PRIVACY POLICY

The following general privacy policy is applied within SC Rotariu Investments SRL, regarding the EU Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of these data and repealing Directive 95/46/CE.

The company SC Rotariu Investments SRL (hereinafter referred to as “the Company”) is in line with the (EU) Regulation 2016/679 of the European Parliament and of the Council – on the protection of individuals with regard to the processing of personal data and on the free movement of these data and repealing Directive 95/46 / EC (hereinafter referred to as the “Regulation” or “GDPR”).


This Policy applies:

- The premises and work points belonging to SC Rotariu Investments SRL

- All departments and all personnel belonging to SC Rotariu Investments SRL

- All contractors, suppliers and other persons working on behalf of SC Rotariu Investments SRL

- To all clients and potential clients of SC Rotariu Investments SRL.

TERMS OF REGULATION:

Operator – the entity – in this case, SC Rotariu Investments SRL, or any other legal person, public authority, agency or non-governmental organization, that processes or establishes the purposes and the means of processing personal data;

Personal data – any information about an identified or identifiable natural person; an identifiable person is that person who can be identified - directly or indirectly, by reference to an identification element: name / surname, address, personal numeric code, e-mail, telephone, income, biometric data, image, IP address or by referring to medical, genetic, ethical or racial origin data, political, religious, philosophical, cultural or trade union beliefs;

The data subject – any individual whose personal data can be or is processed by the operator;

GENERAL INFORMATION:

SC Rotariu Investments SRL, having its headquarters in Theodor Stefanescu Street, no.6, Sector 3, Bucharest, registered at the Trade Register Office under no. J40 / 3978/2020, having fiscal code RO42417365, e-mail: [email protected], is responsible for processing the personal data that we collect directly from the targeted individuals or from other legal sources.

Our company – SC Rotariu Investments SRL, is an operator according to the provisions of the new Regulation. In order for the data of the data subjects to be processed safely, we have made every effort to implement reasonable measures to protect their personal information.

When data subjects enter into a relationship of any kind with us, they entrust us with their information.

The purpose of this General Privacy Policy is to explain to the data subjects what data we process, why we process it and what we do with it – as an operator. We take privacy seriously and never sell lists or email addresses. Being fully aware of the fact that personal information belongs to every individual, we do our best to store it securely and process it carefully. We do not provide information to third parties without first informing the data subjects. This information is important. We hope you read it carefully.

This General Privacy Policy does not cover the apps and sites of other third parties that people may reach by accessing the links on our site. This is beyond our control. We encourage everyone to review the Privacy Policy on every site and / or app before providing personal data.

This General Privacy Policy also covers the recruiting process and that of selecting candidates for positions offered by the company (eg: the company obtains personal data as a result of requesting the completion of a form in an application or by sending a CV via e-mail). The company informs the applicants that personal data will be collected, the purpose for which it is collected and how it will be used, in close connection with the existence of the specific Privacy Policy for the recruitment formulated by the company (in the e-mail recruitment operation there is a link to privacy policy).

According to the legislation, the individual who is the beneficiary of our services or the person in a relationship of any kind with us, is a “data subject”, that is, an identified or identifiable individual. To be completely transparent about data processing and to allow them to easily exercise their rights, at any time, we have implemented measures to facilitate communication between us, the data operator and the data subject.

SC ROTARIU INVESTMENTS SRL COMMITS TO:

The protection of the personal information of the data subjects is very important for us. Therefore, we are committed to respecting the new Regulation (EU) 2016/679, the applicable national legislation in this area, but also the following principles:

Legality, fairness and transparency:

We process personal and legal data correctly. We are always transparent about the information we use and the data subject is properly informed.

The control belongs to the data subject at case:

Within the limits of the law, we offer you the possibility to examine, modify, delete the personal data that you shared with us and to exercise your other rights.

Data integrity and purpose limitation:

We only use the data for the purposes described at the time of collection or for new purposes compatible with the initial ones. In all cases, our goals are compatible with the law. We take reasonable steps to ensure that your personal data is accurate, complete and up to date.

Security:

We have implemented reasonable security and encryption measures to protect the information as best as possible. However, it should be remembered that no website, no app and no internet connection is completely secure.

QUESTIONS:

If there are any questions or concerns regarding the processing of personal data or if the data subjects wish to exercise their legal rights in relation to the data we have or if there are fears about how we treat any confidentiality issue, any interested data subject can contact us via email at: compliance@rotariuinvestments.eu.

We may change this General Privacy Policy at any time. All updates and changes to this Policy are valid immediately upon notification, which we will make by posting on the site and / or email notification.

INFORMATION OF THE DATA SUBJECTS:

When the data subjects interact with us in any way, it is possible to provide or obtain information from other sources such as:

- Name/Surname

- Address

- Age

- E-mail address

- Phone

- Gender

- Social Media profiles

- Interests and preferences

- Social security Number

- Banking information

- Photos

- Skills

- Studies

WHY DOES SC ROTARIU INVESTMENTS SRL COLLECT THIS DATA:

We collect the information of the data subjects for certain and legitimate purposes that include, but are not limited to, the following:

- To be able to communicate with the candidates at the positions available in the company;

- To make the right decision in order to employ them;

- In order to conclude and execute a work contract according to the specialization / qualification of the candidates;

- In order to conclude or execute / modify a contract between the data subjects and the company;

- To answer the questions and requests of the data subjects;

- For marketing purposes, but only if we have the prior consent of the data subject;

- To be able to offer and improve the services and products of the company;

- To diagnose or remedy technical problems;

- To offer advertising and personalized content;

- To defend the company against cyber attacks;

- For the creation and / or maintenance of the accounts;

- To comply with the company law;

- To establish or claim a right in court;

- To authenticate the single user for the purpose of clocking in;

- To monitor the access in the company according to the laws of protection and security;

- To control compliance with labor protection rules;

- To carry out remote quality control, according to the quality standards in force.


THE LEGAL BASIS FOR PROCESSING:

The data subject has given his consent for the processing of personal data:

It is important to remember that the data subjects can withdraw their consent at any time by following the unsubscribe instructions in each e-mail or by sending a written request to the e-mail address: compliance@rotariuinvestments.eu

The processing is necessary for the conclusion or execution of a contract for the provision of services or sale-purchase between the data subject and the company:

The processing is necessary in order to fulfill a legal obligation of the organization, such as Law 333/2003 regarding the guarding of objectives, assets, values and protection of persons.

The processing is necessary to protect the vital interests of the data subject or of another individual;

The processing is necessary for the purposes of our legitimate interests or that of another party:

According to the quality standard SR EN ISO / IEC 17025:2018 the evaluation of the secondary quality control can be done by video monitoring of the test executors; visual identification through digital photography of user accounts on computers; promoting activities within the company on the company's website or on the company's social pages in the interest of service.


DATA STORAGE WITHIN SC ROTARIU INVESTMENTS SRL:

We store personal data only for the period necessary to achieve the goals, but not more than 10 years after the termination of the contract or the last interaction of the data subject concerned with the company. After the end of this period, the personal data will be destroyed or deleted from the information systems or transformed into anonymous data for use for scientific, historical or statistical research purposes.

It is important to remember that in certain explicitly regulated situations, we store data for the period required by law.

SHARING YOUR INFORMATION WITH THIRD PARTIES:

SC ROTARIU INVESTMENTS SRL will not disclose the data obtained from data subjects during the recruitment stages, to other third companies without having previously obtained an explicit and separate consent in this regard.

The company confirms that the personal data obtained from the recruitment process are securely stored or destroyed, meaning that we inform the data subjects that there are data processing agreements with the software provider / providers through which they have provided the company that they are also GDPR compliant.

SC ROTARIU INVESTMENTS SRL may disclose the data of the individuals concerned, respecting the applicable law, to business partners or other third parties, such as their own proxies.

We are constantly making reasonable efforts to ensure that these third parties have implemented adequate protection and security measures. We have contractual terms with these third parties so that your data is protected. We will inform the data subjects every time about the identity of these companies before the transfer or within a reasonable time and we will ensure that any transfer is legitimate, based on their consent or other legal basis.

For example, we may provide personal data to other companies, such as IT or telecommunications service providers, accounting, legal services and other third parties with whom we have a contractual relationship. These third parties are selected with special care so that this data is only processed for the purposes we indicate.

Also, the company could share the data of the targeted individuals to business partners as a result of a joint effort to provide a product or service.

Although unlikely, the company could sell the business or part of the business in the future, which will include the transfer of this data.

We may also transmit the data to other parties with the consent or according to the instructions of the data subject.

Personal information may also be provided to the prosecutor's office, the police, the courts and other authorized bodies of the state, based on and within the limits of the legal provisions and as a result of expressly formulated requests.

Within reasonable limits, the company will ensure that the data of the data subjects do not leave the European Economic Area, but, insofar as it will transfer data to non-EEA countries, it will, in all cases, ensure that the transfers are legitimate, based on the explicit consent of the data subject or other legal basis.

RIGHTS OF THE DATA SUBJECTS IN THE LIGHT OF THE NEW REGULATION:

- The right of withdrawal of the consent where the processing is done based on the consent;

- The right to be informed about the processing of your data;

- The right of access your data;

- The right to rectify inaccurate or incomplete data;

- The right to delete (“the right to be forgotten”);

- The right to restrict processing;

- The right to transmit the data we have about the data subject to another operator;

- The right to oppose data processing;

- The right not to be the subject of a decision based exclusively on automatic processing, including the creation of profiles;

- The right to seek justice;

- The right to file a complaint with the Supervisory Authority.


SC ROTARIU INVESTMENTS SRL informs any concerned individual that:

They may withdraw their consent to the processing of sensitive data and / or for direct marketing at any time by following the unsubscribe instructions from each email / sms or other electronic message.

If you wish to exercise your rights, you can do so by sending a written, signed and dated request to the email address: compliance@rotariuinvestments.eu

The rights listed above are not absolute. There are also exceptions, which is why each received request will be analyzed so that it can be decided whether it is well founded or not. To the extent the claim is well founded, the company will facilitate the exercise of rights. If the request is unfounded, the company will reject it, but it will inform the data subjects about the reasons for the refusal, as well as their rights to file a complaint with the Supervisory Authority and to address the justice.

The company will try to respond to each request within a 30 days period. However, the deadline can be extended depending on different aspects, such as the complexity of the request, the large number of requests received or the inability to identify you in a timely manner.

If, while making every effort, the company fails to identify the data subjects, and they do not provide additional information for their identification, the company will not be required to respond.

APPLICATIONS AND EXERCISE OF RIGHTS:

In the event that you wish to exercise any of the rights listed above in this INFORMATION, make comments or obtain additional information or clarifications regarding the processing of your personal data, if you have any questions or concerns regarding the processing of your information or would like to to exercise your legal rights or any other concerns regarding the confidentiality of your data, please contact SC ROTARIU INVESTMENTS SRL at the email address compliance@rotariuinvestments.eu to ensure that SC ROTARIU INVESTMENTS SRL complies with all GDPR requirements.

The answer to all requests will be sent to you in the shortest possible time, which will not exceed one month from the receipt of the request, with the possibility of extending the duration by maximum 2 months if we talk about a complex processing or a large volume of such requests.

All requests can be submitted personally or sent by post / courier to our headquarters in Bucharest, no. 6, Teodor Stefanescu Street, Sector 3, or via e-mail at: compliance@rotariuinvestments.eu.

It is also good to know that the National Authority for the Supervision of Personal Data Processing (“ANSPDCP”) operates in Romania and that you have the right to file a complaint when you consider that your rights have been violated, by accessing the website www.dataprotection.ro.