Privacy Policy

www.energobit.com

ENERGOBIT S.A.

Content:

1. General provisions
2. Details about our company
3. What kind of data is processed, the purpose of processing and the storage period for and the legal basis for processing for each category of data
4. Processed sensitive data. Purpose, duration and legal basis for processing
5. Mechanisms and use of automated decision-making systems
6. Disclosure and additional use of your data
7. How we collect data
8. Information security
9. Transfer of your data outside the European Economic Area
10. Your rights related to personal data processing
11. Juvenile confidentiality
12. Policy principles
13. Changes

 

1. General provisions

1.1. Privacy of personal data represents one of the main concerns for EnergoBit SA (hereinafter referred to as ,, The Company”). As such, we aspire to provide the highest standards of privacy and transparency for the personal data we’re processing in our current activity.

1.2. Since for conducting our business we are required to process a series of personal data, especially in relation to the specifics of our line of business, we wish to provide assurances that the processing will take place in compliance with the principles of transparency and security of personal data. This privacy policy is meant to help you understand what data we’re collecting, why we’re collecting it and what we’re doing with it.

1.3. Our data protection policy and practices focus on the proper, lawful processing and exchange and storage of personal information and on ensuring confidentiality, integrity and availability. 1.4. All users have free access to the Company’s website www.energobit.com, provided that they comply with this privacy policy. Our website complies with the General Data Protection Regulation – GDPR (Regulation (EU) 2016/679).

2. Details about our company

2.1. ENERGOBIT S.A. (hereinafter referred to as „The Company”) is a Romanian company, established Cluj-Napoca, Taietura Turcului street, no. 47/11, Cluj county registered with the Trade Register under no. J12/1514/1991, VAT number: RO211717.

2.2. The Company acts as operator of personal data collected through the www.energobit.com website (the “website”).

2.3. The operator is required to manage safely and solely for specified purposes, the personal data that the users of the www.energobit.com website are providing.

3. What kind of data is processed, the purpose of processing and the storage period for and the legal basis for processing for each category of data

The moment of processing	What kind of data is being processed	The purpose of processing	Storage period	Legal basis for processing	Moment of processing	Transfer
3.1 Access of the wesbiste	3.1.1 Web server log	Ensuring security of the IT Network	6 months	compliance with legal obligations – Article 6 (1) (c) of Regulation No 40/94 provides: 679/2016	The Hosting site server	no
	3.1.2 cookies*
3.2 Contact through e-mail	3.2.1 Email and any other identification data present in it	To answer to the questions and messages we receive and to keep track of correspondence.	Only as long they are necessary but not longer than one year, as long as there is no litigation.	is required to perform a contract or to start the process of contracting at your request (Article 6 (1) (b))	In electronic format, on the server	no
3.3 Contact through telephone	3.3.1 Telephone number and any other data given in the conversation	To answer to the questions and messages we receive and to keep track of correspondence.	Calls are not recorded	your consent (Article 6 (1) (a)	no	no
3.4 Subscription to the newsletter / invitations to EnergoBit events	3.4.1 First name, last name, position, company, email, phone	To send relevant information to our customers about various solutions and products developed by EnergoBit – (by e-mail) and to be able to invite them to EnergoBit events – product presentations, services, webinars, debates, round tables (by phone).	Until unsubscription	your consent (Article 6 (1) (a) of the General Data Protection Regulation).	In electronic format, on the server	no
3.5. Sending a CV – (curriculum vitae), for recruitment and selection, for available positions.	Name, surname, telephone number, e-mail and other data contained in the CV, completed as you consider in order to increase your chances of being selected. Regarding the content of your CV, we consider relevant for the recruitment and selection process the following information: studies, professional experience, training, specialization, personal skills, the candidate being, however, free to complete with any other data he considers relevant in the recruitment process.	This information will not only be processed in the context of a recruitment for a specific position, available at a given time within EnergoBit, but may also be used for other possible opportunities (positions) that will appear within the company.	2 years from the date the data was received by the Company, if you have not already become an employee of the company.	your consent (Article 6 (1) (a) of the General Data Protection Regulation). You sending us your CV and the application to a position is interpreted as an action / manifestation of free will, informed and unambiguous by which you accept that the personal data in the CV shall be processed under the conditions of this Policy .	In electronic format, on the server	no

*3.1.2. For more information about cookies please see our cookies policy.

3.9 Criteria for establishing storage periods

The data will be stored for the minimum period necessary to achieve the purpose, taking into account the following:

• the purpose and use of your information both now and in the future (for example, if we need to continue to store that information in order to continue to fulfil our obligations under a contract with you or to contact you in the future);
• if we have a legal obligation to continue processing your information (such as any obligations to keep records required by law or relevant regulations);
• if we have any reason to continue processing the information (such as your consent);
• the levels of risk, cost and responsibility involved in continuing to hold the information.

3.10 If we receive information about you by mistake

If we mistakenly receive information about you from a third party and / or do not have a legal basis for the processing of this information, we will delete your information.

4. Processed sensitive data. Purpose, duration and legal basis for processing

The www.energobit.com website does not collect sensitive data.

5. Mechanisms and use of automated decision-making systems

5.1 We use automatic decision-making mechanisms on our website. We do not believe that this has a legal effect on you or affects you in any similar way.

5.2 You have the right to object to our use of automatic decision-making and profiling mechanisms described in this section. You can do this by waiving cookies and similar technologies, in accordance with the method described in the relevant section of this privacy policy. If you do not want us to process your real IP address (usually the IP address assigned by your ISP) when you visit our site, you can use a virtual private network (VPN) or a free service.

5.3 You can learn more about the use of cookies and similar technologies (including the legal basis for their use) and how to opt out of them in the cookie policy available on the Site.

6. Disclosure and additional use of your data

This section sets out the circumstances in which we will disclose your data to third parties and any other additional purposes for which we may use your data.

6.1 Disclosure of your data to service providers

6.1.1 Disclosure and use of your information for legal reasons

1. Indicating to the competent authority any possible criminal acts or threats to public safety.

If we suspect that criminal or potential behaviour has taken place, we will need, in certain circumstances, to contact a competent authority, such as the police. This could be the case, for example, if we suspect the commitment of a fraud or cybercrime or if we receive malicious threats or communications towards us or to third parties.

Legal basis for processing: our legitimate interests (Article 6 (1) (f) of the General Data Protection Regulation), respectively for the prevention of crime or suspected criminal activity (such as fraud).

1. In connection with a legal or potentially legal dispute or procedure

We may need to use your information if we are involved in a dispute with you or a third party, for example, either to resolve the dispute or as part of mediation, arbitration or a court decision or similar process.

Legal basis for processing: our legitimate interests (Article 6 (1) (f) of the General Data Protection Regulation).

Legitimate interest: the settlement of disputes or possible disputes.

III. For continuous compliance with law, regulations and other legal requirements

We will use and process your information to comply with legal obligations. For example, we may need to disclose your information based on a judgment or subpoena if we receive one.

Legal basis for processing: compliance with a legal obligation (Article 6 (1) (c) of the General Data Protection Regulation).

Legal obligation: the legal obligations to disclose information, established in our task by domestic or international normative acts (for example in the form of an international agreement that Romania has signed).

Legal basis for processing: legitimate interest (Article 6 (1) (f) of the General Data Protection Regulation).

Legitimate interest: if the legal obligations are part of the laws of another country and have not been integrated into the legal framework of Romania, we have a legitimate interest to comply with these obligations.

7. How we collect data

7.1 We collect your personal data directly from you, for example, when you send us an email, apply for a position or subscribe to the newsletter.

7.2 We collect your personal data automatically. When you use our services on the Company’s website, we collect information through cookies and by logging your online activity. For more information on the use of cookies, please see the cookies policy.

8. Information security

We take appropriate technical and organizational measures to secure your information and to protect it against unauthorized or illegal use and accidental loss or destruction, including:

• sharing and providing access to your data to the minimum necessary, subject to confidentiality restrictions, where appropriate and anonymously, whenever possible;
• use of secure servers for information storage;
• verifying the identity of any person requesting access to information before granting them access to information;
• use the Secure Sockets Layer (SSL) standard to encrypt any information you send us through any forms on our website;
• we transfer your data only through a closed system or through encrypted data transfers.

8.2 Sending information to us by e-mail

Transferring information on the Internet is not entirely secure and if you send us information via the Internet (by e-mail or in any other way), you do so entirely at your own risk.

We cannot be liable for any expenses, loss of profits, damage to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to provide us with information by such means.

9. Transfer of your data outside the European Economic Area (,,EEA“)

Your data will not be transferred to non-EEA countries.

10. Your rights related to personal data processing

10.1 Responsible for the protection of personal data

We have appointed a personal data protection officer whom you may contact with any matter relating the processing of your data, as well as to exercise your rights under the applicable legal provisions, in particular if you have any questions or concerns about how in which we process your personal data. The e-mail address where you can contact the data protection officer is: dataprotection@energobit.com

10.2 Subject to certain restrictions, you have the following rights in connection with your data which you may exercise by sending a written request or e-mail to dataprotection@energobit.com

• request access to your information and information regarding the use and processing of your information;
• request the correction or deletion of your data;
• request a limitation on the use of your data;
• receive the information you have provided to us in a structured format and the right to transfer that information to another data controller (including a third party data controller);
• object to the processing of your data for certain purposes (for more information, see the section below entitled “Your right to object to the processing of data for certain purposes”);
• withdraw your consent to the use of your data at any time we rely on your consent to use or process this information. Please note that if you withdraw your consent, this will not affect the legality of the use and processing of your data based on your consent before the time you withdraw your consent.

10.3 You can also file a complaint regarding the processing of your data to the National Authority for the Processing and Supervision of Personal Data (B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania, www.dataprotection.ro, anspdcp@dataprotection.ro).

10.4 Verification of your identity if you request access to your information

If you request access to your information, we are required by law to use all reasonable steps to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or unauthorized general access to your information.

10.5 How do we verify your identity?

10.5.1 If we have adequate information about you in the database, we will try to verify your identity using this information.

10.5.2 If we are unable to identify you on the basis of this information or if we do not have enough information about you, we may request copies or certificates of documents in order to verify your identity before we can give you access to your data.

10.5.3 We will be able to confirm the exact information we need to verify your identity in the specific circumstances given, if and when you make such a request.

10.6 Your right to object to the processing of data for certain purposes

You have the following rights regarding your data that you can use by sending an email to dataprotection@energobit.com:

• object to our use or processing of information to perform a task in the public interest or in our legitimate interest, including the analysis or prediction of your conduct based on your information.
• object to the use or processing of your data for direct marketing purposes (including any profile we involve in connection with this direct marketing) by clicking on the unsubscribe link or by sending an email / messages containing only the word “UNSUBSCRIBE” in response to any marketing communication we send.

10.7 For more information on how you can object to the use of data collected through cookies and similar technologies, see our cookie policy.

11. Juvenile confidentiality

11.1 We process data of persons under the age of 16, only with the consent of the legal representative, for the optimal performance of the services contracted by the legal representatives of minors.

11.2 We may receive information about persons under the age of 16 through fraud or deception by a third party. If we are notified about this, as soon as we verify the information, when required by law, we will immediately obtain the consent of the legal representative to use this information or, if we cannot obtain this consent, we will delete the information from our servers. If you would like to notify us of the receipt of information about persons under the age of 16, please do so by sending an email to dataprotection@energobit.com.

12. Policy principles

 

a) The processing of personal data will be done in a legal, fair and transparent manner;

b) The collection of personal data will be done only for specified, explicit and legitimate purposes and the data will not be further processed in a manner incompatible with those purposes;

c) The collection of personal data will be adequate, relevant and limited to the information necessary for the purpose of processing;

d) Personal data will be accurate and, where necessary, updated;

e) All necessary measures shall be taken to ensure that incorrect data are deleted or corrected without delay;

f) The personal data will be kept in a form that allows the identification of the data subject and for a period not longer than the one in which the personal data are processed;

g) All personal data will be kept confidential and stored in a manner that ensures the necessary security;

h) Personal data will not be distributed to third parties unless necessary for the purpose of providing services under the agreements;

i) The data subjects have the right to request access to, rectification and deletion of personal data, opposition or restriction from data processing as well as from the right to data portability.

13. Changes to our privacy policy

13.1 We regularly update and change our privacy policy.

13.2 Minor changes to our privacy policy

If we make minor changes to our privacy policy, we will update the Privacy Policy with a new effective date mentioned at the beginning. The processing of your information will be governed by the practices set out in the new version of the Privacy Policy from its effective date.

13.3 Major changes to our privacy policy or the purposes for which we process your information.

If we make major changes to our privacy policy or we intend to use your data for a new or different purpose from the purposes for which we originally collected it, we will notify you by email (if possible) or by posting an ad on our website.

We will provide you with information about the change in question and the purpose and any other relevant information before using your information for the new purpose.

Whenever necessary, we will obtain your prior consent before using your information for a purpose other than the purposes for which we originally collected it.

 

The latest update of this policy was made on the 7^h of December 2020.