Privacy policy

12. POLICY FOR PERSONAL DATA PROCESSING

OUR COMMITMENT TO YOUR PERSONAL DATA

The Personal Data Processing Policy describes the categories of personal data we process, the ways and purposes for which we collect the data, the circumstances in which we transfer personal data, and your rights and options to that effect. At the same time, the Personal Data Processing Policy details how we process personal data in client relationship management, most often to keep you up-to-date with the latest developments or events in your area of ​​interest.

YOUR CONTROLLER

The Controller in relation to your personal data is PROMELEK XXI S.A., Romanian legal entity with its registered office in Apahida, Libertăţii Street, no.21, Cluj County, registered with the Office of the Trade Register Cluj as no. J12/4202/1994, VAT no. 6845993, the owner of the website www.promelek.ro

CATEGORIES OF PERSONAL DATA PROCESSED

The personal data that we process may include:

• Contact information, such as your name / company name, mailing address, including your home address, if you have communicated it, your business address, telephone number, mobile phone number, fax number and address e-mail;
• Data resulting from your browsing on our website collected through cookies and similar technologies.

LEGAL BACKGROUND FOR PERSONAL DATA PROCESSING

Any processing of your personal data will be made based on one of the legal backgrounds below:

• Processing is required for the conclusion or performance of a contract, a contract in which your company / you hold the status of a party;
• Processing is necessary to comply with a legal obligation of the operator;
• Processing is done based on your consent;
• Processing is necessary to protect the vital interests of your company / you or other natural / legal persons;
• Processing is necessary for the legitimate interests of PROMELEK XXI S.A. or of a third party, unless your interests or fundamental rights and freedoms prevail over these interests;
• For special categories of data, the processing will be done if, besides a general legal basis for data processing, one of the following specific processing conditions is met:
  • The consent of the legal / physical data subject was obtained;
  • We have a legal obligation to process these categories of data;
  • Processing is necessary for the establishment, exercise or defense of a right in court.

THE PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

We may use your personal data for the following purposes (“Permitted Purposes“):

• Offering services and products based on the company’s main activity object: Non-specialized wholesale trade, as well as based on the secondary objects of activity of PROMELEK XXI S.A.
• Management and administration of the contractual relationship with our clients;
• Compliance with our legal obligations;
• Analyzing and improving our services and communications to you, including (since we have a legitimate interest in continuously improving our services) conducting client surveys on the level of client satisfaction with the services and products delivered.
• For any and / or auxiliary purpose of any of the above, or for any other purpose for which your personal data has been provided to us, in compliance with the applicable law.

Also, based on your consent, we can send you various communications through the channels you have approved to keep you up to date on the services, products, events and projects of PROMELEK XXI S.A. or other promotional events.

HOW LONG WE KEEP YOUR PERSONAL DATA

PROMELEK XXI S.A. has implemented technical and organizational measures for the organization of the process and specific criteria for keeping your personal data (including our archiving procedures).

We will cease processing your personal data when it is no longer reasonably required under the Permitted Purposes or when you withdraw your consent (if applicable) and there are no legitimate and compelling reasons that justify further processing by PROMELEK XXI S.A. (including the legal obligation of PROMELEK XXI S.A. to continue to store that data) and prevailing over your interests, rights and freedoms.

YOUR RIGHTS RELATED TO PERSONAL DATA PROCESSING

Subject to certain legal conditions, you have the following rights in relation to the processing of your personal data:

• The right to request a copy of your personal data relating to you, which we own;
• The right to rectify any inaccurate or incomplete personal data;
• The right to oppose or restrict our use of personal data;
• The right to withdraw your consent for the processing of processed data based on consent;
• The right to delete your personal data, in cases where you have withdrawn your consent, processing is no longer required or the processing is contrary to law;
• The right to data portability that allows you to receive a copy of the processed data that we have received from you or to forward it to another entity indicated by you;
• The right to withdraw your consent for consent-based processing. The withdrawal of your consent will not affect the lawfulness of the processing based on the consent prior to its withdrawal. In cases where you withdraw your consent, PROMELEK XXI S.A. will no longer process your personal data and will take appropriate action to delete your personal data. PROMELEK XXI S.A. however, will be able to process your personal data if there is another legal basis for that processing

If you want to exercise the above-mentioned rights, please feel free to contact us, using the following contact details:

Address: loc. Apahida, Libertăţii Street, no.21, Cluj County

E-mail:  marketing@promelek.ro

Tel: 0264207200

Fax: 0264232092

About marketing communications received from us, you can also withdraw your consent at any time by simply accessing the “unsubscribe” link from the bottom of each email message received from us.

To comply with the legal security and confidentiality obligations of our data, when exercising one of your rights as data subject, we may ask you to prove your identity by providing us with a copy of an identification document or any other information necessary to verify that the request comes from the relevant data subject.

We will consider any requests or complaints we receive and we will send you an answer in accordance with the deadlines provided by the law. If you are not satisfied with our response or if you consider that the processing is in breach of the applicable law, you may file a complaint with the Romanian Data Surveillance Authority: the National Supervisory Authority for Personal Data Processing – with the registered office in 28-30Gheorghe Magheru Bd., Bucharest, Romania.

UPDATES OF THIS PERSONAL DATA PROCESSING POLICY

The most recent update of this Personal Data Processing Policy was made in May 2018. We reserve the right to periodically update and amend this Personal Data Processing Policy to reflect any changes in the way that we process your personal data or any changes to your legal requirements. In the event of any such change, we will display on our website the modified version of the Personal Data Processing Policy and / or we will otherwise make it available to you.