Privacy Notice

applicable starting from 11 April 2019

In here you will find the following information on the processing of personal data on our website

 


1. Who we are

We are PrivacyOne (GUIMAN UDUDEC – Societate Civilă de Avocați), a team of lawyers specialised in legal consultancy on data protection matters.

2. Personal data we process on our website

​This website only uses strictly necessary cookies, which can be placed on user terminals without consent. The cookie we use is __cfduid, which is placed by Cloudfare and has a security purpose – to prevent malicious visitors to our Customers’ websites and to minimize blocking legitimate users. The lifespan of this cookie is 1 year.

The only personal data processing that may occur, if you choose to, is when you either (i) subscribe to receive our email alerts, or (ii) use the web form to contact us. If both situations the data is collected directly from you, and the forms are configured so as to collect the smallest amount of data in order to reach you.

We offer you the possibility to subscribe to our posts, i.e. the Monthly Roundup Newsletter as well as our blog articles. In order to send you these alerts, we need your e-mail address and, if you choose to provide it, your name (which may be an alias). We process this personal data strictly for the purpose of sending you the news posted on our website, based on your consent which can be withdrawn at any moment by clicking the “unsubscribe button” which is inserted in our e-mail alerts. Your data is processed for the entire period while you are subscribed to our email alerts.

In order to send you the alerts we use a processor called SendInBlue. They are located and keep the data in the EU.

If you choose to contact us via our web form, the data you fill in will be sent to us through an email. That means that your data is processed through two processors of ours: Bunnyshell which hosts our website, and Microsoft Ireland Ltd which provides our cloud email service. Both of them host our data in the EU.

3. Disclosure of personal data

​We will will not disclose your personal data except where strictly necessary for the purposes and to the following categories of third parties:

  1. organisations which provide us relevant services for maintaining and developing this website and its tools, and which are indicated above.
  2. potentially other entities, where we or they have a prevailing legitimate interest in the disclosure or where we are required by law to make such a disclosure;

While not in our intention to disclose data in this way, we may disclose it:

  1. where you request or agree to it;
  2. to persons who demonstrate they are acting on your behalf;
  3. where we are required to disclose your data in order to comply with a legal obligation or a request from governmental or enforcement agencies;
  4. for the establishment, exercise or defence of legal claims.

4. Transfers outside of the European Economic Area

We do not transfer any personal data outside of the European Economic Area.

5. Your rights

As a data subject you have specific legal rights relating to the personal data we process about you:

(a) Right to withdraw consent: Where you have given consent for the processing of your personal data (i.e. email alerts from us), you may withdraw your consent at any moment by clicking the unsubscribe button in any of the e-mail messages you receive from us.

(b) Right to access: You may ask from us information regarding personal data that we hold about you, including information as to which categories of data we have in our possession or control, what they are being used for, and to whom they have been disclosed, if applicable.

We will provide you with a copy of your personal data upon request. If you request further copies of your personal data, then we can charge you with a reasonable fee that we base on the administrative costs.

(c) Right to rectification: You have the right to obtain the rectification of your personal data, if inaccurate or incomplete. For this, you can contact us at the contact details provided below.

(d) Right to restriction: You may obtain from us restriction of processing of your personal data, if:

– you contest the accuracy of your personal data, for the period we need to verify the accuracy,

– the processing is unlawful, if you request the restriction of the processing instead of the erasure of your personal data,

– we do no longer need your personal data, but you request it for the establishment, exercise or defense of legal claims, or

– you object to the processing while we verify whether our grounded reasons override yours

(e)  Right to portability:  You have the right to receive your personal data that you have provided to us, and, where technically feasible, request that we transmit your personal data (that you have provided to us) to another organization.

You have these rights if, on a cumulative basis:

 – we process your personal data by automated means;

 – the processing of your personal data is based on your consent, or our processing of your personal data is necessary for the execution or performance of a contract to which you are a party;

 – the transmission of your personal data does not adversely affect the rights and the freedoms of other persons.

(f) Right to erasure: You have the right to request that we delete the personal data we process about you. We must comply with this request if we process your personal data, unless the data is necessary:

 – for exercising the right of freedom of expression and information;

 – for compliance with a legal obligation that binds us;

 – for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; or

 – for the establishment, exercise or defense of legal claims.

(g) Right to object: You may object – at any time – to the processing of your personal data due to your particular situation, provided that the processing is based on our legitimate interests or those of a third party. In this event we shall no longer process your personal data, unless (i) we can demonstrate compelling legitimate grounds which justify the processing and override your interests, rights and freedoms, or (ii) in case the purpose is the establishment, exercise or defense of a right in court.

(h) Right to lodge a complaint: If you have any complaints about the way in which we process your personal data, we would prefer that you contact us directly in order to address your problem. However, you may contact the Romanian Data Protection Authority (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal) using the information posted on their website www.dataprotection.ro.

Please note:

  • Time period: We will try to fulfil your request within one month, a period which may be extended due to specific reasons relating to the context of the situation or the complexity of your request, with a maximum additional period of 2 months. In all cases, if this period is extended, we will inform you about the term of extension and the reasons that led to it.
  • Restriction of access: In certain situations, we may not be able to give you access to all or some of your personal data due to legal restrictions. If we deny your request for access, we will inform you of the reason for the refusal.
  • No identification: In some cases, we may not be able to identify your personal data due to the identifiers you provide in your request. In such cases, where we cannot identify you as a data subject, we are not able to comply with your request in accordance with this section, unless you provide additional information enabling your identification. We will inform you and give you the opportunity to provide such additional details.
  • Exercise your legal rights: In order to exercise your rights, please contact us in writing (including electronically) at the contact details provided below.

6. Changes to this privacy notice

We reserve the right to modify, where we deem appropriate, the privacy practices and update and make changes to this notice at any time. For this reason, we encourage you to verify this notice periodically. This notice is current as of the date which appears at the beginning of the document.

7. Contact details

Please use the ocntact details below for any questions regarding the protection of your personal data and for exercising your data subject rights.

Email:           contact[@]privacyone.ro

Address:        PrivacyOne (C.I.A. „Lisievici Andreea”), București, Bd. Aviatorilor nr. 47, Sector 1, etaj 2.