PERSONAL DATA PROCESSING POLICY
Thank you for your interest in our products. Next, please read carefully this Personal Data Processing Policy, containing information about processing your personal data as concerned persons: users of our website, customers, potential customers, consumers, potential consumers, media partners.
We emphasize that it is very important to us to ensure both the protection of the personal data that you provide us with, as well as the privacy of your personal data.
WHO WE ARE?
ABN SYSTEMS INTERNATIONAL S.R.L. is a company duly organized and operating in accordance with the laws of Romania, headquartered in 31 Marinarilor Street, District 1, Bucharest, registered with the Trade Register under no. J40/11024/2002, tax identification code 14988404. References to "ABN SYSTEMS INTERNATIONAL", "we", "us", "ours" mean mainly ABN SYSTEMS INTERNATIONAL SRL and, where appropriate, other companies in the group. ABN SYSTEMS INTERNATIONAL S.R.L. is the operator of all personal data collected and used in connection with the customers and users of this site.
This personal data processing policy explains what we do with your personal data, whether we provide you with products, marketing and informational materials, or we use your personal data as part of our research for marketing or scientific purposes.
At the same time, we inform you that as of the 25th of May 2018, Regulation 2016/679/EU on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as "the Regulation") shall be enforced by all the states of the European Union. The Regulation aims to create a single and uniform legislative framework within the European Union.
ABN SYSTEMS INTERNATIONAL aligns with the provisions of the Regulation and we believe this is a good time to point out some important issues.
This document describes how we collect, use and process your personal data and how, in this way, we comply with our legal duties towards you.
Your privacy is important to us and we are committed to protecting your personal data and to protecting your rights.
Should you be dissatisfied with any aspect of our data processing policy, you may have the legal rights that we have described below, where applicable.
We may occasionally change this notification. Please visit this page if you want to stay up-to-date the next time we post any changes here.
WHICH ARE YOUR PERSONAL DATA THAT WE PROCESS?
Your personal data are collected through our website, by e-mail, through the platforms used by us and our call centre and by mail/courier. Depending on the relevant circumstances and the enforceable local laws and requirements, we may collect some of or all the information listed below to help us in this regard:
Name and first name;
Contact telephone number/numbers;
Date of birth;
Contact details: e-mail address, contact address, delivery/billing address;
Correspondence between you and us; or
Any other additional information that you choose to provide us with.
Additionally, when you visit our site, we automatically collect technical information, including the Internet Protocol used to connect your computer to the Internet, your login information, browser type and version, time zone setting, plug-in browser types and versions, system and platform, passwords and hints, similar security information used to authenticate and access the account.
Please note that when using our web site, the cookies are stored by the browser on your device. Please note that if you disable cookies, our website may not work properly in your browser. We want to make sure that our website offers visitors what they are looking for and that they benefit from the most relevant marketing messages. In order to achieve this goal, we may store and use your data for market research, for improving the quality of our website and services, for service developments, to improve the performance of the website, to measure the success of our advertising campaigns or to adapt our services to your needs.
HOW DO WE USE YOUR PERSONAL DATA?
We collect and use your personal data for the following purposes:
To register your account on our website. For this purpose, we collect the following data: name, first name, e-mail address, IP address, telephone number.
To facilitate service and product supply (including from third parties) on our website, to inform customers/buyers on their user account status, including validating, dispatching and billing orders, resolving issues of any kind related to an order, respectively to the purchased goods and/or services, other sales activities and administration of the clients' account. For this purpose, we collect the following data: name and first name, telephone number, e-mail address, delivery/billing address, payment data;
For the purpose of providing after-market activities that include customer service for the assessment of the provided products and service intervention or product replacement. For this purpose, we collect: name and first name, telephone/fax, e-mail, delivery/billing address, payment data, voice recordings, habits/preferences/behaviour, other data emerging from customer evaluation of the products; We also collect identification data (ID serial number and number) and bank data only for product replacements/returns.
To send you newsletters. For this purpose, we collect the following data: name, first name and e-mail address, IP address;
To provide you with offers based on your preferences. To this end, we collect the following data: name, first name, telephone number and e-mail address, delivery/billing address, habits/preferences/behaviour;
To communicate with you in conducting customer satisfaction surveys for analysis purposes, for quality enhancements, for service development, to improve the website performance, to measure the success of the advertising campaigns or to adapt our services to your requirements. To this end, we collect the following data: name, first name, telephone number and e-mail address.
To forward information and/or marketing materials about us as well as invitations to the events organized by us directly or together with other entities. For this purpose, we collect the following data: name, first name, telephone/fax number, e-mail address, job, position, contact address, gender and date of birth.
We may also use your personal data for these reasons if we consider it necessary to ensure our legitimate interests. For further information, please read below.
DO WE FORWARD YOUR PERSONAL DATA TO THIRD PARTIES?
We will primarily forward your personal data to third parties only to ensure the optimal performance of our contractual relationships and to fulfil specific legal duties as follows:
Any company within the ABN Systems International group, as necessary, in compliance with the legal provisions on personal data protection and their transfer;
Financial consultants, audit firms, as well as any public authority, and any legal duty to disclose personal data (for example, should we receive such notification and/or letter from the central or local public authorities or in connection with an ongoing litigation pending with the Romanian courts);
Service providers acting on our behalf (including, without limitation external consultants, lawyers, auditors and/or accountants, consultants and IT experts);
If any company in the Abn Systems International group is acquired or merges with another company or group of companies in the future, we will be able to provide your personal data to the representatives of the new owners (and notify you of such an approach and the implications on your personal data).
HOW DO WE ENSURE THE SECURITY OF YOUR PERSONAL DATA?
We are concerned with protecting your personal data. This is the reason why we have implemented or are in the process of implementing appropriate measures that are designed to prevent any unauthorized access and misuse of your personal data.
We commit to taking all reasonable and appropriate measures to ensure your data security against theft and unauthorized access and make every effort thereto. We do all this by implementing specific technical and organizational measures, including encryption, anonymization and data recovery/back up.
If you suspect any unauthorized use or theft of your personal data, please inform us as soon as you suspect such unauthorized activity. In this regard, please contact us first by email at. For this purpose, please contact us first by email at email@example.com in order to investigate the situation and to provide you with updated information on the progress of the incident resolution, as well as on the steps to be taken.
HOW LONG WILL WE BE PROCESSING YOUR PERSONAL DATA?
We will not keep your personal data in our records for a period exceeding the purposes of the collection thereof, except where the legal provisions bind us to keep your personal data for a certain period of time longer than our purpose (for example, should we receive such notification and/or letter from the central or local public authorities or in connection with a litigation pending with the Romanian courts).
WHAT ARE YOUR RIGHTS REGARDING THE PERSONAL DATA THAT WE PROCESS?
One of the main objectives of the Regulation is to protect and clarify the rights of natural persons in terms of personal data protection. Thus, although we process your personal data, the Regulation provides you with several rights regarding your personal data.
Also, the Regulation grants more rights to the individuals whose personal data are processed. Thus, in addition to the existing rights, we also find the right to data portability or to data deletion.
These are your rights, briefly:
The right of access means that you have the right to obtain the confirmation from us that we process your personal data or not and, if so, you have access to those data and to the information regarding the way data are processed. You also have the right to obtain a copy of your personal data provided to us and which are processed (we would like to inform you that for any other copies requested by you, a reasonable fee may be charged, based on administrative costs). If you submit the request electronically and unless you request a different format, the information will be provided to you in the currently used electronic format.
The right to data portability refers to the right to receive personal data in a currently used structured format, and which may be read automatically, and to the right to transmit these data directly to another operator if this is technically feasible.
The right to opposition means your right to oppose the processing of your personal data when processing is necessary for the performance of a task which is in the public interest or when it has a legitimate interest of ABN SYSTEMS INTERNATIONAL. When processing your personal data is for direct marketing, you have the right to oppose it at any time.
The right to withdraw your consent concerns the cases when we have obtained your consent to process your personal data for certain activities (for example, for direct marketing purposes). You may withdraw your consent at any time and we will cease to conduct that specific activity unless we consider that there is an alternative legal basis to justify further processing of your personal data for that purpose, and we shall inform you about this condition.
The right to rectification refers to correcting, without undue delay, the inaccurate personal data. The rectification shall be notified to each recipient the data were forwarded to, unless this proves impossible or requires disproportionate efforts, and we will notify you on these recipients if you request so.
The right to erasure of data (the "right to be forgotten") means that you have the right to ask us to erase your personal data without undue delay for one of the following reasons:
they are no longer required for the fulfilment of the purposes they were collected or processed for;
you withdraw your consent and there is no other legal basis for processing;
you oppose the processing and there are no prevailing legitimate reasons;
your personal data have been illegally processed;
your personal data must be deleted for compliance with a legal duty;
your personal data have been collected in connection with the provision of services of the information society;
In doing so, we shall notify each recipient the personal data have been disclosed to, upon any deletion thereof, unless this proves impossible or involves disproportionate efforts, and we will notify you on these recipients if you request so.
The right to restrict the processing may be used in one of the following cases:
when you challenge the accuracy of the data over a period that enables us to verify the accuracy of the data;
processing is illegal, and you oppose the deletion of your personal data, requesting the restriction instead;
in case ABN SYSTEMS INTERNATIONAL no longer needs your personal data for processing, but you request them for the establishment, exercise or defence of a right in court;
in case you opposed the processing for the period when we are checking if our legitimate rights prevail, in which case we will broadly explain our reasons to you.
In doing so, we shall notify each recipient the personal data have been disclosed to, upon any restriction on processing, unless this proves impossible or involves disproportionate efforts, and we will notify you on these recipients if you request so.
All these rights may be exercised through a written, signed and dated application, sent to our office or by email; the necessary contact details are in Annex no. 1.
Upon request, you will receive from us a copy of your processed personal data; you may request and receive a response from us in any way you want (including email).
Please note that your right to request a copy, as outlined above, should not interfere with the rights and freedoms of others.
The right not to be the subject of a decision based solely on automatic processing, including profiles generation
The right to lodge a complaint with the supervisory authority - Should you consider that your personal data rights have been violated, you may also contact and file a complaint with the local data protection authority:
The National Supervisory Authority for Personal Data Processing
28-30 G-ral. Gheorghe Magheru Blvd.
District 1, postal code 010336
WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA PROTECTION?
ABN SYSTEMS INTERNATIONAL is responsible for the protection of your personal data. Its headquarters are in Bucharest, district 1, 31 Marinarilor Street.
For any comments or suggestions regarding this notice, please contact us using the contact information in Annex no. 1. We are very concerned with the security of your personal data and will respond to you within maximum 5 (five) business days.
YOUR PERSONAL DATA TRANSFER? HOW AND TO WHOM?
In order to carry out one or more of the above activities, it is possible to disclose your personal data to external or internal providers ("Processors").
At the same time, we ensure the collaboration, based on a confidentiality commitment, with processors providing sufficient guarantees for the implementation of the appropriate technical and organizational measures, so that the processing of your data comply with the legal requirements and also to ensure the proper protection of your personal data rights.
In order to ensure the smooth running of our contractual relationships, your personal data may be transferred:
Among the companies within the ABN SYSTEMS INTERNATIONAL group;
To third parties (e.g. consultants of the ABN SYSTEMS INTERNATIONAL group);
To a cloud storage service provider.
The categories of services for which we collaborate with processors and the personal data transferred to them are as follows:
1. Newsletter services - email address, name, first name, telephone number;
2. Billing services - name, first name, e-mail address, telephone number, billing address;
3. Courier/mail services - name, first name, e-mail address, telephone number, delivery/billing address;
4. Online payments processing services - name, first name, payment data;
5. Commenting services - name, first name, e-mail;
6. Accounting services - name, first name, billing address, telephone, e-mail;
7. Legal services - name, first name, address of delivery/billing, identification data, e-mail telephone, correspondence, audio/video recordings.
We want to make ensure that your personal data are stored and transferred in such a way that ensures their proper security.
For those reasons, we will transfer your personal data outside of the European Economic Area (the Member States of the European Union, Norway, Iceland and Liechtenstein) only if the transfer is carried out in compliance with the legal provisions on personal data protection and assuring the proper security level as follows:
By transferring your personal data to a state providing an adequate level of protection, recognized as such by a decision of the European Commission;
If you have granted your free and informed consent as to the transfer of your personal data outside the European Economic Area;
By concluding a contract for the transfer of the personal data to a third party, a contract that incorporates the standard clauses adopted by the Commission of the European Union on the transfer of personal data to operators and mandated persons in states that provide an adequate level of protection.
LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA
The Regulation provides for several ways we can legally process your personal data as described below.
The legal basis for the processing is the contract performance
Article 6 paragraph (1) of the Regulation states that "Processing shall be lawful only if and to the extent that at least one of the following applies: [...] b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract".
Therefore, we rely on this legal basis to process your personal data to enable us to perform both our contractual obligations as well as our obligations to third parties, but also to ensure that you properly perform your obligations towards us.
Processing is based on a legal obligation
Besides our contractual obligations we are also bound by other legal obligations that we must observe. Article 6 paragraph (1), item (c) of the Regulation provides that we may process your personal data if such processing is "is necessary for compliance with a legal obligation we are subject to.”
An example of a legal obligation we must observe it is our duty to cooperate with the tax authorities.
Processing is based on a legitimate interest
Article 6 paragraph (1) letter (f) of the Regulation explains that we can process your data if they "are necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by [your] interests or fundamental rights and freedoms which require protection of personal data."
We consider the following as non-exhaustive examples of your personal data processing according to our legitimate interests:
for our internal administrative purposes;
to prevent the unauthorized use of our information and equipment;
to carry out the investigations regarding presumed deviations; and
for the establishment, pursuit or support of the legal claims
Processing is legally based on the freely expressed consent.
In certain circumstances, we will obtain your opt-in consent before undertaking certain requirements regarding the processing of your personal data.
Article 4 paragraph (11) of the Regulation states that the opt-in consent is "any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her".
In simple words, this means that:
you must express your free consent without any pressure;
you need to know what you express your consent for - therefore we assure you that we will provide you with sufficient information;
you should be required to accept a single processing activity at a certain time - therefore we avoid asking for a single consent for several processing activities so that you may not know exactly what you agree with; and
you need to take specific measures to give us your consent - it is very likely that you are asked to fill in a checkbox to ensure that this requirement is met in a clear and unambiguous manner.
Along with the introduction of these specific personal data processing activities, we will give you more information so that you may decide whether you want to sign up.
You have the right to withdraw your consent for these activities. You can do this at any time, and details about how you can do this can be found in the "The right to withdraw your consent" section above.
Please note that we need the personal data listed in Section 1 to provide you with our services.
If you do not provide us with your personal data, we will not be able to provide you, in whole or in part, with the services you requested. If you withdraw your consent, we may not be able to provide you, in whole or in part, with the services you requested.
We do not consider that any of the above activities harm you in any way.
However, you have the right to oppose the processing of your personal data under certain circumstances.
If you want to know more about these circumstances and how to object to our processing activities, please see the "The right to Opposition" section.
Your opinion is important to us!
For any questions or requests relating to the processing of your personal data, including the exercise of your rights, you may send us an email using the data listed in Annex 1, or you may contact us at Bucharest, 31 Marinarilor Street, District 1.
We will provide you with the requested information in electronic format whenever possible, unless you request another format.
All information provided, as well as any notification and measures taken by you in exercising your rights above are offered for free. However, if your claims are unfounded or excessive, especially because of their repetitive nature, we inform you that there is a possibility (i) to charge a fee, considering the administrative costs of providing you with the information or notification or to take the requested measures, or (ii) to refuse to comply with your request.
This Personal Data Processing Policy becomes effective on the 25th of May 2018.
By expressing your consent, your personal data will be processed by ABN SYSTEMS INTERNATIONAL SRL, as stated in this Personal Data Processing Policy.
To keep informed, please check this Personal Data Processing Policy whenever you access our website.
ANNEX NO. 1
For personal data protection questions, to exercise your rights or to file a claim, contact ABN SYSTEMS INTERNATIONAL by email to the address below.
You can contact us by mail at the following address:
Details for contacting ABN SYSTEMS INTERNATIONAL
Post Address: Bucharest, District 1, 31 Marinarilor Street.
Attn: ABN Systems International SRL – personal data protection