The Training Boutique S.R.L. | Brainovate | EI Romania | The Perfect 10 | Revealing the Leader Within
Last updated: 1 September 2026
This Privacy Policy explains how The Training Boutique S.R.L. (“The Training Boutique”, “we”, “us” or “our”) collects, uses, stores and protects personal data when you interact with us, use our websites, participate in our learning, training, coaching or assessment services, contact us, or otherwise engage with us in a professional or commercial capacity.
We process personal data in accordance with applicable data protection law, including the EU General Data Protection Regulation (GDPR) and applicable Romanian data protection legislation.
This Policy applies to services and activities delivered through our brands Brainovate, EI Romania, The Perfect 10 and Revealing the Leader Within. These are brands and service offerings of The Training Boutique S.R.L. and are not separate legal entities.
Where a specific service or assessment has its own privacy notice or contractual data protection terms, those terms should be read together with this Policy.
The legal entity responsible for the processing described in this Privacy Policy is The Training Boutique S.R.L.
Registered address: 30D Hipodromului Street, Corbeanca, Ilfov County, Romania
VAT/CUI: RO14823562
Trade Registry number: J23/1727/2006
Privacy contact: Alina Banescu Perkins
Email: alina@eiromania.com
The Training Boutique provides professional learning, leadership development, coaching, consulting, facilitation and assessment services through its brands.
Our services may include leadership and management development; emotional intelligence training and certification; executive, leadership and team coaching; workshops and organisational development; psychometric, behavioural and emotional intelligence assessments; customised assessments developed by The Training Boutique; certification and facilitator development; and consulting and organisational transformation.
Our services are delivered globally, both face-to-face in client locations or agreed venues and online through virtual learning, video-conferencing and digital collaboration platforms.
Depending on how you interact with us, we may process name and contact details; job title, role, employer and professional information; registration, attendance and participation information; learning objectives and development goals; coaching scheduling and administration information; assessment responses, scores, results, reports and feedback; information provided through enquiries, forms and communications; billing, invoicing and contractual information; technical, device, usage and website information; marketing preferences and communication history; certification records; and other information necessary to deliver an agreed service.
We seek to collect only information that is relevant and proportionate to the service or purpose for which it is processed.
We may collect personal data directly from you; from the organisation commissioning a service, such as an employer or corporate client; through assessment platforms or providers; automatically through our websites and digital services; from authorised representatives, facilitators, coaches or programme administrators; and, where appropriate for legitimate business purposes, from publicly available professional sources.
We use personal data only for purposes relevant to our relationship with you and, where services are commissioned by an organisation, for the purposes specified in the applicable contract or service agreement.
These purposes include delivering and administering training, coaching, assessment and development services; registering participants; scheduling and communications; delivering learning resources; producing agreed reports and assessment outputs; maintaining certification records; quality assurance; improving service and assessment accuracy; contract, invoicing and business administration; website and information security; legal compliance; protecting our rights; and permitted business or marketing communications.
We do not use client or participant personal data for unrelated commercial purposes. Where a further purpose is proposed, we will ensure an appropriate legal basis and, where required, obtain consent or provide additional information.
We may process personal data where necessary to perform a contract; where necessary for our legitimate interests and those interests are not overridden by your rights; with your consent where consent is required; to comply with legal obligations; or on another lawful basis available under the GDPR.
Where consent is the basis, it may be withdrawn at any time. Withdrawal does not affect processing carried out before withdrawal.
Many services are commissioned by organisations for employees, leaders, teams or participants. Client and participant data is used only to deliver the contracted services and for purposes specified in the applicable client agreement, service description or other documented arrangement, or as otherwise permitted or required by law.
Depending on the service, The Training Boutique may act as controller, processor, or have different roles for different processing activities. The applicable role is determined by the service and contractual arrangements.
When you participate in training, coaching, workshops or facilitated development programmes, we process personal data only to the extent necessary to deliver the agreed services.
Information shared during coaching engagements is treated as confidential and handled in accordance with the applicable coaching agreement, client agreement and professional obligations. We do not disclose the content of individual coaching conversations to a client organisation unless the participant has consented, disclosure is required by law, or it is expressly provided for in the applicable agreement.
We work with two global assessment providers: Core Strengths and Genos International.
Where an assessment is delivered using a provider’s platform, product or methodology, personal data may be processed through the provider’s systems. The provider’s own privacy notice, terms and security arrangements apply to its own processing.
Where The Training Boutique receives or otherwise processes information relating to such an assessment, we process it for the purposes of the relevant service, client agreement and applicable law.
For assessments developed by The Training Boutique, we determine the purposes and means of processing the assessment data, subject to the client agreement and applicable law.
Assessment data may include participant details, responses, scores, results, profiles, reports, feedback and completion information. It may be used to administer assessments, produce agreed reports, provide development insights, maintain and improve accuracy, reliability and validity, conduct quality assurance, develop methodologies and services, and for other commercial or operational purposes expressly agreed with the relevant client.
Where data does not need to remain identifiable, we may anonymise or aggregate it. Where identifiable assessment data is retained, it will be used and retained only for agreed purposes and as permitted by applicable law.
We do not sell identifiable individual assessment results to unrelated third parties.
Where possible and appropriate, we anonymise or aggregate information so that individuals can no longer reasonably be identified. Such information may be used for assessment analysis, quality assurance, research, service improvement, methodology development, trend analysis and aggregated reporting.
Once properly anonymised, information is no longer personal data for GDPR purposes.
Information relating to clients, participants, coaching engagements, assessments and organisational development work may be commercially or personally sensitive. We treat such information as confidential and limit access to people who need it to deliver, administer, support or quality-assure the contracted service. Employees, associates, facilitators and coaches are subject to appropriate confidentiality obligations.
When you use our websites, we may collect technical information such as IP address, browser and device information, operating system, pages visited, dates and times of access, referring website and security logs.
We use cookies and similar technologies to operate our websites, remember preferences, understand website usage, improve performance and, where applicable and permitted, support marketing activities.
Where required by law, we will obtain consent before placing non-essential cookies. Further details should be provided in our Cookie Policy.
We use HubSpot for customer relationship management, business contact databases, communications and certain website-related database and marketing activities. Depending on the service and functionality, HubSpot may act as our processor or as an independent controller for particular activities.
We may also use providers for website hosting, cloud storage, communications, assessment delivery, video conferencing, analytics, payment processing, IT, security, accounting and professional services. Where providers process personal data on our behalf, we use appropriate contractual and organisational safeguards.
We may share personal data where necessary and lawful with organisations commissioning our services; assessment providers; service providers and processors; technology, hosting and communications providers; payment and financial service providers; professional advisers; regulators or authorities where required or permitted by law; and parties involved in a corporate transaction where legally permitted.
We do not sell personal data to third parties.
The Training Boutique delivers services globally, including to clients and participants outside Romania and the EEA. Personal data may therefore be accessed or processed by our team, authorised facilitators, assessment providers or service providers in other countries where necessary to deliver agreed services.
Where personal data is transferred outside the EEA, we use an appropriate legal transfer mechanism and safeguards required by applicable law, such as an adequacy decision, Standard Contractual Clauses or another recognised mechanism.
We retain personal data only for as long as necessary for the purposes for which it was collected, including contractual, legal, accounting, tax, quality assurance and legitimate business requirements.
Retention periods vary according to the type of information, service, client agreement and our role as controller or processor. Where a client agreement specifies retention or deletion, we follow it subject to applicable law. Properly anonymised information may be retained longer.
We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. Measures may include access controls, authentication, confidentiality obligations, secure systems and communications, data minimisation, backups, security monitoring and incident-response procedures.
We may contact clients, business contacts and prospective clients about our services, programmes, assessments, events and relevant professional information where permitted by law. You can unsubscribe from marketing at any time. Unsubscribing does not prevent essential service, contractual, administrative or transactional communications.
Some assessments involve structured scoring, profiling or generation of results from participant responses. An assessment score or profile does not, by itself, mean that a decision concerning an individual is made solely by automated means.
Where solely automated decision-making produces legal or similarly significant effects, we will comply with applicable GDPR requirements and provide the safeguards required by law.
Subject to applicable law, you may have the right to access your personal data; request correction; request erasure; request restriction; object to certain processing; request portability; withdraw consent; and benefit from safeguards relating to automated decision-making.
These rights are subject to legal conditions and exceptions. Where another organisation is the controller, you may need to exercise your rights directly with that organisation.
Where an assessment is commissioned by an organisation, access to results may be determined by the contractual and data protection arrangements applicable to the assessment. The commissioning organisation may receive agreed reports or results for legitimate organisational purposes, while the participant may have rights to access their personal data under applicable law.
Where The Training Boutique is not the controller for the relevant processing, we may direct a participant to the relevant organisation or assessment provider.
If you provide us with personal data relating to another person, you should ensure that you are authorised to provide it and that the person has been appropriately informed where required.
Where a client provides participant information to us, the client is responsible for ensuring an appropriate lawful basis and required privacy information unless The Training Boutique is responsible under the applicable arrangement.
If you have concerns about how we process your personal data, please contact us first so that we can investigate and address your concern.
You also have the right to lodge a complaint with the competent Romanian supervisory authority: Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP). Website: https://www.dataprotection.ro/
We may update this Policy to reflect changes to our services, technology, business practices or legal requirements. For material changes, we will update the “Last updated” date and, where appropriate, provide additional notice.
The Training Boutique S.R.L.
30D Hipodromului Street, Corbeanca, Ilfov County, Romania
CUI: RO14823562
Trade Registry: J23/1727/2006
Data protection contact: Alina Banescu Perkins
Email: alina@eiromania.com
