Introduction
The Hellenic-Romanian Bilateral Chamber of Commerce (hereinafter HRCC), with Sole identification Code 25717206, headquartered at 9 B Fabrica de Glucoza Str, ap. 102, 1st Floor, 2ra District, is committed to protecting user privacy and the security of personal data in accordance with Regulation (EU) 679/2016 (GDPR) and Law No. 190/2018 regarding measures for the implementation of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, which repeals Directive 95/46/EC (the General Data Protection Regulation) in Romania. This policy explains how we collect, use, store, and protect your personal information.
The purpose of this policy is to ensure that HRCC complies with the applicable legislation regarding the General Data Protection Regulation (GDPR).
2. Information Collected and Purpose of Use
We may collect and process the following types of personal data:
- Personal identification information: name, address, phone number, email address, company.
- Online activity data: IP address, behavior on the website, cookies, browser used, website login time, pages visited, interaction logs.
- Additional data: depending on the services requested (e.g., financial data for billing, data included in forms, etc.).
We process your personal information for the purposes outlined in this privacy policy. Additionally, we have identified certain legal grounds for processing your personal information (these depend on the category of personal information being processed). We process standard personal information when it is necessary to provide services under a contract, when it is in our legitimate interest or that of third parties, or when it is required or permitted by applicable law. Detailed information about this is provided below.
Under applicable law, we must have a legal basis for processing personal information. We process standard personal information about you if it is:
- Necessary to provide services established in a contract – if we have a contract with you, if your employer or another person has entered into a contract on your behalf, we will process your personal information to fulfill that contract.
- For our legitimate interests.
- Based on your consent.
- Necessary or permitted by law.
3. Legal Basis for Processing
The processing is based on one of the following legal grounds:
- To conclude or execute a contract with you under Article 6(1)(b) of the GDPR, namely, “processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract.”
- Based on your consent, we may process data for marketing communications, advertising, newsletters, or notifications in accordance with Article 6(1)(a) of the GDPR, namely, “the data subject has given consent to the processing of their personal data for one or more specific purposes.”
- To fulfill a legal obligation, such as the obligation to provide information to public authorities or entities authorized by them, or to comply with archiving obligations in accordance with Article 6(1)(c) of the GDPR, namely, “processing is necessary for compliance with a legal obligation to which the controller is subject.”
- Processing is necessary for the purposes of our legitimate interests, in accordance with Article 6(1)(f) of the GDPR, namely, “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party…” while respecting the provisions of Article 5 of the GDPR.
4. Data Storage and Security
Data is stored securely, using appropriate technical and organizational measures to protect it against unauthorized access or loss. Data retention duration is a maximum of [specify duration] or as required by legal obligations.
Personal data is retained as long as necessary to fulfill the purposes of collection, except in cases where we are legally required to retain it.
We collect personal information from you and third parties (any person acting on your behalf, online forms, through call recordings or directly during phone calls, with the explicit consent of the person we are interacting with, the employing company, brokers, suppliers, among others, though the list is not exhaustive).
When you provide us with information about other individuals, you must ensure that they have seen a copy of this privacy policy and agree to you providing us with their information.
We collect personal information from you through your contact with us, including by phone, email, our websites, applications, post, completing a request or other forms (including on our website), through social media, or face-to-face interactions.
5. User Rights
You have the right to access your information and request corrections, deletions, or restrictions on its use. You also have the right to object to the use of your information, request the transfer of the information you provided, withdraw your consent for its use, and request that we do not use automated decision-making processes that may have legal effects on you.
You have the following rights (subject to certain exceptions):
- Right of Access: The right to request details regarding your personal data and a copy of your personal information.
- Right to Rectification: The right to correct or remove inaccurate information about you.
- Right to Erasure (“Right to be Forgotten”): The right to delete certain personal information about you.
- Right to Restrict Processing: The right to request that your personal information is used only for restricted purposes.
- Right to Object: The right to object to the processing of your personal information when our processing is based on public interest or our legitimate interests, or if we inform you that processing is necessary for our legitimate interests or those of a third party.
- Right to Data Portability: The right to request the transfer of your personal information to a third party in a machine-readable format.
- Right to Withdraw Consent: The right to withdraw any previously given consent for processing your personal information. Withdrawing consent does not affect the legality of processing by HRCC prior to the withdrawal of your consent, and we will notify you if we can no longer provide the chosen service or fulfill its purpose.
- Right Regarding Automated Decision-Making: The right not to be subject to decisions based solely on automated processing, which have legal effects or significantly affect you, unless necessary to complete a contract, authorized by law, or explicitly consented to. We will notify you when such decisions are made, the legal grounds for them, and your rights.
To exercise these rights, users may contact the Data Protection Officer at [email address].
Our website may contain links to external sites, including business partner sites or other pages of interest. By accessing these links, you will leave our website, and the management of these sites is beyond our control. Therefore, we do not assume responsibility for the protection of personal data you provide on these external sites. We recommend reviewing their privacy policies before providing personal data.
6. Use of Cookies
The website uses cookies to personalize the user experience and analyze browsing behavior. Upon first accessing the site, the user may express their consent regarding the use of cookies.
For more information, please refer to the Cookie Policy page.
7. International Data Transfer
If data transfer is necessary to countries outside the EU, we ensure compliance with GDPR protection standards, either through appropriate contractual commitments or through transfers to countries that benefit from an adequacy decision by the European Commission.
8. Changes to the Privacy Policy
We reserve the right to update this privacy policy. Any changes will be published on our website, and users will be adequately notified.
It is essential to consult a legal professional to tailor this model to your specific activities and ensure compliance with all applicable regulations.
