Starckrom Tehnologii S.R.L. (hereinafter referred to as "Starckrom" or "Operator"), a Romanian legal entity, headquartered in Bucharest, Str. Presei No. 5, Apt. 1, Sector 1, registered with the Trade Register of Bucharest under no. J40/5910/2003, unique registration code RO15400498, hereby informs you about this Privacy Policy as to explain how we process and protect personal data as the Operator responsible for the processing of personal data within the meaning of the GDPR Regulation.

1. DEFINITIONS:
   • Data Protection Officer (DPO) contact details = Address to which requests for information regarding the processing of personal data can be sent: Str. Ing. Zablovschi no. 21, Sector 1, Postal Code 011311, Bucharest - for the attention of the DATA PROTECTION OFFICER or to the e-mail address: dpo@starckrom.com.
   • Cookies = A "cookie" is a small digital file, usually made up of letters and numbers. It is downloaded into the memory of a computer or other type of device used for browsing the internet (smartphone, tablet, etc.), when the user accesses a particular website.
   • Data subject, within the meaning of the GDPR Regulation = an identified or identifiable natural person (who can be identified, directly or indirectly, in particular by reference to an identifier: name, NPC, identification number, location data, an online identifier, or to one or more specific elements specific to his or her physical identity). The data subject may be the applicant for a service offered by the Operator, as well as any other natural person whose personal data are transmitted to the Operator (for example, a client or potential client, a candidate for a specific available position, a user of the Starckrom website, etc.).
   • Categories of processed data = Personal data (first name, last name, employer name, position held, telephone number and e-mail address, etc.) are processed by us only if you enter this data in a field on the site or send it to us by phone or e-mail.
   • Processing of personal data means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automatic 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.
2. TO WHOM THIS DOCUMENT CONCERNS: This Information Notice applies to the processing of personal data belonging to:
   • Our contractual partners, such as representatives of suppliers or customers (“Business Partners”);
   • Visitors and registered users of our website starckrom.com and other sites in the same domain (“Users”);
   • To natural persons who communicate us their personal data in the context of their interaction with Starckrom, such as visitors or persons requesting information, commercial offers or concluding a contract, persons registered as users of an online service offered by Starckrom ("Users") or participants applying for a job within a recruitment process.
3. WHAT DATA WE COLLECT ABOUT YOU AND HOW WE ARE DOING THIS: We collect and process your personal data as follows:
   • in the information you provide to us by filling out the form on the Contact page on our website;
   • by communicating with us by phone, email or in any other way in which you transmit personal data to us;
   • by browsing the websites within the domain starckrom.com;
   • by registering as a user on websites within the domain starckrom.com

The information you provide to us may include your full name, employer name, position/job title, email address and telephone number, as well as other information, as applicable.

Through the activity carried out on the site, we will not collect or process sensitive personal data related to you (i.e. information about racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual life or orientation, trade union membership or data regarding criminal convictions or offenses), unless we are required to do so by the Romanian and EU law.

Every time you visit the website www.starckrom.com, we automatically collect the following data:

• technical data, for example the Internet Protocol (IP) address used to connect your computer to the internet, login information, browser type and version, browser extension (plug-in) types and versions, operating system, device type and mobile device brand; this data is collected and processed on our behalf, through third-party cookies and you can find more information about this in the Cookies Policy section;
• data related to your visit, for example data about the pages you have visited, the sequence of clicks to, through and from the starckrom.com website (including date and time), the information or products you viewed or searched for on the website.

4. FOR WHAT PURPOSE DO WE PROCESS PERSONAL DATA: We may process your personal data in the following cases:
   • within the purposes of customer relationship management activities
   • as part of regular marketing activities targeting existing or potential customers, including improving the browsing experience on sites in the starckrom.com domain
   • within the framework of relationship management with business partners and suppliers, in order to establish or execute a contractual relationship
   • in the context of the activities of selling products or services / data through online store(s)
   • if you are applying for an available job published on a specialized website

In some cases, we will process your personal data only on the basis of your consent (for example for marketing purposes). In these cases, we will separately request your consent, in a transparent manner, when you provide your personal data and the agreement to receive communications. You can subsequently withdraw this consent at any time by automated means made available within the marketing meessage or by sending a request to the e-mail address dpo@starckrom.com. The withdrawal of consent will not affect the lawfulness of the processing that took place before its withdrawal.

When we request personal data to comply with legal or contractual obligations, 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 or comply with legal obligations imposed on us or voluntarily assumed by us. In all other cases, the provision of personal data is optional and you are not obliged to provide it.

We may process your personal data, such as identification data, contact details and residential address, for the purpose of the possible exercise of our rights or claims against you in the future. This processing is based on our legitimate interest, as it is necessary to exercise our rights in the event of potential disputes.

We may process personal data to provide you with information about or in connection with goods and services that you have previously purchased or that we believe you may be interested in. If you are an existing customer, we will only contact you by email with information about goods and services that have been the subject of a previous sale or with information about the main news in the field, through the weekly newsletter.

If you are a potential customer, we will contact you by electronic means only if we have your explicit consent. We may transmit certain personal data strictly necessary to satisfy your request (contact details) to external partners in order to satisfy as completely as possible any requests for quotation or technical support from you that require details that we cannot provide directly and promptly.

In connection with your participation in the recruitment and selection process for one of the positions mentioned as available, within Starckrom Tehnologii S.R.L., we may collect and process your personal data (provided in the CV you send us), for the purpose of selection, assessment of professional skills for the position you are applying for, as well as for communication with you, during the recruitment process.

This processing is based on the legitimate interest of Starckrom Tehnologii S.R.L.

5. TRANSMISSION OF PERSONAL DATA TO THIRD PARTIES: Starckrom Tehnologii S.R.L does not sell or rent your personal data to third parties. Your personal data may, however, be disclosed to third parties under the following circumstances:
   • To business partners, suppliers or subcontractors for the execution of all contracts we conclude with you, in order to provide the products and services requested by you;
   • For the delivery or collection of physical products, to companies specialized in courier services;
   • To service providers who provide administrative, professional and technical support to Starckrom for technical, IT, security and commercial support;
   • To external consultants (i.e. lawyers, auditors, debt collection firms), for specific purposes, when necessary.

Personal data may be communicated to government authorities, tax authorities and/or law enforcement bodies, if this is required by applicable laws or if necessary for the exercise of our rights, including the terms of use, or to protect our legitimate interests (including the legitimate interests of third parties) in accordance with applicable Romanian and international law.

6. PERSONAL DATA RETENTION PERIOD:

We will retain your personal data for the period necessary to fulfill the purposes listed in this Policy or for the period required by applicable national law, in accordance with applicable minimum legal retention periods and/or as long as necessary to exercise our legitimate rights (and the legitimate rights of others).

If you are a user of a site in the starckrom.com domain (you have created a user account on the site), we will retain your personal data for the period in which the user account is active.

If you are subscribed to newsletter-type electronic communications, we will retain your personal data for as long as you wish to receive these communications.

7. YOUR RIGHTS AS A DATA SUBJECT WITH REGARD TO THE PROCESSING OF PERSONAL DATA PROVIDED: According to the GDPR Regulation, as a data subject you benefit from a set of rights, namely:
   1. Right to information and access to personal data: the right to obtain confirmation of whether or not personal data concerning you is being processed and, if so, access to that data.
   2. Right to rectification: the right to request from the Operator and further to obtain, without undue delay, the rectification of inaccurate personal data concerning you, and/or to obtain the completion of incomplete personal data, with the mention that in the case of an online account you can make these changes yourself from the account management and editing section.
   3. Right to erasure ("right to be forgotten"): the right to obtain the erasure of personal data concerning you, without undue delay, where certain reasons mentioned in the GDPR Regulation apply.
   4. Right to restriction of processing: the right to obtain restriction of processing in certain cases.
   5. Right to data portability: the right to receive personal data concerning you and to transmit it to another controller.
   6. Right to object: the right to object at any time to the processing of personal data concerning you, under the terms of the GDPR Regulation.
   7. The right of not being subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
   8. The right to file a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP) if you consider that your data has not been processed in accordance with the legal provisions.

To exercise the above mentioned rights, please send a written, dated and signed request to the postal address: Str. Ing. Zablovschi no. 21, Sector 1, Bucharest, for the attention of the DATA PROTECTION OFFICER, or by contacting us at the e-mail address dpo@starckrom.com.

Within a maximum of one month from the receipt of your request, you will be provided with information on the actions taken or, where applicable, on the reasons why the requested measures cannot be taken.

Please note that your rights described above are subject to applicable data protection laws and regulations and may be limited in certain situations. For example, the right to object to the processing of your personal data may be limited where we can demonstrate that we have compelling legitimate grounds for processing your personal data which override your interests. You will need to prove your identity and provide us with other reasonable details to enable us to respond to your request.

We will not charge a fee to respond to your request unless permitted by law, and if such a fee is charged, it will be reasonable and proportionate to your request.

Also, according to the GDPR Regulation, the response deadline mentioned above may be extended by a maximum of two months if necessary, taking into account the complexity and number of requests, and we will inform you about this aspect, if necessary.

8. SECURITY OF PERSONAL DATA PROVIDED:

Your personal data transmitted to Starckrom is stored on servers hosted in data centers located in Romania. We use best practices to ensure appropriate technical and organizational measures to protect personal data and prevent unauthorized access to it.

However, you are responsible for maintaining the confidentiality of all authentication means (e.g. username, passwords, etc.) used by you to access parts of the starckrom.com website. Data transmission over the Internet is not completely secure. Although we do our best to protect your data, we cannot guarantee 100% security of your data transmitted to our website; any transmission of personal data is at your own risk. Once we receive your data, we will use strict security procedures to try to prevent unauthorized access to it.

9. COOKIES:

Site-ul www.starckrom.com utilizează fișiere de tip Cookie pentru a vă oferi o experiență de navigare mai bună. Informații mai detaliate despre fișierele de tip cookie și despre opțiunile pe care le aveți cu privire la acestea le găsiți la linkul Cookies Policy.

10. CONTACT:

Pentru întrebări, nelămuriri sau solicitări de altă natură privitoare la prelucrarea datelor cu caracter personal de către situl www.starckrom.com, ne puteți contacta la adresa de e-mail dpo@starckrom.com.

Vă rugăm să nu divulgați date cu caracter personal sensibile atunci când ne contactați (de exemplu numere de asigurare socială, parole personale, informații legate de conturi bancare, informații legate de originea rasială sau etnică, de opinii politice, de convingeri religioase sau de altă natură, de sănătate sau de apartenență la un sindicat).

Ultima actualizare: 14 mai 2020. Vom putea actualiza periodic această politică de confidențialitate. Modificările vor fi publicate pe site-ul starckrom.com. Vă rugăm să consultați periodic această pagină pentru a fi la curent cu cele mai recente actualizări.