Version 1.0, 25 MAR 2019
Policy on the processing of Personal Data
1.Categories of Personal Data, purposes of processing and legal grounds
1.1 Browsing data
Computer systems and software procedures used for the Platform’s operation acquire, during their normal operation, some Personal Data (so-called log files), the transmission of which is implicit in the use of internet communication protocols.
This information is not collected in order to be associated to identified persons, but due to its nature can, by means of processing and integration with data held by third parties, allow users to be identified. Such information includes the IP addresses, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, and other parameters concerning the user’s operating system and computer environment.
Insofar such information leads to the identification of a user, the provisions of this Policy shall become applicable.
Purpose of processing
We use this data only to obtain anonymous statistical information about the use of the Platform and verify its proper functioning.
- Our legitimate interest in improving our Platform and managing server capabilities and for seamlessly preserving our Platform (Article. 6 para. 1, let. f GDPR);
- Compliance with the legal obligations concerning the security aspects of our systems (Article. 6 para. 1, let. c GDPR).
1.2 Contacting ITPrepared
You can contact us in different ways: by email, by phone, by contact form or through the offer request form. In this case, we will process the following Personal Data: name, surname, email, telephone, company and any other information that you voluntarily provide when you contact us.
Purpose of processing
In this situation, we will use your Personal Data only to contact you regarding the requested offer or regarding the solving of the reported problem.
- Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Article. 6 para. 1, let. b GDPR);
- Our legitimate interest in ensuring communication with our customers and provide the necessary support for the use of the Platform (Article. 6 para. 1, let. F GDPR);
1.3 Prospecting customers by Data Partners
In the context, we use the following Personal Data: name, surname, telephone number, email address, company, function, position, LinkedIn account.
Purpose of processing
In this situation, we will use your Personal Data only to contact you in connection with providing our services.
- Our legitimate interest in promoting Data Partners’ services and contracting new customers (Article. 6 para. 1, let. f of GDPR);
- Your consent (Article. 6 para. 1, let. a of GDPR);
1.4 Concluding and/or executing a contract with Data Partners
In order to conclude and/or execute a contract with you, or with the company you represent, we processes the following Personal Data: name and surname, address, personal telephone number, e-mail, sex, marital status, date and place of birth, nationality, personal identification number, other data included in the identity card; contact details from the workplace, office location and address, company telephone number, fax, company e-mail, function, position, power of attorney.
Purpose of processing
The processing of Personal Data is necessary for the drafting, execution and termination of the contract established with you or the company you represent.
- Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Article. 6 para. 1, let. B of GDPR);
- We may process your Personal Data for the protection of legitimate rights and interests and support any claims before judicial bodies or any other public authorities, based on our legitimate interests to defend legitimate rights or interests or to support the claims arising or in close connection with drafting or executing the contract established with you, or the company you represent (Article. 6 para. 1, let. f of GDPR);
1.5 Providing Personal Data
2.Source of Personal Data
In case that the Personal Data is not collected directly from you, its source may differ as follows:
- We may obtain your Personal Data on social networks (for example, LinkedIn);
- We may obtain your Personal Data from the website of the company you represent;
- We may obtain your Personal Data from a third party who recommended you;
- We may obtain your Personal Data on different public platforms (e.g. AD platforms).
3.Automatic processing of Personal Data
Your Personal Data will not be processed to take decisions based solely on automatic processing that would result in legal effects on you or affect you to a significant extent.
4.Duration of processing
As a rule, we will process your Personal Data during the performance of the contract with Data Partners.
If there is no contract concluded with Data Partners, as a rule, we will process Personal Data for a period of 12 months.
In certain circumstances, we may retain Personal Data for longer periods of time, for example if we are obliged to do so in accordance with the legal, regulatory, tax or accounting requirements.
We may also keep Personal Data for longer periods of time so that we have accurate records of your interactions with us in the event of any complaints or if we reasonably consider that there is a prospect of litigation related to the processing of your Personal Data.
5.Transfer of Personal Data
We may transfer Personal Data when necessary to the following categories of recipients:
- Contractual partners;
- Companies offering courier services;
- Companies offering IT services;
- Software or hardware vendors;
- Marketing companies;
- Public authorities, courts or arbitration, and competent authorities to investigate criminal offences.
These recipients can be located in the European Union and/or in the European Economic Area. When recipients are located outside the European Union and the European Economic Area, including in countries not recognized as ensuring an adequate level of protection, the transfer of Personal Data shall be carried out only if there are appropriate guarantees, in accordance with the applicable law. In this respect, we rely on several guarantees, such as the Privacy Shield certificate or the standard contractual clauses issued by the European Commission. You may receive from us a list of recipients from third countries, as well as a copy of the agreed provisions that ensure an adequate level of protection of Personal Data. For any request to this effect, please reach out to us at the contact details mentioned below.
6.Security of Personal Data
The security of your Personal Data is important to us. Your Personal Data will therefore be processed by applying reasonable technical and organizational measures to protect Personal Data, such as limiting access to Personal Data, encryption or anonymization of Personal Data, storage on secure environments. However, despite the efforts we make, we cannot always guarantee the effectiveness of the security measures implemented, and therefore we cannot guarantee the security of Personal Data at any time.
7.Your rights in relation to the processing of Personal Data
7.1 Your rights
Access right: You have the right to obtain from us confirmation that your Personal Data is processed by us, as well as information on the specific processing, such as: the purposes of processing, categories of processed Personal Data, recipients of Personal Data, the period for which Personal Data is stored, if we transfer the Personal Data abroad and how we protect it, your rights, the right to lodge a complaint before the supervisory authority, the source of your Personal Data.
Right to rectification: You have the possibility to request rectification of your Personal Data, provided that the applicable legal requirements are met. In the event of errors, after notification, we will immediately correct your Personal Data.
Right to erasure: In certain cases, you have the possibility to request the deletion of Personal Data, namely when: (i) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent on which the processing is based according and where there is no other legal ground for the processing; (iii) you exercise the right to object to the processing; (iv) the Personal Data have been unlawfully processed. We are not obliged to comply with your request when the processing is necessary (among others) for compliance with a legal obligation or for the establishment, exercise or defense of legal claims. There are also other circumstances in which we are not obliged to comply with this request for the deletion of Personal Data.
Restriction of processing: You may request us to restrict the processing of your Personal Data in the following circumstances: (i) you contest the accuracy of the Personal Data, for a period enabling us to verify the accuracy of the Personal Data; (ii) the processing is unlawful and the you oppose to the erasure of the Personal Data and request the restriction of their use instead; (iii) we no longer need the Personal Data for the purposes of the processing, but you require them for the establishment, exercise or defense of legal claims; (iv) you have objected to processing, pending the verification whether our legitimate grounds override yours. However, we can continue to process your Personal Data (i) when you consent; (ii) for the establishment, exercise or defense of legal claims or (iii) for the protection of the rights of another natural or legal person.
Right to data portability: Insofar the Personal Data is processed based on your consent or on the execution of the agreement and the processing is carried out by automated means, you have the right to have your data Personal Data provided to you in a structured format, which is currently used and can be read automatically and you have the right to request us to transfer this Personal Data to another controller. This right shall not adversely affect the rights and freedoms of others.
Right to opposition: In certain situations, such as when we process your Personal Data on the basis of a legitimate interest, you have the right to object to the processing of your Personal Data by us. In the event of unjustified objection, Data Partners is entitled to continue processing Personal Data.
Objection to direct marketing: You can also object to the processing of your Personal Data for the purpose of sending marketing messages.
Revocation of consent: Insofar you consented to the processing of your Personal Data, you can at all times revoke your consent, without affecting the lawfulness of processing based on consent before its withdrawal.
Right not to be subject to any automatic individual decisions: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Such right cannot be exercised when the decision: (i) is necessary for entering into, or performance of, a contract between you and us; (ii) is authorized by law which lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (iii) is based on your explicit consent.
Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with The National Supervisory Authority for Personal Data Processing (“DPA”) in relation to any breach of your rights regarding the processing of your Personal Data. The contact details of the DPA are: 28-30 Gheorghe Magheru Boulevard, District 1, Postal Code 010336, Bucharest, Romania; e-mail: email@example.com
7.2 How to exercise your rights
To learn more about the manner in which you may exercise the aforementioned rights, please contact us at firstname.lastname@example.org .
Identity verification: We take utmost care of the confidentiality of all Personal Data and we reserve the right to verify your identity if you make a request in relation to your Personal Data
Fees: As a rule, you can exercise your rights free of charge. However, we reserve the right to request a reasonable fee if your claims are manifestly unfounded or excessive, in particular because of their repetitive nature.
Response Time: We make every effort to respond to your request within one month of receiving the request. This period may be extended by two further months where necessary, taking into account the complexity and number of the requests, in which case we will inform you of any such extension and of the reasons for the delay.