Contents:
- General provisions
- Details about our company
- Data processed. The purpose, duration and basis of processing
- Sensitive data processed. The purpose, duration and basis of processing
- Mechanisms and use of automated decision-making systems
- Disclosure and further use of your data
- How we collect data
- Information security
- Transfer of your data outside the European Economic Area
- Your rights over personal data
- Confidentiality of minors
- Policy principles
- Changes
- General provisions
1.1 The confidentiality of personal data represents one of the main concerns within the company ELM ELECTROMONTAJ CLUJ SA (hereinafter the "Company"). As such, we want to ensure the highest standards of confidentiality, integrity and transparency with regard to the personal data we process in our activity.
1.2 Since in carrying out our activity it is necessary to process a series of personal data, predominantly in relation to the specific nature of our object of activity, we want to provide assurances that the processing will take place in compliance with the principles of transparency and security of personal data. This privacy policy is intended to help you understand what data we collect, why we collect it and what we do with it.
1.3 Our data protection policy and practices focus on the appropriate and lawful processing, exchange and storage of personal information and, at the same time, on ensuring confidentiality, integrity and availability.
1.4 All users have free access to the website www.elm.ro on condition that they comply with this privacy policy. Our website complies with the General Data Protection Regulation - GDPR (Regulation (EU) 2016/679).
- Details about our company
2.1 ELM ELECTROMONTAJ CLUJ S.A. (hereinafter the "Company") is a Romanian company, established according to Romanian law, with its registered office in the municipality of Cluj-Napoca, str. Traian Vuia, no. 240-242, Cluj county, registered with the Trade Register Office attached to the Cluj Tribunal under no. J12/3821/1991, having Tax ID RO201594 (hereinafter referred to as "Elm Electromontaj Cluj" or the "Company").
2.2 The Company acts as the controller of the personal data collected through the internet page www.elm.ro (the "Site").
2.3 The controller is obliged to administer, under conditions of safety and only for the specified purposes, the personal data that the users of www.elm.ro provide.
- Data processed. The purpose, duration and basis of processing
Moment of processing | Data processed | Purpose of processing | Retention period | Basis of processing | Where it is stored | Transfer |
3.1 Accessing the site | 3.1.1 The web server log | Ensuring IT network security | 6 months | compliance with legal obligations - Article 6 paragraph (1) letter (c) of Regulation no. 679/2016 | The hosting site's server | no |
3.1.2 cookies* |
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3.2 Contact by email | 3.2.1 Email and any other identification data present in it | To respond to the questions and messages we receive and to keep a record of correspondence. | Only for as long as they are necessary and at most one year, insofar as there is no litigious nature. | it is necessary for the performance of a contract or to initiate the process of entering into a contract at your request (article 6 paragraph (1) letter (b) | in electronic format, on the server | no |
3.3 Contact by phone | 3.4.1 phone number + data provided in conversation | To respond to the questions and messages we receive and to keep a record of correspondence | Calls are not recorded. | your consent (article 6 paragraph (1) letter (a) | no | no |
3.4 Subscribing to the newsletter/ invitations to EnergoBit events | 3.6.1 First name, last name, position, company, email, phone | To send relevant information to our clients about various solutions and products developed by Elm Electromontaj Cluj - (e-mail) and to be able to invite them to Elm Electromontaj Cluj events - product presentations, services, webinars, debates, round tables (phone). | Until unsubscribing | your consent (article 6 paragraph (1) letter (a) of the General Data Protection Regulation). | in electronic format on the server | no |
3.7 Sending a CV - (curriculum vitae), for the purpose of recruitment and selection, for the available positions. | First name, last name, phone number, e-mail and other data contained in the CV, completed as you consider necessary to increase your chances of being selected. With regard to the content of your CV, we consider the following information relevant for the recruitment and selection process: education, professional experience, training, specialisations, personal skills, the candidate being, however, free to complete it with any other data they consider relevant in the recruitment process. | This information will not be processed only in the context of a recruitment for a certain specific position, available at a given time within EnergoBit, but may also be used for other possible opportunities (positions) that will arise within the company. | 2 years from the date on which the data came into our possession, in the event that you have not already become an employee of the company. | your consent (article 6 paragraph (1) letter (a) of the General Data Protection Regulation). Your provision of the CV and your application to a position proposed by us is interpreted as an unequivocal action/expression of free, informed and unambiguous will by which you accept that the personal data in the CV be processed under the terms of this Policy. | in electronic format, on the server | no |
*3.1.2 for more information about cookies please consult our cookies policy.
3.9 Criteria for establishing retention periods
Data will be stored for the minimum period necessary to fulfil the purpose, taking into account the following:
- the purpose and use of your information both now and in the future (for example, whether it is necessary to continue storing that information to continue to fulfil our obligations under a contract with you or to contact you in the future);
- whether we have a legal obligation to continue processing your information (such as any record-keeping obligations imposed by relevant law or regulations);
- whether we have any basis to continue processing the information (such as your consent);
- the levels of risk, cost and responsibility involved in continuing to hold the information.
3.10 If we receive information about you by mistake
If we receive information about you by mistake from a third party and/or we do not have a legal basis for processing this information, we will delete your information.
- Sensitive data processed. The purpose, duration and basis of processing
The website www.elm.ro does not collect sensitive data.
- Mechanisms and use of automated decision-making systems
5.1 We use automated decision-making mechanisms on our website. We do not consider that this has a legal effect on you or affects you in a similar way.
5.2 You have the right to object to our use of automated decision-making and profiling mechanisms described in this section. You can do this by opting out of cookies and similar technologies, in accordance with the method described in the relevant section of this privacy policy. If you do not want us to process your real IP address (usually the IP address assigned by the Internet Service Provider) when you visit our site, you can use a virtual private network (VPN) or a free service.
5.3 You can find out more about the use of cookies and similar technologies (including the legal basis for their use) and how to opt out of them in the cookies policy, available on the Site.
- Disclosure and further use of your data
This section sets out the circumstances in which we will disclose your data to third parties and any other additional purposes for which we use your data.
6.1 Disclosure of your data to service providers
6.1.1 Disclosure and use of your information for legal reasons
- Indicating possible criminal acts or threats to public safety to a competent authority.
If we suspect that criminal or potential conduct has taken place, we will need, in certain circumstances, to contact a competent authority, such as the police. This might be the case, for example, if we suspect the commission of fraud or a cybercrime, or if we receive threats or malicious communications directed at us or at third parties.
Legal basis for processing: our legitimate interests (article 6 paragraph (1) letter (f) of the General Data Protection Regulation), namely for the prevention of crime or suspected criminal activity (such as fraud).
- In connection with a dispute or a legal or potential legal procedure
It may be necessary for us to use your information if we are involved in a dispute with you or with a third party, for example, either to resolve the dispute or as part of mediation, arbitration or a court decision or a similar process.
The legal basis for processing: our legitimate interests (article 6 paragraph (1) letter (f) of the General Data Protection Regulation).
Legitimate interest: the resolution of disputes or possible disputes.
III. For continued compliance with laws, regulations and other legal requirements
We will use and process your information to comply with the legal obligations to which we are subject. For example, it may be necessary to disclose your information under a court order or a subpoena, if we receive one.
Legal basis for processing: compliance with a legal obligation (article 6 paragraph (1) letter (c) of the General Data Protection Regulation).
Legal obligation: the legal obligations to disclose information, established as our responsibility through internal or international normative acts (for example in the form of an international agreement that Romania has signed).
Legal basis for processing: legitimate interest (article 6 paragraph (1) letter (f) of the General Data Protection Regulation).
Legitimate interest: in the event that the legal obligations are part of the laws of another country and have not been integrated into the legal framework of Romania, we have a legitimate interest in complying with these obligations.
- How we collect data
7.1 We collect your personal data directly from you, for example, when you send us an email, apply for a position or subscribe to the newsletter.
7.2 We also collect your personal data automatically. When you use our services on the Company's site, we collect information through cookies and by logging your activity. For more information on the use of cookies, please consult the cookies policy.
- Information security
8.1 We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and against accidental loss or destruction, including:
- sharing and providing access to your data to the minimum extent necessary, subject to confidentiality restrictions, where appropriate and anonymously, whenever possible;
- using secure servers for storing information;
- verifying the identity of any person requesting access to information before granting them access to information;
- using the Secure Sockets Layer (SSL) standard to encrypt any information you send us through any forms on our website;
- we transfer your data only through a closed system or through encrypted data transfers.
8.2 Transmitting information to us by e-mail
The transmission of information over the internet is not entirely secure and if you send us information over the internet (by e-mail or by any other means), you do so entirely at your own risk.
We cannot be responsible for any expenses, loss of profit, damage to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
- Transfer of your data outside the Economic European Area (hereinafter "EEA")
9.1 Your data will not be transferred to countries outside the EEA.
- Your rights over personal data
10.1 The person responsible for the protection of personal data
We have appointed a person responsible for the protection of personal data whom you can contact in connection with any matter related to the processing of your data, as well as for the exercise of your rights under the applicable legal provisions, in particular if you have questions or concerns about the way in which we process your personal data. The e-mail address at which you can contact the person responsible for data protection is: dataprotection@energobit.com
10.2 Subject to certain restrictions, you have the following rights in connection with your data, which you can exercise by sending a written request or an e-mail to dataprotection@energobit.com
- to request access to your information and information regarding the use and processing of your information;
- to request the correction or deletion of your data;
- to request the restriction of the use of your data;
- to receive the information you have provided to us in a structured format and the right to transfer that information to another data controller (including a third-party data controller);
- to object to the processing of your data for certain purposes (for more information, see the section below entitled "Your right to object to the processing of data for certain purposes");
- to withdraw your consent for the use of your data at any time when we rely on your consent to use or process this information. Please note that, if you withdraw your consent, this will not affect the lawfulness of the use and processing of your data based on your consent before the moment at which you withdraw your consent.
10.3 You can also file a complaint related to the processing of your data with the National Authority for the Processing and Supervision of Personal Data (B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania, www.dataprotection.ro, anspdcp@dataprotection.ro).
10.4 Verifying your identity in the event that you request access to your information
In the event that you request access to your information, we are obliged by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
10.5 How do we verify your identity?
10.5.1 In the event that we have adequate information about you in the database, we will attempt to verify your identity using this information.
10.5.2 If it is not possible to identify you based on this information or if we do not have sufficient information about you, we may request copies or certificates of certain documents in order to be able to verify your identity before we can offer you access to your data.
10.5.3 We will be able to confirm the exact information we need to verify your identity in the given specific circumstances, if and when you make such a request.
10.6 Your right to object to the processing of data for certain purposes
You have the following rights with respect to your data, which you can exercise by sending an e-mail to dataprotection@energobit.com:
- to object to our use or processing of information to perform a task in the public interest or in our legitimate interest, including the analysis or prediction of your behaviour based on your information.
- to object to the use or processing of your data for direct marketing purposes (including any profile we involve in connection with this direct marketing) by clicking on the unsubscribe link or by sending an e-mail/sms containing only the word "UNSUBSCRIBE" in response to any marketing communication we send.
10.7 For more information about how you can object to the use of data collected through cookies and similar technologies, consult our cookies policy.
- Confidentiality of minors
11.1 We process the data of persons under the age of 16 only with the consent of the legal representative, for carrying out under optimal conditions the services contracted by the legal representatives of the minors.
11.2 We may receive information relating to persons who have not reached the age of 16 through the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, when the law requires this, we will immediately obtain the consent of the legal representative to use this information or, if we cannot obtain this consent, we will delete the information from our servers. If you wish to notify us of the receipt of information about persons under the age of 16, please do so by sending an e-mail to the address dataprotection@energobit.com.
- The principles on which our data protection policy is based:
- a) The processing of personal data will be carried out in a lawful, fair and transparent manner;
- b) The collection of personal data will be carried out only for specified, explicit and legitimate purposes and the data will not be processed further in a manner incompatible with those purposes;
- c) The collection of personal data will be adequate, relevant and limited to the information necessary for the purpose of processing;
- d) Personal data will be accurate and, where necessary, up to date;
- e) All necessary measures will be taken to ensure that incorrect data is deleted or corrected without delay;
- f) Personal data will be kept in a form that allows the identification of the data subject and for a period no longer than that in which the personal data is processed;
- g) All personal data will be kept confidential and stored in a manner that ensures the necessary security;
- h) Personal data will not be distributed to third parties except where necessary for the purpose of providing services in accordance with the agreements;
- i) Data subjects have the right to request access to personal data, its rectification and deletion, to object to or restrict the processing of the data, as well as the right to data portability.
- Changes to our privacy policy
13.1 We update and modify our privacy policy periodically.
13.2 Minor changes to our privacy policy
In the event that we make minor changes to our privacy policy, we will update the Privacy Policy with a new effective date mentioned at its beginning. The processing of your information will be governed by the practices established in the new version of the Privacy Policy from its effective date.
13.3 Major changes to our privacy policy or to the purposes for which we process your information
In the event that we make major changes to our privacy policy or intend to use your data for a new purpose or for a purpose different from the purposes for which we initially collected it, we will notify you by e-mail (if possible) or by publishing a notice on our website.
We will provide you with the information about the change in question and about the purpose and any other relevant information before using your information for the new purpose.
Whenever necessary, we will obtain your prior consent before using your information for a purpose different from the purposes for which we initially collected it.
