Personal data protection policy
Regulation 679/2016 on the protection of personal data, GDPR (“General Data Protection Regulation”) takes effect from 25 May 2018.
Given its importance, as well as the protection of your personal data is important to us, we therefore pay particular attention to protecting the privacy of individuals who access the www.hedventure.ro website as well as those whose personal data has been provided to us by a third party, or to which we have had access from another source, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (“GDPR”).
Please read the following section of the Policy (hereinafter “GDPR-DPP”) carefully to better understand how your information (“personal data”) will be handled.
The DPP explains HED VENTURE SRL’s practices regarding the application of the GDPR provisions, as well as your rights regarding how your information is processed by HED VENTURE SRL.
The processing of personal data by HED VENTURE SRL will be carried out in accordance with the provisions of the GDPR, as well as with the personal data protection regulations specific to each country in which HED VENTURE SRL operates.
Through the DPP, HED VENTURE SRL wishes to inform data subjects about the nature of the personal data we collect and process, as well as the purposes of the processing. In addition, data subjects are also informed through the DPP about their rights.
Getting to know us better
We are HED VENTURE SRL, a company with registered office in Iasi, Str. Nicolae Costin 33, with registration number in the Trade Register J22/2017/2013 and unique registration code 32541772. Our main field of activity is wholesale trade with the exception of trade in motor vehicles and motorcycles, CAEN 46.
What is personal data?
“Personal data” means any information or information that can identify you directly (e.g. your name) or indirectly (e.g. through pseudonymous data such as a unique identification number). This means that personal data includes things like your email address, home address, mobile phone, username, profile photos, personal preferences and shopping habits, user-generated content, financial information and financial status information. It may also include unique numeric identifiers such as the IP address of your computer or the MAC address of your mobile device, as well as cookies.
What does the processing of personal data mean?
“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
What is your data. What personal data do we process?
We may process data to enable us to contact you. (“contact data”) Contact data may include your name, email address, phone number, postal address and/or social media account identifiers. The source of the contact data is you.
We may process information contained in or relating to any communication you send or we send (“Communication Data”). Communication Data may include the content of the communication and metadata associated with the communication. Our website will generate metadata associated with communications made using the website contact forms.
We may process data about the use of our website and services (“usage data”). Usage data may include IP address, geographic location, browser type and version, operating system, access mode, duration of visit, page views and navigation paths on the website, and information about the frequency and pattern of use of the website. The source of usage data is our analytics tracking system.
Data processing principles
HED VENTURE SRL is committed to the principles of personal data protection (hereinafter referred to as the “Principles”) set out in the GDPR to ensure that all data are:
1. Processed fairly, legally and transparently;
2. Collected for specified, explicit and legitimate purposes;
3. Adequate, relevant and limited in relation to the purposes for which they are processed;
4. Fair and up-to-date;
5. kept in a form which does not enable identification of data subjects for longer than is necessary for the purposes of processing;
6. Processed in accordance with the rights of the data subject, in a way that ensures adequate security of processing so that the data are integral, confidential and available.
Basis and purposes of the processing of personal data:
- Operations – We may process your personal data for the purposes of operating the website and responding to messages sent by you via contact forms. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business
- Relationships and communications – We may process contact data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communication for direct marketing purposes) by email, SMS, post, fax and/or telephone, support services and complaint resolution. The legal basis for this processing is our legitimate interests, namely communicating with our website visitors, service users, individual customers and customer staff, maintaining relationships and the proper administration of our website, services and business
- Research and Analysis – We may process usage data for the purposes of researching and analyzing the use of our website and our services, and for researching and analyzing other interactions with our website. The legal basis for this processing is our legitimate interests, namely to monitor, support, improve and secure our website, services and business in general
- Record Keeping – We may process your personal data for the purposes of creating and maintaining databases and backup copies of our databases. The lawful basis for this processing is our legitimate interests in ensuring that we have access to all the information we need to run our business fairly and efficiently in accordance with this policy.
- Security – We may process your personal data for security purposes and to prevent fraud and other criminal activity. The legal basis for this processing is our legitimate interests, namely the protection of our website, our services and our business, and the protection of others.
- Legal compliance and vital interests – We may also process your personal data when such processing is necessary to comply with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.
- For the purpose of recruitment to vacant posts – According to Art. 6 para. 1 lit. a) of the GDPR, personal data may be processed if the data subject has consented to the processing of his/her personal data for one or more specific purposes. If you have subscribed to the CAREERS section your personal data will be used for the sole purpose of contacting you when we consider that a job offered by us matches your qualifications.
Disclosure of personal data to third parties
Personal data processed by HED VENTURE SRL may be disclosed and/or transferred to third parties only if you have given your express consent to do so, unless there is a legal/contractual obligation for HED VENTURE SRL to do so. Please be aware that we may, in certain circumstances, be required to disclose your personal data to partners with whom HED VENTURE SRL collaborates and/or other third party service providers of HED VENTURE SRL.
Personal data held in our website database will be stored on our internal servers and/or on the servers of our hosting service providers
DATA PROCESSING BY THIRD PARTIES, OTHER WEBSITES AND SPONSORS
The www.hedventure.ro website may at some point contain links to other websites whose data processing policies may differ from those of HED VENTURE SRL
Please be aware of and consult the personal data protection policies of other sites, as HED VENTURE SRL assumes no responsibility for information submitted to or collected by these third parties.
Automatic data processing.
Data storage period
HED VENTURE SRL may keep the processed data for various periods of time, deemed reasonable, in accordance with the purposes indicated above. We keep your data only for the period necessary to achieve the purpose for which we hold the data, to meet your needs or to fulfil our obligations imposed by law.
We use the following criteria to know how long your data may be kept:
- When you purchase products and services, we keep your personal data for the duration of our contractual relationship;
- If you participate in a promotional offer, we keep your personal data for the duration of the promotional offer;
- If you contact us with a question, we keep your personal data for as long as it takes to process your question, but no longer than 5 years from the last correspondence sent;
- If you create an account, we keep your personal data until you ask us to delete it or after a period of inactivity (no active interaction with us). In this regard, we note that the data processed for this purpose will be deleted 5 years after the last interaction with the account user (such as logging into your account);
- If you have given your consent for marketing, we keep your personal data until you unsubscribe or request deletion or after a period of inactivity (no active interaction with us). In this regard, we note that data stored in our databases for the purpose of direct marketing communications is deleted from the records of these databases 5 years after your last interaction with us;
- Where cookies are stored on your computer, we retain them for as long as necessary for them to achieve their purposes (for example, for the duration of a session for shopping cart cookies or session ID cookies) and for a period defined in accordance with local regulations and guidelines. In this regard, we note that the data processed through cookies used to deliver online behavioural advertising, to personalise our services to you and to enable the distribution of our content on social media sites (distribution buttons intended for the display of the site), will be kept for a maximum period of 5 years from their collection, based on your consent.
Rights of data subjects
Under the GDPR, you have a number of rights with regard to the personal data that HED VENTURE SRL processes:
- Right of access to processing data – You have the right to access the personal data we hold. The first provision of information will be without any charge. If you require further copies of the information already provided, we may charge a reasonable fee taking into account the administrative costs of providing the information. Obvious unreasonable, excessive or repeated requests may not be answered.
- Right to rectify data – You have the right to ask for your Data to be rectified if they are indexed or out of date and/or to complete them if they are incomplete. If you have an account, it may be easier to correct your own data via the “My Account” function.
- Right to erasure (“right to be forgotten”) – In some cases, you have the right to have your Data erased or destroyed. This is not an absolute right, as sometimes we may be forced to retain your Data for legal or judicial reasons.
- Right to restrict processing – You have the right to request restriction of the processing of your Data. This means that the processing of your Data is restricted so that we can keep the Data but not use or process it. This right applies in specific circumstances set out in the General Data Protection Regulation, namely:
– the accuracy of the Data is contested by the data subject (i.e. by you), for a period allowing the controller (i.e. HED VENTURE SRL) to verify the accuracy of the Data;
– the processing is unlawful and the data subject (i.e. you) objects to the erasure of the Data and requests the restriction of their use;
– the controller (i.e. HED VENTURE SRL) no longer needs the Data for processing, but they are required by the data subject (i.e. you) for the establishment, exercise or defence of legal claims;
– the data subject (i.e. you) has raised objections to the processing based on legitimate grounds on the part of the controller (in this case HED VENTURE SRL) on the basis of the verification whether the legitimate grounds of the controller (HED VENTURE SRL) outweigh those of the data subject (i.e. you).
- Right to data portability – You have the right to move, copy or transfer the data you are interested in from our database to another. This only applies to data you have provided, where the processing is based on your consent or on the basis of a contract and is implemented by automated means.
- Right to object – You may object at any time to the processing of your data when such processing is based on a legitimate interest.
- Right to withdraw consent at any time – You can withdraw your consent to the processing of your data where such processing is based on consent. Withdrawal of consent does not affect the lawfulness of processing based on consent prior to withdrawal of consent.
- Right to lodge a complaint with the competent supervisory authority – You have the right to lodge a complaint with the data protection authority in your country of residence or domicile to challenge the data protection practices of HED VENTURE SRL
- The right to object to the processing of your data for direct marketing purposes – You can unsubscribe or opt-out of our direct marketing communications at any time. It is easiest to do so by clicking on the “unsubscribe” link in any email or communication we send you.
- The right to object to the processing of your data by us when we are acting in the public interest or in our own or a third party’s legitimate interests – You may object to the processing of your data at any time when such processing is based on a legitimate interest.
- Right to disable Cookies – you have the right to disable cookies. Internet browser settings are usually programmed by default to accept cookies, but you can easily adjust them by changing your browser settings. Many cookies are used to enhance the usability or functionality of websites/applications; therefore, disabling cookies may prevent you from using certain parts of our websites or applications, as detailed in the relevant Cookie table. If you wish to restrict or block all cookies set by our websites/apps (which may prevent you from using certain parts of the site) or any other websites/apps, you can do so through your browser settings. The Help function in your browser will tell you how. For more information, see the following links: http://www.aboutcookies.org/;
You can exercise any of these rights with regard to the personal data that HED VENTURE SRL processes by sending a simple request to the DPO of HED VENTURE SRL In such a situation we may well require proof of your identity.
We access, retain and provide your information to regulators, law enforcement or other entities:
- In response to a legal request, when we believe in good faith that the law requires us to do so. We may also respond to legal requests when we believe in good faith that the response required by the laws of that jurisdiction affects users in that jurisdiction and is consistent with internationally recognised standards.
- When we believe in good faith that it is necessary to: detect, prevent and respond to acts of fraud, unauthorized use of any material belonging to us, violations of our terms or policies, or other harmful or illegal activity; protect us (including our rights, property or materials), you and others, including in the course of regulatory investigations or inquiries; or prevent imminent death or injury. For example, where relevant, we provide information to and receive information from third party partners about the reliability of your account to prevent fraud, abuse and other harmful activities within and outside of our materials.
Information we receive about you may be accessed and stored for a longer period of time when subject to a legal request or legal obligation, government investigation, or investigation of possible violations of our terms or policies, or in other cases to prevent harm.
Relations with other operators
Depending on the context, we may find that we absolutely need to provide information at a higher level, both globally and internally or externally, to our partners and those with whom we transfer data in compliance with GDPR, by virtue of ensuring that we provide the most professional service possible. Information controlled by HED VENTURE SRL may be transferred, transmitted or stored and processed in the EU or in countries other than the country in which you reside for the purposes described in this policy. These data transfers are necessary to be able to provide services at the highest level, as well as to continue to provide you with our materials at the best professional level. We use standard contractual clauses approved by the European Commission and rely on the adequacy decisions issued by the European Commission with respect to specific countries, as appropriate, for data transfers from the EEA to the United States and other countries.
HED VENTURE SRL has adopted technical and organizational data processing measures, updated in accordance with GDPR requirements, in order to protect your personal data against any unauthorized access, misuse or disclosure, unauthorized modification, destruction or accidental loss. All employees and collaborators of HED VENTURE SRL, as well as any third parties acting on behalf of and for HED VENTURE SRL are obliged to respect the confidentiality of your information and the requirements of the GDPR, in accordance with the provisions of the DPP.
The www.hedventure.ro website may contain links to other websites and/or other webpages that are not owned by HED VENTURE SRL so HED VENTURE SRL assumes no responsibility for the content of such websites and therefore shall not be liable for the content, advertising, goods, services, software, information or other materials available on or through such websites. HED VENTURE SRL shall not be liable for any loss of personal data, any negative effects on visitors’ personal data or any other moral and/or pecuniary damage caused by access to such sites.
Update of the personal data protection and processing policy
Please note that this Policy may be subject to periodic content changes by updating the www.hedventure.ro website.
You can also contact us:
-by post, to the postal address mentioned above;
-using the contact forms on this website;
-by telephone, at the contact numbers published on this website; or
– by e-mail, using the e-mail addresses published on this website