Privacy Policy
INFORMATION NOTE CONCERNING THE PROCESSING OF PERSONAL DATA
PERFORMED BY GLOBAL INDEPENDENT AGENCY SRL
1. WHO WE ARE AND WHAT IS THE PURPOSE OF THIS DOCUMENT
This information note was prepared by Global Independent Agency SRL with registered office in Romania, Ilfov county, Fundeni Village, Dobroești Commune, 16C Cireșului Street, no. 16C, app. B8, registered at the Trade Register under number J23/5080/2022, Fiscal Code RO43106650, as a personal data operator (hereinafter referred to as "GIA" or "the Company").
Through this document we want to explain why and how we process personal data of users of the gepeto.works Website ("Users") and of natural persons who represent and/or carry out professional activities ("Representatives" or "Designated Contact Representatives" .”) within legal entities (“Possible Clients” or “Clients”): (i) in the context of communication with persons interested in services offered by the Company, respectively (ii) in the context of the development of the contractual relationship of services concluded with the Clients or in other situations permitted by law.
"Personal data" means any information relating to an identified or identifiable natural person, and an identifiable individual is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a number, an identification, location data, an online identifier, or to one or more specific elements, its own physical, physiological, genetic, psychological, economic, cultural or social identities.
This information note mainly describes:
· who are we;
· the purposes for which we collect and use your personal data in the context of solving your requests/reports, communicating with you regarding relevant aspects and of interest to you in relation to the Company's services, in the context of the development of the contractual relationship and in other situations provided for by law;
· the legal grounds on which personal data processing is based;
· the categories of personal data that we process;
· the period of storage of personal data;
· your rights as a data subject and the manner in which you can exercise these rights;
· categories of recipients to whom we disclose your personal data in the context of solving your requests/reports, communicating with you regarding relevant aspects and of interest to you in relation to the Company's services, in the context of the development of the contractual relationship of service provision concluded with the Clients or in other situations provided by law.
2. PURPOSES, BASIS OF PROCESSING AND CATEGORIES OF PERSONAL DATA WE PROCESS
Depending on the context in which we interact with you, we process the following categories of personal data, for the purposes and on the grounds described below:
2.1 If you are a User, a Representative or a Contact Person designated by a Potential Client, who requests a price offer or makes other requests and/or notifications through the contact form on the Website, by e-mail, by phone or other means of communication:
Activity (a): Response to price offers
Purpose (a): Submission of price offers requested in the pre-contractual stage;
Personal Data Categories (a): Contacts;
Processing Grounds (a): The processing is necessary to take steps at the request of the data subject before concluding a contract (Art. 6 para. 1 letter b) sentence II) of the GDPR).
Activity (b): Solving requests/reports
Purpose (b): Submitting a response to requests/reports received from you via e-mail/contact form/phone call/any other means of communication used;
Personal Data Categories (b): Contacts; Identification data; Any other data sent with the submitted requests/reports;
Processing Grounds (b): Our legitimate interest to ensure the management of requests/reports (Art. 6 para. 1 letter f) of the GDPR).
2.2 If you are a Representative or a Contact Person designated by a Potential Client interested in the services offered by the Company or another person with whom we interact in the context of carrying out our activity:
Activity (a): Communication with you
Purpose (a): Communicating with you regarding any relevant aspects related to the Services offered by the Company and/or in the context of carrying out our activity;
Personal Data Categories (a): Contacts; Other data that can be provided in the context of the transmission of information regarding the Company's services;
Processing Grounds (a): Our legitimate interest to ensure the transmission of relevant information regarding the Company's services, respectively to communicate in the context of carrying out our activity (Art. 6 para. 1 letter f) of the GDPR).
2.3 If you are a Customer Representative with whom we have concluded a service contract or a Contact Person designated by him/her:
Activity (a): Conclusion of the Contract
Purpose (a): Conclusion of the Contract
Personal Data Categories (a): Identification data; contacts; signature; function;
Processing Grounds (a): The processing is necessary to conclude the contract (Art. 6 para. 1 letter b) thesis I of the GDPR).
Activity (b): Running and managing the contractual relationship
Purpose (b): Communicating with you about any relevant aspects related to the contractual relationship with the Client;
Personal Data Categories (b): Contacts; Identification data; Any other transmissions;
Processing Grounds (b): Our legitimate interest in ensuring the proper management of the contractual relationship with the Client (Art. 6 para. 1 letter f) of the GDPR).
Activity (c): In order to fulfill some legal obligations
Purpose (c): In order to fulfill some legal obligations (e.g., keeping accounting records);
Personal Data Categories (c): Financial data; Any other data required according to legal obligations;
Processing Grounds (c): In order to comply with the legal obligations that are the responsibility of the Company (Art. 6 para. 1 letter c) of the GDPR).
You can object at any time to processing based on our or our customers' legitimate interest, for reasons related to your specific situation. For more details about your rights, please see the "Your Rights" section below.
3. THE NEED TO PROVIDE DATA
Failure to provide the necessary data for the processing purposes mentioned in 2.1 will not allow us to respond to your requests/reports.
4. TO WHOM WE DISCLOSE YOUR PERSONAL DATA
4.1. Addressees
In order to fulfill the purposes for which you provide it to us, we disclose your data to the following categories of recipients, if and as applicable:
(i) the Company's service providers, if necessary in connection with services such as courier, accounting and invoicing services, maintenance and administration of the Site or other services contracted by us based on our legitimate interest to organize our activity in a manner suitable.
(ii) to our auditors, consultants, lawyers or other specialized professional service providers, if necessary for their provision of the services contracted by us, considering our legitimate interest in contracting these services;
(iii) third parties with whom we could discuss/negotiate changes in associates, structure (e.g. reorganizations, mergers, divisions, spin-offs, etc.) or similar transactions aimed at the Company, if necessary and considering our legitimate interest in this regard;
(iv)public authorities and institutions, if we have a legal obligation to do so or at their express request, if permitted by law.
4.2. International Data Transfers
If the use of the services of some of our suppliers would involve international data transfers, including to the United States of America, the data collected will be subject to appropriate transfer mechanisms, including with respect to the transfer to the United States of America, as a result of the adoption by the Commission of the Decision on the adequacy of the level of protection for secure data flows between the EU and the US. Based on this adequacy decision, personal data can flow safely from the EU to US businesses participating in the framework without the need to put in place additional data protection safeguards.
5. HOW WE PROTECT YOUR DATA
We implement technical and organizational measures to ensure the security of personal data, including:
· Dedicated physical and electronic security measures. We adopt and review our physical and electronic security measures to protect against unauthorized access and other possible threats to their security.
· Specific technical measures. We use technologies to ensure the security of the personal data we process and verify that the security technology used is appropriate to the level of risk.
· Staff training. We train our employees and collaborators on the legislation and best practices in the field of personal data processing.
Although we take all reasonable measures to ensure the security of your data, GIA cannot guarantee the absence of any security breach or the impossibility of penetrating security systems. In the unfortunate event that such a breach occurs, we will follow legal procedures to limit the effects and inform the data subjects.
6. HOW LONG WE KEEP YOUR DATA
Your personal data will be kept for the period necessary to fulfill the purposes mentioned in Section 2. For example, if we collect your personal data for the purposes mentioned in 2.1 and 2.2, the data will be kept for as long as necessary to solve the requests /requests and notifications submitted by you, and for the entire period necessary to communicate with you in relation to the services offered by the Company/in the context of carrying out our activity. This period can be extended if necessary to establish, exercise or defend a right in court.
Also, if you are a Customer of the Company, we intend to retain your data for at least the entire duration of the contractual relationship between us and you, and thereafter for a reasonable period corresponding to the applicable statute of limitations or in accordance with the legal period for which we are obliged to keep them.
7. YOUR RIGHTS
According to the law, you have the following rights related to the processing of your personal data that we carry out:
(i) The right of access: you can obtain from us confirmation that we are processing your personal data, as well as information regarding the specifics of the processing such as: the purpose, the categories of personal data processed, the recipients of the data, the period for which the data is kept , the existence of the right to rectification, deletion or restriction of processing. This right allows you to obtain a copy of the processed personal data free of charge, as well as any additional copies for a fee.
(ii) The right to data rectification: you can ask us to change your incorrect personal data or, as the case may be, to complete data that is incomplete.
(iii) The right to erasure: you can request the erasure of your personal data when: (i) it is no longer necessary for the purposes for which we collected and process it; (ii) you have withdrawn your consent for the processing of personal data and we can no longer process them on the basis of other legal grounds; (iii) personal data are processed against the law; respectively (iv) the personal data must be deleted according to the relevant legislation.
(iv) Withdrawal of consent: you can withdraw your consent at any time regarding the processing of personal data processed on the basis of consent, without this affecting in any way the processing carried out prior to the withdrawal.
(v) The right to object: you can object at any time to processing based on our legitimate interest, for reasons related to your specific situation. For details of the processing we carry out in legitimate interest, please see section 2 above.
(vi) Restriction: you may request the restriction of the processing of your personal data if: (i) you dispute the accuracy of the personal data, for a period that allows us to verify the accuracy of the data in question; (ii) the processing is unlawful and you object to the deletion of the personal data, requesting instead the restriction of its use; (iii) the data is no longer necessary for us to process, but you request it from us for a court action; respectively (iv) if you have objected to the processing, for the period of time in which it is checked whether our legitimate rights as an operator prevail over your rights as a data subject.
(vii) The right to portability: you can request, in accordance with the law, that we provide your personal data that you have provided to us in a structured, frequently used and machine-readable form (for example in CSV). Also, if you expressly request us, we may transfer your personal data to another entity, if technically possible.
(viii) The right not to be subject to automated individual decision-making, including profiling.
(ix) The right to lodge a complaint with the The National Supervisory Authority for Personal Data Processing: you have the right to lodge a complaint with The National Supervisory Authority for Personal Data Processing (www.dataprotection.ro) if you consider that your rights were violated:
The National Supervisory Authority for Personal Data Processing
Contact: 28-30 G-ral Gheorghe Magheru Bld., District 1, post code 010336, Bucharest, Romania anspdcp@dataprotection.ro
To exercise one or more of the rights stated above or to ask a question about these rights or about our processing of your personal data, please contact us by email at office@gia.works or by mail at our headquarters in Ilfov county, Fundeni Village, Dobroești Commune, Str. Cireșului no. 16C, apartment B8.
(Date of last revision, 01.04.2024)