Terms and conditions

Privacy & data processing policy

Date of last modification: 19.01.2021 

 

1.            The purpose of this policy

In short: you are on a site managed by Internet Corp SRL. We have in our portfolio several sites that we manage and through this Policy we want to tell you what kind of data we collect from you, why we do it, what is the impact on you, what rights you have and how you can exercise them. 

 

This Privacy Policy & processing of personal data (hereinafter referred to as " Policy ") aims to inform you about how Internet Corp SRL , known under the generic brand " Internet Corp ", which we can refer to by "us", “Organization” or “enterprise”) treats the confidentiality of the data it collects and when you provide it to us by using this site, including any data you provide to us when, for example, you subscribe to our newsletter. , participate in one of our promotions or purchase a product or service. 

Internet Corp administers several sites (hereinafter individually referred to as the “ Site ” and collectively the “ Sites ”), and this Policy applies to all sites in the portfolio, namely:

• www.wall-street.ro
• www.kudika.ro
• www.9am.ro
• www.start-up.ro
• www.garbo.ro
• www.biztool.ro
• www.urbo.ro
• www.retail.ro
• ic.events
• virtual.ic.events   

as well as subdomains, affiliated domains and pages / profiles on social networks ( Linkedin, Facebook, Instagram ). A complete list can be found below, and it will be constantly updated according to the latest changes.

 

Our sites are not intended for children under 16, we do not collect and do not want to consciously collect data about children. To this end, we take all necessary steps to verify, reasonably, that the person providing us with the data is not a child, as defined above - the responsibility for any information provided to us with circumvention of these provisions being entirely to the person who transmits this data to us.

 

It is important that you read this policy along with all notices regarding the processing & privacy of the data we provide on various occasions when we collect or process your personal data in order to be fully informed of why and how we use this data. This policy comes as an addition to the other notifications and is not intended to remove them.

2.            Who are we?

Below you will also find our identification data:

to the extent that you have any doubts, comments or complaints about us or the personal data we process for you and how we ensure the confidentiality of this data, you can always send us an e-mail at the above address.

3.            Copyright

The company as author, owner, administrator of the Sites, collects and processes personal data belonging to persons accessing the Sites, in accordance with the legal provisions on the processing of personal data and the free movement of such data. Through this policy, we tell you what information we collect about you as a user of the Site (hereinafter referred to as " User "), how we use (process) it, and the options you have regarding this data.

 

This Policy applies to all devices used to access the Sites, such as, but not limited to, smartphones and tablets, laptops, smartwatches, and any other device with an Internet connection that allows access to remote control of the Site. The Company owns all copyrights on all content that the Company posts on the Sites, the persons who access the Site have no rights over the content, including, without limitation, reproduction, copying, distribution, modification, etc.

 

if you do not agree with the terms and conditions related to their use (set forth in this document in terms of personal data protection, but also in other documents on the website in terms of confidential information, etc. ), please do not use the Internet Corp Sites.

 

4.            Changes to this policy

This policy became applicable at Company level on the date indicated at the top of this website. to the extent we deem necessary, this policy may be subject to occasional changes. When we make changes, the updated policy will be published on this page, indicating the date from which it became applicable. In such a case, it will remain at the discretion of the Company if it notifies the persons on these changes in another way than the simple display on the website, as well as the way in which it will be performed ( e-mail, pop-up, slide bar, announcement, etc. ).

 

We encourage you to check for updates and changes to this policy by verifying this data when you access our Sites and mobile applications. We will notify you of any changes to this Policy that may significantly affect the way we use or disclose your personal information before the change becomes effective through a message on this site, when possible.

 

5.            Links to other sites

 

The site you are on is part of an ensemble that also includes the pages on social networks, as we mentioned in the beginning section. Even if we use these platforms to contact you and provide you with useful information or give you the opportunity to place an order for a product or service, they are governed by their own privacy policy, which we encourage you to read it here: Facebook , Instagram , Youtube , LinkedIn .    

 

On the Site or on the pages of the social networks mentioned above, there may be links to other sites over which we have no control, the respective links not being an indication of interdependence / connectivity with the respective entities. If you visit one of these websites, we recommend that you familiarize yourself with the rules of use of that website, the privacy and data processing policy, and the security standards used. The company is not responsible for the expressions and procedures used by the operators of these websites, you being solely responsible for the transmission of personal data on these websites.

6.            User Conduct

 

In short : you must behave properly on the Sites, so as not to harm other people. You must also not use the Sites in any way that would harm us.

By accessing the Site, you agree to comply with the legal rules in force in Romania when using this Site, to act invariably in accordance with good morals and those rules and not to destroy in any way the reputation and rights of the Company or other users.

 

1.            You will not use the Site:

2.            in any way that violates any local, national or other laws or regulations or any order of a court in any relevant jurisdiction;

3.            for any purpose not permitted by these rules;

4.            in any way that infringes the rights of any person or entity, including their copyright, trademark or other intellectual property rights or other private or contractual rights;

5.            to distribute advertisements of any kind or post or otherwise communicate any false or misleading material or message of any kind, including with respect to competitors, potential competitors, etc. ( we also include defamatory comments, reviews left with the intention of creating a negative image, comments that do not reflect reality, etc. );

6.            in any way that, intentionally or unintentionally, harasses, threatens or intimidates any other User or visitor;

7.            in any way that, whether intentional or not, promotes or incites racism, violence, hatred or physical or moral harm of any kind;

8.            in any way that is abusive, defamatory, inaccurate, obscene, offensive or sexually explicit;

9.            post photos, pictures or videos of another person without their permission (and if they are a minor, without the permission of the minor's legal guardian);

10.            to promote illegal activities or in any way that would lead to the encouragement, acquisition or pursuit of any illegal or criminal activity or that could cause injury, suffering or inconvenience to any person;

11.        access, manipulate, damage or use non-public areas of our suppliers' computer systems, servers or equipment or our technical delivery systems;

12.        access or attempt to access data of other Users of the Sites or to enter, access, penetrate any of the security measures relating to the Sites or to probe, scan or test the vulnerability of any system or network or to infringe or avoid any security or authentication measures;

13.        in any way that, intentionally or unintentionally, misleads or aims to deceive another User or visitor of the Sites;

14.        enter any malicious program, virus or other malicious software that harms or interferes with the operation of the Sites, including, but not limited to cancelbots, denial of services, time bombs, worms , Trojan horses, viruses or any other malicious software or hardware;

15.        interfere with or disrupt (or attempt to do so) the access of any User, host or network, including, without limitation, sending a virus, overloading, flooding, spaming, mailing services or writing content-creating scripts as such so as to interfere or create an unjustified burden on services;

16.        copy, modify or distribute the content of other Users without their consent;

17.        for commercial purposes other than those expressly permitted in these rules;

18.        circumvent the measures used to prevent or restrict access to the Sites;

19.        to request or provide illegal services;

20.        collect or collect information about other Users or visitors without their consent;

21.        obtain unauthorized access to the Products, the server on which the Products are stored, or any server, computer, or database connected to the Products;

22.        falsify any TCP / IP packet header or any part of the header information in any e-mail or post, or in any way use the Sites to send altered, misleading or false source information;

23.        scrape, crawl or otherwise retain or use the Sites or any content for phishing, spam, trolling or any unauthorized (commercial) purpose; or

24.        to promote or support or solicit involvement in any other platform or political, religious (recognized as organized or unorganized), cult or sect of any kind.

    2.            We are not liable for any damages caused to you as a User or to any third party as a result of our fulfillment of any of our obligations under these rules or for damages resulting from improper use of the Sites.

    3.            You agree to keep the username and password of the account on the site safe, where applicable, and you are solely responsible in the event of their fraudulent use by a third party.

We are not responsible for any damage caused by any technical malfunctions of the Sites ( eg , the impossibility of accessing any link on the Sites).

7.            Liability

In short : you are directly responsible for the content you post on the Sites.

All risks that may affect you from using this Site are entirely your responsibility and the Company is not responsible for them. All disputes arising in connection with the use of the Site will be resolved by the competent material and territorial court in Romania.

1.            All content (text, photo, video, etc.) that you post through the Sites (such as product reviews or comments left on social networks, including video, photo or private message), hereinafter referred to as " Content " is the sole responsibility of the person who created such content.

2.            Although we do not routinely monitor content posted by Users, we reserve the right to do so and remove content that violates this Policy (or applicable law) of which we are aware, but we have no obligation to do so. We are constantly making efforts to delete or delete these messages or comments, but due to the short time, we may not be able to act promptly on all the issues reported.

3.            in case we are held liable for the content posted by the Users on the Platform, we reserve the right to go against the respective User for a full reparation of the damage suffered.

4.            any use or reliance on any content or materials posted through the Sites or obtained by you through the Sites is at your own risk. If we are notified by a third party that the content you submit or post violates these terms of use or any applicable law, either by letter or in the spirit of these terms, we reserve the right to remove such content from the Site. without prior notice. 

5.            We do not encourage, support, represent or warrant in any way the accuracy of the content or communications posted through the Sites, nor do we support and / or agree with the views expressed by Users on or in connection with the Sites, they being solely responsible for the content. respectively.

By using the Sites, you agree and accept that you may be exposed to content that may be defamatory, derogatory, inaccurate or inappropriate or, in certain cases, that there may be misleading posts. We will not be liable in any way for this content, including, but not limited to, errors or omissions or for any damage, material or moral, direct or indirect that has been posted, emailed or transmitted. socialization or made in any other way public through the Sites or in another context.

8.            Information on the processing of personal data

In short : because we process personal data, we have a number of obligations to you. Here you will find more details about who we are, what we do, what data we collect and where and what rights you have.

1.            To whom does this policy apply?

According to the legislation, as a User of the Sites you are a beneficiary of our services ( including by purchasing physical products, participating in certain events we organize, etc. ). Whether you do it in person, through a representative or if you are the contact person of a company or the person in a relationship of any kind with our Company, you are a " target person ", ie an identified or identifiable natural person.  

In order to be completely transparent about data processing and to allow you to easily exercise your rights at any time, we have implemented measures to facilitate communication between us, the data controller and you, as the data subject.

2.            We are in line with national and European regulations

in the course of its current activity, we process certain personal data relating to our customers, users and employees and assume the role of personal data controller in connection with the processing of such personal data.

When we process personal data, we carry out our activity in accordance with legal regulations, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (hereinafter referred to as the " General Data Protection Regulation " or " GDPR / RGDP "), as well as relevant national legislation or other legal provisions.

 

in accordance with the above-mentioned provisions on the protection of individuals with regard to the processing of personal data and the free movement of such data, we process and manage personal data for the purposes listed below, having implemented technical, organizational and security solutions in line with legal regulations.

 

During the use of the Site, we take all necessary steps to maintain the confidentiality of personal data transmitted by Users through the Site, both directly and indirectly.

 

This policy describes how the Company and its affiliates collect and use the personal data of users / employees in order to provide the products and services offered.

 

Examples of operations falling here include, but are not limited to, the following:

•                user / customer support, which involves requesting information or submitting complaints, after-sales activities, including customer service, informing users about the evaluation of services provided ( feedback );

•                carrying out the competitions organized by the Company through the Site or social networks, regardless of whether they are subject to legal rules or not;

•                delivery of prizes won or products ordered;

•                information about services, accounts, programs, contests and raffles;

•                presenting special offers, personalized promotions, advertising messages, promoting products and events, loyalty programs or other marketing purposes;

•                maintaining, improving and analyzing the websites, products and services we offer;

•                organizing events and registering for events, whether online or offline;

•                maintaining appropriate records for internal administrative purposes, maintaining the functionality of our websites and maintaining their relevance to customer needs;

•                providing information on marketed products and services;

•                providing important information on the safety of marketed products, where appropriate;

•                for activities specific to the human resources department, in case you are interested in being part of our team and you have sent a CV to the Human Resources department through the Site, in the dedicated section or you have been redirected to the contact page;

•                to respond to requests received on the contact address of the Company or in the dedicated section on the Site or through social networks, etc .;

Personal data will be kept for as long as necessary for the purposes mentioned above or, where appropriate, in accordance with legal provisions ( such as, for example, in the case of organizing competitions or maintaining financial-accounting records ).  

 

3.            Who we are? What do we do as a data operator?

As you have seen or will see, we request certain personal data depending on the stage you are in on the Site. in the matter of personal data, we are a personal data operator . In this capacity, we also have a number of obligations, including informing you about the data we process, how we do it, what rights you have and how you can exercise those rights. 

Below you will also find our identification data:

If you have any questions, comments or complaints about us or the personal data we process for you, you can always send us an e-mail at the above address.

4.            What information do we collect?

In short: we do not collect more personal data than we need. When you enter a site, depending on what you want to do, you send us a series of personal data. This data helps us better understand your profile and improve the content and services we offer. 

Personal data or personal information means any kind of information about an individual that can help identify that person. We do not include here those data where the identity was removed ( anonymized data ).

depending on the products, services or features you want to benefit from, we will need to process certain personal data, which will generally be as follows (this list is indicative and will be, where appropriate, detailed):

We also collect, use and share Aggregate Data for any purpose , such as statistical or demographic data. Aggregate data may be derived from your personal data, but are not considered personal data within the meaning of the law as this information does not directly or indirectly reveal your identity.   

 

For example, we may aggregate your Usage Data to calculate the percentage of users who access a site's specific functionality. However, if we combine or correlate the Aggregate Data with your personal data so that we can identify you directly or indirectly, we will treat the resulting combined data as personal data that will be used as described in this document. 

 

We do NOT collect any Special Categories of Personal Data about you (this includes details about racial or ethnic origin, political opinions, religion or philosophical beliefs or trade union membership and the processing of genetic data, biometric data for your unique identification, health data or data on sexual life or sexual orientation). We also do not collect information on criminal convictions and offenses.  

1.            Where do we collect this data from?

In short : we collect data mainly from you, when you register and participate in our events, subscribe to the newsletter, interact with us on social networks, ask us for more information about what we do or send us a CV for employment. There are also situations when we take this data from public sources or automatically, during your interaction with our Sites. 

 

You will see that as you use our Site, we collect information about you and the services you use.

 

The information we collect falls into three different categories:

2.            The information you provide us

as a customer (user who has purchased a product or service from the Site) - some information we collect is provided by you when you use our services, purchase one of the products, subscribe to the newsletter or get in touch with us on social media pages, e-mail or other way of linking. This may include your first and last name, username, password, email address, mailing address, telephone number, date of birth, and any other information you provide to us.  

 

any information provided by you, even if not requested by us ( such as sending certain documents via the contact form or social networks ) will be taken into account and you agree that your personal data may be used by us for the purposes set out below.

For these situations, the following examples of personal data will be considered:

•                your first and last name,

•                place of residence,

•                Email Address,

•                date of birth,

•                phone number,

•                payment details,

•                where appropriate, appropriate information on the order placed and,

•                photo-video images when you participate in offline or online events.

in this case, your personal data are processed in accordance with the terms & conditions found on the Site and on the pages of the related social networks. If you choose not to provide us with your data, we will not be able to complete your order, respond to your requests, register for contests or promotions, or allow you to enjoy the entire user and customer experience.

 

Customers' personal data are processed for the following purposes:

•                to facilitate the management of the client's orders;

•                marketing (for example, as part of the Company's marketing campaigns, to provide information about new products, to deliver the Company's commercial communications or to provide notifications of prizes won and other customer benefits);

•                customer satisfaction monitoring.

in the case of contests organized on the Site or through the pages on social networks, personal data are processed for the purpose of handing out prizes to the winners of a contest. Personal data can be used to send you information about products, services, events, etc. which we offer and host, provided that you tick the box corresponding to this option in the registration form for the contest (promotion) or have sent such data for one of the purposes mentioned above.

as a user - when you use the contact address, the contact number, write to us on one of the pages related to social networks or send us a request through the dedicated section of the Site through which you request certain information about the Company, you want to notify us certain aspects etc. In order to be able to reply to the sent messages, the Company must process the sent data. 

 

Careful! any information and personal data that you transmit in any way or another to the Company falls under your full responsibility, you being solely responsible for the accuracy of the information and data transmitted to the Company. 

 

3.            The information we automatically collect using technology

Some information is automatically collected by us, including when you access our Websites or otherwise use our services. This information includes:

•                Shopping information - we may collect information about your transactions on the Site, including what products you purchase, how often you access them, whether you have purchased other products, and any rewards or promotions associated with your purchases. 

•                Device information and general usage - we may collect information about your browser or device. This information may include the type of device you are using, the operating system, the browser, the Internet service provider, your domain name, the Internet Protocol (IP) address, the device and mobile ad identifiers, the website that will sent to the Site, the web pages you view (including the date and time you viewed them), the services or functionality you access or use (including the date and time you accessed or used them), and the subject of the ads you make click or view them. To collect this information, we use cookies, web beacons and / or similar technologies. The purpose of processing this data is their use by the Company to compile statistics, by using Aggregate Data, which analyzes the use of the site and to personalize advertising to Users, to the extent that they have agreed to this. 

•  

  4.            Statistical data & anonymous data

We may use statistical data or anonymous data resulting from processing for the following purposes:

•                preparation of reports / analyzes;

•                collecting information for own purposes;

•                publishing, promoting, offering the services offered by us.

  5.            Communication data. Cookies policy & other tracking technologies.

In short: cookies are not something to beware of, but we must manage them correctly. They help us to better understand what you would like to find on the Sites and to be able to offer you a pleasant experience through interactive content (video, podcast, sounds, interactive documents, etc.). Disabling cookies does not mean that you will no longer receive ads, only that they will no longer be personalized for you. 

This section on cookies explains how and why cookies, web beacons , pixels, gifs, and other similar technologies (collectively, "Cookies and other tracking technologies") can be stored and accessed. from your device when you use or visit the Site.

1.            What are cookies & other tracking technologies?

A "cookie" is a small text file of information that can be stored on your computer or mobile device with Internet access (smartphone, tablet or other devices that allow you to connect to the Internet and access a web instance) when you access the Internet. is installed at the request of a web server on a browser (eg Internet Explorer, Chrome) and cannot access the information on the user's computer / mobile device We mention that this technology does not contain software, viruses or spyware.

 

Other tracking technologies work similarly to cookies and place small data files on your devices or monitor your activity on the Site to allow us to collect information about how you use the Site. This allows the Site to recognize your device from other users of the Sites. The information provided below about cookies also applies to these other tracking technologies. You can find more information at www.allaboutcookies.org and www.youronlinechoices.eu.  

 

2.            What do we use cookies for?

Use of cookies - We use cookies and other tracking technologies to make the Site easier to use and to better adapt it to our interests, through our offers, to your interests and needs. Cookies are also used to increase the speed of your future activities and experiences on our site. These relate to your preferences for online privacy or relevant advertising. We also use cookies to compile anonymous, cumulative statistics that allow us to understand how people use the Site and to help us improve its structure and content, excluding personal identification of the user.  

 

3.            What types of cookies do we use?

The company uses two types of cookies: (a) session cookies and (b) persistent cookies .   

Session cookies are temporarily used and remain stored on your device until you log out of the site or close the application (web browser).

Persistent cookies remain on your device either for the period defined in the relevant cookie parameters or until you delete it. In general, we store cookies and files from other tracking technologies for a maximum period of 30 days . 

The cookies we use are included in one or more of the following categories:

1.            strictly necessary : These types of cookies are essential for the provision of services specifically requested by visitors to websites. without them, the websites may not function and may not provide the requested services.

A detailed presentation of the strictly necessary cookies of our website is given below:

2.            Performance : These cookies collect information about how visitors use a web page, such as which pages are the most popular, which method of connecting the pages is most effective, and whether users receive error messages from the pages. of Internet. These cookies allow us to offer users a high quality user experience and also allow us to measure the audience of the website. The information collected by these cookies does not identify users, but only has the role of helping to improve the way our website works, by transmitting information that allows us to offer a personalized experience in the future.

 

The information obtained by using cookies can be collected only for the purpose of mediating and performing certain functions of users. This data is encrypted in a way that disables access by unauthorized persons.

 

4.            What are cookies provided by third parties?

In certain situations, our Site uses cookies provided by third parties. Please note that we are not responsible for the processing of personal data by them and we recommend that you read their privacy and cookie policy.

 

For example , we include in this category cookies provided by third parties such as YouTube or Vimeo (for playing video content), Facebook (for displaying our fan page, events, etc.), Instagram (for displaying the feed and the ability to interaction with those posts), Linkedin (for displaying our business pages and events), Soundcloud, Apple Podcasts, Anchor FM (for playing podcasts), etc.

 

Although not required, if you choose not to accept these cookies, your experience with the Site may be limited ( for example, you may not be able to view entire items on a page, such as video content). 

 

A detailed presentation of the strictly necessary cookies of our website is given below:

5.            What types of similar tracking technologies do we use?

 

Our website uses Google Analytics, a web analytics service provided by Google, Inc. (" Google "). Google Analytics uses cookies to help the website analyze how users use that page. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You can refuse the use of cookies by selecting the appropriate settings on your browser. in the event that you choose to do so, you may not be able to use the full functionality of the website.

 

You can learn more about Google Analytics' privacy policy here . 

To disable the Google Analytics option, you can access the following link .

 

We also use the technology provided by Facebook, through Facebook Pixel and Facebook Custom Ads.

 

Facebook Custom Ads is a set of cookies that track your interactions with our Site, in order to offer you personalized advertising on Facebook where you are a registered user of such a service. Your encrypted email address is also shared by us or our third-party service providers with Facebook for this purpose. 

 

Facebook Pixel is used to track the level of conversion in Facebook ads and to target users with Facebook ads based on the actions they take on our site. 

 

This pixel records information about a user's browser session, which they send to Facebook, along with an anonymous version of their Facebook ID and URL. This allows us to target our Facebook ads to the audience of people who have visited the site.

We also use the technology provided by Linkedin, through Linkedin Insight Tag.

Linkedin Insight Tag is used to track the level of conversion in LInkedin ads and to target users with Linkedin ads based on the actions they take on our site. This pixel records information about a user's browser session, which they send to Linkedin, along with an anonymous version of their Linkedin ID and URL. This allows us to target our Linkedin ads to the audience of people who have visited the site.

 

Users' personal data is processed subject to their consent, which is voluntary and provided by the User when he accesses the Site.

Most Internet browsers are initially set to automatically accept cookies. You can change your settings to block cookies or to be notified when cookies are sent to your computer or mobile device (smartphone, tablet). If you cancel the cookies we use, you will no longer receive personalized information when you visit the Site. If you use multiple devices to view and access the Site (eg computer, smartphone, tablet, etc.) you will need to ensure that each browser on each device is set to match your cookie preferences. By accessing the "cookie settings" in the browsers you use, you will find instructions on how to change your cookie settings. These settings are usually found in the "options" or "preferences" menu of the browser. For more details you can also use the "help" option of your browser.

 

The browser may allow you to delete all cookies after closing them. However, this option leads to the deletion of permanent cookies that could store your preferences and personalized settings on the websites you visit regularly. However, you can keep the cookies you want, as your browser may allow you to specify which web pages always or never have permission to use cookies.

 

You can find additional details on how you can delete cookies or how you can manage cookies on different internet browsers by accessing the links below:

Internet explorer

Firefox

Chrome

iOS

 

9.            How do we use the information obtained?

In short: we use all this information obtained, either from you or indirectly from other interactions and sources in order to carry out our business. We use your data to be able to deliver services, to continue to offer good quality materials, to realize what you expect from us and to improve our services. 

 

As I said, we collect this information so that we can offer you our products and services, to improve the provision of services, as well as to develop new technologies to help you.

 

Specifically, we use the information:

•                to be able to deliver the purchased products and services;

•                to provide you with regular business information;

•                to keep you up to date with our latest news;

•                to improve the safety and security of our users and services;

•                for user support;

•                for research and development;

•                to allow communications to or between users;

•                in connection with legal proceedings.

 

We do not sell or distribute your personal information to third parties for direct third party marketing purposes.

 

1.            Providing services and providing functions

 

The company uses the information collected to provide, customize, maintain and improve its products and services. This includes the use of information to:

•                creating and updating your account on the Site, where applicable;

•                processing orders placed by you;

•                confirmation of your identity and / or the company you represent;

•                allowing access to your account and viewing the status as well as the transactions performed;

•                performing the internal operations necessary to provide our services, including troubleshooting software and operational errors, performing data analysis, testing, studying, monitoring and analyzing usage and business trends;

•                activities specific to the human resources department, in case you are interested in being part of our team and you have sent a CV to the Human Resources department through the Site;

 

2.            Customer support

We use the information provided by you (such as the history on the Sites, comments, messages or reviews left on social platforms or transmitted by e-mail or telephone, payment methods, personal data, etc.) to improve the support service. offered to users, such as for:

•                to respond to your requests in connection with the services and products we offer or the activities / campaigns we carry out;

•                to investigate and solve your problems that you bring to our attention;

•                monitor and improve customer support responses;

 

3.            Research and development

The company is in a continuous process of improving the services and products offered to users and customers, through continuous research and development, in order to constantly provide quality services and products.

 

Therefore, your data is very important to us and we will be able to use it for testing, research, analysis and product development. This allows us to improve the safety and security of our services, to develop new features and products, and to facilitate the provision and expansion of our services.

4.            Posts

The company may use the information you use to provide you with messages (via the platform, e-mail, phone number or social networks) regarding the status of your account, updates to the Site and social platforms, loyalty, reward, newly introduced events, services or products and the like when we think you might be interested.

 

5.            Legal proceedings

We may use the information you provide to us to investigate or resolve disputes, complaints or any existing issues regarding the use of the products or for any other purpose permitted by applicable law. We will also be able to transmit the information provided in accordance with the requests coming from the judicial bodies that have competence regarding the access to this information, such as criminal investigations, files pending before the courts or in a preliminary procedure, etc.

 

6.            Transfer of information obtained

We will only disclose your personal data for the purposes and to third parties described below.

 

 

Personal data may be distributed to any other member company of our group, if we consider that this is in our legitimate interest for internal administrative purposes ( eg data storage) or for auditing and monitoring our internal processes.

We will be able to share personal data with and / or to companies in our group if they provide us with products and services, such as IT systems or the human resources department and the financial-accounting department.

 

7.            Transfer of personal data abroad

We work with a number of partners and service providers that we carefully select to ensure that your data is secure. We consider it important that you are informed about where the data you provide to us is transferred.

 

The transfer of personal data to a third country may take place only if the State to which the transfer is intended provides an adequate level of protection.

 

The transfer of data to a State whose legislation does not provide a level of protection at least equal to that provided by the General Data Protection Regulation is possible only if there are sufficient guarantees regarding the protection of the fundamental rights of data subjects. These guarantees will be established by us through contracts concluded with the providers / service providers to whom the transfer of your personal data will be made.

 

Some of our service providers may be located outside the European Economic Area ( EEA ), so the processing of your personal data by them will involve a transfer of data outside the EEA.

 

Each time we transfer your personal data outside the EEA, we will ensure that there is a similar level of protection through one of the following safeguard mechanisms:

•                we will transfer your personal data to countries where the European Commission has been shown to provide an adequate level of security for your personal data. For more details, click here . 

•                when we turn to certain service providers, we will be able to use certain model contracts provided and approved by the European Commission that offer personal data the same protection that they have in Europe. For more details, click here . 

•                when we call US suppliers, we will be able to transfer the data if they are part of the EU-US Security Shield which obliges them to provide similar protection conditions for data shared between the EU and the US. For more details, click here . 

if the Company will be obliged to provide personal data or is not allowed to do so, only the data necessary to fulfill the strict purpose of the request will be disclosed.

8.            Providing data to third parties

In short: providing data to third parties does not mean that we sell your data or that we misuse it. Third parties are also the providers of accounting services, human resources, those who help us to send the newsletter you subscribed to, to generate your invoice or to allow you to make the payment online. 

 

We may disclose personal data to third parties. We will provide partners only with personal data that we have already processed, on which technical and organizational data protection measures have been established and other obligations arising from the General Data Protection Regulation have been fulfilled. Partners or group companies have access to personal data only to the extent necessary for the performance of their tasks.

We do not provide, in any case, for a fee, personal data to third parties.

 

The categories of recipients to whom we will be able to transmit the personal data collected are:

•                the contractual partners of the Company (as is the case of the companies with which we are in partnership, but only on the basis of a confidentiality commitment from them, which guarantees that this data is kept secure and that the provision of this personal information is done according to law in force); 

•                service providers that provide us with services related to the placement of personal data on servers, the management of digital resources ( such as CRM platforms ), the management of customer interactions, the processing of online payments and the evaluation of marketing inquiries ( eg marketing services, payment / banking services or other services), including entities that assist us in processing data as proxies, insurers, etc.); competent authorities (Prosecutor's Office, Police, courts and other competent state bodies and institutions), on the basis and within the limits of legal provisions and as a result of expressly formulated requests, as well as when required in accordance with applicable law;     

•                other companies in the same group , investors or advisory boards, other experts or consultants, who help us make decisions, as well as other business purposes. For example , we may share your information with affiliates and affiliates to administer our loyalty or reward programs, process orders and requests, and to expand and promote our product and service offerings, 

•                specialists, lawyers, accountants and other professional service providers.

We may also transmit personal data to third parties:

•                if you request or give us your consent;

•                persons who can prove that they have the legal authority to act on your behalf;

•                if it is in our legitimate interest to do so in order to administer, expand or develop the business;

•                in the event of a change of control within our Company ( such as merger, acquisition, division ) - we will transfer your personal data to the new owners of the Company's business;

•                if there is a change in the identity of the Company in terms of name, branding, international association, and your personal data will be processed under the identity of the new operator or association;

•                if we have an obligation to disclose your personal data in order to comply with a legal obligation, any legal request from governmental or executive authorities, including public or private institutions empowered to do so and as may become necessary to meet certain requirements of national security or law enforcement or to prevent certain illegal activities;

•                to respond to any claims, to protect our rights or those of a third party, to protect the safety of any person or to prevent any illegal activity; or

•                to protect the rights, property or safety of the Company, its employees, its customers, suppliers or others. Some of these recipients (including our affiliates) may use your data in countries outside the European Economic Area.

10.        Safety and security

we understand the importance of the confidentiality and security of personal data and take the necessary measures to protect our customers and others whose data we process from unauthorized access to personal data, as well as from unauthorized modification, disclosure or destruction of the data we process. current activity.

We have implemented the following technical and organizational measures for the security of personal data:

 

Dedicated policies. We constantly adopt and review internal practices and policies for the processing of personal data (including physical and electronic security measures), in order to protect our systems from unauthorized access or other possible threats to their security. These policies are subject to constant scrutiny to ensure that we comply with legal requirements and that the systems function properly. 

 

Data minimization. We ensure that your personal data we process is limited to those that are necessary, appropriate and relevant to the purposes stated in this Policy. 

 

Restricting access to data. we try to restrict as much as possible the access to the personal data that we process to the minimum necessary: employees, collaborators and other people who need to access this data in order to process it and carry out a service. Our partners and collaborators are subject to strict confidentiality obligations (either by contract or legal). 

 

Specific technical measures. We use technologies to ensure the security of our customers, always trying to implement the best solutions for data protection. We also perform periodic data backups in order to recover them in the event of an incident and we have implemented periodic audit procedures regarding the security of the equipment used. However, no website, no application and no internet connection is completely secure and untouchable (see NASA). 

 

Ensuring the accuracy of your data. Sometimes we may ask you to confirm the accuracy or timeliness of your data to make sure it reflects reality. 

 

Staff training. We constantly train and test our employees and collaborators on the legislation and best practices in the field of personal data processing. 

Data anonymization. Where we can, we try as much as possible to anonymize / pseudonymize the personal data we process, so that we can no longer identify the people they refer to. 

However, although we make every effort to ensure the security of the data you entrust to us, we may also experience less fortunate events and security incidents / breaches. in these cases, we will strictly follow the procedure for reporting and notifying security incidents and we will take all necessary measures to restore the situation to normal as soon as possible.

 

11.        Data retention

In short : we don't want to keep the data longer than we need it. However, we have some obligations, including legal ones, to keep them for a certain period of time. Below you will find explanations for the main processing we do. as long as you need more information, do not hesitate to write to us.

 

We keep personal data only for the time necessary to achieve the purpose of its processing and we do so according to the rules specified below:  

•                in the case of contests organized on Sites or social networks, personal data are kept only for the period of time in which you participate in that contest ( including the prize delivery procedure ), except for certain financial-fiscal provisions that may require a longer period of time. After this date, we will be able to keep the data obtained, after they have been anonymized, to use them for statistical purposes, for research, development, extension and improvement of the services provided; 

•                the personal data of the Users are kept for a maximum of two years from the last visit to the Site. After this period, in case of deletion of the account, we will be able to keep the data obtained, after they have been anonymized, to use them for statistical purposes, for research, development, extension and improvement of services provided.

•                in the case of employees, personal data are kept for a period in accordance with the archiving deadlines provided by law;

•                in the case of posts on social networks, events, conferences, promotional materials of any kind (indoor / outdoor / digital format / print format), the images or photo-video materials of Customers or Users will be maintained until an express request of the persons which occur in such materials. However, in the case of a request for deletion, we reserve the right not to grant such a request if we consider that our interest prevails over the interest of the data subject.

•                we retain information related to transactions and usage statistics, in accordance with regulations, tax and insurance requirements as well as other requirements in force where applicable. After this period, we delete or anonymize this information in accordance with applicable laws.

Below you will find an overview of our main activities in relation to you and the related storage periods:

 

In short, we will retain your personal data for as long as is necessary to fulfill our purposes for which we have collected it, including in order to meet any legal, accounting or reporting requirements. 

 

we try as much as possible to establish from the very beginning the period necessary for the storage of personal data, but this is not always possible. To determine the appropriate retention period for personal data, we consider the value, nature and sensitivity of personal data, the potential risk of harm caused by unauthorized use or disclosure of your personal data, the purposes for which we process personal data and whether we can achieve these purposes. by other means and applicable legal requirements.

 

By law, we must retain basic information about our customers (including contact details, identity, financial and trading data) for 5 years after they are no longer customers for tax purposes.

 

In certain circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for scientific, historical or statistical research purposes, in which case we may use this information indefinitely without prior notice.

 

Please note that in certain expressly regulated situations, we store data for the period required by law.

12.        Storage of data provided

 

The personal data you provide us and that we process are processed in the EEA ("European Economic Area") and stored on servers in Europe.

 

A full list of third-party sub-proxies details of their privacy policies can be found on our website when they exist.

 

Some non-EEA countries may not offer the same level of adequate protection of your rights and freedoms as regards the processing of personal data; however, by using our services, you consent to your personal data being disclosed by the Company to third parties. 

Please contact us if you would like more details about the specific safeguards applied to the transfer of your personal information outside the EEA.

 

13.        Purpose of processing

 

We use the information you provide to give you access to:

•                our current products and offers;

•                information about our activity;

•                our marketing campaigns;

•                various promotional offers carried out by us on a regular basis or during certain periods;

•                various campaigns that we think you would be reasonably interested in at some point given the history you have with us;

•                inform about the available jobs and the stages of the recruitment process, etc.

 

For the good performance of these services, we will be able to use the information provided for other purposes such as invoicing, statistics, research & development, etc. to the extent that we consider that the information provided may be used for purposes other than those mentioned above, we will immediately inform users about this issue.

 

14.        What do we rely on when we process your data?

In short : our data processing must be justified by a reason. Below you can find out about our processing grounds (based on what?) That give us the opportunity to use the data you entrust to us to achieve the purposes we mentioned earlier. If you need more details, please contact us.

1.            Data processing is required to provide the services you request

In order to provide the services and products you request from us, we need to collect and process certain information. These include:

•                information about the user's profile for participating in promotions and contests, so that we can verify the identity, compliance with the conditions, as well as to be able to deliver prizes or receive payments;

•                information about candidates and employees (CVs, documents required for employment), documents required to verify compliance with legal conditions and background and other information necessary to allow us to conclude the employment contract or to proceed to the interview period;

•                information about Customers or Users (for the purpose of promotion) in case of participation in events organized by the Company, where it will be possible to take photos and video recordings with participants / people who are present at the event, regardless of their quality. We reserve the right to use such data for further promotion of other events / in the current promotional activity of the Company to show others how past events were, in order to increase interest in future events;

•                information about transactions and cases entered into the Sites, which must be generated and stored in connection with the way the user interacts with the products and services they benefit from;

•                information about the use of our services, necessary to maintain, optimize and improve the services.

  2.            Processing is necessary for the legitimate interests of the Company

We collect and use personal information to the extent necessary to fulfill our legitimate interests. This includes the collection and use of information:

•                to maintain and improve the safety and security of users;

•                to prevent, detect and combat fraud that may be related to the use of our services;

•                to provide customer support services;

•                to optimize the service provided and develop new services;

•                for research, development and analysis purposes (we include here the analysis of usage trends to improve the user experience and the provision of new services);

•                to establish the marketing and communication strategy;

•                to carry out any promotions, contests or campaigns organized.

  3.            Processing is necessary to fulfill our legal obligations

Certain personal data will need to be processed in accordance with legal regulations ( for example , obligations to maintain financial-accounting records, employment documents, information on the resolution of complaints, etc.).

 

At the same time, there may be situations in which we have to transmit your personal data to the competent bodies and authorities when we are asked for this data in order to resolve or prevent disputes.

4.            Other grounds

We use various data processing grounds provided by you in order to provide you with services. These are:

15.        Data belonging to minors

 

We do not pursue in our data processing activities, the processing of personal data of minors under 16 years. Special attention is paid to ensure that any processing of personal data of minors is carried out in accordance with legal requirements and in strictly determined cases.

 

We do not carry out promotional marketing activities directly for minors. Minors who have not reached the age of 16 are not allowed to request services, nor to communicate on the Company's Website, nor to participate in contests, events or campaigns of the Company, unless this is done on behalf of the minor by the representative legal or guardian of the minor in question, according to the law.

 

Minors under the age of 16 may purchase products or services and request and receive communications from the Company only if they have the consent of their legal representative or guardian, in accordance with the law.

 

Also, any person who provides us with personal data through the Sites or other applications or devices covered by this Policy guarantees that he is of age, respectively has full capacity to exercise.

 

any collection or processing of personal data of minors will be carried out only in accordance with the law, and taking into account the above.

 

16.        Your rights

under the GDPR, you have a number of rights regarding your personal data:

 

Please note that:  

•                you can withdraw your consent for direct marketing at any time by following the unsubscribe instructions in each email / sms or other email.

•                if you want to exercise your rights, you can do so by sending a written request, signed and dated to the e-mail address: [email protected] or by any other way in which the Company makes it available to you and is highlighted in this Politics.  

•                the rights listed above are not absolute. There are exceptions, so each request received will be analyzed so that we can decide whether it is justified or not. to the extent that the request is substantiated, we will facilitate your exercise of your rights. If the request is unfounded, we will reject it, but we will inform you of the reasons for the refusal and of the rights to lodge a complaint with the Supervisory Authority and to go to court.

•                we will try to respond to your request within 30 days. However, the deadline may be extended depending on various issues, such as the complexity of the request, the large number of requests received or the inability to identify yourself in a timely manner.

•                we may in some cases have to charge a certain fee for the exercise of rights, especially when we consider that this is unjustified. in this case, we will inform you within the legal term about the need to pay the fee and we will proceed to resolve the request only after this fee has been paid.

•                we may not be able to provide the information requested in certain cases because it would involve "mixed data", ie personal data belonging to other persons and which we cannot reasonably and efficiently keep confidential. in such a case we will inform you within the legal term, including the fact that you will be able to submit a complaint to the competent authority.

•                if, although we make every effort, we are unable to identify you and you do not provide us with additional information in order to identify you, we are not required to comply with the request.

 

17.        Claims

If you want your personal data to be accessed, updated, rectified or deleted in certain circumstances (for example, when personal data is no longer needed for the purposes mentioned above), if you want to request a restriction on the processing of data in certain circumstances (e.g. , when you challenge the accuracy of the data - for a period that would allow us to verify the accuracy of the data in question); If you wish to lodge a complaint with us, if you wish to object to the processing of your data and at any time wish to withdraw your consent to the processing of your personal data which you have previously provided, you may notify us at any time by written requests, dated and signed, to the following e-mail address: [email protected] in connection with the processing of personal data within the Company.  

 

For the exercise of these rights, as well as for any additional questions regarding this notification or in connection with the use, by the Company, of personal data, please contact us by choosing any of the means of communication described above, also specifying the name your postal or email address (depending on how you wish to communicate), your telephone number and the purpose of your request.

 

We will make every effort to resolve your request as soon as possible.

You can also file a complaint with the personal data controller. For Romania, the contact details can be found below:

 

18.        Changes to this Note

We may occasionally update this Note and we will notify you via the platform or by email about the latest version. All updates and changes to this Note are valid immediately upon notification, which we will make by posting on the site and / or e-mail notification. Even if you do not receive a notification, we encourage you to access and read this Note periodically to keep up to date with the latest versions.

Note updated on Jan 21, 2021 .