INFORMATION NOTE REGARDING THE PROCESSING OF PERSONAL DATA
1. Who is the company that manages www.condesign.ro?
1.1 The company CONDESIGN S.R.L (hereinafter referred to as “CONDESIGN”, “the Company”, “we” or similar) is a design office with its registered office in Şelimbăr, st. Mihai Viteazu, nr. 2B, county Sibiu, registered at the Trade Register under number J32/1194/2007, having CUI 22067028.
1.2 www.condesign.ro is a website that aims to promote in a detailed way the services and projects developed by CONDESIGN. In order to be able to fulfill this purpose, we come into contact with individuals or companies interested in purchasing one or more of the services offered, meaning that we provide you with a platform through which you can obtain the desired information. Although our website is informative, it may collect personal data of natural persons (for example from natural persons who wish to apply for a position in our company or from other natural persons/potential customers who wish to inquire about related to the works and services offered by our company). In order to minimize the volume of personal data collected, we have not introduced a registration/authentication option on our website, nor an option to subscribe to a newsletter.
1.3 This document is very important because it explains why we need certain personal data in order to provide certain services. Before sending us personal data and/or using our website www.condesign.ro, please read carefully this Information Note regarding the processing of personal data, because it includes a number of useful principles and concepts both in interacting with our website and in interacting with the online environment in general. In accordance with the General Data Protection Regulation – RGPD[1], we will also set out below information about the categories of personal data collected from you, the purpose and basis of processing, to whom we disclose this data, the storage period, what rights you have in relation to the personal data we process for you , as well as what actions you can take to better understand and control the volume of personal data that is processed online.
[1] REGULATION no. 679 of April 27, 2016 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/EC (General Data Protection Regulation – RGPD).
2. Categories of data subjects
2.1 www.condesign.ro collects some personal data from its visitors, data that is obtained directly from visitors through the forms in the “Contact” or “Careers” sections, or is provided by traffic reports and cookies.
3. Categories of personal data processed
3.1 General information
3.1.1 According to the General Data Protection Regulation – RGPD: “personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more many specific elements, specific to its physical, physiological, genetic, psychological, economic, cultural or social identity.
3.1.2 www.condesign.ro collects personal data from its visitors in two important ways:
a). Information provided directly by you through the forms in the “Contact” section (as a result of sending us a message), or the form in the “Careers” section (if you are applying for one of the available positions in the company).
b) Information we obtain from traffic reports recorded by the server and through cookies when you use the website.
3.2 Personal data collected through the “Contact” section of the website
3.2.1 www.condesign.ro contains indications, sections and forms regarding simplified contact with us. When contacting us by e-mail or through a contact form, the data communicated by you (which can be, for example, your e-mail address, your first and last name, your phone number, or other data related to your reason or request for establishing contact) are saved by us to answer your question or request. These data are used only for the purpose of processing the respective situation, questions or requests from you. By establishing contact with us, you express your consent for us to process your personal data sent, in order to resolve the respective situation, questions or requests from you.
3.3 Personal data collected through the “Careers” section of the website
3.3.1 www.condesign.ro contains a “Career” section and a form related to the recruitment procedure within the CONDESIGN company. If a potential candidate (on a vacant position within the company or in the absence of a vacancy for possible recruitment through a “speculative application”), send to us by e-mail or through a recruitment form data necessary for recruitment, the respective data communicated by you will be processed by us for the purpose of recruiting for that vacant position.
3.3.2 In order to process your application, data necessary for recruitment, sent by you, are collected and processed, such as: general identification data (surname, first name, gender), correspondence data with you (address, e-mail address/telephone/fax), personal data included in CVs, as well as other personal data that, as the case may be, you can provide them directly to us in connection with the purpose of the processing (for example driving license data, education and professional qualification data). For more details regarding the recruitment procedure we encourage you to consult the Information Note Regarding the Processing of Personal Data in the Recruitment Procedure
3.4 Information automatically provided by traffic reports
3.4.1 www.condesign.ro automatically collects, on each visit by you, certain data and information, which it stores in its traffic reports, data that may include: the IP of the device from which we visit, the region or general location from which you access the site, as well as the type of browser, operating system or device from which you access us and a history of the pages you access, the Internet page from which you were redirected.
3.4.2 We use this information on the basis of our legitimate interest to ensure the security of our website, to administer it, to ensure the optimal functioning of the website, to observe to what extent the website pages correspond to the display needs of your device, to diagnose any problems our servers have when delivering pages to certain types of devices, to analyze trends, to observe how users can better navigate our pages, to improve our services and the information provided by Web page. www.condesign.ro uses external traffic analysis services (only Google Analytics). These aforementioned data are collected anonymously by our website and we do not use traffic data to identify visitors behind IP addresses.
3.5 Information provided by cookies and similar technologies
3.5.1 We also collect statistical demographic information that helps us identify the preferences of www.condesign.ro visitors. They use cookies. Cookies were invented to allow users to benefit from services such as authentication when accessing a website or using online stores. They are small text files, placed on a reader’s terminal, that play the role of site memory. Whenever the person in question accesses a certain website, he can write or read in the cookie he placed on the terminal information that the reader has already sent to the website, directly or indirectly. Later, from this point, other technologies aimed at the same goal were developed. We use cookies and similar technologies on www.condesign.ro. These technologies are detailed on the page entitled Cookies.
3.6 Links to other Internet pages
3.6.1 Our website contains links to other websites, i.e. there may be other websites that refer to our website (“external websites”). We will not be responsible in any way for your interaction with these external websites, nor for the content, operation or degree of compliance by these external websites with the provisions regarding data protection, in which sense we recommend that you inform yourself with regarding these aspects on these pages before visiting them.
4. Purpose of processing and legal basis
4.1 Contact form
a) When contacting us by e-mail or through a contact form on www.condesign.ro, the data communicated by you are saved by us in order to answer your question or request.
b) In this case, data processing will be based on your consent for the processing of personal data sent in order to resolve the respective situation, questions, complaints or requests from you, or the preparation and execution of a contract to which you are a party (if you wish to become our customer or you are already a customer), or the fulfillment of a legal obligation that falls to our company (which derives for example from tax legislation), or our legitimate interest in relation to the purpose of the processing (for example to solve the question, request or complaint received from you), or to protect a legitimate interest of ours through administrative, judicial or arbitration means.
4.2 Recruitment
a) For the purpose of recruiting potential employees by us, to evaluate their qualifications, to communicate with these people for the purpose of recruitment, to fulfill the pre-contractual measures of concluding the individual employment contract (if the recruitment is successful), or to fulfill our legitimate interest in in connection with this purpose of processing, we use the personal data contained in the CVs, diplomas and documents that we receive from you, for the purpose of recruitment (data received by e-mail or the form in the “Careers” section).
b) In this case, data processing will be based on your consent, or the performance of steps by us before the conclusion of the employment contract, or the fulfillment of a legal obligation of our company, or a legitimate interest of ours in relation to the purpose of the processing, or protecting the vital interests of the data subject or another natural person, or protecting legitimate interests of our company in relation to the purpose of processing through administrative, judicial or arbitration means.
4.3 Traffic Analysis
a) In order to carry out various analyses, statistics and reports on the operation of the website, to ensure its operation, administration and security, to improve the information provided by the website as well as the experience offered by the website to visitors when you access it, we collect certain data when you access the website (as mentioned in points 3.4 above) and we also use cookies and other similar technologies (described in point 3.5 of this document).
b) In this case, data processing will be based on your consent (the provision of certain data is voluntary and you can set some privacy aspects from the browser, as described on the page entitled Cookies, or our legitimate interest to ensure the correct functioning of the website, its security, to permanently improve the information provided, as well as the experience offered by the website to its visitors, to manage a possible computer attack on the website, or to protect through administrative, judicial or arbitration of legitimate interests of our company in relation to the purpose of the processing.
5. Disclosure of Personal Data
5.1 Depending on the purpose of the processing, if applicable, we may need to disclose your personal data to:
a) state authorities (for the fulfillment of legal obligations, for example of a fiscal nature);
b) service providers, collaborators, agents and employees of our company or business partners (for example, IT service providers and service providers involved in the operation, security and administration of the website (providers and support of information technology systems, including e-mail archiving, telecommunications providers, back-up and recovery services in case of disaster and cyber security services), media agencies, business partners to answer/solve your question, request or complaint, lawyers, external consultants, accountants, auditors);
c) judicial or administrative authorities, to establish, exercise or defend our legal rights in court, arbitration, or administratively;
d) persons who demonstrate that they act legally on your behalf;
e) other companies and/or natural persons in Romania, for example, for the purpose of a reorganization, mergers, divisions, absorption of companies, associations, sales, transfer, liquidation, bankruptcy, assignments of receivables, or to other companies in the group from which CONDESIGN is part of (the CON-A Group), for internal administrative purposes, auditing, recruitment, etc. Your data is not transferred to a third country or an international organization. Such transfers, if applicable, will be carried out by us only in compliance with the provisions of the GDPR in force and secondary legislation on the protection of personal data.
6. Duration of processing. Technical security measures
6.1 Duration of processing
6.1.1 Personal data are stored for their processing for the duration necessary to fulfill the purposes mentioned above and/or for the duration imposed by the applicable legislation, and subsequently for the fulfillment of some legal obligations of the Company, either according to the Company’s policy, or for documentation and exercising the Company’s right to defense in court, arbitration or administratively, or to fulfill legal archiving obligations.
6.1.2 In the case of recruitment regarding the storage and deletion of personal data we encourage you to also consult the information on the processing of personal data in the recruitment procedure.
6.1.3 If the provision of personal data represents a legal or contractual obligation or an obligation necessary for the conclusion of a contract, the refusal regarding the provision of personal data may determine the impossibility of concluding/executing the contract or the impossibility of the Company fulfilling its goals processing (for example, we will not be able to process your application).
6.2 Technical security measures
6.2.1 The CONDESIGN SRL company is committed to protecting your personal data against loss, misuse, disclosure, modification, unavailability, unauthorized access and destruction and takes all reasonable precautions to protect the confidentiality of this data, including by using organizational measures and appropriate techniques. Organizational measures include controlling physical access to our premises, training staff and locking physical files in storage facilities. Technical measures include the use of encryption, passwords for access to our systems, the use of SSL security certificates, to encrypt data in transit, etc.
6.2.2 During your provision of personal data, it may be transferred over the Internet. Although we make every effort to protect the personal data that you provide us, the transmission of information between you and us over the Internet is not completely secure (the terminal from which you write may be monitored by third parties, for example, without we have any control over this). Therefore, we cannot guarantee the security of your personal information transmitted over the Internet. Therefore, any such transmission is at your own risk. Once we receive personal data, we will use strict procedures and security features to prevent unauthorized access to it.
7. What rights do you have as a user of the www.condesign.ro website?
7.1 As a data subject, the GDPR gives you a number of rights, including:
a) The right to information (art. 13 and 14 RGPD): the data subject has the right to obtain from the operator concise, accessible and transparent information regarding the processing;
b) The right of access (art. 15 RGPD): allows you to obtain from us a confirmation that personal data concerning you is being processed or not and, if so, access to said data and other useful information;
c) The right to data deletion (“the right to be forgotten” art. 17 GDPR): allows you to obtain from us the deletion of personal data concerning you, without undue delay. There are, however, exceptions to this rule, such as the fact that some data are processed to provide the public with the right to information, that they are processed for statistical or archiving purposes, that they are processed to fulfill a legal obligation or that we process them for establishing or defending a right in court;
d) The right to rectification of data (art. 16 RGPD): allows you to obtain from us, without undue delay, the rectification or completion of inaccurate personal data concerning you;
e) The right to data restriction (art. 18 RGPD): the data subject has the right to obtain from the operator the restriction of the processing of personal data in certain cases (for example, when the data subject contests the accuracy of the personal data, for a period that allows the operator to check the accuracy of the data);
f) The right to data portability (art. 20 RGPD): you have the right to receive the personal data concerning you and which you have provided to the operator (who processes them under a contract or under your consent, by automated means) in a structured format, currently used and which can be read automatically and you have the right to transmit this data to another operator without hindrance from us. In other words, the personal data will be provided to you, in a structured format, so that you can decide to download it or, on the contrary, to send it to another operator;
g) The right to object (art. 21 GDPR): the data subject has the right to object to the further processing of his personal data, under certain conditions and limits established by the GDPR, including to object to the processing of data for direct marketing purposes;
h) The right not to be subject to a decision based exclusively on automatic processing, including the creation of profiles, which produces legal effects concerning the data subject or similarly affects him to a significant extent (art. 22 RGPD): www.condesign.ro does not perform such profiling that is followed by automated decisions with legal or similar significant effect for the person concerned. When we carry out such profiling, we will notify you and modify this Information Note regarding the processing of personal data;
i) In addition, if you want to submit a complaint related to the processing of your personal data, you can contact us in writing, at the address in point 7.2. You also have the right to file a complaint with the National Authority for the Supervision of Personal Data Processing, B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania +40.318.059.211/+40.318.059.212, anspdcp@dataprotection.ro;
7.2 If you wish to exercise any of your rights or if you have any questions about this Information Notice on the processing of personal data or about the processing of your personal data, you can contact us by sending a written request to the attention of the Data Protection Officer at the address: Şelimbăr, Str. Mihai Viteazu, no. 2B, county Sibiu, e-mail: office@condesign.ro; fax: 0269/560408.
8. Changes in the Information Note regarding the processing of personal data
8.1 The date of the last revision of this Information Note on the processing of personal data is indicated below. If necessary, for example as a result of legislative changes, we reserve the right to change our privacy practices, update and make changes to this Information Notice on the processing of personal data at any time in the future without any prior notice to you In the event of any such change, we will display on our website the modified version of this Information Note on the processing of personal data, which is why we encourage you to periodically check its content.
Version 01/30/09/2022