Data Processing Agreement
While ensuring your protection on data processing is an extremely important goal to us, we used our best endeavours to comply with the standards imposed in the UE Regulation 2016/679 (https://eur-lex.europa.eu/legal-content/ro/TXT/PDF/?uri=CELEX:32016R0679) and in any other legal act in force on the Romanian territory
An important step towards achieving this goal is the information on how your data will be processed (processing means any operation or set of operations performed on the personal data or set of personal data, with or without the use of automated means, such as collection, registration, organisation, structuring, storage, adaptation or alteration, extraction, consultation, use, disclosure or otherwise rendering available, alignment or combination, restricting, deletion or destruction).
1. Who we are and how can you reach us:
Collection of data / types of data
- Gathered automatically as a result of access (by type)
- IP Address
- Date and time of access<
- Timezone difference to Meridian Greenwich (GMT)
- Content content (website specific)
- Access status / HTTP status code
- The volume of data transferred
- Required access to the website
- Browser, language settings, browser version, operating system and surface
Collected after completing contact form:
- First and last name;
- Email address;
Third party cookies
- Within our Website, we use Google Analytics, a Google Inc. analysis service, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (hereinafter referred to as “Google”).
- Google will analyse the use of our Website on our behalf. The cookies will be used for this purpose. The information collected by Google regarding your use of our Website (such as the related URL, our web sites you visit, your type of browser, your language settings, your operating system, screen resolution etc.) will be sent to a Google server in the USA, where they will be stored and analysed. The results will be further rendered available to us in pseudonymised form. Moreover, Google complies with EU–US Privacy Shield, that ensures an adequate level of protection regarding the data processing by Google in the USA.
- You can withdraw your consent regarding the use of the web analysis at any time, by downloading and installing Google browser plugin provided.
Purpose of data processing
- To communicate with you
- To enable us to provide you with services customized to your needs
- For marketing purposes
- We can use the relevant information to improve the products and services we are offering you.
- To safeguard our legitimate interests
- To safeguard our legitimate interests (in exceptional circumstances such as cyber attacks that can endanger the safety of our platform or in case the information are requested by our competent public institutions aiming at solving ongoing investigations, we reserve our right to process the information concerned)
For how long we keep your personal data
The length of time for which your data will be kept is limited and will be subject to the period required for fulfilling the purposes for which the data are processed, this period non exceeding 2 years.
- In case we are bound by the law or we are required to safeguard a legitimate interest, we may disclose certain personal data to public authorities.
- We make sure that the access to your data by the third parties private law legal entities is in compliance with the legal provisions on data protection and information privacy, based on agreements concluded with them.
The data will be processed exclusively on the territory of Romania. Except for the pseudonymous data used in the site analytics function described at point 3. 1 “Third parties cookies” which is done in the USA according to the procedure described and is regulated by EU–US Privacy Shield
8.1. The Supplier commits to assist the Beneficiary to carry out the obligations that the latter has in relation to the data subject;
8.2. The Supplier commits to observe the data subject’s right as contemplated in the GDPR;
Right of access by the data subject
(1) The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
Right to rectification
(1) The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure (‘right to be forgotten’)
(1) The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
(c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
(d) the personal data have been unlawfully processed;
(e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
(f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).
(2) Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
(3) Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
(a) for exercising the right of freedom of expression and information;
(b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
(e) for the establishment, exercise or defence of legal claims.
Right to restriction of processing
(1) The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
(a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
(b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
(c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims
(d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
(2) Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
(3) A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.
Right to data portability
(1) The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
(a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
(b) the processing is carried out by automated means.
(2) In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
(3) The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
(4) The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.
Notification obligation regarding rectification or erasure of personal data or restriction of processing
(1) The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.
Without prejudice to your right to contact the supervisory authority at any time, you may preliminary contact the e-mail email@example.com and we will do our utmost to solve any issue.
You are entitled to file a complaint to the supervisory authority with regard to your personal data processing. In Romania, the contact details of the supervisory authority for personal data processing are:
National Supervisory Authority For Personal Data Processing
28-30 G-ral. Gheorghe Magheru Blvd., 1st district, postal code 010336, Bucharest, Romania