IPSO SRL, whose registered office is at Mogosoaia, sos. Bucuresti - Targoviste nr.174D, jud. Ilfov (hereinafter „Society” or „ "We„), as an independent data controller, would like to inform you about the processing methods (e.g. collection, use si sharing) your personal data through this website (hereinafter referred to as „Website„) sand the use of associated services such as [Google Ads, Facebook Ads, tawk.to] (hereinafter referred to as „Services”), in accordance with the laws si applicable regulations on the protection of personal data, in particular: (i) Regulation (EU) 2016/679 of 27 April 2016 (hereinafter referred to as „GDPR„), which entered into force on 25 May 2018; (ii) any other legislation applicable in Romania; si (iii) any other legislative enactment, decree, regulation or provision that would be adopted by a competent national or European supervisory authority (hereinafter collectively referred to as „Applicable data protection regulations„).

The company is an entity of MONNOYEUR, a French corporate group, with its parent company located in France, Sainte-Denis, Str. Charles Michels, 117 - 93200.

1.     What is the scope of this policy?

The Company processes personal data (i.e. any information relating to an identified or identifiable person, referred to as „Person concerned„) concerning you, processed through the Website si for using the Services, subject to the conditions set out in this policy („Privacy Policy„).

This Privacy Policy as well as the Cookie Policy, available here (https://www.ipso.ro/politica-de-cookie-uri/), covers all users, including those who use the Website and the Services without being registered or subscribed to a particular service (hereinafter collectively referred to as „Users„).

2.     What types of personal data do we collect?

The Company collects (1) personal data that you have voluntarily shared with the Company and (2) personal browsing data related to your access and use of the Website and Services. In particular, the Company collects the following information:

–          Personal data you voluntarily share with the Company: The Company may collect your personal data (by e.g. first name, surname, e-mail address, address, telephone number etc.) when you submit a request through an online form on the Website or when you use our Services;

–          Navigation dataWhen you access and use the Website or Services, the Company may collect information about those visits. For example, in order to establish your connection to the Website or Services, our servers receive and record information about your visits to the Website or Services.https://www.ipso.ro/politica-de-cookie-uri/).

–          Third party services: The Services may be associated with the websites of third party companies that are not affiliated with the Company and may include advertising, online content and features, games, newsletters, contests or sweepstakes or applications developed by third party companies. Company is not responsible for the privacy practices of these third party companies. After you leave the Services and/or Website or click on an advertisement, it is your responsibility to check the applicable privacy policy for that other service.

3.     For what purposes do we collect your personal data?

We process your personal data:

a) To enable you to use the Website and the Services;

b) To evaluate and improve our Services and the functionality of the Services;

c) To improve your experience using the Website and the Services;

d) To assist customers and answer your questions;

e) To serve the interests of the Company; in certain cases, the Company may disclose your personal data, including where the Company believes in good faith that such processing is necessary to: (i) protect, exercise or defend the rights, privacy, safety, security or property of the Company or its employees, agents and contractors (including the performance of our contracts and terms and conditions of use); (ii) protect the safety, privacy and security of users or the public; (iii) protect against fraud or for risk management purposes;

f) Comply with legal obligations (including obligations related to service provision and consumer information) or respond to requests from public and governmental authorities;

g) To provide goods and/or services to you under a contract;

h) Subject to your consent, to send you messages of a commercial nature and/or our newsletter and to share your personal data with our trusted business partners, including other MONNOYEUR entities, to enable them to send you messages of a commercial nature.

4.     On what legal basis do we process your personal data?

- The purposes of processing set out in sections 3(a) to 3(e) and in section 3(g) of this Privacy Policy are, in principle, based on the legitimate interest of the data controller for the purposes of operating the Website, responding to Users' requests and providing the Services.

As an exception: if you log in to a personal account/customer area of the Website under a service contract with the Company, the processing of personal data in this personal account is based on the contract you have with the Company.

- The purpose of processing, as set out in section 3 (f) of this Privacy Policy, is based on applicable legal and regulatory obligations;

- The purpose of the processing set out in section 3 (h) of this Privacy Policy is carried out on the basis of your consent, if required.

5.     How long is your personal data kept?

The Company retains your personal data for as long as necessary for the fulfilment of the purposes described in section 3 above.

Your personal data is stored:

- For the time strictly necessary for the use of the Website, the Services or for the needs of the Company, and for a maximum period of 3 years from the date of collection, in the absence of a contract with the Company for marketing purposes;

- In the event of the conclusion of a contract or an order, within the framework of the Services or otherwise, for the entire duration of the contractual relationship, then kept in intermediate archives for a period corresponding to the possible warranty period, plus the applicable general legal limitation period (of 3 years);
- For data processed by the Company in order to comply with legal obligations, for the period necessary for the fulfilment of these legal obligations.
- Until withdrawal of consent, in the case of data processed on the basis of your consent.
- For the required period as set out in the Cookie Policy available here (https://www.ipso.ro/politica-de-cookie-uri/).

6.     How do we process your personal data?

Personal data is processed both manually and electronically and is protected by appropriate security measures. In this respect, although the Company uses appropriate administrative, technical and organisational measures to protect personal data against theft, loss, unauthorised use, disclosure or alteration, it cannot guarantee that it will be able to protect against all existing IT risks.

7.     Who has access to your personal data?

For the purposes of the processing outlined in Section 3 of the Privacy Policy, your personal data is communicated internally within the Company, to the Customer Service, Marketing/Commercial and Communications departments. The Company may also communicate your personal data to the following recipients:

- Other MONNOYEUR entities;

- Third-party service providers, subcontractors (e.g. IT service providers, service providers related to the Services - for illustrative purposes and without this list being exhaustive, experts, consultants and lawyers, companies involved in potential mergers, divisions or other transformations);

- Competent national authorities: in order to comply with the legislation in force, as well as any administrative or judicial authority which might request it or which should have access to it in the context of a possible control or litigation.

- Trusted business partners

8.     Is your personal data transmitted abroad?

Your personal data may be transferred to other MONNOYEUR entities and service providers acting on its behalf and located in the European Union.

We will not transfer personal data to countries outside the EEA.

9.     Minors under 16

The Website does not target or offer Services to persons under the age of 16, and the Company does not knowingly collect personal data from persons under the age of 16 or from minors in general.

10.   What security measures are applicable?

The Company shall implement all appropriate technical and organisational security measures to ensure a level of security of personal data appropriate to the risk and, in particular, to protect data against accidental or unlawful destruction or accidental loss, accidental or unlawful alteration, loss, damage, unauthorised disclosure or access.
The same level of protection is contractually imposed by the Company on all its subcontractors. Any employee of the Company who, in the performance of his or her duties, may have access to your personal data undertakes to hold them in strict confidence.

11.   What are your rights regarding your personal data?

In accordance with the applicable Data Protection Regulations, depending on the situation, you have the right to request access, rectification, erasure and portability of your personal data and to request restriction or object to the processing of your personal data, as well as to withdraw your consent at any time. You can exercise these rights by writing to the following e-mail address: dpo@monnoyeur.com

However, you are advised that your objection may, in practice and on a case-by-case basis, affect or make it impossible to consider your enquiry, registration or use of the Services offered on the Website.

You also have the right to lodge a complaint against a supervisory authority, such as the National Supervisory Authority for Personal Data Processing in Romania, in the event of a breach of the applicable Data Protection Regulations.

12.   Changes and updates

We keep our Privacy Policy under regular review and will place any updates on this web page.

This Privacy Policy was last updated on - March 2021.

13.   Data Protection Officer

The Company has appointed a Data Protection Officer („DPO”) whom you can contact for any questions related to the processing of your personal data and to exercise your rights.

Mogosoaia, sos. Bucuresti - Targoviste nr.174D, jud. Ilfov, dpo@monnoyeur.com.