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Your GDPR rights

Last updated: August 4, 2026

HOLA25 SRL lets you exercise the rights provided by Regulation (EU) 2016/679 (the "GDPR") and Romanian Law No. 190/2018. These rights apply to data we control; some requests may be limited by another person's rights or by a legal obligation.

The privacy notice is not blanket consent

The privacy notice gives you information. Reading or accepting it does not mean you consent to every processing activity. We request separate consent only for purposes that require it, such as marketing or optional cookies. Withdrawing such consent does not stop processing required for a contract, security, or the law. Live-lesson recording is a mandatory product characteristic, separately accepted before checkout; that acceptance proves notice and is not presented as the GDPR ground by itself. The grounds are explained in the Privacy Policy.

1. Your rights

Access and a copy

You may ask us to confirm processing, provide a copy, and explain purposes, categories, recipients, sources, retention, and transfers.

Rectification

You may correct inaccurate data and complete incomplete data. You can also edit eligible profile fields in account settings.

Erasure

You may request erasure when Article 17 GDPR applies. The right is not absolute: we may restrict and retain data required by law, a legal claim, fraud prevention, or another participant's rights.

Live-lesson recordings: in the product, the teacher and participants authorised for a segment may access the file under the product rules, while authorised Hola25 personnel may review it only for safety, refunds, or disputes. The teacher, attendee, or person validly exercising that attendee's rights may request a copy or early erasure, subject to the rights of other participants and assessment of the request. The ability to access, play back, internally review, or publish the file through Hola25 expires automatically no later than 90 days after the lesson, and the file becomes unavailable. The technical process then attempts deletion; if deletion is not confirmed, the file remains blocked and inaccessible while the operation is retried and escalated. A dispute or legal duty does not extend retention of the file in the current configuration. Separate acceptance, attendance, payment, refund, and dispute evidence may remain restricted for longer, without access to the audio-video file. We do not currently intentionally extend retention of the video file beyond the 90-day maximum and do not apply a legal-hold mechanism to it. Such a mechanism may be introduced later for litigation, investigations, legal duties, or the defence of rights only after technical activation and an update to the applicable notice and terms, and acceptance where required; it would not extend ordinary participant access, and internal access would be limited to authorised people with a need to review it. Only audio, video, and screen streams you enable are captured; the camera may remain off where the room permits. A technical error may prevent the recording from starting, continuing, synchronising, or being saved. Processing may take time, and there may be offsets of a few seconds, gaps, interruptions, or incomplete files. Hola25 does not guarantee exact synchronisation, completeness, or availability of a recording. The status shown in the room is the applicable status; if the product requires recording and the system cannot confirm it, the lesson may be stopped and there may be no playable file. Report any problem without delay through the support channel. Joining the lesson and accepting recording does not authorise public or advertising use: that requires separate express permission from every identifiable person and, for a minor, their parent or legal guardian where applicable.

Restriction

You may ask us to limit use of data, for example while we verify its accuracy or assess an objection. Restricted data is marked and available only to authorised roles.

Portability

For data you provided that is processed automatically on consent or contract, you may request a structured, commonly used, machine-readable format.

Objection and direct marketing

You may object to processing based on legitimate interests. An objection to direct marketing takes effect without justification; you can also change that preference in account settings.

Withdrawal of consent

Where a purpose relies on consent, you may withdraw it at any time. Withdrawal does not affect processing that was lawful beforehand.

Solely automated decisions

You may request human intervention and challenge a solely automated decision that produces legal or similarly significant effects. Eligibility rules, security or fraud signals, moderation tools, search, ordering, and recommendations may involve automated processing and, where applicable, profiling. A technical or payment check may automatically stop an operation; you may request an explanation and, where Hola25 owns the decision, human review. We do not use an automated result as a final decision with legal or similarly significant effects without the applicable safeguards and rights.

3. Providers and app stores

A request to Hola25 covers our systems and data we manage through the infrastructure, payment, app-store, and file services identified in the Privacy Policy recipient register. For the video room, we use the Live Lesson Service identified in that register. We may ask for details needed to find a transaction or booking and will instruct the relevant processor where it handles data for us.

If a teacher received and retained data outside Hola25 after a tutoring listing contact, that teacher handles the request for their independent system. We can help identify the channel but cannot erase data from a teacher's separate system.

4. Erasure, retention, and legal holds

On account deletion, we assess each category and erase or anonymise operational data that is no longer needed. A receipt acknowledgment or response does not mean that every permitted erasure or anonymisation operation is complete; we explain the status and any applicable limitation without describing pending work as completed. The following categories may be locked from ordinary use and remain available only to authorised personnel:

  • accounting source and supporting records — generally 5 years calculated from 1 July of the year after the relevant financial year;
  • annual financial statements — 10 years;
  • available records of the contract, accepted legal version, specific declarations, withdrawal, and refund — for legal duties, dispute resolution, and the defence of rights;
  • fraud, chargeback, safety, moderation, or litigation data — until resolution and expiry of applicable periods.

A legal or fiscal hold temporarily overrides erasure. Held data is not used for marketing or recommendations and is erased or anonymised when the legal basis ends.

5. How to submit a request

Email contact@hola25.com, preferably from your account address. State the right you are exercising and the account, child, booking, or transaction concerned. We request only what is necessary and proportionate to verify identity; do not send identity-document copies unless we ask through an appropriate channel.

Submit a GDPR request

We respond without undue delay and no later than one month. For a complex or numerous request, we may extend by up to two further months and notify you within the first month of the extension and its reasons. If we do not act on the request, we communicate the reasons, the right to complain, and the available judicial remedy within one month. Requests are free, subject to the GDPR's limited exception for manifestly unfounded or excessive requests.

6. Complaints and resources

If you are dissatisfied, you may complain to the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP) at www.dataprotection.ro, or to the authority in the Member State of your habitual residence, place of work, or the alleged infringement, without losing your right to a judicial remedy.