Privacy Policy

Ultima actualizare 07 martie 2024

This privacy notice for COMPLEX HERASTRAU SA (“Company“, “we“, “us“, or “our“,), describes how and why we may collect, store, use and/or distribute (“process” ) your information. when you use our services (“Services“), such as when:

• Visit our website at https://www.herastrau.ro or any of our websites that link to this privacy notice

• Interact with us in other related ways, including in any sales, marketing or events

Questions or concerns? Reading this privacy notice will help you understand your rights and choices. privacy rights. If you do not agree with our policies and practices, please do not use our Services. If you have any further questions or concerns, please contact us at dataprotection@herastrau.ro.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can learn more about any of these topics by clicking on the link after each key point or using the table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use or browse our Services, we may process personal information based on how you interact with Sc COMPLEX HERASTRAU SA and the Services, the choices you make and the products and features you use.

Do we process sensitive personal information? We do not process sensitive personal information.

Do we receive information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve and administer our Services, to communicate with you, for security and fraud prevention and to comply with the law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may also share information in specific situations with certain third parties.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal or alter your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean that you have certain rights with respect to your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by completing our data subject request form available here: https://www.herastrau.ro or by contacting us. We will consider and act on any request in accordance with applicable data protection laws.

Want to know more about what COMPLEX HERASTRAU SA does with any information we collect?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In short: We collect the personal information you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and services, when you participate in activities on the Services, or otherwise when you contact us.

Personal information provided by you The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• name

• email addresses

• phone numbers

Sensitive information. We do not process sensitive information.

All personal information you provide to us must be true, complete and accurate and you must notify us of any changes to such personal information.

Automatically collected information

In short: some information, such as your address. Internet Protocol (IP) address and/or browser and device characteristics are automatically collected when you visit our Services.

We automatically collect certain information when you visit, use or browse the Services. This information does not reveal your identity. specific information (such as your name or contact information), but may include device and usage information such as your address. IP address, browser and device features, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is needed primarily to maintain the security and operation of our Services, as well as for our internal analysis and reporting purposes.

Like many companies, we also collect information through cookies and similar technologies. You can learn more about this in our Cookie Notice: https://www.herastrau.ro/politica-cookies.

The information we collect includes:

• Logbook and usage data. Log and usage data is service, diagnostic, usage and performance information that our servers automatically collect when you access or use our Services and that we record in log files. Depending on how you interact with us, this log data may include your address. IP address, device information, browser type and settings, and information about your activity. in the Services (such as date/time stamps associated with your usage, pages and files viewed). , searches and other actions you take, such as the features you use), information about device events (such as system activity, error reports (sometimes called “lock dumps”) and hardware settings.

• Device data. We collect device data, such as information about the computer, phone, tablet or other device you use to access the Services. Depending on the device used, the data on this device may include information such as your address. IP (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile operator, operating system and system configuration information.

• Location data. We collect location data, such as information about the location of your device, which may be either accurate or inaccurate. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt-out of allowing us to collect this information by either refusing access to the information or by disabling the location setting on your device. However, if you choose to opt-out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In brief: We process your information to provide, improve and administer our Services, to communicate with you, for security and fraud prevention and to comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To provide and facilitate the provision of services to the user. We may process your information in order to provide you with the requested service.

• To answer users’ questions/to provide assistance to users. We may process your information in order to respond to your queries and to resolve any problems you may have with the requested service.

• To save or protect a person’s vital interest. We may process your information when necessary to safeguard or protect a person’s vital interest, such as to prevent injury.
• To be able to communicate with you, for telephone confirmations, product or service reservations, appointments, etc;
• To send promotional offers, newsletters and to inform you about new offers;
• To send you advertising that might interest you, personalised ads, offers relevant to you, competitions available on the website;
• For our marketing campaigns and for our efforts to make our brand known to reach you;
• To prevent and detect fraud and abuse;
• To improve your website experience, functionality and system administration;

3. ON WHAT LEGAL BASIS DO WE PROCESS YOUR INFORMATION?

In short: We process your personal information only when we believe it is necessary and have a valid legal reason (i.e. a lawful basis) to do so under applicable law, such as with your consent, to comply with laws, to provide services to you to enter into or fulfill our contractual obligations, to protect your rights or to fulfill our legitimate business interests.

The General Data Protection Regulation (GDPR) and the UK GDPR require us to explain the valid legal bases on which we rely to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a particular purpose. You can withdraw your consent at any time.

• Execution of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including the provision of our Services or at your request prior to entering into a contract with you.

• Legal obligations. We may process your information. where we believe it is necessary to comply with our legal obligations, such as cooperating with a law enforcement or regulatory agency, exercising or defending our legal rights, or disclosing your information. as evidence in litigation in which we are involved.

• Vital Interests. We may process your information. where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

4. WHEN AND WITH WHOM WE SHARE YOUR INFORMATION.

In short: we may share information in the specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business transfers. We may share or transfer your information in connection with or during negotiations regarding any merger, sale of company assets, financing or acquisition of all or part of our business to another company.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In shortWe may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (such as web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://www.herastrau.ro/politica-cookies.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In short: We retain your information as long as necessary to fulfill the purposes outlined in this privacy notice, unless otherwise required by law.

We will retain your personal information only as long as necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). Nothing in this notice will require us to keep your personal information for more than 1 year.

Where we do not have a legitimate ongoing business need to process your personal information, we will delete or anonymise this information or, if this is not possible (for example, because your personal information has been stored in back-up archives), then we will be safe. store your personal information and isolate it from further processing until it can be deleted.

7. HOW WE KEEP YOUR INFORMATION. SAFE?

In brief: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and our efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will not be able to defeat our security and collect, access, steal or alter your information. While we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services in a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In short:We do not knowingly collect data from or market to children under the age of 18.

We do not knowingly solicit data from or target children under the age of 18. By using the Services, you represent that you are at least 18 years old or that you are the parent or guardian of such minor and that you consent to the use of the Services by such dependent minor. If we learn that personal information has been collected from users under the age of 18, we will deactivate the account and take reasonable steps to delete this data from our records immediately. Dacă luați cunoștință de orice date pe care le-am colectat de la copii cu vârsta sub 18 ani, vă rugăm să ne contactați la dataprotection@herastrau.ro.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In brief: In some regions, such as the European Economic Area (EEA) and the United Kingdom (UK), you have rights that give you greater access to and control over your information. personal. You can review, change or close your account at any time.

In some regions (such as the EEA and the UK), you have certain rights under applicable data protection laws. These may include the right to (i) request access to and obtain a copy of your information. personal information, (ii) request rectification or erasure; (iii) to restrict the processing of your information. personal data; and (iv) if applicable, data portability. In certain circumstances, you may also have the right to object to the processing of your information. personal data. You can make such a request by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS AD?” below.

We will consider and act on any request in accordance with applicable data protection laws.

If you are in the EEA or the UK and you believe we are unlawfully processing your information. You also have the right to lodge a complaint with your local data protection supervisory authority. You can find contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details of the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawal of your consent: Where we rely on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS AD?” below.

However, please note that this will not affect the lawfulness of the processing prior to its withdrawal, nor will it affect the processing of your information. personal data carried out on the basis of lawful grounds for processing other than consent.

Discontinue promotional and marketing communications: You can unsubscribe from our promotional and marketing communications at any time by clicking on the unsubscribe link in the emails we send, by replying “STOP” or “UNSUBSCRIBE” to the SMS messages we send, or by contacting us using the details provided in the “HOW CAN YOU CONTACT US ABOUT THIS AD?” section. below. You will then be removed from marketing lists. However, we may still communicate with you – for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to reject cookies. If you choose to remove cookies or reject them, this may affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services, please visit https://www.aboutads.info/choices/. For more information, please see our Cookie Notice: https://www.herastrau.ro/politica-cookies.

If you have any questions or comments about your privacy rights, you can email us at dataprotection@herastrau.ro.

10. COMMANDS FOR DO-NOT-TRACK FUNCTIONS

Most web browsers and some mobile operating systems and mobile apps include a Do-Not-Track (“DNT”) feature or setting that you can activate to signal your preference. to not have data about your activities monitored and collected. online browsing activities. At this stage, no uniform technology standard for the recognition and implementation of DNT signals has been finalised. As such, we do not currently respond to browser DNT signals or any other mechanism that automatically communicates your opt-out choice to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you of this practice in a revised version of this privacy notice.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In brief:Yes, if you are a California resident, you are granted specific rights regarding access to your personal information.

Section 1798.83 of the California Civil Code, also known as the “Shine The Light” law, allows our users who are California residents to request and obtain from us, once a year and free of charge, information about the categories of personal information (if any) that we have disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with whom we have shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing using the contact information provided below.

If you are under 18, live in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you post publicly on the Services. To request removal of this data, please contact us using the contact information provided below and include the email address associated with your account. and a statement that you reside in California. We will ensure that data is not publicly displayed within the Services, but please be aware that data may not be completely or fully removed from all of our systems (e.g. backups, etc.).

CCAC Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) any person who is in the State of California for other than temporary or transient purposes; and

(2) any natural person who is domiciled in the State of California and who is outside the State of California for a temporary or transient purpose

All other persons are defined as ‘non-residents’.

If this definition of “resident” applies to you, we must respect certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information over the past twelve (12) months:

Category	Example	Collected
A. Identifiers	Contact details such as real name, nickname, postal address, contact telephone number or mobile number, unique personal identifier, online identifier, internet protocol address, email address and account name.	NO
B. Categories of personal information listed in the California Customer Records Act	Name, contact details, education, employment, employment history and financial information	NO
C. Classification characteristics protected under California or federal law	Sex and date of birth	NO
D. Commercial information	Transaction information, purchase history, financial details and payment information	NO
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or similar network activities	Browsing history, search history, online behavior, interest data and interactions with our website and other websites, applications, systems and advertisements	NO
G. Geolocation data	Location of the device	NO
H. Audio, electronic, visual, thermal, olfactory or similar information	Images and audio, video or telephone recordings created in connection with our business activities	NO
I. Professional or job-related information	Business contact details to provide you with our Business Level Services or job title, work history and professional qualifications if you are applying for a job with us.	NO
J. Education information	Student files and information from the director	NO
K. Deductions from other personal information	Inferences drawn from any of the personal information collected listed above to create a profile or summary about, for example, a person’s preferences and characteristics.	NO

We may also collect other personal information outside of these categories where you interact with us in person, online, by phone or by mail in the context:

• Getting help through our customer support channels;

• Participation in customer surveys or competitions; and

• To facilitate the provision of our services and to respond to your requests.

How we use and share your information. personal information?

More information about our data collection and sharing practices can be found in this Privacy Notice and in our Cookie Notice: https://www.herastrau.ro/politica-cookies.

You can contact us by e-mail at dataprotection@herastrau.ro, by visiting https://www.herastrau.ro/ or by consulting the contact details at the bottom of this document.

If you use an authorised agent to exercise your right of withdrawal, we may refuse a request if the authorised agent does not provide proof that he or she has been validly authorised to act on your behalf.

Will your information be shared with anyone else?

We may disclose your information. We may disclose your personal information to our service providers in accordance with a written contract between us and each service provider. Each service provider is a for-profit entity that processes information on our behalf.

We may use your information We may use your personal information for our own business purposes, such as internal research for technology development and demonstrations. This is not considered to be a “sale” of your personal information.

COMPLEX HERASTRAU SA has not disclosed or sold any personal information to third parties for commercial or business purposes in the last twelve (12) months. COMPLEX HERASTRAU SA will not sell personal information belonging to visitors to the site, users and other consumers in the future.

Your rights regarding your personal data

Right to request deletion of data – Request for deletion

You can request deletion of your information. personal information. If you ask us to delete your personal information, we will comply with your request. and we will delete your information. subject to certain exceptions provided by law, such as (but not limited to) another consumer’s exercise of his or her right to free speech, our compliance requirements arising from a legal obligation, or any processing that may be necessary to protect against illegal activities.

Right to be informed – Demand to know

Depending on the circumstances, you have the right to know:

• if we collect and use your information. personal information;

• the categories of personal information we collect;

• the purposes for which the personal information collected is used;

• if we sell your information personal information to third parties;

• categories of personal information that we have sold or disclosed for commercial purposes;

• the categories of third parties to whom personal information has been sold or disclosed for commercial purposes; and

• the commercial or business purpose of collecting or selling personal information.

Under applicable law, we are not required to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

The right to non-discrimination for the exercise of a consumer’s right to privacy

We will not discriminate against you if you exercise your right to privacy.

The verification process

When we receive your request, we will need to verify your identity to ensure that you are the same person we have information about in our system. These verification efforts require us to ask you to provide information to compare with information you have previously provided to us. For example, depending on the type of request you submit, we may ask you to provide certain information so that we can compare the information you provide with information we already have on file, or we may contact you through a method of communication (e.g., phone or email) that you have previously provided to us. We can also use other verification methods, depending on the circumstances.

We will only use the personal information provided in your application to verify your identity or authority to make the request. As far as possible, we will avoid asking you for additional information for verification purposes. However, if we are unable to verify your identity from the information we already hold, we may ask you to provide additional information in order to verify your identity. and for security or fraud prevention purposes. We will delete such additionally provided information as soon as we finish your verification.

Other privacy rights

• You can object to the processing of your personal information.

• You can request the correction of your personal data if they are incorrect or no longer relevant, or you can request the restriction of the processing of the information.

• You can appoint an authorised agent to file a claim under the CCPA on your behalf. We may refuse an application from an authorised agent who does not provide proof that he or she has been validly authorised to act on your behalf under the CCPA.

• You can request to opt-out of the future sale of your information. to third parties. Upon receipt of a waiver request, we will act on the request as soon as possible, but no later than fifteen (15) days from the date of submission of the request.

To exercise these rights, you can contact us by e-mail at dataprotection@herastrau.roby visiting https://www.herastrau.ro/ or by consulting the contact details at the bottom of this document. If you have a complaint about the way we handle your data, we would like you to contact us.

12. DO WE MAKE UPDATES TO THIS NOTIFICATION?

In short:Yes, we will update this notice as necessary to remain in compliance with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will take effect as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by sending you a notice directly. We encourage you to frequently review this privacy notice to be informed about how we protect your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have any questions or comments about this notice, you can contact our Data Protection Officer (DPO) by e-mail at dataprotection@herastrau.ro, by phone at +40 786 77 77 88 00 , or by mail at:

COMPLEX HERASTRAU SA Șoseaua Nordului, Nr. 7 – 9, sector 1 Bucuresti Romania

14. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

Depending on the applicable laws in your country, you may have the right to request access to, amend or delete the personal information we collect from you. To request a review, update or deletion of your information. personal information, please visit: https://www.herastrau.ro/.