1. WHO WE ARE
ASOCIATIA RESPO WEEE (hereinafter referred to as the Association), established based on Resolution No. 4944/23.04.2019 delivered by Buftea Court in the file no. 6190/94/2019, registered under the no. 54PJ/ 14.06.2019 with the Special Register of Associations and Foundations, holder of Operating License No. 09/02.08.2019 issued by the Ministry of Environment, as author, owner and administrator of respo.ro website, as “operator” for the purposes of the rules established by the national law and the General Data Protection Regulation (Regulation No. 679 developed by the European Parliament and the Council of the European Union on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/CE) (GDPR), which became effective as of 25 May 2018, it processes personal data, committing in this respect to comply with the right to privacy of the persons who access the site and to ensure the correct protection of the processing of Personal Data (PD) for visitors and users.
You can contact us at any time for additional information and clarifications regarding the processing of your personal data, using the following contact details:
– Postal address: Bucharest, 13 Radu Captariu Street, 2nd floor, ap. 2, District 2, postal code 020315;
– Telephone: 021.796.92.72;
– The person in charge of personal data protection (PDP) can be contacted at the email address l: email@example.com.
2. TO WHOM IS THIS POLICY ADDRESSED
– Visitors – they are the people who access the respo.ro webpage, anonymous;
– Users – they are the people who use the website and fill in the contact forms on the site.
The provision of the data / information requested through respo.ro website is considered your express consent for your personal data to be used by the Association, in accordance with the purposes mentioned below.
We expressly warn visitors and users that all processing of personal data refers exclusively to persons who have reached the age of 16. The use of the website by children under the age of 16 is prohibited. If, however, such a situation occurs, having as a consequence the processing of personal data of children under 16, we will stop processing this data as soon as we find out such a fact. The responsibility for the use of the site by children belongs exclusively to the parents.
3. WHAT PERSONAL DATA DO WE PROCESS
The personal data we request by filling in the communication forms on respo.ro website are as follows:
– last name and first name;
– email and correspondence address;
– telephone number;
– geographical location;
– user name and password for access to accounts and services;
If you do not agree with the processing of your personal data, please do not fill in the user form on the site. At the same time, insofar as you initially agreed to the processing, but later changed your mind, you can withdraw your consent regarding the processing at any time, for which purpose: with regard to the identification and contact data you can send us your request by email or by telephone, using the data on the website.
For cases when your personal data are filled in by a third party, we do not undertake any responsibility for the author of such entries.
4. FOR WHAT PURPOSES DO WE PROCESS PERSONAL DATA
The purposes for which we process the personal data you provide to us are as follows:
– for your registration as a beneficiary of the online services;
– to receive further information by email regarding our marketing campaigns, insofar as you have expressed your express consent in this regard, by accessing the existing online form;
– to be able to send us comments regarding our services and products;
– to receive our newsletter – If you have expressed your approval by accessing the existing online form, we will be sending periodic information by e-mail in order to keep you updated on the latest news.;
– for a further correspondence with you;
– for the transmission of the offers specially requested through the written comments on the website; the processing of the offer requests, until the takeover of the clients by the sales department; going through the stages prior to entering into a contract;
– in order to solve various requests / questions / notifications / complaints made by users.
Please note that if we intend to process your personal data for purposes other than those for which we initially collected them and which are not purposes related to the initial ones, we will inform you in advance and we will provide all relevant information, the subsequent processing being done only insofar as there is a legal basis for the performance thereof.
5. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA:
CONSENT – if no other processing legal ground provided below applies, the Association shall obtain always obtain your consent for the processing of personal data for one or several of the specific purposes mentioned above. For the processing of personal data of children under 16 years of age, the consent of the parent or other holder of the parental authority will be required.
EXECUTION / CONCLUSION OF A CONTRACT – the processing is necessary for the execution by the Association of a contract to which you are a party or to take steps, at your request, before entering into a contract.
LEGAL OBLIGATION – the processing is necessary in order to fulfil a legal obligation incumbent on the operator, i.e., the Association, an obligation established under the EU laws or under the laws of a Member State, including Romania (for example, to fulfil the billing and reporting obligations provided by law, etc.)
LEGITIMATE INTEREST – The processing is necessary for the purposes of the legitimate interests pursued by the Association or a third party, unless the interests or fundamental rights and freedoms of the data subject prevail (for example, for the purposes of establishing, exercising or defending a right in court, for internal administrative purposes, for the protection of copyright and related rights, etc.)
6. WHO ARE THE RECIPIENTS OF THE PERSONAL DATA WE PROCESS
The personal data entered by you on this site are also seen by other legal entities, which, depending on each specific situation, may have the quality of independent operators / associated operators or proxies.
To that end, it is possible that we could send your personal data to:
– IT specialists in charge of maintenance, application amendment, updates, actions performed by the selected provider to ensure the maintenance of the website;
– IT specialists dealing with infrastructure security;
– Security specialists who deal with the audit of security tools used, performed only on request and to prevent the occurrence of cyber vulnerabilities, audit carried out by the provider selected for that end;
– Companies with which we collaborate for the purpose of making commercial communications;
– Companies with which we collaborate for invoicing, accounting and auditing purposes;
– Other collaborators or contractors with whom the Association has concluded contractual relations in order to deliver / provide the products or services contracted or requested by you;
– External consultants that we contact in specific situations (for example, lawyers, experts, etc., in the event of litigation);
– Public authorities and bodies, i.e., investigation bodies and courts of law, insofar as the transmission of data to them is required by law and / or is necessary in case of litigation.
7. HOW LONG AND IN WHAT MANNER DO WE KEEP YOUR PERSONAL DATA
The personal data you have provided to us are processed only within the EU and the European Economic Area and will not be transferred outside the EU or the European Economic Area.
Your personal data is not subject to automated decision-making, including profiling.
The period during which we will keep the users’ data on the site is determined according to the following criteria:
a) for site visitors, the data collected through cookies are kept for the defined period, for each case apart, in About cookies;
b) for site users who have created an account, the collected data are kept as long as the user has not requested the deactivation of his/her user account and for another 6 months after deactivation;
c) when a potential partner / client requests to be contacted, provided the request has not been completed by the conclusion of a contract, the data are kept for a maximum of 6 months as of the date of the collection thereof.
d) for partners / clients who have signed a contract – for a period equal to the contractual duration, plus the period necessary for the expiry of the limitation period (general term of 3 years or another special term, if applicable) and for compliance with the legal provisions on archiving.
e) for any other data subjects whose data are collected and who do not fall into any of the categories mentioned in items 1-4 above and for which there is a basis for processing, the data will be processed by the Association for a maximum of 5 (five) years, with the possibility of withdrawing your consent at any time.
8. YOUR RIGHTS REGARDING THE PERSONAL DATA WE PROCESS
The users of respo.ro website have the possibility to exercise the following rights in relation to the Association a:
8.1 THE RIGHT OF ACCESS TO PERSONAL DATA
You have the right to obtain from the Association, when it acts in its capacity as operator, upon request and free of charge (provided there is no legal interdiction on the disclosure of source), the confirmation that your data are or are not processed by it, and if they are, you shall be provided with the information on: the purposes of the processing; the categories of data concerned; recipients or categories of recipients of the data; where possible, the period during which personal data are expected to be stored or, if this is not possible, the criteria used to determine such period; the existence of the right to request the Association to rectify or delete your data or the restriction of the processing thereof or the right to oppose the processing; the right to file a complaint with The National Supervisory Authority for the Processing of Personal Data (ANSPDCP); if the data are not collected from the data subject, any available information on their source; if applicable, the existence of an automated decision-making process, including profiling, as well as relevant information on the logic used, the meaning and the expected consequences of such processing for the data subject.
8.2 THE RIGHT TO CORRECT THE DATA
If you notice that your personal data are inaccurate or incomplete, you have the right to request their rectification or supplementation by sending a request to: firstname.lastname@example.org
You must know that any rectification can be made within a maximum period of one month as of the date of request, and in special conditions this period can be extended by a maximum of two months, in which case we will inform you about the extension.
8.3 RIGHT TO DELETE THE DATA OR THE “RIGHT TO BE FORGOTTEN”
It is your right to obtain from our Association the deletion of your personal data from the site, without undue delay, and we, as operator, have the obligation to process the request if one of the reasons exist:
– the data are no longer necessary for the purposes for which they were collected or processed;
– you withdraw your consent on the basis of which the processing takes place or when the legal basis of the processing no longer subsists;
– when you object to the processing of your data;
– when your personal data have been processed illegally;
– if there is a legal obligation to delete, which we will comply with as an operator;
– if the personal data belong to children under 16 years of age, and their parents or the persons exercising parental rights withdraw their consent.
Please note that the Association may refuse the request to delete the data in the following cases:
a) the processing is necessary for the exercise of the right to freedom of expression and information;
b) the processing is necessary for the observance of a legal obligation applicable to the Association;
c) the processing is necessary for reasons related to the public interest in the field of public health, under the restrictive conditions imposed by GDPR;
d) the processing is necessary for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes, under the terms of GDPR, insofar as the exercise of the right may render impossible or seriously affect the achievement of such processing objectives;
e) the processing is necessary for the establishment, exercise or defense of a right in court.
8.4 THE RIGHT TO RESTRICT THE PROCESSING OF PERSONAL DATA
You have the right to request the restriction of access to your personal data in one of the following cases:
– if you challenge the accuracy of the processed data, you can request to restrict access to them in the period necessary for data verification and rectification;
– if you find that the processing is illegal, but still do not want to your delete personal data, instead you may request the restriction of the use thereof;
– if our Association no longer needs your personal data, but you want us to keep them for use in a lawsuit;
– if you have objected to the processing, for the period of time in which it is verified whether the legitimate rights of our Association, as operator, prevail over your rights.
Also, if there is a case of removing the restriction on processing, we will inform you in due time.
8.5 THE RIGHT TO WITHDRAW YOUR CONSENT
If your data is processed as a result of the express agreement, you can at any time send an e-mail to email@example.com informing us that you no longer agree with the processing of personal data. The withdrawal of the consent / consent to the processing of your personal data has the effect of ceasing processing. The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of the consent before its withdrawal. You can choose to unsubscribe from the newsletter materials at any time by simply accessing the ‘unsubscribe’ link from the footer of each newsletter or event invitation.
8.6 THE RIGHT TO DATA PORTABILITY
You have the right to receive from the Association – in a structured, commonly used and automatically readable format – your personal data that you have provided to our Association and to send them directly to another operator (provided such transmission is technically feasible) when:
– the processing is based on consent or a contract; and
– the processing is performed by automated means.
8.7 THE RIGHT TO OPPOSE PROCESSING
The right to object to the processing of your data includes the following aspects:
– to oppose at any time, for reasons related to your particular situation, that your data be subject to processing based on the public interest or the legitimate interest. In the event of opposition, the processing can no longer target the data in question unless there are legitimate and compelling reasons justifying the processing and prevailing over your rights or if the purpose is to establish, exercise or defend a right in court.
– to oppose at any time, free of charge and without any justification, that your data be processed for the purposes of direct marketing, including the creation of profiles to that end.
8.8 THE RIGHT NOT TO BE SUBJECT TO AN AUTOMATED DECISION (INCLUDING PROFILING)
To that end, you have the right towards the Association not to be subject to a decision based only on automated processing (including profiling) and which will produce legal effects towards you or which will significantly affect you.
This right will not apply in the following exceptional cases, when the automated decision:
a) is necessary for concluding or executing a contract between you and the Association;
b) is authorized by EU or the domestic law abided by the Association and which also provides for appropriate measures to protect the rights, freedoms and legitimate interests of the data subject; or
c) is based on your explicit consent.
In the cases from letters a) and c) of this paragraph, the Association is required to implement the appropriate measures to protect the rights, freedoms and legitimate interests of the data subject, at least your right to obtain human intervention from the operator, to express your point of view and to challenge the decision.
8.9 THE RIGHT TO ADDRESS TO JUSTICE AND / OR ANSPDCP;
If you consider that the processing of your data is done by the Association with the violation of GDPR, you have the following rights:
a) the right to submit a complaint to ANSPDCP (head office: Bucharest, 28-30 Gen. Gheorghe Magheru Bd., District 1, CP 010336; Telephone: +40.318.05.92.11, Fax: +40.318.05.96.02 email: firstname.lastname@example.org, site: dataprotection.ro);
b) the right to bring an action in court.
8.10 CONTACT DETAILS REGARDING THE APPLICATION OF RIGHTS
All the rights mentioned in items 8.1-8.8 above are exercised by sending a written request, dated and signed at the headquarters of the Association in Bucharest, 13 Radu Captariu Str., 2nd floor, ap. 2, District 2, postal code 020315 or at email address: email@example.com with the reference “GDPR request”, and the rights provided in item 8.9 shall be exercised by written request submitted with the competent authority, as per item 8.9.
Please note that if we have doubts about the identity of the applicant, we may request additional information to confirm the identity.
Please note that if the provision of certain personal data is required by law or is an absolutely necessary requirement for signing the contract, failure to provide such data (initially or subsequently by exercising your rights) may lead to the impossibility of provision / delivery by the Association of the service / product you requested.
9. USE OF SOCIAL MEDIA CHANNELS
The association also uses social media channels to present the activity, services and particular conditions we offer to our clients. The use of the specific social media channel is highlighted on this site with buttons specific to each channel.
You can watch the presentations we upload on our YouTube page or you can follow the links on our website or on those associated with your Facebook, Instagram, Linkedin account. Each social media channel has its own policy on how it processes your personal data when you access their sites.
For example, if you choose to watch one of our videos on YouTube, you will be asked for explicit consent to accept YouTube cookies; if you look at our activities on Facebook you will be asked for explicit consent to accept Facebook cookies; the same is true for other services.
If you have any questions or concerns regarding the use of your personal data by those sites associated with the media channels mentioned above, you should carefully read the privacy policies provided by them before using them.
For information on the purpose and volume of data collection and the processing and subsequent use of data by Facebook, as well as on your rights in this regard and the configuration possibilities for protecting your private space, please consult Facebook information on data protection: http://www.facebook.com/
If you do not want Facebook to associate the data collected when accessing our website with your Facebook account, you must log out of Facebook when accessing our website.
For information on the purpose and volume of data collection and the processing and subsequent use of data by YouTube, as well as on your rights in this regard and the configuration possibilities for protecting your private space, please consult, Google information on data protection: https://www.google.com/
On the assumption that your personal data have undergone changes, and, as a consequence it is necessary to update them, we kindly ask you to promptly communicate such changes to the following address: Bucharest, 13 Radu Captariu Str., 2nd floor, ap. 2, District 2, postal code 020315, with the clear mention on the envelope “GDPR Request” or by email at: firstname.lastname@example.org (please see the right to rectify the data).
11. USEFUL LINKS
National Supervisory Authority For Personal Data Processing – click HERE.