1. Hi there, we’re Gemba Partners, Bucharest, Romania  (“Gemba Partners”) and welcome to our privacy policy. This policy sets out how we handle your personal information if you’re a Gemba Partners subscriber or visitor to our Sites. It applies across www.gembapartners.ro (the “Site”).

2. When we say ‘we’, ‘us’ or ‘Gemba Partners’ it’s because that’s who we are and we own and run the Site.

3. If we say ‘policy’ we’re talking about this privacy policy. If we say ‘user terms’ we’re talking about the rules for using the Site. The rules vary by service provided and each service makes them separately available and seeks consent to them separately to this policy.

The type of personal information we collect

1. We collect certain personal information about visitors and subscribers of our Site.

2. The most common types of information we collect include things like: full name, email addresses, telephone number, IP addresses, other contact details, survey responses, and web analytics data.

How we collect personal information

1. We collect personal information directly when you provide it to us, automatically as you navigate through the Site, or through other people when you use services associated with the Site.

2. We collect your personal information when you provide it to us when you subscribe to a newsletter, email list, submit feedback, enter a contest, fill out a survey, or send us a communication.

​How we use personal information

1. We will use your personal information:

   1. To fulfil a contract, or take steps linked to a contract: in particular, in distributing relevant content for your area of interest

   2. Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests include:

      1. operating the Site;

      2. providing you with services described on the Site;

      3. updating you with operational news and information about our Site and services e.g. to notify you about changes to our Site, website disruptions or security updates;

      4. carrying out technical analysis to determine how to improve the Site and services we provide;

      5. monitoring activity on the Site, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the Site;

      6. managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the Site or asking for your feedback or whether you want to participate in a survey;

      7. training Gemba Partners staff about how to best serve our user community;

      8. improving our products and services.

      9. providing general administrative and performance functions and activities.

   3. Where you give us consent:

      1. providing you with marketing information about products and services which we feel may interest you; and

      2. customising our services and websites, like advertising that appear on the Site – where this involves the use of cookies or similar technologies – in order to provide a more personalised experience.

   4. For purposes which are required by law.

   5. For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.

When we disclose your personal information

1. We will disclose personal information to the following recipients:

   1. Gemba Partners staff

   2. subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above), in particular: website hosting providers which are located in US and UK; technical and customer support services and analytics services which are located in the US; subcontractors and services providers may also transfer and access such information from  other countries in which they have operations.

   3. our professional advisers (lawyers, accountants, financial advisers etc.) which are located in Romania;

   4. regulators and government authorities in connection with our compliance procedures and obligations;

   5. a purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase;

   6. a third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;

   7. a third party, in order to enforce or defend our rights, or to address financial or reputational risks;

   8. a rights holder in relation to an allegation of intellectual property  infringement or any other infringement; and

   9. other recipients where we are authorised or required by law to do so.

Where we transfer and/or store your personal information

1. We are based in Romania so your data will be processed in Romania and the US. Some of the recipients we have described in section 10 above, and to whom we disclose your personal information, are based outside Romania like UK and the US. We do this on the basis of your consent to this policy.In order to protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.

How we keep your personal information secure

1. We store personal information on secure servers that are managed by us and our service providers, and occasionally hard copy files that are kept in a secure location in Romania. Personal information that we store or transmit is protected by security and access controls, including username and password authentication, two-factor authentication, and data encryption where appropriate.

How you can access your personal information

1. You can access some of the personal information that we collect about you by contacting us at hello@gembapartners.com. You also have the right to make a request to access other personal information we hold about you and to request corrections of any errors in that data. You can also terminate the subscription you have with us for any of our Site at any time. To make an access or correction request, contact our privacy champion using the contact details at the end of this policy.

Marketing Choices regarding your personal information

1. Where we have your consent to do so (e.g. if you have subscribed to one of our e-mail lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.

2. You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our Site may not work properly in your case.

Cookies (not the type you eat!) and web analytics​

1. When you visit our Site, there’s certain information that’s recorded which is generally anonymous information and does not reveal your identity. We’re talking about the following kinds of details:

   1. your IP address or proxy server IP address’;

   2. the domain name you requested;

   3. the name of your internet service provider is sometimes captured depending on the configuration of your ISP connection;

   4. the date and time of your visit to the website;

   5. the length of your session;

   6. the pages which you have accessed;

   7. the number of times you access our site within any month;

   8. the file URL you look at and information relating to it;

   9. the website which referred you to our Sites; and

   10. the operating system which your computer uses.

2. Occasionally, we will use third party advertising companies to serve ads based on prior visits to our Site.  For example, if you visit our Site, you may later see an ad for our products and services when you visit a different Site.

Information you make public or give to others

1. If you make your personal information available to other people, we can’t control or accept responsibility for the way they will use or manage that data. There are lots of ways that you can find yourself providing information to other people, like when you post a public message on a forum thread, share information via social media. Before making your information publicly available or giving your information to anyone else, think carefully. If giving information to another user via our Site, ask them how they will handle your information. If you’re sharing information via another website, check the privacy policy for that site to understand its information management practices as this privacy policy will not apply.

How long we keep your personal information

1. We retain your personal information for as long as is necessary to provide the services to you and others, and to comply with our legal obligations. If you no longer want us to use your personal information or to provide you with the Gemba Partners services, you can request that we erase your personal information and close your Gemba Partners email subscription. Please note that if you request the erasure of your personal information we will retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the terms of service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

When we need to update this policy

1. We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.

2. When we do change the policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.

How you can contact us

1. If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact us at hello@gembapartners.com

2. We’re really glad you made it to the end of the privacy policy, because knowing this stuff is the best way to understand how your personal information is used and how to best manage it!

If you’re a subscriber or visitor in the European Economic Area these rights also apply to you:

1. For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information.

How you can access your personal information

1. You are also entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent as more fully described below.

2. These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.

3. Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.

4. If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.

Both personal information and personal data have the same meaning in the context of this Privacy Policy.

Gemba Partners Privacy Policy, effective date 1 January 2019