INITIAL INFORMATION REGARDING THE PERSONAL DATA PROCESSING
ISSUED BY NORMANDIA S.R.L.
NORMANDIA SRL with registered office in Braşov, str. MUNTENIEI nr. 11, jud. Braşov, fiscal identification code RO 3051963, Trade Registry number J08/3714/1992, dully represented by Mrs Socol Marioara, as General Manager, considering that protection of natural persons rights and liberties regarding the personal data processing needs the adoption of appropriate technical and organisational measures, regarding the requirements of art. 13 of the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL / 27th of April 2016,
the fact that Normandia S.R.L. submits – in the definition formulated by art. 4 point 7 of the Regulation no. 279/2016 – to the personal data controller (“controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law),
the fact that data you are going to provide us, submits – in the definition formulated by the dispositions of art. 4 point 1 of the same Regulation – to the personal (“personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person:), we hereby
We inform you that we shall collect and process your personal data: first name, name, e-mail address, phone number, in order to improve our services and our relation with the customers; at the same time, we process your personal data in order to conclude or apply an agreement or to manage the business relation between the company and a client, supplier or other business partner, in case you have the quality of employee, collaborator, representative or contact person of the respective client, supplier or partner.
The data collected and stored helps us find more about your requests, needs and interests, facts that allows us to elaborate services to technical, professional and economic standards, meeting your needs to the best extent.
This Application collects some Personal Data from its Users.
Owner and Data Controller
Owner contact email: firstname.lastname@example.org
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Cookies, Usage Data, email address, first name and last name.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Legal ground of your personal data processing is Art. 6 (1st) paragraph, letters (a) and (b), (c), (f) of the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL / 27th of April 2016) related to:
- the interest of the company in managing the business relation (based on an agreement or regarding the conclusion of an agreement) with a client, supplier or other business partner, and in administrating its related internal activities and process, in case you have the quality of employee, collaborator, representative or the contact person of the related client, supplier or partner;
- based on your consent, in the cases when the data processing involves this legal ground.
- the processing is necessary in order to accomplish a legal obligation which is laid upon the controller;
- the processing is necessary for the purpose of the legal interest followed by collector or by a third party, except the case when the data subject`s interests or rights and fundamental liberties prevail.
a) the right to obtain from Normandia S.R.L. a confirmation whether personal data regarding you is processed or not, as well as the categories of the specific personal data (art. 15 of the Regulation 679/2016 UE);
b) the right to be informed about the purposes of the processing (art.15 Regulation 679/2016 UE);
c) the right to obtain information about the recipients or the categories of recipients whose personal data was or is going to be disclosed;
d) where possible, the periods of time for which it is foreseen that the personal data shall be stored or, if not possible, the criteria used to establish this period of time;
e) the right to request the rectification or the clearing of the personal data (art.18 of the Regulation 679/2016 EU);
f) the right to oppose to stand against the data processing, with the intention to stop the processing (the right to object art. 21 of the Regulation 679/2016 EU);
g) the right to withdraw anytime a consent given in order to stop a personal data processing, based on your consent. The withdrawal shall not affect the legality of the processing based on the consent given before the withdrawal (the right to withdrawal consent, art. 7 of the Regulation 679/2016 EU)
h) The right to submit a complaint to the National Supervisory Authority for Personal Data Processing, to the address: Bd. G-ral Gheorghe Magheru 28-30, sector 1, cod postal 010336, Bucharest, Romania, contact number: +40318059211, e-mail: email@example.com (art. 77 of the Regulation 679/2016 EU);
The company may request further information necessary to confirm the identity before allowing you the access to your personal data or to action in relation to the exercise of your rights mentioned before.
To render efficient those rights, at the level of the company, a representative in charge of personal data processing was assigned, who shall answer in a reasonable term, depending on the information complexity, to the requests regarding your data, provided that it is not obviously unfounded or excessive. The e-mail address that you may use to send your requests is ___________.
Regarding your right to request the rectification of your data, you need to appeal, in this sense, to the Responsible of the data personal processing, who, without any ungrounded delays, shall rectify your inexact personal data.
You have the right to obtain as well the filling of data by providing a subsequent declaration in this sense.
Regarding your right to have your data cleared from the company records, both the physical and the electronic one, please keep in mind that you may request it only to the extent the legal term for personal data record expired.
The restrictions regarding the exercise of the rights mentioned to the previous point:
In so far as a legal disposition of internal or communitarian law is set, by which the essence of rights and fundamental liberties is respected, and represents a necessary and proportional measure in a democratic company, to ensure:
a) the national security;
b) the defence;
c) the public security;
d) the prevention, investigation, the finding or the criminal suit of criminal offences or the execution of the vindicatory sanctions, including the protection against the threat to public security and their prevention;
e) other important objectives of general public interest of the Union or of a member state, especially an important economic or financial interest of the Union or of a member state, including the monetary, budgetary and fiscal domains as well as in the domain of public health and of social security;
f) the protection of the judicial independence and of judicial procedures;
g) the prevention, the investigation, the finding and the criminal suit of the ethic infringement in the case of regulated professions;
h) the surveillance, inspection position, or the legal regulation one, even occasionally, the official authority exercise in the cases mentioned to letters (a)-(e) and (g);
i) the protection of the data subject or of others` rights and liberties;
(j) the enforcement of the civil right requirements.
Your rights mentioned to the previous point may be restricted, but only to the extent indicated in the text of law and with the respect of the guaranties regarding the protection of rights and fundamental liberties.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Managing contacts and sending messages, Contacting the User and Hosting and backend infrastructure.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Contacting the User
Contact form (this Application)
By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: email address, first name and last name.
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
DigitalOcean (DigitalOcean Inc.)
DigitalOcean is a hosting service provided by DigitalOcean Inc.
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
MailChimp (The Rocket Science Group, LLC.)
MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.
Personal Data collected: email address.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User’s device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
Latest update: May 16, 2018
Moreover, we inform you that if we wish to process your personal data, for other purposes than those described in the present informative note, we shall expressly request your consent in this sense, in accordance with the art. 6 1st paragraph letter a of the Regulation regarding the personal data processing.
We inform you, at the same time, that at the level of Normandia S.R.L., a set of technical and procedural measures is being elaborated in order to protect and ensure the confidentiality, the integrity and the accessibility of your processed personal data, and which shall ensure the confidentiality, the integrity and the accessibility of your personal data.