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CONFIDENTIALITY AND DATA PROTECTION
Last updated: October 2019
We are kindly asking you to carefully read the present notice regarding the confidentiality and the protection of your personal data. It intends to explain why and how information about you will be collected, how such information will be protected and how long the information will be stored. Your personal data will be stored, as reasonably possible, in appropriate safety and security conditions, such personal data will be protected against loss and disclosure or against unauthorized access and will be used in accordance with the applicable laws regarding the protection of the personal data, according to the General Regulation on the protection of the personal data no. 679 din 27 April 2016 ('GDPR').
This privacy notice was drafted as a question and answer list:
1. WHO WILL PROCESS MY PERSONAL DATA?
The controller for your personal data will be the following entity:
Name of the controller: Tremend Software Consulting S.R.L.
Headquarter: Bucharest, no. 83 Cluj Street, building 8B, Entrance 1, 7th floor, Ap 32, room no. 2, 1st District
Registered with the Trade Registry under no. J40/18290/2005, Fiscal Code 18089451
Phone: +4021 223 7700, Fax: +4021 223 7700, e-mail: firstname.lastname@example.org.
Administrated by: Mr. Cocan Ioan
The person responsible for data protection issues: Mrs. Simona Sunel: Tel: +4021 223 7700; e-mail: email@example.com
2. CATEGORIES OF DATA SUBJECTS AND PERSONAL DATA THAT WE USE FOR MARKETING ACTIVITIES?
For marketing purposes Tremend will use the data listed below for the following categories of targeted persons:
· Representatives of the companies we work with (clients/suppliers) or companies we intend or want to work with;
· Individuals and representatives of companies/entities that participate in Tremend organized events or in profile events, and who leave us their contact details;
· Children and elderly people participating in the "Hour of Code" campaign or in other campaigns and social projects in which Tremend is involved;
· People enrolling in our newsletter / professional updates and case studies program through the contact forms available on the Tremend website or Tremend advertising and marketing platforms such as Active Campaign or others.
3. WHAT IS THE PURPOSE OF MY PERSONAL DATA PROCESSING?
The purpose of processing your personal data is to send you newsletters or emails or other marketing material (e.g. Tremend’s activity and newsletters, offers and news, etc.) as well as to use your image in campaigns advertising, including through Tremend pages on various social networks (Facebook, Instagram, LinkedIn, etc.).
4. WHAT CATEGORY OF PERSONAL DATA WILL BE PROCESSED?
Personal data is all information about you or on the basis of which you could be identified. Anonymous data that does not provide us with the ability to identify you is not considered personal data. For the purposes mentioned above, the data we process will include the following:
· Identification data: name, surname, country, company you work with (in some cases);
· Contact details: email, phone;
· Data on the experience of beneficiaries of the "Hour of Code" program: pictures, testimonials.
5. WHERE DOES MY DATA COME FROM AND WHO WILL HAVE ACCESS TO MY PERSONAL DATA?
We receive the above-mentioned data categories from private sources, namely: (i) directly from you within the commercial relationships we run with the companies or entities you are working with; (ii) through B2B events (or other professional or social events) where we collect business cards or audiences fill out certain forms where they leave their contact details; (iii) via the contact form on the Tremend website; (iv) via the newsletter subscription form on the Tremend website; (v) via the "download case study / white paper" form from the Tremend website; (vi) via the contact form on pages used in online campaigns.
The Marketing Department and Tremend Managers will have access to your personal data on the basis of a strict "need to know" requirement for the purposes described above.
We pass on your data to advertisers such as Active Campaign, Campaign Monitor or Survey Monkey, or cloud data service providers.
6. WILL MY PERSONAL DATA BE TRANSFERRED OUTSIDE EEA?
We store your personal data on equipment (servers and back-up servers) located in non-EEA countries. In order to transfer your personal data in accordance with data protection principles, Tremend has implemented appropriate safeguards in line with the GDPR.
A list of companies to whom we transfer your data to be stored outside of the EEA includes: companies within the Google Group.
7. WILL TREMEND MAKE USE OF AUTOMATED DECISION-MAKING?
Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects or that significantly affect the individuals involved. As a rule, Tremend does not make use of automated decision-making as described above.
8. HOW LONG WILL MY PERSONAL DATA BE RETAINED?
As a rule, we will only retain your personal data for a period of 3 years (or in some cases 4 years) from the moment when the data was collected. We can only keep your data if you agree with it. If you withdraw your consent with regard to the processing of your personal data for the purpose above, we will delete your data immediately.
9. WHAT ARE MY RIGHTS WITH REGARD TO THE PROCESSING OF MY PERSONAL DATA AND WHO CAN I CONTACT?
You have the right to contact Tremend at any time in order to exercise the following rights you have under the GDPR:
The ACCESS right, based on which, you may request and obtain from Tremend a confirmation that your personal data is being processed or not, as well as complete set of information about the purpose, the means of processing the storage period and other information. At the same time, you can request and obtain from Tremend, free of charge, a copy of the personal data that is subject to processing if this does not violate the rights of others.
The right to data PORTABILITY, based on which you can receive from Tremend the personal data that you have provided us yourself, in a structured, commonly used and automatically readable format. At the same time, you may request Tremend to directly transmit this data to another operator.
The right to obtain the RECTIFICATION of your personal data, under which you can request and obtain from Tremend the rectification or updating of your personal data that no longer corresponds to the reality (for example, if you have changed your name, address, phone number or e-mail).
The right to obtain the ERASURE of your personal data, under which, in certain circumstances (such as when the data are no longer required for the purpose for which they were collected or the data are processed illegally or in other situations prescribed by law), you may request and Tremend is bound to delete your personal data.
The right to RESTRICT the processing of your personal data, based on which, in certain circumstances (such as when you consider that the date processed by Tremend is not accurate or in other situations provided by law), you may request and Tremend temporarily suspends the use of your personal data, until the exact situation of this data is clarified.
CONSENT WITHDRAWAL, which means that:
· When Tremend processes your personal data based on your express consent (pursuant to Article 6 paragraph 1 letter a of EC Regulation No. 679/2016), in addition to the above rights, you have the right to withdraw your consent regarding the processing of your personal data;
· If you use this right, Tremend can no longer process your personal data in regard to which you have withdrawn your consent;
· In order to use this right, you only need to notify us by email or by other means (but in writing) that you no longer agree to the processing of your personal data on the basis of the previously given consent.
Also if you consider that Tremend has not complied with the legal provisions in force related to data protection you can contact or file a complaint at:
· The National Supervisory Authority For Personal Data Processing headquartered No. 28-30 G-ral. Gheorghe Magheru Bld., District 1, post code 010336, Bucharest, Romania; E-mail firstname.lastname@example.org; Telephone +40.318.059.211;
· The Administrative and Fiscal Section of the Courthouse (Sectia de Contencios Administrativ si Fiscal din cadrul Tribunalului) competent at your place of residence or at Tremend’s headquarters.
Your contact at Tremend for any additional information regarding your rights and the processing of your personal data is Mrs. Simona Sunel. You can contact her/him:
· By telephone at: +4021 223 7700;
· By e-mail at email@example.com