SECUNET PROJECT S.R.L., headquartered in Bucharest, str. Militin no. 49, sector 3, registered at the Trade Register with no. J40 / 1693/2016, fiscal code RO22947470, understands to update its personal data processing policy in order to comply with the new rules introduced by EU Regulation no. 679/2016 and the national legislation in force.
What is this Policy?
Through this policy we inform you about:
- Certain important concepts regarding personal data;
- What personal data do we process;
- How we use this data;
- To whom can we transmit the data;
- What are your data rights?
What are personal data?
“Personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identification element, such as a name, an identification number (Sr. and no. CI, CNP, no. mobile phone. ), location data (GPS), an online identifier (the IP address of your computer or the MAC address of your mobile device, as well as cookies), or one or more specific elements specific to your physical identity (profile photos, filming), physiological, genetic, mental, economic,
What does the processing of personal data mean?
“Processing” means any operation or set of operations performed on personal data or on personal data sets, with or without the use of automated means, such as the collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, restriction, deletion or destruction.
How should the data be processed?
- Fair, legal and transparent (“legality, fairness and transparency”);
- Collected for specified, explicit and legitimate purposes (“purpose limitations”);
- Adequate, relevant and limited in relation to the purposes for which they are processed (“data minimization”);
- Correct and up to date (“accuracy”);
- Kept in a form that does not allow the identification of persons for longer than is necessary in relation to the purpose of the processing (“shock limitations”);
- Processed in accordance with the rights of the data subject and in a manner that ensures adequate security and protection against unauthorized or illegal processing and against loss (“integrity and confidentiality”).
- Processing must be performed with (“responsibility”).
What does this policy cover?
The policy we implement covers all services of SECUNET PROJECT S.R.L. no matter how they are offered.
The policy applies to the processing of personal data of:
- To our respective contractual partners: beneficiaries of our services as well as service and equipment providers, sellers, customers (“Business Partners”);
- Visitors and users of our site that can be accessed at www.secunet.ro, (“Users”);
- Mobile application users (“Application users”);
- Interested persons to apply for certain positions within SECUNET (“Candidates”);
- Participants in training programs organized by the company (“Participants”).
What categories of information do we collect about you?
Information you provide to us
We collect and process your personal data when you interact with us to gain access to the services we provide (for example, the information you provide for the preparation of contracts and documents attached to them, invoices and other documents related to the sale / purchase of equipment).
This includes information that you provide when you register to use our site, participate in discussion forums or other social media activities on our site, by completing a registration form or otherwise, when you sign up for various online activities or when you report a problem with our site.
The information you provide to us in this way may include your name, surname, address, e-mail address and telephone number, personal description and photo, age, date of birth and sex, as well as other information, if relevant. for the service provided.
Information provided by the technology you are using
Each time you visit our site, we collect the following data according to the settings you can manage at any time, from any page:
- Technical data, for example, may include the Internet Protocol (IP) address used to connect your computer to the Internet, the connection information, the browser type and version, the time zone setting, the types and versions of browser extensions (plug-ins), the system and operating platform, device type and mobile device brand; this data may be collected and processed on our behalf through third-party cookies and you can find more information about this at https // www.secunet.ro / politica – de-cookies.
- Data about how you use our services, for example this can complete Uniform Resource Locators (URLs), cycle sequences to, through and from our Website (including date and time), information or products that you have viewed or searched the top categories accessed, page response times, download errors, average time spent in an application and the number of views in such applications, the average number of items / equipment viewed on our site, the methods used to navigate the page, User behavior data and any phone number used to call or any email address used to contact our customer service department.
- Sensitive dates
We will not collect or process sensitive personal data about you (for example, information about racial or ethnic origin, political opinions, religion or philosophical beliefs, health, sex life or sexual orientation), unless you have given us your consent. your explicit separately.
If you voluntarily provide personal data (including sensitive personal data) through your interaction with our site or through correspondence with us, by telephone, e-mail or any other means, on your own initiative and not at our request, we will delete such personal data from our systems if we do not consider that their processing is necessary for a legitimate purpose of SECUNET, unless you have made this data public (for example, in a message board which is visible to the public).
How and on what basis do we use personal data?
We must have a legal basis for processing personal data. It is called “legality of processing”.
Sometimes we will ask for your consent, as well as in the case of communications with you (for example, when you open an account, when you want to participate in certain campaigns or for marketing purposes) or if we process sensitive data.
In these cases, we will ask for your consent separately, transparently, when providing your personal data. Subsequently, you will be able to withdraw your consent at any time via the e-mail address [email protected] if the consent and / or personal data have been provided through the website. However, the withdrawal of consent will not affect the legality of any processing that took place before its withdrawal.
In other cases, we do not ask your permission to use your personal data, but we use other legal grounds for processing, namely when the legal provisions allow us to do so and if they are appropriate to your rights.
Thus, we can process your personal data:
- To conclude or execute a contract that we have concluded with you (especially applicable to trading partners);
- To provide our services;
- To comply with a legal obligation (for example, applicable employment law, accounting, auditing, equal opportunities monitoring);
- When necessary for our legitimate interests (or those of a third party) and your interests (for example, to detect and prevent fraud or to ensure the security of IT and networks), unless your fundamental rights prevail over of these interests;
- For various technical, administrative and operational reasons, such as to ensure that the content is presented in the most efficient way for you and your computer; to improve our website, including its functionality;
- For advertising and marketing, including specific marketing purposes, so that we provide content, including for personalized content, that would be of interest to you;
- To contact you (for example, to respond to a request, to keep you informed of changes or updates to our policies and practices, to respond to you when you contact us);
- As part of our efforts to keep electronic communications systems safe, accurate and up to date.
If we request personal data in order to comply with legal or contractual obligations, the provision of such personal data by you is mandatory. This means that if such personal data is not provided, we will not be able to manage the contractual relations or comply with the obligations imposed on us. In all these cases, the provision of personal data is optional and you have no obligation to provide it.
We may also process your personal data, such as identification data, contact details and address of residence, for the purpose of possibly exercising our rights or complaints against you in the future. This processing is based on our legitimate interest, being necessary to exercise our rights in case of possible litigation.
Most often, we will use your personal information in the following situations, as follows:
- Users and customers
- For the purpose of providing services, delivering goods or making payments under contracts, we may process your personal data, such as identification data, contact details, bank details. This processing is based on the performance of a contract to which I am a party or on a legal obligation imposed on us.
- We may process personal data so that we can provide you with information about goods or services that we believe are of interest to you.
- If you are an existing customer, we will contact you by email, phone, SMS or push notifications via Mobile Applications (as applicable) with information about goods and services similar to those that have been the subject of a previous sale or negotiation. with you for sale, unless you have previously opted to do so.
- If you are a new customer, we will only contact you by electronic means if we have your prior consent. If you do not want us to use your data in this way, check the appropriate box on the form by which we collect your data in the registration form. If you have installed a Mobile Application and no longer receive push notifications, you can change the settings of the mobile device or the settings in the Mobile Application.
In connection with your use of our mobile applications, we may collect and process your personal data, such as identification data, contact details, debit or credit card information, and geographic location data, when:
- You register to use our Mobile Application (including free trials) and provide us with information about you;
- Provide an evaluation or other post using the Mobile Application;
- Interact with us using the Mobile App;
- Interact with us by other means, such as telephone, fax, SMS, e-mail or social media.
This processing can be based on:
- Execution of a contract to which the users of the application are party by registering in such application;
- Our legitimate interests to verify the data of the user account related to the service provided and for the detection and prevention of fraud;
- A legal obligation that has been imposed on us;
- Your consent to information messages regarding the services provided by SECUNET PROJECT S.R.L., newsletters, subsequent promotional campaigns and other marketing information sent by SECUNET PROJECT S.R.L.
How and to whom we disclose your personal data
We do not sell your personal data to third parties.
Within the company, only a limited number of staff members, such as those in the sales, procurement, legal, accounting, marketing, HR and IT departments, have access to your personal data according to the principle of need to know (“on a need to know basis ”). These staff members are subject to confidentiality obligations regarding personal data. Appropriate technical and organizational measures are taken for the protection of personal data. Company staff members have the right to manage personal data only in accordance with the company’s instructions and, if necessary, in connection with their responsibilities.
Personal data may be disclosed to government authorities and / or law enforcement agencies, if required by applicable law or if necessary for the exercise of our rights, including conditions of use, or for the protection of our legitimate interests (including legitimate interests of third parties) in accordance with applicable laws.
Your personal data may also be disclosed to third parties, including:
- (i) service providers providing administrative, personal and technical support to the company, security and commercial resources;
- (ii) business partners, suppliers and subcontractors for the execution of all contracts we conclude with you;
The company may also disclose personal data to external consultants (eg lawyers, accountants, auditors, experts), if necessary.
The company wishes to carry out an adequate prior assessment in the selection of third parties – service providers and requires these service providers to maintain adequate technical and organizational security measures to protect personal data and to process personal data only according to company instructions. . Service providers will have the right to use subcontractors in the provision of services to the company, provided that the subcontractor complies with the same data protection obligations as service providers.
Storing your personal data
Your personal data that we collect is stored on our servers and in physical library / file / archive format.
Personal data is your property, so you have the following rights:
- You may ask us to confirm whether or not your personal data is processed by us, to provide you with a copy of your personal data and / or to collect it.
- In certain circumstances, you have the right to ask us to delete your personal data or, on the basis of the right to portability, to ask us to transfer some of your personal data to you or other entities.
- You also have the right to object to or restrict the processing of your personal data (for example, the use of processing for direct marketing purposes).
- If we ask for your consent to the processing of personal data, you have the right to withdraw this consent without adverse effects on you and without affecting the lawfulness of the processing carried out on the basis of the consent prior to its withdrawal.
We will not charge a fee to respond to your request unless permitted by law, and if a fee is charged it will be reasonable and proportionate to your request.
If you want to exercise these rights, please contact us through the contact persons, respectively: Silvia GÎRCOVEANU, [email protected], 0787.437.894. The requests are sent during the working hours, respectively: from Monday to Friday, 08.30 – 17.30.
We hope we can answer all your questions about how we process your personal data. However, you also have the right to lodge a complaint, in the event of a breach of the processing of your personal data, with the National Authority for the Processing of Personal Data.
As long as we keep your personal data
We intend to retain your personal data only for as long as is necessary, in accordance with our Data Protection Policy, for a period not exceeding the time required to fulfill the purposes listed in this information note and / or required by applicable law, in in accordance with the applicable minimum legal retention periods and / or as necessary to exercise our legitimate rights (and the legitimate rights of others).
For example, if you are a business partner, we will keep your personal data for the duration of the contractual relationship with you. If we have an ongoing business relationship, as a business partner (for example, if we may use the same personal data in separate contractual relationships with you), we will continue to retain this personal data until it is terminated. our business relationship and for the minimum retention period required by law.
In the case of application users, we will keep your personal data for the period during which the mobile application is downloaded or the period indicated by the relevant legislation. If you want more information about how long we keep your personal data, please contact us at [email protected].
If we process your personal data on the basis of your consent, such personal data will only be processed for the period provided by your consent, unless
re vă retrajeţi sau limitaţi consimţământul înainte de expirarea acestei perioada.
We want to keep your personal data safe! That is why, when we create new services and technologies, we take this principle into account.
We store your data on our servers and on third-party hosted servers. We use appropriate technical and organizational measures to protect your personal data and prevent unauthorized access.
You must be careful to keep confidential all the means of authentication (for example, passwords) used by you to access our site.
Data transmission over the Internet is not completely secure. Once we receive your data, we will use strict procedures and security features to prevent unauthorized access.
Confidentiality of juvenile data
The company does not knowingly collect personal data of persons under the age of 16. If a parent or guardian is aware that his or her children have provided SECUNET PROJECT S.R.L. their personal data, they must immediately inform our company. If SECUNET PROJECT S.R.L. discovers that a person under the age of 16 has provided him / her with personal data, the company will immediately delete this information from its servers, unless the parent or guardian gives his / her explicit consent for the company to process personal data. of the child for the specified purposes.
Cookies and social media widgets
Links to websites
Our site may provide links to websites that the company does not control. After you click on a third-party link, you will be directed to a third-party website. If you visit any of these connected websites, you should review their privacy policies. We are not responsible for the policies and practices of other companies. Our company does not control and assume no responsibility for the content, privacy policies and disclosures or practices of third party websites or services.
For the exercise of any rights but also if you have questions or concerns regarding the processing of your personal data or if you want to exercise a right you can contact SECUNET PROJECT S.R.L. at the address [email protected]. Or you can send a letter to Miletin Street no. 49, sector 3, Bucharest.
We may update this policy and notify you of any changes by posting the new version on our site. Please check this policy regularly to keep up to date with any changes.