators providing services such as web hosting, website development and maintenance, digital marketing, or communication services;
- You have explicitly and specifically consented to the disclosure of certain data for a particular purpose.
If personal data is transferred outside the European Economic Area, either directly by the Company or via its partners, we ensure that such transfers are carried out in accordance with the GDPR (especially Article 46), based on appropriate safeguards (e.g., standard contractual clauses adopted by the European Commission), and that enforceable data subject rights and legal remedies are ensured.
WHAT SECURITY MEASURES AND SAFEGUARDS DO WE APPLY?
The Company implements appropriate technical and organizational measures to ensure a high level of security and data protection. We use secure technologies and methods, along with internal policies and procedures — including control and audit mechanisms — to protect personal data in accordance with the relevant legal provisions.
WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?
As a data subject, you may exercise the following rights under the GDPR:
- Right of access;
- Right to rectification;
- Right to erasure;
- Right to restriction of processing;
- Right to data portability;
- Right to object to processing;
- Right not to be subject to a decision based solely on automated processing, including profiling;
- Right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (www.dataprotection.ro) or the competent courts.
To exercise your rights or if you have any questions regarding the processing of your personal data, please contact us at: gdpr@upgrade.education or by phone at +40 745 508 673, contact person: Ionel Orza.
Our Data Protection Officer (DPO) services are outsourced and provided by GDPRComplet.