The protection of your private sphere during the processing of personal data as well as the security of all business data is a major concern for us, that we take into consideration in our business processes.
Data protection and information security are an integral part of our corporate policy.
Therefore, we take care to process your personal data in accordance with the principles set forth in the data protection legislation applicable in Romania, including (EU) Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”).
As provided by GDPR – in force as of 25th of May 2018, Personal data represents any information relating to an identified or identifiable natural person, and an identifiable person is that person that may be identified directly or indirectly, particularly by reference to an identification number or to one or more factors specific to its physical, psychological, mental, economic, cultural or social identity.
This privacy policy regards the personal data of our clients, business partners, other persons contacting and visiting us and of the representatives thereof, potential employees and it applies to data collected through our web-site as well as to all other personal data we collect through e-mail or other off-line contacts. This privacy policy describes:
- the purposes for which we collect and use your personal data;
- the processing grounds for such purposes;
- the categories of personal data we collect from you and process;
- the duration of processing of such data;
- your rights as data subjects and the manner in which you may exercise them;
- to whom we may disclose your personal data
PURPOSES, GROUNDS FOR PROCESSING AND CATEGORIES OF PERSONAL DATA
In the context of your interaction with us, you, as a natural person, may be subject to the data processing activities that we perform. Thus, we use your personal data in the following cases:
- If you are a client or potential client:
1.1. Providing the services/and/or products requested from us
We use your relevant personal data in order to prepare and provide the services and/or products you order from us. For instance, when drafting the contract/s to be signed with your company, when you are providing payment guarantees, we may have to rely on your personal data of relevance for our relationship. We rely in this case on the execution of our agreement as grounds for processing.
1.2. Communicating with you
We use your contact details in order to communicate with you with respect to your orders and any other relevant business-related matters. We rely in this case on execution of our agreement as grounds for processing.
1.3 Data processing as obligation imposed by the law
We may process some of your data in the context of providing the goods/products or services you request based on legal obligations. In such case, the grounds for processing is the legal obligation.
1.4 Sending newsletters
We may also use your contact details in order to provide to you in electronic form our special offers/ other information related to our business but only if you have subscribed and, hence, given your express consent to such processing. You can always withdraw your consent expressing your option not to receive our newsletters in the future by clicking “Unsubscribe” when you receive the respective e-mail or by writing to us.
The categories of data processed in the context of our relationship with you are your name, e-mail, phone, fax, no., as well as other personal data you may provide directly to us.
- If you are a representative, contact person or an employee or other collaborator of our client or potential client of ours
2.1. Providing the services/and/or products requested from us
We use your relevant personal data in order to prepare and provide the services/products orders requested from us. For instance, we may use the personal data to manage the relationship with the client you represent. We rely in this case on the legitimate interest in providing our services according to our area of activity and managing the relationship with our clients.
2.2. Communicating with you
We use your contact details in order to communicate with you with respect to your requests and any other relevant business-related matters. We also rely in this case on the legitimate interest in providing our services according to our area of activity.
2.3 Data processing as obligation imposed by the law
We may process some of your data in the context of providing the services/products you order form us based on legal obligations. In such case, the grounds for processing is the legal obligation.
2.4 Sending newsletters
We may also use your contact details in order to provide to you in electronic form our special offers/ other information related to our business but only if you have subscribed and, hence, given your express consent to such processing. You can always withdraw your consent expressing your option not to receive our newsletters in the future by clicking “Unsubscribe” when you receive the respective e-mail or by writing to us.
The data is provided either directly by you or by our client that you represent. The categories of data processed in the context of our relationship with you are your name, e-mail, phone, fax, no., as well as other personal data you may provide directly to us.
- If you are our business partner
3.1 Maintaining our contractual relationship with you
We use your relevant personal data in order to maintain our contractual relationship with you. We rely in this case on the execution of our agreement as grounds for processing.
3.2 Communicating with you
We use your contact details in order to communicate with you with respect to any relevant business-related matters. We rely in this case on the execution of our agreement as grounds for processing.
3.3 Data processing as obligation imposed by law
We may process some of your data in the context of providing the services/products you order form us based on legal obligations. In such case, the grounds for processing is the legal obligation.
The categories of data processed in the context of our relationship with you are your name, e-mail, phone, fax, no. address, as well as other personal data you may provide directly to us.
- If you are a representative, contact person, employee or other collaborator of our business partner
4.1. Maintaining our contractual relationship with our business partner
We use your relevant personal data in order to maintain our contractual relationship with our business partner. We rely in this case on the legitimate interest in ensuring that the contractual relationship is managed properly.
4.2. Communicating with you
We use your contact details in order to communicate with you with respect to any relevant business-related matters. We rely in this case on the legitimate interest of ensuring that the contractual relationship is adequately carried out.
4.3 Data processing as obligation imposed by law
We may process some of your data in the context of providing the services/products you order form us based on legal obligations. In such case, the grounds for processing is the legal obligation.
The data is provided either directly by you or by the business partner. The categories of data processed in the context of our relationship with you are your name, e-mail, phone, fax, no. address, as well as other personal data you may provide directly to us.
- If you are a job applicant:
We use the personal data contained in the CVs we receive in order to assess the applicants’ qualifications for a position within us. We base our processing on the grounds of entering into and performing of the labor agreement.
The categories of data processed in the context of our relationship with you are your name, e-mail, phone, fax, address, personal data included in CVs, education and training details, professional qualifications, as well as other personal data you may provide directly to us.
- If you are a visitor of our premises:
We use your personal data in order to ensure the security of our premises, assets and personnel. In this case, we base our data processing on the legitimate interest of us, namely the protection of such premises, assets and personnel.
The categories of data processed in this context are your name as well as other personal data you may provide directly to us.
- If you are a user of our Internet web-sites:
We use the personal data we collect from you when you visit our Internet sites, in order monitor the traffic and improve the content of the website. We base this data processing activity on our legitimate interest in ensuring the proper functioning of our Internet web-sites, as well as its improvement.
The categories of data processed in this context are the hour and date of accessing the Internet web-sites and the IP address from which our Internet web-sites were accessed.
For all above categories of data subjects, we may also process your data in the context of changes in structure or similar transactions involving any affiliated/mother legal entities. In this case, the grounds for processing may be represented by the legal obligation, the performance of the agreement concluded by us in the context of such transaction (if you are a party to such agreement) or the legitimate interest of us to carry out the transaction in the most effective manner (in the rest of the cases).
PROVIDING THE PERSONAL DATA
When the data is required directly from you, we will asks you to provide all categories of personal data we request in the aforementioned purposes, as otherwise we shall not be able to carry out our activity (including, among others, to provide you with our products/services).
If you provide us with the personal data of other natural persons, we kindly ask you to communicate to them before such disclosure the modality in which we intends to process their personal data, as described in this Privacy Policy.
DISCLOSURE OF YOUR PERSONAL DATA
As a rule - we shall not disclose your personal data to any third parties.
However, there may be cases where:
-we disclose your contact details to our affiliates within our group of companies;
-if in your interest and necessary, disclose relevant personal data to relevant authorities, in the context of providing the products/services you have ordered from us.
DURATION OF PROCESSING
We intend to keep your personal data for the duration of the contract signed between the parties, as well as afterwards, according to our internal policies and the legal obligations incumbent upon us.
In case the data is not collected in the context of a signed contract, such data will be kept for as long as necessary in order to satisfy the purpose of the envisaged data collection.
YOUR RIGHTS
In your capacity as data subjects, the GDPR provides you with a series of rights including:
- the right of access – allowing you to obtain confirmation that your personal data is being processed by us and, if affirmative, the relevant details of such processing activities;
- the right to rectification – allowing you to rectify your personal data if inaccurate;
- right to erasure – allowing you to obtain the erasure of your personal data in certain cases (e.g., if the data is no longer necessary in relation to the purposes for which it was collected);
- right to restriction – allowing you to obtain the restriction of processing your personal data in certain cases (e.g., when you contest the accuracy of your personal data, for a period enabling us to verify such accuracy);
- the right to object – allowing you to object to further processing of your personal data within the conditions and limits set forth by law;
- right to data portability – allowing you to receive the personal data concerning you that you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another data controller.
We are committed to ensure your exercise of these rights.
You may exercise the afore mentioned rights and find out more about such rights by filing with us, as data controller by emailing us.
You also have the right to file a complaint with the data protection authority.
We shall always treat your requests with the highest degree of attention and address any queries you may have in the shortest time possible.
VERSIONS TO THIS PRIVACY POLICY
This Privacy Policy is in force as of April 25, 2018.
We reserve the right to make modifications to our security and data protection measures, insofar as this is necessary due to the technical development. In these cases, we will also adapt our privacy policy accordingly. Therefore, please note the currently valid version of our privacy policy.
