POLICY ON PERSONAL DATA PROTECTION (GDPR) OF SC A_BEST INTERACTIV SRL (“A_BEST FOREIGN LANGUAGE CENTRE”)

I. PREAMBLE

SC A_BEST INTERACTIV SRL is a personal data operator, registered under no. 16332/2010, in the Register of Personal Data Processing Records.

So as to provide its services, in order to fulfill its contractual obligations, as well as to fulfill its legal obligations in the matter of taxation, SC A_BEST INTERACTIV SRL processes certain personal data.

Protecting your personal data is important to us, so we pay special attention to protecting it.

From May 25, 2018, EU Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and the free movement of such data comes into force. Because we collect your personal data, we want to inform you for what purposes we use it and what are the rights you have under the General Data Protection Regulation (GDPR).

II. WHO ARE WE?

The personal data operator is SC A_BEST INTERACTIV SRL, having its registered office on 15A General Ernest Broşteanu, Room 8, District 1, Bucharest. The company is legally represented by Ms. Aura Valentina Icodin, Unique Administrator.

III. WHAT IS PERSONAL DATA?

“Personal Data” refers to any information that can identify you directly or indirectly. This means that your personal data includes information such as: your name, email address, home, mobile phone, username, your computer’s IP address, and cookies.

IV. WHAT CONSTITUTES DATA PROCESSING?

“Processing” personal data refers to any operations performed on this personal data (whether those operations are automated or not). Common types of personal data processing include (but are not limited to) collecting, recording, organising, structuring, storing, adapting, modifying, extracting, consulting, using, revealing by sharing, publishing or any other type of disclosure, combining, restricting, erasing, and destroying data.

V. PRINCIPLES OF SC A_BEST INTERACTIV SRL REGARDING DATA PROCESSING

SC A_BEST INTERACTIV SRL undertakes to observe the principles of personal data protection provided by GDPR to ensure that all data is:

  1. processed fairly, legally and transparently;
  2. collected for specified, explicit and legitimate purposes;
  3. adequate, relevant and limited in relation to the purposes for which the data is processed;
  4. accurate and up-to-date;
  5. kept in a form that does not allow the identification of the data subject for longer than is necessary in relation to the purpose of the processing;
  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

VI. WHAT DOES THE CURRENT CONFIDENTIALITYPOLICY OF SC A_BEST INCLUDE?

The current privacy policy includes matters related to:

  1. CATEGORIES OF PERSONAL DATA THAT WE COLLECT AND PROCESS;
  2. THE PURPOSES AND THE REASONS FOR WHICH WE COLLECT AND MANAGE YOUR PERSONAL DATA;
  3. PERSONAL DATA STORAGE PERIOD;
  4. YOUR RIGHTS AS A DATA SUBJECT AND THE WAYS IN WHICH YOU CAN EXERCISE THEM;
  5. TO WHOM WE MAY DISCLOSE PERSONAL DATA (DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES).

A. CATEGORIES OF PERSONAL DATA THAT WE COLLECT AND PROCESS

Your personal data that can be processed includes, as the case may be: name, surname, email address, profession, job position, fixed / mobile phone number, fax number. If personal invoicing is necessary, the CPR – number (Central personal register number) and your home address will also be processed in order to issue the invoice.

B. THE PURPOSES AND THE REASONS FOR WHICH WE COLLECT AND MANAGE YOUR PERSONAL DATA

The purposes of processing are:

  1. Providing services offered by SC A_BEST INTERACTIV

For the purpose of concluding and executing contracts – According to Article 6 (1) (b) of the GDPR, personal data may be processed for the purpose of concluding or executing the contract. We use your personal information to provide you with the requested services. We rely on the legitimate interest in providing our services, depending on our field of activity and the business relationship we have establised with you.

  1. Communicating with you

We use the contact information to communicate with you about the activities of SC A_BEST INTRERACTIV SRL and any other relevant aspects of the collaboration or possible collaboration between us. We also rely on the legitimate interest in providing our services, according to our field of activity.

  1. Processing of data as a requirement imposed by law

For the purpose of fulfilling legal obligations – According to Article 6 (1) (c) of GDPR, personal data may be processed for the purpose of fulfilling legal obligations. Thus, we request a series of personal data to fulfill our obligations imposed by tax authorities on invoicing and reporting to tax authorities

  1. Sending newsletters and emails

We may also use your contact information to provide you with electronic newsletters about our services, as well as about our events, competitions and/or raffles. This will be done in full compliance with the new Regulation, only if you have subscribed and have expressed your direct consent to such processing. You can withdraw your consent at any time by choosing the option of not receiving newsletters in the future by pressing the “Unsubscribe” button when you receive the email or you can request this by sending an email to data.protection@abest.ro.

C. PERSONAL DATA STORAGE PERIOD 

SC A_BEST INTERACTIV may retain the data processed for different periods of time deemed reasonable for the purposes indicated above to meet your needs or to fulfill our statutory obligations.

D. YOUR RIGHTS AS A DATA SUBJECT AND THE WAYS IN WHICH YOU CAN EXERCISE THEM

According to GDPR, you have a series of rights with respect to the personal data that SC A_BEST INTERACTIV processes:

  1. The right of access – You have the right to access the personal data we have pertaining to you.
  2. The right to rectification – You have the right to ask for your personal data to be rectified if it is inaccurate or obsolete and/or to fill it in if it is incomplete.
  3. The right to erasure (‘the right to be forgotten’) – In some cases, you have the right to obtain the deletion or destruction of your personal data. This is not an absolute right, because sometimes we may be forced to retain your data for legal or judicial reasons.
  4. The right to restrict processing – You have the right to request restriction of your data processing. This means that your data processing is limited, so we can keep the data, but not use or process it. This right applies only under specific circumstances, provided for in the General Data Protection Regulation.
  5. The right to data portability – You may move, copy or transfer the data you are interested in from our database to another. This applies only to the data you have provided when processing is based on your consent or contract and is implemented by automatic means.
  6. The right to object – You may at any time oppose the processing of your data when such processing is based on a legitimate interest.
  7. The right to withdraw consent at any time – You can withdraw your consent to the processing of your data when such processing is based on consent. Withdrawal of consent does not affect the lawfulness of processing on the basis of consent prior to its withdrawal.
  8. The right to lodge a complaint with the competent supervisory authority – You have the right to complain to the data protection authority in your country of residence or domicile to challenge the data protection practices of SC A_BEST INTERACTIV SRL.
  9. The right to oppose processing of your data for direct marketing purposes – You can unsubscribe or renounce our marketing communication at any time.

You may exercise any of these rights with respect to the personal data that SC A_BEST INTERACTIV SRL processes by submitting a written request to our company’s secretariat or by sending an email to data.protection@abest.ro. In such situations, we may request proof of your identity. 

E. TO WHOM WE MAY DISCLOSE PERSONAL DATA (DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES)

Personal data processed by SC A_BEST INTERACTIV SRL may be disclosed and/or transferred to third parties only if you have given your express consent to doing so, unless there is a legal/contractual obligation for SC A_BEST INTERACTIV SRL to do this.

Thus, we access, store and provide your data to regulatory authorities, law enforcement or other entities when the law so requires.

VII. PROCESSING SECURITY

SC A_BEST INTERACTIV SRL has adopted technical and organizational data processing measures, updated in accordance with GDPR requirements, to protect your personal data from any unauthorized access, improper use or disclosure, unauthorized modification, destruction or accidental loss. All employees and collaborators of SC A_BEST INTERACTIV SRL, as well as any third parties acting in the name and on behalf of SC A_BEST INTERACTIV SRL are under the obligation to respect the confidentiality of your information and the GDPR requirements, in accordance with the provisions of this Regulation.

VIII. LIABILITY EXONERATION

  1. SC A_BEST INTERCTIV SRL does not assume responsibility for the accuracy of the data provided by the users via the registration form on www.abest.ro. SC A_BEST INTERCTIV SRL understands that, instead, it has the obligation to manage the personal data provided, only for the specified purposes. SC A_BEST INTERACTIV SRL will use the information you provide in the appropriate contact section, available on the website (www.abest.ro), solely for the purpose of processing your request. By providing any personal data through the abest.ro website, understand and agree that your data will be processed in accordance with the provisions of this Regulation.
  2. The website www.abest.ro may contain links to other websites and/or other web pages that are not the property of SC A_BEST INTERACTIV SRL. SC A_BEST INTERACTIV SRL assumes no responsibility for the content of these websites and therefore can not be held responsible for the content, advertising, goods, services, software, information or other materials available on or through these websites. SC A_BEST INTERACTIV SRL will not be responsible for the loss of personal data, any negative effects on visitors’ personal data or other moral and/or patrimonial damage caused as a result of accessing those websites.

IX. DATA PROTECTION AND PROCESSING POLICY UPDATE 

This Regulation may be subject to periodic content changes. Therefore, we recommend that you check this page to be up to date with the updates made.

X. CLARIFICATIONS

The terms of this GENERAL DATA PROTECTION REGULATION (GDPR) shall be interpreted in accordance with the applicable law.

If you have any questions or wish to exercise any of your rights, please send us a written request using the following contact details: 15A General Ernest Broșteanu Street, Room 8, District 1, Bucharest or data.protection@abest.ro.

We will ensure that appropriate measures are taken to respond to your request without undue delay within 30 (thirty) days of receipt of your request. Information will be provided electronically, if possible, unless expressly requested in writing.

Date of last update: 23.05.2018.