This information note describes why and how we process personal data and provides information about your rights when the Company acts as a Personal Data Operator.
Personal data means any information about an individual that identifies or may lead to his or her identification.
Our policy is to collect personal data necessary for the purposes determined by the Company’s activities and we ask our customers and partners to provide us with those personal data necessary for these purposes. Due to the diversity of services and / or products we offer, described here, it is possible to process several categories of personal data, which vary depending on the type of product / service / activity / purpose of processing.
The main data / categories of data processed by the Company may be, as the case may be and depending on the purposes associated with the processing, data such as:
- identity data (name, surname, series and number of identity document / marital status, etc.), other data in the identity documents (such as date of birth, etc.)
- contact details (email address (es), home / residence address, phone numbers)
- preferences regarding types of services and products,
- data necessary for the risk assessment related to the natural persons representatives / guarantors in connection with the clients legal persons
SOURCE OF PERSONAL DATA AND, IF APPROPRIATE, PUBLICLY AVAILABLE SOURCES
We generally collect personal data directly from you. We may process personal data collected from other sources such as:
suppliers or partners
other publicly available sources (such as ORC, ANAF, media, social networking sites, etc.)
WHAT TYPES OF DATA PROCESSING DOES OUR COMPANY CARRY OUT?
Our company processes personal data for the purposes stated in this information note, and for each purpose may be used one or more data processing operations such as collection, registration, organization, structuring, storage, adaptation or modification, extraction , consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, deletion or destruction.
PURPOSES FOR WHICH PERSONAL DATA ARE PROCESSED
The company processes personal data for multiple purposes, and the methods of collection, legal basis for processing, use, disclosure, retention periods, etc. they can be different, depending on the purpose.
We may use personal data for one or more of the purposes described in this information note. If the Company will subsequently process personal data for a purpose other than that for which you have already been informed and which is not compatible with the purposes for which the data was originally collected / brought to your attention, the Company will provide information on that secondary purpose and any relevant additional information.
We use personal data primarily for the following purposes:
Carrying out the object of activity of the Company, providing products and providing services related in particular to the main activity of the Company
Managing our relationships with customers, suppliers, professionals in various fields of activity, etc., improving the activity and services of the Company in relation to our customers and partners, correspondence, offers, negotiations, contract management.
We process personal data in order to fulfill our contractual obligations and commitments to you.
Managing the risks associated with our business, in the sense that we take security measures to protect personal data, measures that involve the detection, investigation and resolution of security threats. Personal data may be processed as part of the physical security monitoring or in the computer applications we use. At the same time, we can perform checks on individuals who act as representatives and / or guarantors of clients or partners, legal entities.
In case of visiting our sites or our pages on social networks, it is possible to process some information about the online identifier of the visitor for the purposes mentioned in the Cookies Policy (for more information access the Cookies Policy) or other personal data potentially received / collected through these platforms and / or from social networks or other digital public sources.
Compliance with legal and / or regulatory requirements, such as those of a fiscal nature or those requested by special normative acts that regulate our object of activity or, as the case may be, archiving.
Finding the exercise or defense of a right in court.
LEGAL BASIS AND LEGALITY CONDITIONS ON WHICH DATA PROCESSING IS BASED
The legal bases of the processing take into account the provisions of the Regulation and the normative acts regarding the processing of personal data adopted in Romania, the provisions of the applicable legislation in the Company’s field of activity, Civil Code, Fiscal Code and related tax legislation.
The processing is based on at least one of the following conditions of legality of the processing:
- the processing may be necessary in order to conclude a legal relationship / contract and / or for its execution;
- the processing may be necessary in order to fulfill a legal obligation incumbent on the Company (eg those relating to the management of tax supporting documents);
- processing may be necessary to perform a task that serves a public interest (eg those related to archiving operations);
- the processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party, respectively:
- for the administration of our activity, the provision of goods and the provision of services related in particular to the main activity of the Company
- for the management of our relations with potential customers and clients or our partners
- for the management of the risks related to our activity
- the management of the notifications / complaints in connection with our services, in order to be able to solve the eventual notified issues, respectively to be able to improve our products and / or services, to ascertain the exercise or defense of a right in court
the processing can be based on your consent, only if we are in one of the cases expressly provided by the Regulation in this regard.
HOW LONG DO WE KEEP PERSONAL DATA?
We retain the personal data we process only for as long as is necessary for the purpose for which it was collected (including in accordance with applicable law or regulation), such as:
- During the performance of the contract / legal report for the personal data necessary in its execution, including personal data with which the Company may come into contact in the development of the legal relationship
- Until the expiry of the limitation period, in cases where the Company would have a legitimate interest in retaining certain personal data in connection with a potential dispute that may arise between the parties.
- For the period provided by law in situations where there are applicable regulations in this regard (eg in the case of mandatory accounting records and supporting documents underlying the records in financial accounting etc)
- During the management of the relationship with potential clients / clients / beneficiaries of our services / partners of the Company and their representatives, respectively until the exercise of the right of waiver (opt-out), for the transmission of communications containing information and offers regarding our services and / or products. of other persons as appropriate, commercial communications
- Until the withdrawal of consent for the processing of personal data based solely on consent
- During the archiving period in the public interest mentioned by law or in the applicable policies of the Company, as the case may be, for the data contained in the documents for which the law or the Company provided for the archiving
In any other case or in the absence of specific legal, regulatory or contractual requirements, our reference period for the retention of personal data is at least 3 years from the date of termination of relations / last contact between the Company and the data subject.
Any data may be retained by the Company, except from the foregoing provisions where applicable, until the expiry of the limitation period, in respect of situations in which the Company would have a legitimate interest in retaining certain personal data in connection with a potential litigation that may arise between the parties, for example in the context of the possible employment of the legal liability of the Company or of the person concerned by the processing.
In any case, except as required by applicable law, we will delete your data at the time you request it. The applicable exceptional situations will be communicated to the applicant through the response submitted to him by our company in connection with the request to delete the data.
YOUR RIGHTS AND HOW TO PRACTICE THEM
Our company is responsible for facilitating the exercise of any of your rights listed below.
Any of these rights can be exercised by sending an e-mail to email@example.com.
For the protection of your data, in order to prevent the abuse of malicious people who would follow the access to your data, our company may ask you to go through some identification steps in advance, to ensure that you are the person exercising your rights. mentioned below by means of a request. If we receive a request from you regarding the exercise of any of the above rights, we may ask you for additional information to verify your identity before acting on your request.
If you submit an application in electronic format for the exercise of your rights, the information will be provided by our company also in electronic format where possible, unless you request another format.
We will try to respond promptly to any request from you and, in any case, within the time limits expressly stated in the applicable legal provisions (usually 30 days from the registration of the request). In certain situations expressly provided for by applicable law, we may charge a request for access which will take into account the administrative costs required to fulfill the request.
In the event that, as a result of the application of legal provisions, our company cannot comply, in whole or in part, with a request received from you as a data subject, then the applicable exceptional situations will be communicated to you by by means of the reply submitted by our company in connection with the request in question.
- Right of access You have the right of access, in accordance with Article 15 of the Regulation, respectively to obtain confirmation from the Company whether or not it processes personal data concerning you and, if so, the following information: (a) the purposes of processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipients to whom personal data have been or are to be disclosed, in particular recipients from third countries or international organizations; (d) where possible, the period for which personal data are expected to be stored or, if this is not possible, the criteria used to determine this period; (e) the existence of the right to request the rectification or deletion of personal data or the restriction of the processing of personal data or the right to oppose the processing; (f) the right to lodge a complaint with a supervisory authority; (g) if personal data is not collected from you, any available information on its source; (h) the existence of an automated decision-making process including profiling, referred to in Article 22 (1) and (4) of the Regulation, as well as, at least in those cases, relevant information on the logic used and the importance and expected consequences of a such processing for the data subject.
- If personal data are transferred to a third country or an international organization, you have the right to be informed of the appropriate safeguards under Article 46 of the Transfer Regulation.
At your request, the Company provides a copy of the personal data subject to processing.
- Right to rectification of data You have the right to obtain from the Company, without undue delay, the rectification of inaccurate personal data concerning you, in accordance with Article 16 of the Regulation. Depending on the purposes for which the data were processed, you have the right to obtain the completion of personal data that are incomplete, including by providing an additional statement.
- When possible or necessary we will make corrections (as appropriate) based on up-to-date information and we will inform you about this if necessary.
- Right of deletion of data You have the right to obtain from the Company the deletion of personal data concerning you (according to Article 17 of the Regulation), without undue delay, except for certain cases provided by the Regulation, if one of the following reasons applies:
a) personal data are no longer necessary for the purposes for which they were collected or processed;
b) withdraw the consent on the basis of which the processing takes place insofar as the processing is based exclusively on the consent and there is no other legal basis for the processing;
c) you object to the processing carried out for the purpose of a public interest or for the legitimate interests pursued by the Company or a third party and there are no legitimate reasons to prevail over your interests / fundamental rights and freedoms regarding processing or you object to the processing for direct purposes
d) personal data have been processed illegally;
e) personal data must be deleted in order to comply with a legal obligation incumbent on the Company under Union or national law under which it is subject;
f) other situations provided by the Regulation insofar as they are applicable
- Right to a restriction on processing You have the right to obtain a restriction on processing (according to Article 18 of the Regulation) in the following cases:
- a) Contest the accuracy of the data, for a period that allows the Company to verify the accuracy of the data;
b) The processing is illegal, and you object to the deletion of personal data, requesting in return the restriction of their use;
c) The company no longer needs the personal data for the purpose of processing, but you request them for the ascertainment, exercise or defense of a right in court; or
d) You have objected to the processing in accordance with Article 21 (1) of the Regulation, for the period during which it is verified whether the legitimate rights of the controller prevail over those of the data subject.
Right to data portability You have the right to receive your personal data (according to Article 20 of the Regulation) that you have provided to the Company, in a structured, commonly used and automatically readable format, and upon transmission to another operator, without hindrance from the Company, if:
(i) the processing is based on consent pursuant to Article 6 (1) (a) or Article 9 (2) (a) of the Regulation or to a contract pursuant to Article 6 (1) (b) of the Regulation; and
(ii) processing is carried out by automatic means.
In the case of exercising the right to the portability of personal data, they may be transmitted directly from the Company to another operator expressly indicated by you, where this is technically feasible.
- The right to object when the processing is carried out for the purpose of the legitimate interests pursued by the Company or by a third party At any time you have the right to oppose, for reasons related to your particular situation, the processing carried out the purpose of the legitimate interests pursued by the Company or by a third party, including the creation of profiles. In this case, the Company will no longer process your personal data, unless it demonstrates that it has legitimate and compelling reasons justifying the processing and prevailing over your interests, rights and freedoms or that the purpose is to establish, exercise or defend a right in court.
- Right to object to processing for direct marketing purposes When processing is aimed at direct marketing, you have the right to object at any time to the processing of personal data concerning you for this purpose, including the creation of profiles, to the extent is related to that direct marketing.
- Right to Withdraw Consent If processing is based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of the consent prior to its withdrawal. The assumption of withdrawal of consent is not applicable in cases where the basis for processing is not consent.
THE RIGHT TO SUBMIT A COMPLAINT OR CLAIM
If you wish to complain about the use of your personal data, please send an e-mail with the details of your complaint to firstname.lastname@example.org.
We will analyze and respond to any complaints we receive within the legal deadlines.
You also have the right to file a complaint with the National Authority for the Supervision of the Processing of Personal Data (“ANSPDCP”).
RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL DATA:
The company may transmit / grant access / disclose personal data mainly to the following categories of entities:
• public authorities and entities (such as tax authorities, etc.)
• business partners
Transfers and disclosures are not made in principle to entities outside the European Union. If the Company transmits your personal data to a third country or to an international organization, we will ensure that it is properly protected, that we transmit the data in a country that provides an adequate level of protection as assessed by the European Commission or, if it is considered that the country does not have laws equivalent to EU data protection standards, we will ask the third party to enter into a legally binding contract / agreement / instrument that reflects the latter standards or provides other appropriate safeguards. this sense.
CONSEQUENCES OF REFUSAL OF PROVISION OF PERSONAL DATA
If personal data is collected directly from you, we inform you that you are not usually obliged to provide your personal information to the Company, unless their provision is a legal or contractual obligation or a necessary obligation. for concluding a legal relationship / contract.
Thus, in such situations, depending on the data you refuse to provide, it is possible that:
• our company is unable to conclude the contract or to continue the contractual relationship with you
• our company has made it impossible for it to partially / fully honor its obligations to you.
If you consider that the information contained herein is ambiguous or contains ambiguities, you can request clarifications in this regard from us at email@example.com.
By this Note, I have taken note of the information provided by Apollo Technologies in the light of the Regulation and I have been informed by Apollo Technologies about the rights conferred by the Regulation and the Romanian law on the protection of persons with regard to processing. personal data and the free movement of such data.