We are committed to informing you about how Inmotion Emanagement Srl. ("Inmotion" or "we" or "our") manages your information. This Privacy Policy ("Privacy Policy") applies to the information we collect and process about the users of our services, as well as those who communicate with us about our services, interact with us on social media, participate in our events, surveys, contests and promotions, or subscribe to our marketing and informational communications ("Interactions"). In this Privacy Policy, "Services" means:

• Inmotion websites that link to this Privacy Policy, including any versions optimized for viewing on a mobile device ("Sites"),
• Inmotion mobile applications (each an "app"),
• Services available through our sites and apps

We have established this Privacy Policy to inform you about the types of information we may collect during your use of the Services and other related interactions, how we use your information, when we might disclose your information, and your rights and choices regarding the information we collect and process.

Inmotion provides its services to users in Romania. Inmotion Emanagement Srl. (Jud. Constanţa, Mun. Constanţa, Str. Brizei, Nr.3d, Bl.Fb12, Sc.B, Et.1, Ap.23, Romania with fiscal identification data CUI: 47187364, Reg. Com. J13/4121/2022) is the data controller for personal data collected from users within the European Economic Area.

This Privacy Policy contains the following sections:

• The information we collect
• Use and processing of information and EU legal bases
• Sharing your information
• Use of cookies and other online tracking technologies
• How we protect your information
• Retention of your information
• Storing your information
• Links and third-party services
• Changes to this privacy policy
• EU rights regarding data subjects
• Contact information

THE INFORMATION WE COLLECT

We collect information related to our services and interactions directly from users, automatically related to the use of our services and interactions, as well as from third parties. We may combine the information we collect from these different sources.

Information you provide us

We collect information directly from users:

• Registration, management, creation, and modification of profile
• Access and use of account, as well as uploading content to services and other associated activities
• Access and use of sites and applications
• Sending payment information
• Registration and participation in events
• Participation in surveys, contests, lotteries, and promotions sponsored by Inmotion Emanagement
• Customer service, technical support, and related communications

The types of information we collect directly from you are: your name, email address, telephone number, payment and transaction history, and any other information you submit or otherwise provide to us. We also collect certain data if you provide us with your age, gender, preferred language.

USE AND PROCESSING OF INFORMATION AND EU LEGAL BASES

In general, we use the information we collect from and about you to provide and operate the Services, to respond to user requests, for customer support and assistance, to protect our rights and those of others, to send marketing communications, to help us personalize user experiences, and to improve the Services, as detailed below.

Legal bases for processing under EU law.

In Romania, the EU law on data protection applies, we process your personal data, as defined by applicable EU legislation for the purposes set out in the table below, based on the following legal grounds:

• Our contract with you. Our processing is necessary to fulfill our obligations under a contract with you or to take steps at your request before entering into a contract with you (for example, to verify the information you have provided us and to provide you with the Services).
• Our legitimate interests. Our processing is necessary for our legitimate interests, including protecting the security of our Services; to establish, protect, and defend our legal rights and interests; preventing fraud and verifying the identity and authorization of users; to personalize user experiences and content.
• Legal compliance. Where our processing is required to comply with applicable law (for example, to maintain your payment transaction history for tax reporting purposes).
• Your consent. When we have your consent, as defined by applicable law.

Purpose of use and processing

In general, we use the information we collect as presented in the table below:

Purposes of use and processing of information	EU Legal Bases	Collected Data
Providing support and services To provide and operate the Services and related features, fulfill orders and requests, and process your payments To update the Services To allow you to update, edit, and manage your content To communicate with you about the use of the Services and respond to your inquiries and complaints For troubleshooting, technical services, and customer support purposes	Our contract with you Our legitimate interests Protecting legal rights	first name, last name email address telephone number
Verification To verify the identity of users, applicants, and others we interact with To confirm the authorization of users accessing and using the Services	Our contract with you Our legitimate interests	first name, last name email address telephone number
Communication with you To communicate with you about your account or transactions with us To communicate with you about changes to our policies	Our contract with you Our legitimate interests Protecting legal rights	first name, last name email address telephone number
Protecting legal rights and preventing misuse To protect the Services and our business operations To detect, investigate, prevent, or take action regarding illegal activities, misuse, suspicion of fraud, or situations involving potential threats to the security or legal rights of any person or entity and as evidence in Litigation To investigate, enforce, and prevent violations of our policies and terms (including this Privacy Policy, Terms of Use) As necessary, to establish, protect, and defend our legal rights	Our legitimate interests Our contract with you Protecting legal rights	first name, last name email address telephone number
Complying with legal obligations To comply with the law To respond to legal process or law enforcement or regulatory authorities' requests, e.g., in response to subpoenas, court orders, and other legal requests from regulatory, court, and law enforcement agencies or related to national security requests	Legal compliance Our legitimate interests Protecting legal rights	any data held by us and requested by authorities
General operations Where necessary for the administration of our general operations, accounting, record keeping, and legal functions As part of routine administrative operations, such as employee training, compliance auditing, and similar internal activities	Our legitimate interests Protecting legal rights	first name, last name email address telephone number

In addition, we may process the information to the extent necessary to protect the health, safety, or vital interests of any person and to establish, protect, and defend our legal rights.

SHARING YOUR INFORMATION

We disclose the information we collect, in the following ways:

• Business partners and third parties. We may share your information with business partners; where required by applicable law, we will obtain your prior consent. You can withdraw your consent or tell us not to share your personal information (as defined in applicable law) with business partners and third parties at any time by following the opt-out process described in the "Your Choices" section below.
• Third-party service providers. We use a variety of third-party service providers who perform functions on our behalf, such as hosting, billing and payment processing, push notifications, storage, bandwidth, content management tools, customer services, fraud protection, etc.
• General operations. Where necessary for the administration of our general, accounting, record-keeping, and legal functions, to our tax advisors, legal counsel, and other entities or professional service agents.
• Legal compliance and protection of rights. We may also use or disclose information if it is necessary to do so by law or in good faith that such action is necessary to
  (a) comply with applicable law or comply with legal process upon us or the Services;
  (b) establish, protect, and defend our rights or property, the Services, or our users, including investigating, preventing, or taking action regarding illegal activities, suspicion of fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use, Rental Agreement, other agreements or policies, or as evidence in litigation in which we are involved; and
  (c) act in emergency circumstances to protect our personal safety, that of our affiliates, agents, or service users, or the public. This includes exchanging information with other companies and organizations for fraud protection.
• Business transfers. As we continue to develop our business, we may seek to buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions), user information may be among the transferred assets. If a part or all of our assets are sold or transferred to a third party, customer information would likely be one of the business assets transferred. If such a transfer is subject to additional mandatory restrictions under applicable laws, we will comply with those restrictions.

To request more information about the companies to whom we have disclosed the information, please contact us, as set out in the "Contact Information" section.

USE OF COOKIES AND OTHER ONLINE TRACKING TECHNOLOGIES

Cookies are a standard feature of websites that allow us to store small amounts of data on your computer about your visit to the site. Cookies help us determine which areas of the site are useful and which areas need improvement. We also do not use these files to provide access to marketing and re-marketing information. These files contain a unique code for each visitor and can be considered personal data under the GDPR.

For more information on our use of cookies, please see our Cookie Policy.

HOW WE PROTECT YOUR INFORMATION

We take technical, physical, and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, disclosure, or unauthorized access. However, no method of transmission over the internet and no means of electronic or physical storage is absolutely secure. We recommend you take steps to protect your information and to prevent unauthorized access to your password or account, among other things, by logging out after using a shared computer, choosing a robust password that no one else knows or can easily guess, and keeping your log private and password-protected. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

RETENTION OF YOUR INFORMATION

We keep your information for as long as necessary to satisfy the purpose for which it is collected and used (for example, for the time needed to provide you with the services, to respond to inquiries, or to resolve technical issues), except where a longer period is necessary for our legal obligations or to establish, protect, or defend legal claims.

STORING YOUR INFORMATION

Your information may be transferred, accessed, stored, and otherwise processed by us and these third parties for the purposes described above and subject to law enforcement requests, in jurisdictions outside of your home jurisdiction and the European Economic Area where we or our service providers operate. Some of these jurisdictions may not offer an equivalent level of data protection as your home jurisdiction. By providing us with your information, you acknowledge any such transfer, storage, or use. We will take steps to ensure that your information receives an adequate level of protection in the jurisdictions where we process it, including through data processing terms and / or appropriate data transfer agreements.

Persons in the EEA If you are in the European Economic Area, where your information is processed by Inmotion or third-party service providers and processors in a jurisdiction that the European Commission has considered does not provide an adequate level of data protection (a "third country"), we will take appropriate measures to ensure that your information is subject to adequate safeguards, such as by signing the relevant EU standard contractual clauses approved by the European Commission (the form for these clauses can be found here) or another measure that has been approved by the European Commission as providing adequate safeguards for the protection of information when transferred to a third country. If you are in the EEA, you have the right to obtain details about the mechanism by which your information is transferred to a third country. For more information about these transfer mechanisms, please contact us, as set out in the "Contact Information" section below.

LINKS AND THIRD-PARTY SERVICES

The Services contain links to third-party websites and also contain plugins and functionalities of third parties (such as the Facebook "like" button). If you choose to use these sites or features, you may disclose your information not only to those third parties but also to their users and the public in general, depending on how their services operate. We are not responsible for the content or practices of these sites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of third-party sites or services, not this Privacy Policy. Please read the privacy and security policies of these third parties.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised privacy policy accessible through the services and update the "effective date" for the privacy policy. If we make a significant change to the Privacy Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you confirm that you have read and understood the most recent version of this Privacy Policy.

EU RIGHTS REGARDING DATA SUBJECTS

Subject to applicable EU laws, you have the following rights:

• The right to obtain access to and/or a copy of certain information we hold about you.
• The right to obtain, in certain circumstances, a copy of certain information we have about you in a structured, commonly used, and machine-readable format and to ask us to transfer this to a third party of your choice.
• The right to request an update to your information if it is outdated or incorrect.
• The right to request that we delete certain information we hold about you.
• The right to request the restriction of how we process and disclose certain information.
• The right to revoke your consent for processing your information, to the extent that the processing of your information is not based on another legal basis.
• The right to object to certain processing of your information as follows: the right to object to direct marketing: you can object to our processing of information for direct marketing purposes. See "Your Choices" above for more information.
• The right to object to processing (including profiling) based on legitimate interest grounds: additionally, when we rely on our legitimate interests to process information, you can object to this processing. If you object, we must stop this processing unless we can demonstrate compelling legitimate grounds for the processing that outweigh your interests, rights, and freedoms, or we need to process the information for the establishment, exercise, or defense of legal claims.

We will consider each case individually.

You can exercise your rights or make a request regarding the information we hold about you, request additional information about your legal rights under applicable law, or send a complaint about our privacy practices by contacting us at any time, using the contact details provided in the "Contact Information" section below. Also, you can access and modify much of the information you have transmitted by logging into your account and updating your profile. Please note that copies of the information you have updated, modified, or deleted may remain visible in cached and archived pages of the sites or applications for a period of time. In addition, we may retain certain information about you, as required by law or as permitted by law for legitimate business purposes. For example, if you request that we delete your information, but we believe you have violated the Terms of Use, we may retain information about you to try to resolve the issue before deleting it. In addition, you will not be allowed to review another person's or entity's information.

We will consider all requests and provide our response within the time period prescribed by applicable law. We may also ask you to provide us with the necessary information to confirm your identity before responding to your request.

Complaints. If applicable, you can file a complaint with the privacy regulatory authority or supervisory authority in Romania. Alternatively, you can seek a remedy through local courts if you believe your rights have been violated.

Categories of personal information we collect

Throughout this policy, we discuss in detail the specific elements of personal information we collect from and about our users.
1. identifiers (such as name, address, email address);
2. commercial information (such as transaction data);
3. financial data (such as credit card information collected by our payment processors on our behalf);

How we use and share these categories of personal information

We use and share the categories of personal information we collect about you in accordance with the various business purposes we discuss throughout this Policy. See the "Information We Collect", "Use and Processing of Information and EU Legal Bases", and the "Sharing Your Information" section above for more information.

CONTACT INFORMATION

If you have questions about this privacy policy, want to exercise your rights regarding the information we hold, or wish to make a change regarding your information, contact us: office@inmotion-app.ro