PERSONAL DATA PROCESSING POLICY

INFORMATION NOTE

 

I. The company that manages the “https://www.mth.digital/” website

 

S.C. MTH STRATEGIC MANAGEMENT S.R.L., headquartered in Bucharest, district 2, 120 Sos. Mihai Bravu, registered at the Trade Register Office attached to the Bucharest Court under no. J2015013172400, having the Fiscal Code: RO 35171240, duly represented by the administrator Mrs. Raluca Georgescu (hereinafter referred to as the “Operator”),

 

II. Our contact details

If you did not find what any regarding the protection of personal data in the information below and you have a question for us, you can write to us at the following email address: gpdr@mth.digital

 

You can send us any requests regarding the processing of personal data by mail or courier to the following address: 75-77 Buzești Street, 10th floor, Sector 1, Bucharest, 011013

We will investigate and attempt to solve any request or complaint related to the use or disclosure of your personal information.

 

If you are not satisfied with our response, you can file a complaint with the National Supervisory Authority for the Processing of Personal Data.

The information below is very important, we explain why we need certain personal data to be able to provide certain services. Please read it carefully!

You will also find here the 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 and beyond.

 

III. Relevant definitions in the context of personal data protection

 

“Personal data” = according to the GDPR, refers to any information regarding an identified or identifiable individual (“data subject”). An identifiable individual 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 one or more specific elements, specific to his physical, physiological, genetic, psychological, economic, cultural or social identity.

 

There is no list of personal data, for the simple reason that a date may become personal data in one context and simply be information without personal data value in another context.

 

As an example, we list some personal data: name, date of birth, address, email address, identity card number, IP, cookie ID, vehicle registration number, etc.

Therefore, personal data means data related to a living person who can be identified: using that data; or starting from this data and using additional information that is or may come into the possession of the data controller.

 

“Personal data processing” – refers to any operation or set of operations performed on personal data or sets of personal data, with or without the use of automated means, such as collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, disclosure by transmission, dissemination or otherwise made available, alignment or combining, restriction, deletion or destruction.

 

“Operator” = an individual or a legal entity, who determines the purpose and means of personal data processing; is the person with whom the service requester would conclude or has concluded one or more contracts.

 

“Consent” = any manifestation of free will, specific, informed and unambiguous by the data subject by which he accepts, through a statement or an unequivocal action, that the personal data concerning him be processed.

IV. Personal data that S.C. MTH STRATEGIC MANAGEMENT S.R.L. collects

The information provided directly by you, or at the time of signing a contract / order with / to S.C. MTH STRATEGIC MANAGEMENT S.R.L.

Information we obtain when you use our services (for example, we process the history of your interactions with our newsletters in order to be able to understand and limit the newsletters to those interesting you).

 

Data collected directly from you

S.C. MTH STRATEGIC MANAGEMENT S.R.L. collects personal data directly from you, usually that information is provided when signing a contract or during its performance and is processed in order to perform the contract:

 

– Name and surname, date of birth;

– Correspondence and email address;

– Telephone number;

– Details of the performed transactions, as appropriate;

 

In case we are required to file tax returns, to the extent required by law, we will request additional tax information from you. Thus, personal data such as the home address as well as other tax data the law obliges us to collect and process in connection with the transaction in question, may be necessary to be included in the tax invoice. In such case, the legal basis for processing will be the obligation to comply with the provisions of the legal regulations in force.

 

The https://www.mth.digital/ website also uses forms through which you can contact us and request various information, as well as forms through which you can subscribe to newsletters. They also include fields to  be filled in with your personal data, such as: name, email address, mobile phone number, topics of interest, etc.

We use this data to allow you access to the site and to be able to deliver the services you have chosen to receive (newsletter, responses to requests, etc.). The legal basis for this processing is the conclusion and performance of a contract to which you are a party (whenever you perform the above operations, you agree to the terms and conditions of the provision of those services).

You also have the possibility to send us a message directly from our website. The data you submit following the use of this option is processed based on our legitimate interest to respond to your request and / or to keep a record of your complaint, service request and others.

Any marketing notifications will not be sent to you unless you have previously expressed your consent for this. We also inform you that at any time you have the choice to withdraw your consent, either in the notification itself or by contacting us according to point II hereof.

 

Data collected automatically by using our website

 

In certain cases, S.C. MTH STRATEGIC MANAGEMENT S.R.L. can also collect your data by automatic means. For example, personal data may be collected through cookies when you visit our website or when you interact with our mobile applications.

 

The information we are talking about may include the IP of the device from which you are visiting us, the region or general location from which you are accessing the site, as well as the type of browser, operating system or device from which you are accessing us.

 

We use this information based on our legitimate interest to see how well the website pages meet the display needs of your particular device, to analyse trends, to see how users can better navigate our pages.

 

V. PERIOD FOR WHICH PERSONAL DATA WILL BE STORED

 

Personal data will be stored as long as necessary for the purposes mentioned above or for the period of time provided by the applicable legal provisions, including those regarding archiving.

When your personal data is no longer necessary for the purpose for which it was collected or agreed upon, nor is there any obligation or legal interest of our company to keep it, S.C. MTH STRATEGIC MANAGEMENT S.R.L. will destroy or delete it in safe way.

 

VI. TO WHOM WE DISCLOSE YOUR PERSONAL DATA

 

AFFILIATED COMPANIES

Your personal information may be disclosed to any company affiliated to S.C. MTH STRATEGIC MANAGEMENT S.R.L., if we believe it is in our legitimate interest to do so for internal administrative purposes or for auditing and monitoring our internal processes.

 

Access to your personal information is limited to those employees who have a need to know the personal information and may include employees in the marketing, sales, information technology, legal, accounting and security departments.

 

THIRD PARTY RECIPIENTS

 

We send your personal data, where strictly necessary, based on the need to know, to the following categories of recipients:

  1. Third parties who provide us with products and services (proxies), such as: accounting and HR service providers; IT systems and support providers, etc.
  2. Companies involved in the operation of our website.
  3. Other parties, such as public authorities and institutions, auditors, lawyers and other external consultants, whose activity involves the need to know this data or where the law obliges us to make this disclosure.

 

We may also disclose your data:

 

– To third parties, if you give us your consent for this disclosure;

– To people who prove that they are acting legally on your behalf.

– To respond to any complaints, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity;

– to protect the rights, property or safety of S.C. MTH STRATEGIC MANAGEMENT S.R.L., our employees, customers, suppliers or other persons.

The recipients to whom we send your personal data are limited by law or contract in their ability to use your personal data only for the purposes specifically identified by us. We will always ensure that any third parties to whom we disclose your personal information are subject to confidentiality and security obligations in accordance with their contracts and applicable laws. However, for the avoidance of doubt, this may not be applicable where disclosure is not our decision.

 

Except as expressly detailed above, we will never disclose, sell or rent your personal information to a third party without notifying you and, if applicable, obtaining your consent.

 

We also inform you that we do NOT transfer personal data to countries outside the EU or EEA, or to international organizations.

 

VII. THE RIGHTS YOU HAVE IN CONNECTION WITH THE PROCESSING OF PERSONAL DATA

The European Regulation recognizes a number of important rights for data subjects, as follows:

  1. The right to be informed – art. 13 and 14 GDPR. It allows you to know, right from the moment of collection, how that data will be used, to whom it will be disclosed or transferred, what rights you have regarding the processed data, etc.
  2. The right of access to data – art. 15 GDPR. allows you to obtain, from us, a confirmation that personal data concerning you is being processed or not and, if so, you will be able to request access to that data and other useful information.
  3. The right to rectification of data – art. 16 GDPR. allows you to obtain from us, the rectification or completion of inaccurate personal data concerning you.
  4. The right to erase data – art. 17 GDPR. allows you to obtain from us the deletion of personal data concerning you, in accordance with the legal provisions in force. However, there may be exceptions to this rule, such as if the data is processed to fulfil a legal obligation or to establish or defend a right in court.
  5. The right to withdraw consent. You have the right to withdraw your consent for the processing of certain personal data at any time. We will immediately stop processing this data and possibly delete it, if it is not associated with other processing based on another justified basis
  6. The right to restrict the data – art. 18 GDPR. It is a temporary right. In case you dispute the accuracy of personal data, the restriction operates for the period that allows us to verify the accuracy of the data. You also have the right to obtain the restriction of data processing if it is illegal and you object to data deletion; in cases where we no longer need your data for the purpose of processing, but you request the retention of the data for the establishment, exercise or defence of a right in court; for the time frame when it is checked whether the legitimate interests of S.C. MTH STRATEGIC MANAGEMENT S.R.L. prevail over your interests.
  7. The right to data portability – art. 20 GDPR. You have the right to receive the personal data that concern you and that you have provided to the operator (who processes them according to a contract or based on your consent, by automatic means) in a structured format, currently used and which can be read automatically and you have the right to send this data to another operator, without our opposition. In other words, the personal data will be provided to you, in a structured format, so that you can decide whether to download it or, on the contrary, to send it to another operator.
  8. The right to opposition – art. 21 GDPR. You have the right to object, for example, to the processing of your personal data, when it is processed for direct marketing purposes. To make it clearer how you can exercise this right, it should be mentioned, for example, that in all the newsletters received from S.C. MTH STRATEGIC MANAGEMENT S.R.L. (regardless of whether we are talking about newsletters that only provide information or newsletters that promote services or products S.C. MTH STRATEGIC MANAGEMENT S.R.L.) you will always have the possibility to unsubscribe.
  9. The right not to be subject to a decision based solely on the automatic processing of your data, including the creation of profiles that produce legal effects or significantly affect you. S.C. MTH STRATEGIC MANAGEMENT S.R.L. does not make such profiles that are 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 notice. The right to address the court or the National Supervisory Authority for the Processing of Personal Data. You have the right to complain to the ANSPDCP, respectively to address the competent courts for the defence of any rights guaranteed by the applicable legislation in the field of personal data protection, which have been breached.

 

We will try to respond to your request within 30 days and may extend this period for specific reasons related to the complexity of your request. In all cases, if this period is extended, we will inform you of the extension period and the reasons that led to it.

 

In some cases, we may not be able to search your personal data because of the identifiers you provide in the request. In such cases, where we are unable to identify you as a data subject, we are unable to comply with the request to enforce your legal rights described in this section, unless you provide additional information to enable identification. We will inform you and give you the opportunity to provide such additional details.

 

VIII. SECURITY OF YOUR DATA

Personal data are processed by S.C. MTH STRATEGIC MANAGEMENT S.R.L. in compliance with all your rights, as well as by applying appropriate technical and organizational measures to protect them against illegal or unauthorized access. These actions may consist of limiting access to data, encryption or anonymization of personal data, storage on secure media, etc.

Although we make every effort to protect the personal data you provide us, the transmission of information between you and us over the Internet is not completely secure (it is possible that the terminal from which you write may be monitored by third parties, for example, without we can do nothing in this respect). Therefore, we cannot guarantee the security of your personal information sent via the Internet. Therefore, you understand that 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.

 

IX. How the regulations on the processing of personal data apply to legal entities

The client, a legal entity, undertakes that before transferring personal data of the representative or the contact person to S.C. MTH STRATEGIC MANAGEMENT S.R.L., to obtain their consent for the processing carried out by S.C. MTH STRATEGIC MANAGEMENT S.R.L. in the contract performance and for the aforementioned data processing. By transferring the personal data of the representative or the contact person to S.C. MTH STRATEGIC MANAGEMENT S.R.L., the legal entity client certifies that he has obtained the consent of the representative / contact person for the processing of their personal data by S.C. MTH STRATEGIC MANAGEMENT S.R.L. in accordance with all of the above and undertakes full responsibility for this.

 

X. Amendment of this NOTICE

We inform you that, at any time, we can amend / update / complete the personal data processing policy. Therefore, please refer to this Information Note constantly. We will treat your personal data in a manner consistent with the privacy notice according to which it was collected, unless we have your consent to address it differently.