Privacy Policy – CONSIERGO

Personal Data Privacy Policy

This privacy policy applies between you, the User of this Website and CONSIERGO, the owner and provider of this Website. CONSIERGO takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

Please read this privacy policy carefully.

DEFINITIONS

In this privacy policy, the following deﬁnitions are used:

Data	collectively all information that you submit to CONSIERGO via the Website. This deﬁnition incorporates, where applicable, the deﬁnitions provided in the Data Protection Laws
Personal data	any information relating to an identified or identifiable natural person (Data Subject)
Data Subject or Identifiable natural person	an identifiable natural person is one 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 factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
Processing	any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
Controller	the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law
Processor	a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller
Recipient	a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not
Consent	any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her
Cookies	a small text ﬁle placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies)
Data Protection Laws	any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the EU;
GDPR	the General Data Protection Regulation (EU) 2016/679;
CONSIERGO, we or us	a company incorporated in Romania whose registered office is at Baneasa Residential zone, 147 Erou Iancu Nicolae street, Voluntari
User or you	any third party, individuals that accesses the Website
Website	the website that you are currently using, CONSIERGO.RO, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

SCOPE OF THIS PRIVACY POLICY

This privacy policy applies only to the actions of CONSIERGO and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

For purposes of the applicable Data Protection Laws:

CONSIERGO is a Controller in relation to the personal data processed in its internal processes. This means that CONSIERGO determines the purposes for which, and the manner in which, your Data is processed;
CONSIERGO is a Processor in relation to the personal data processed on behalf of its Clients, in order to fulfill its contractual and business obligations. This means that CONSIERGO will process the personal data only on documented instructions from the Client (i.e. Controller).

WHO ARE THE DATA SUBJECTS INVOLVED IN OUR DATA PROCESSING?

This Policy applies to the processing of the personal data of the following persons:

visitors and users of the CONSIERGO site, www.consiergo.ro (“Users”);
contact persons, legal or conventional representatives, employees, employees or individuals designated by a contractual partner of CONSIERGO;
candidates applying for a job at CONSIERGO.

WHAT TYPES OF PERSONAL DATA ARE COLLECTED AND PROCESSED?

CONSIERGO processes the data you provide us directly, as well as the data that is subsequently generated based on them. We collect your data when you use the CONSIERGO site when you contact us by e-mail via the “Contact” page on www.consiergo.ro, as well as part of the contractual relationship you have with CONSIERGO.

The information you provide may include the name, surname, e-mail address, telephone number, IP address (automatically collected), as well as other information as appropriate.

HOW WE COLLECT DATA?

We collect Data in the following ways:

data is given by you to us;
data is received from other sources; and
data is collected automatically.

Data that is provided by you to us:

CONSIERGO will collect your Data in a number of ways, for example:

when you contact us through the Website, by telephone, post, e-mail or through any other means;
when you register with us and set up an account to receive our services;
when you apply for an open job position in our company.

Data that is received from other sources:

CONSIERGO may receive Data about you from the Business Partners we work with.

Data that is collected automatically

To the extent that you access the Website, we will collect your Data automatically, for example:

we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, related to “Cookies“.

LEGAL BASES AND PURPOSES OF PROCESSING PERSONAL DATA

Processing personal data of visitors and users which access our website:

When you make requests on the Contact page of our website, or when you call us at 021-319.09.93, we will use the personal data you provide to us (your name, your email address or other personal data provided in the body of the message or telephone communications) to respond to any requests you make to us. This processing is based on our legitimate interest in knowing the person to whom the response is to be addressed.

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Processing personal data of representatives of CONSIERGO contractual partners:

This Policy applies when CONSIERGO processes personal data of legal or conventional representatives, contact persons, employees, or other natural persons designated by CONSIERGO’s contractual partners.

These personal data are provided directly by the contractual partner in the documents submitted to CONSIERGO upon the start of the contractual relationship or during the course of the contract.

The legal purposes and underlying grounds on which CONSIERGO processes the personal data of the individuals concerned are as follows:

fulfillment of the legal obligations incumbent on CONSIERGO in the context of the contractual relationship;
the fulfillment of CONSIERGO legitimate interest in the context of the CONSIERGO business. Storing and processing this information can give us a more profound understanding of the consumers’ needs or the way in which Consiergo can improve the quality of its offered products or services.

Processing personal data of candidates which apply for a vacant job at CONSIERGO:

In connection with the participation of a candidate in the recruitment and selection process for a CONSIERGO job, CONSIERGO will process the personal data provided directly by the person concerned through the resume, referral letters and / or referrals.

The data processing of the data subject is carried out for the purpose of assessing professional competences as well as communicating with the candidate during the recruitment process.

This processing is based on the demarches at the request of the candidate before the conclusion of the individual labor contract, according to art.6 paragraph (1) letter b) of GDPR.

IS THE PROVISION OF PERSONAL DATA MANDATORY?

When we request personal data to comply with legal or contractual obligations or to fulfill our legitimate interest, the provision of such personal data by you is mandatory. This means that if such personal data is not provided, we will not be able to manage contractual relationships, comply with the legal obligations imposed on us, or provide you with our services under optimum conditions.

When process personal data based on your consent, the provision of required data is not mandatory, but refusing to provide it may lead to the inability to provide you with certain particular services.

WITH WHOM WE SHARE THE PERSONAL DATA WE COLLECT?

CONSIERGO will not transmit (by selling or lending) to any third party your personal data.

In CONSIERGO, only a limited number of staff members have access to your personal data, on a need-to-know basis. CONSIERGO staff members have the right to manage personal data only on the basis of the instructions given by CONSIERGO regarding their job responsibilities.

Personal data may be communicated to governmental authorities, tax authorities and / or law enforcement agencies, if required by applicable law, or if necessary for the exercise of our rights, including conditions of use, or for the protection of our legitimate interests (including the legitimate interests of third parties) in accordance with the applicable laws.

Your personal data may also be disclosed to third parties as follows:

To business partners, suppliers and subcontractors for the execution of all the contracts we conclude with them in order to provide the services requested by them;
To service providers providing administrative, professional and technical support to CONSIERGO;
To external consultants (i.e. lawyers, accountants, auditors) for specific purposes, when needed.

CONSIERGO performs an appropriate prior assessment of the selection of third party service providers and requires these service providers to maintain adequate technical and organizational security measures to protect personal data and process personal data only in accordance with the instructions specified by CONSIERGO. Service providers will be entitled to use subcontractors to provide services to CONSIERGO, provided that each subcontractor respects the same data protection obligations as service providers.

WHAT IS THE PROCESSING PERIOD FOR PERSONAL DATA?

In order to meet the processing purposes outlined above, personal data will be processed during the contractual relationship with CONSIERGO and, after termination, for the period required by applicable law, including but not limited to the applicable legal minimum filing periods and / or as long as it is necessary to exercise our legitimate rights.

Regarding the data collected through the Contact form, we will keep it for as long as you agree to request consierge services from us.

If you are a candidate for one or more of our CONSIERGO jobs, we will keep your personal data throughout the recruitment and selection process. If the candidate was not employed by Consiergo, the data may be retained for a period of 12 months from the date on which the application for employment was filed but only with the consent of the candidate.

WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?

Under the Regulation on the processing of personal data, you have the following rights regarding the personal data that belongs to you:

Right to be informed

You have the right to receive information about CONSIERGO’s personal data processing activities.

Right of access to your personal data

Upon your request, we will confirm that we process your personal data and, if so, we will provide you with a copy of your personal data processed in CONSIERGO as well as the following information:

the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their source;
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

The first copy of your personal data is provided free of charge. For additional requests, we may charge a reasonable additional charge, taking into account the related administrative costs.

Right to rectification of your personal data

If the data we hold about you is inaccurate or incomplete, you have the right to correct or fill it out. You can make a request in this regard, and we will perform the necessary operations to fullfil your request.

Unless this proves impossible or involves disproportionate efforts, we will notify each recipient to whom your personal data has been disclosed of your rectification request. Upon your request, we will inform you of those recipients.

Right to erasure („right to be forgotten”)

You may ask us to delete your personal data and we will respond to your request without undue delay if one of the following situations applies:

the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
the personal data have been unlawfully processed;
the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).

We reserve the right to refuse to delete your data when processing is required for:

for exercising the right of freedom of expression and information;
for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
for the establishment, exercise or defence of legal claims.

Right to restriction of processing

You may ask us to block and restrict the processing of your personal data if one of the following situations below applies:

a) the accuracy of the personal data is contested by you – in this case, at your request, we will restrict the processing of your personal data for the period needed by us to perform the necessary checks in order to verify the accuracy of your data;
b) the processing is unlawful and you oppose to the erasure of the personal data and request the restriction of their use instead;
c) we no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
d) You oppose your processing of your data based on our legitimate interest, including the creation of profiles based on this basis – in this case, at your request, we will restrict the processing for the period we verify that our legitimate rights do not prevail over your rights.

If the processing of your personal data has been restricted, we will only be able to store your data, but no longer process it. Any other way of processing, excluding storage, will only be done:

After obtaining your consent;
For exercising or defending a right in court;
To protect the rights of another natural or legal person;
For reasons of public interest of the Union or of a Member State.

We will inform you before lifting any processing restriction as set out above.

Right to object

You may request that we do not further process your personal data for reasons relating to your particular circumstances and whether your processing of your data is based on our legitimate interest. We will cease processing your data unless we demonstrate that we have legitimate and compelling reasons that justify processing and that prevail over your interests, rights and freedoms, or whether the purpose of the processing is to establish, exercise or defend a right in court.

Right to data portability

You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

the processing is carried out by automated means, and
the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1).

Right to file a complaint to the National Supervisory Authority for Personal Data Processing

You may lodge a complaint to the National Authority for the Supervision of Personal Data Processing (ANSPDCP), if the you consider that the processing of personal data relating to you infringes the GDPR.

Right to withdraw consent

When processing of your personal data is based on consent, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Right to a judicial remedy

Without prejudice to any other administrative or non-judicial remedy, each natural or legal person shall have the right to an effective judicial remedy against a legally binding decision of a supervisory authority concerning them.

HOW CAN YOU REQUEST YOUR RIGHTS?

Submitting a request to exercise one or more of your rights. In order to exercise one or more of the rights described above, you can address CONSIERGO with a written, dated and signed request at CONSIERGO Headquarters in Baneasa Residential zone, 147 Erou Iancu Nicolae street, Voluntari, Romania or e-mail us at: office@consiergo.ro . Any request made by you will be processed properly by us.

Identifying you. In order to be able to properly manage your request, we have the urge to identify you as fully as possible. As long as we have reasonable doubts as to the identity of the applicant, we will ask for further information to confirm your identity.

Response time. We will respond to your requests without undue delay, and in any case within one month of receipt of the request. Insofar as your application is complex or we are in a position to process a large number of requests, we may reasonably postpone the delivery of your response for up to two months at your prior notice.

Providing the answer. We will provide you with our response and any requested information in electronic format, unless you request them to be provided in another format.

Refusal. In so far as we refuse to meet your request, we will inform you of the reasons which led to such a decision and of your possibility of submitting a complaint to ANSPDCP and of introducing a judicial remedy.

Taxes. Exercising your rights as a data subject is free. However, to the extent that your claims are manifestly unfounded or excessive, especially in the light of their repetitiveness, we reserve the right to levy a fee or refuse to meet the request.

CONFIDENTIALITY AND SECURITY OF PERSONAL DATA

CONSIERGO pays special attention to personal data and ensures privacy and data security throughout its processing. CONSIERGO implements technical and organizational measures to protect against unauthorized or unlawful processing and against loss, destruction or accidental damage.

Monitoring compliance with legal requirements in the field of personal data protection is ensured by CONSIERGO. CONSIERGO has contractual relations with third parties that have undertaken obligations regarding the confidentiality and organizational and technical security of personal data.

TRANSFERS OUTSIDE THE EUROPEAN ECONOMIC AREA

Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. We also share information with our group companies, some of which are located outside the EEA.

We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, e.g. by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission, or by signing up to the EU-US Privacy Shield Framework, in the event that the Organisation in receipt of the Data is based in the United States of America.

To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

SENSITIVE DATA COLLECTION

As part of your interaction with us, on both the company’s website and during the contractual relationship with CONSIERGO, we will avoid processing personal sensitive data related to you (e.g. information about racial or ethnic origin, political opinions, religious confession, or philosophical beliefs, health, sexual life, or sexual orientation).

CONFIDENTIALITY OF CHILDREN’S PERSONAL DATA

Our website does not knowingly collect personal identification data from persons under the age of 16. If the parent or legal guardian is aware that the child in custody has provided his personal data to www.consiergo.ro, he should immediately inform CONSIERGO at e-mail office@consiergo.ro . If we find that a person under the age of 16 has provided personal data via the www.consiergo.ro website, then we will destroy this information from our servers immediately, unless the parent or guardian gives his explicit consent to the site’s processing of the child’s personal data for the specified purposes.

LINKS TO OTHER WEBSITES

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them

COOKIES

The www.consiergo.ro site uses cookies to provide a better experience when using the CONSIERGO site. This data processing is based on the consent of the site visitor, expressed directly on the site or through browser settings. More information about cookies can be found in the Cookie Policy, which is available on the CONSIERGO website.

HOW CAN YOU CONTACT CONSIERGO?

For any uncertainty or additional information regarding the processing of personal data carried out by CONSIERGO, or for the exercise of the rights you are entitled to as a data subject, you may address CONSIERGO in the following ways:

By submitting a written, dated and signed application, to CONSIERGO, Headquarters Baneasa Residential zone, 147 Erou Iancu Nicolae street, Voluntari, Romania
By email at the address office@consiergo.ro

CHANGES TO THIS PRIVACY POLICY

CONSIERGO reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

Personal Data Privacy Policy

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