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Last updated: October 2019
1. Who we are
2. What personal data we process and where we obtain it from
3. What is the purpose of the processing of personal data
4. What is the period that the personal data will be stored for
5. Who has access to your personal data
6. Transfers outside the EEA
7. Automated decisions
8. Your right in relation to the processing of the personal data
9. Who can you contact if you believe your personal data was unlawfully processed
10. Cookies Policy
1. WHO WE ARE
Tremend Software Consulting S.R.L. (further referred to as “Tremend”) is a company established in Romania headquartered in Bucharest, Cluj Street no. 83, Building 8B, Entrance 1, Floor 7, Ap. 32, Room no. 2, 1st District, registered with the Trade Registry under no. J40/18290/2005, Fiscal Code 18089451; Tel: +4021 223 7700, Fax: +4021 223 7700, e-mail: firstname.lastname@example.org, Administrated by: Mr. Cocan Ioan; the person responsible with data protection issues: Mrs. Simona Sunel: Tel: +4021 223 7700; e-mail: email@example.com
2. WHAT PERSONAL DATA WE PROCESS AND WHERE WE OBTAIN IT FROM
· Visitors and users of our web pages or our existing social networking pages;
· Applicants/candidates for Tremend jobs;
· Representatives of the companies we work with (actual or potential clients or suppliers).
We process data that you or the devices you use provide to us, under circumstances such as:
· You access or use our Sites;
· You contact us through the online form available on our Sites, through email or by telephone;
· You use the apps developed by Tremend;
· You purchase/access the services or other content on our Sites;
· You initiate contact through our social media pages.
· Fill in and submit personal data in tax / administrative or other documents (e.g., activity reports, complaints, comments on Tremend's work, etc.).
We process your data only to the extent that we have reason to do so, such as: in order to deliver to you (or the company which you work for or represent) the requested Tremend services in order to respond to the requests that you or your company/ the entities you work with or represent send us, to inform you about the latest IT products and other news or to improve our services.
2.1. Data that you provide when you use our Site or our Social Media pages:
Many of the data we process about you is provided by you directly, such as:
· Identification data such as name, surname, and email or telephone number, you provide to us when you contact us through the contact form available on the Site;
· Content that you generate through our Sites, such as the messages you send to us through the existing contact form on the Site and the data contained in the documents so submitted by you;
· The content of the generation when you contact us by email or telephone and the data contained in the documents so delivered;
· Content that you generate through our existing social networking sites like Facebook, Twitter, or LinkedIn. In situations like when you like the Tremend page or our posts, when you post messages or post comments, such as your username, the image/picture or message content will be processed.
2.2. Data that we process automatically when you access our Site:
When you access any of our Sites, we use the following services to collect information about your interaction with our Sites:
· Google Analytics
· Google Tag Manager
· Facebook Pixel
· LinkedIn Insight Tag
· Active Campaign.
This information allows us to provide access to our Site, but also to receive information on how visitors use our Sites to improve our services.
· Information on the use of the Site - we process information on how to use the Site to find information such as the number of visitors on the various pages of the Site.
· Information provided through Cookies and other technologies - a cookie is an alphanumeric identifier installed on your hard drive when you visit a website, mobile application, or advertisement. It stores information about your visit to our Sites (visited pages, date, and duration of visits, etc.). The cookies used by Tremend do not collect data such as your name or email address. You can set your browser to refuse all or some cookies or to warn you when Internet pages set or access cookies. If you disable or decline cookies, please note that certain parts of our Sites may become inaccessible or may not work properly. For more information on the cookies we use, please refer to our Cookies Policy.
2.3. Data that we process in other contexts:
Within the current activity (i.e. supply of materials and the provision of services), Tremend collects the following data regarding the Tremend’s partners, irrespective of the location of the services or the supply of materials:
· Identification data, name, surname, professional phone number, e-mail;
· Your photo, if attached to your email address or communication applications you use in relation to Tremend (e.g., Whatsup, Skype, Messenger, etc.);
· Data regarding your position, position, and activity in the company that your representatives represent in relation to Tremend.
3. WHAT ARE THE PURPOSE AND LEGAL BASIS OF THE PROCESSING ACTIVITIES?
For the purpose of concluding and executing a contract or to fulfill our contractual obligations with respect to our existing or future clients - e.g. when you place an order or an enquiry on the Site or otherwise, we will process the data you provide us with for the validation, analysis, offering, fulfillment and invoicing of the contracted services, for the processing of payments as well as for solving the claims, complaints or other requests for Tremend services you are requesting.
Based on your agreement - when you send us messages via the existing contact form on the Site, we will use the data to respond to your messages. Also, if you ask us questions about a particular service, and for this reason, you provide us with information about your activity, your preferences or other issues, this data will be processed but only to the extent needed in order to answer your questions.
If you choose to opt for receiving newsletters and/or alerts, we will use the data to send you such commercial communications by email or SMS, telephone call. Such communications will only be sent to you if you have given your prior consent.
Please note that under the applicable legal provisions in the field of electronic communications, we will be able to use your email address provided to us at the time of purchase of a service for the purpose of making commercial communications if they relate to services similar to those previously acquired from us.
You have the right to withdraw your consent at any time by submitting a request as set out below.
Because the law compels us to carry out such processing - e.g. we keep contracts, accompanying shipments, activity reports on Tremend business operations - to meet our legal obligations in tax matters and other regulated areas.
Based on a legitimate interest - when your rights and freedoms are unaffected - we will use the data processed when you access the Site to identify and correct any malfunctions that may occur during the use of the Site and to be able to evaluate the security level of the Site, to make improvements and to evaluate, measure and improve our services as a result of analyzing your preferences on the Site.
We also process your data to record the company you are working within Tremend's suppliers and customers database or to notify the company you are working with orders/offers/confirmations of offers/invoices/newsletters about the contracts concluded between Tremend and the company you are working for, or other documents and / or information relevant to the existing or potential business relationships between Tremend and the company you are working for.
We have analyzed and compared our legitimate interest in carrying out the current activities listed above in relation to your legitimate rights and interests and the consequences this data processing has on you and we have come to the conclusion that we do not violate your rights and interests because:
· we have limited the purposes of the processing as well as the volume of processed data to the maximum extent and have taken the necessary steps to guarantee the exercise of your legal rights in relation to the data we process, including the right to oppose;
· we have limited the access to the processed data of our employees and have instructed employees to only process the data that is strictly needed to be processed for the purposes indicated above; and
· we keep your personal data in safe conditions and proper protection.
4. HOW LONG WILL WE STORE YOUR DATA?
We will keep your personal data as long as it is necessary in order to meet the purposes we have collected them for, including for the purpose of meeting any legal, accounting, or reporting requirements. Most of your personal data will be retained for the entire duration of the activity / operation that generated the data collection, and for a reasonable time since the last activity, except for the information contained in the taxable documents that we retain 10 fiscal years from the date of the tax transaction to which these data refer.
5. WHO WILL HAVE ACCESS TO YOUR PERSONAL DATA
Within Tremend, your personal data will be disclosed to Tremend employees in the departments that need to know this data to conduct their business, the IT department employees, and the administrators only to the extent necessary for the activities and purposes for which we process your data.
For the purposes mentioned above, your personal data will possibly be disclosed and even processed by third parties such as:
· Public institutions law enforcement authorities in accordance with relevant legislation;
· Tax administration;
· External suppliers of mailing services;
· Cloud service providers;
· Specialized service providers appointed by Tremend for various services related to Tremend affairs;
· Other professional consultants.
Employees, managers and / or representatives of the above-mentioned service providers or service providers and the dedicated service providers designated by them must respect the confidentiality of your personal data and may use such data only in accordance with the Tremend instructions.
6. WILL MY PERSONAL DATA BE TRANSFERRED OUTSIDE MY COUNTRY OF RESIDENCE OR 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 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. Tremend does not base its decision on whether or not to hire you solely on automated processing of your personal data.
8. 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 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.
The right to OPPOSE, based on which:
· When Tremend processes your data in order to ensure a legitimate interest (based on art. 6 par. 1 letter. f of the GDPR), in addition to the rights listed above you have the right to oppose to the processing of your personal data.
· If you enforce this right, Tremend will not be able to process your data unless it shows and can explain to you why the way and reasons for processing your data are very important and why processing your data further, will not violate your legitimate rights and interests and will not harm you.
· If Tremend cannot prove the above, Tremend must stop processing your data immediately.
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.
9. WHO CAN YOU ADDRESS TO IN THE EVEN THAT YOU CONSIDER THAT THE PERSONAL DATA IS PROCESSED UNLAWFULLY?
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, postcode 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.