Policy regarding the confidentiality and security of the personal data
The purpose of this document is to describe the manner in which the Operator INTERNATIONAL ALEXANDER S.R.L., with the head office in Arad, str. Memorandului nr.10, Arad county, registered at Trade Register Office Arad under no. J02/1688/2003, Sole Identification Number 16002342 represented by Administrator: APREUTESE Simion Ioan (e-mail: email@example.com), responsible with the Personal Data: MAFTEI Iulian, Telephone 0746069727; e-mail: firstname.lastname@example.org processes your personal data following the use of the Site www.international-alexander.ro as well as presents your rights regarding the Personal data which will are processed.
We assure you that the confidentiality is valuable to us, engaging to respect the private character and the security of the information supplied by you when you use the Site. We are not interested in your Personal data except those data which are necessary for attaining the purposes aimed. We engage not to disclose your Personal data to third parties who are not part of the Group International Alexander Holding.
Defining certain terms
Besides the definitions contained in the Terms and Conditions of use of the site www.international-alexander.ro, within the present Policy regarding the confidentiality and security of the personal data, may be used the following terms, which are defined and used in accordance with the Regulation GDPR no. 679/2016.
(a) Operator’s site – the internet page of the personal data Operator INTERNATIONAL ALEXANDER S.R.L. is www.international-alexander.ro, which any user may navigate and/or read and/or use the informational contents exposed on the site. In addition, the internet page of the Operator allows to any interested User to be able to send the contact form with a view to receiving any type of informing regarding the operator’s activity or that of any companies from the group INTERNATIONAL ALEXANDER HOLDING. The Site of the Operator INTERNATIONAL ALEXANDER S.R.L. is a site mainly used for presenting the activity of the Operator and does not have the role to collect personal data from the Users, except for those supplied with their express consent at the time of sending a contact form.
(b) Contact form – the users may formulate and transmit messages with a various contents to the Operator INTERNATIONAL ALEXANDER S.R.L., by accessing the column “Contact” from the contents of the site. In order to be able to formulate such a message, the user of the site mentioned above fills in the columns regarding the name, email and telephone number.
(c) Personal data – any information with regard to the User which allows its identification directly or indirectly, including, but without limiting to name, first name, email address, mobile number, which are supplied by the User for the purpose of transmitting opinions or requesting information by the contact form.
(d) The Consent regarding the processing of personal data – means any manifestation of free will, specific, informed and lacking ambiguity of the person concerned, by which the latter accepts, by a statement or by an action without ambiguity, that the personal data which concern it would be processed.
(e) Regulation no. 679/2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC – hereinafter named GDPR – represents the general legal framework applicable in the matter of the personal data protection of the natural persons to the extent to which the processing is carried out by an Operator.
THE TYPE OF DATA COLLECTED ON THE OCCASION OF ACCESSING THE SITE
The users may access the site of the Operator INTERNATIONAL ALEXANDER S.R.L. simply for information. The use of the site by the User for information constitutes expressly and without ambiguity the consent regarding the acceptance and understanding of the Terms and Conditions of the Operator, which are presented in a separate column on the site.
The only area from the site which requires the supply of personal data from the User is allocated within the column “Contact” for sending a form to the Operator with a view to obtaining various information regarding the activity carried out.
Taking into account the operation for which are supplied personal data (sending the form to the operator), to the User are requested the following data: name, email address, mobile number. Other personal data may be supplied by you by the message formulated or by the folder attached to this, the processing observing the provisions of Regulation no. 679/2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC – hereinafter named GDPR.
In the situation that, by the contact form existent on the site, you wish to send, in attachment, your CV for a possible employment within the entities from the Group INTERNATIONAL ALEXANDER HOLDING, we will process also the personal data as foreseen by GDRP, registered in the contents of your CV.
The operator INTERNATIONAL ALEXANDER does not request to the Users of the site in order to fill in the contact form other personal data than those mentioned above, these being sufficient for the carrying out of the processing purpose. Thus, it is recommended to use the personal data strictly necessary for drawing up the message and the trial to use irrelevant personal data, which would imply a supplementary processing of the data disclosed to the Operator and which exceed, by their contents, the minimum, relevant and adequate character of the personal data according to art. 5 par. 1 lett. c from GDPR.
The data requested for sending the contact form are used for the identification, validation, completion of the Form regarding the information requested to the Operator or other entities from the Group INTERNATIONAL ALEXANDER HOLDING by the User and in order to be able to thus answer to the requests transmitted by this Form in a term of maximum 24 hours from the receipt of the request.
The user may consult the Operator’s Site also without disclosing the identity or supplying the smallest piece of information regarding his personal data. However, information may be obtained automatically, when visiting the Site, by the cookies modules used in order to improve the navigation experience of all visitors as well as to measure the efficiency of this site.
By the cookie modules we do not collect and do not process any information based on which the user could be identified. For more details, access „Policy of use of Cookie modules”. We notify you that it is possible to deactivate the collection of these data by blocking the cookies from the settings of the browser, however certain functions from our Site may be affected.
THE PURPOSES AND GROUNDS FOR PERSONAL DATA PROCESSING
The processing of the personal data consisting in: name, phone number and email is made in order to identify, at a minimum level, the User who formulated a request to the Operator and to respond to it, in a 24-hour maximum term from the receipt of the request.
INTERNATIONAL ALEXANDER will process also other personal data supplied by you either by the contents of the message sent or by the folder attached to it, only to answer in a prompt and efficient manner to your request.
From this perspective, the purpose of personal data processing mentioned above may consist in offering information regarding the goods and services requested by you, allowing you to make suggestions and notifications regarding various information published on our site in order to offer you the possibility to contact the entities from the group INTERNATIONAL ALEXANDER HOLDING by our site, informing you about the news concerning the products and the services found in the portfolio of the company or of another entity from the Group International Alexander Holding or in order to invite you to the actions/campaigns/activities organized by us.
In addition, reported to the contents of the message formulated by you, the purpose for which we process your personal data may consist also in the fulfilment of operations of tendering, contracting, invoicing or for conformation to the legislation in force.
In the situation that, by the contact form existent on the site, you send, in attachment, your CV for a possible employment, the processing of the personal data from the contents of the attached material is made in order to determine your skills and specializations and in order to appreciate the possibility of your occupying a position within the entities from the Group INTERNATIONAL ALEXANDER HOLDING.
The legal ground for processing the personal data which may be sent by you through the contact form is:
your consent as concerned person (art. 6, par. 1, lett. a from GDPR).
If we must use your personal data for a purpose which is not related to the initial purpose for which we collected the data, we will notify you, we will explain the legal grounds of the processing, while this operation will be carried out only after the obtainment of your approval in this regard to the extent to which it is necessary.
PROCESSING THE PERSONAL DATA CONTAINED IN THE CONTACT FORM SENT BY THE USERS
The contact form existent on the site of the Operator INTERNATIONAL ALEXANDER S.R.L. may be used after taking note, by the User, of the present Confidentiality policy regarding the processing of personal data and offering the express acceptance regarding the personal data processing activity in accordance with the mentioned Policy.
In order to satisfy the mentioned requirement and implicitly to be able to use the Contact Form existent on the site, before sending the message to the Operator the User will tick the column accompanied by the message “Yes, I am over 18 years old, I took note of the Confidentiality policy regarding the processing of personal data of the Operator INTERNATIONAL ALEXANDER and I express my agreement that the processing of my personal data would be carried out in accordance with this.”
The contact forms are automatically sent as emails at the address email@example.com. The Operator will collect and stock all the correspondence which is transmitted to it, such as notifications, questions and requests from a secured server.
At the same time, by sending a contact form to the Operator INTERNATIONAL ALEXANDER S.R.L., the User may express its agreement regarding the collection, stocking and use of the data for the purpose of fulfilling the obligations to answer to the contact forms sent from the site of the Operator.
The User will formulate the message addressed to the Operator by the form so that it would not contain irrelevant personal data, which would imply a supplementary processing of the personal data disclosed to the Operator and which exceed, by their contents, the minimum, relevant and adequate character of the personal data according to art. 5 par. 1 lett. c from GDPR.
The personal data supplied by the Users together with the completion of the contact form will be processed only by the person authorized from the Operator, who has access to the serve where the forms are stocked and only for the purpose of answering the requests of the Users. The person authorized from the Operator, responsible with the processing of the personal data, is obliged to keep the confidentiality of the processed data and is trained in this regard.
In accordance with the exercising of the right foreseen by art. 17 from GDPR, we will be able to delete your data afferent to the contact form sent if you decide to formulate a request in this regard, request which will be analysed by the authorized person in a reasonable time. The result of your request will be notified at the email address supplied by you on the occasion of filling in the field “e-mail” from the contact form.
The Operator International Alexander S.R.L. will take all the security measures necessary for the protection of your data against the unauthorized access to data or modification, disclosure or unauthorized destruction of data.
ADDRESSEES OR CATEGORIES OF ADDRESSEES OF THE PERSONAL DATA
The Operator does not disclose the personal data obtained by the contact form existent on its site, except for the cases in which it must supply to the judicial bodies, at their request, their attached message or contents to the extent to which there are indications about the committing of deeds of infringing the law or in the situation in which there is a legal obligation in this regard.
THE TRANSFER OF PERSONAL DATA TO A THIRD COUNTRY OR INTERNATIONAL ORGANIZATION
The data thus processed will not be transmitted outside the country or to other international organizations.
THE AUTOMATIZED DECISIONAL PROCESS
Processing the personal data by the Operator does not imply any activity of creating profiles based on these data.
MEASURES FOR THE PROTECTION OF THE PERSONAL DATA
The personal data are processed in safety conditions. The operator INTERNATIONAL ALEXANDER took adequate technical and organizational measures regarding the security of the data, against the processing or unauthorized alteration, against the loss or destruction as well as against disclosure and unauthorized access to the personal data transmitted, stocked or processed, these measures being foreseen in detail within the Policy for personal data processing adopted at the level of the Operator.
In addition, INTERNATIONAL ALEXANDER assures the integrity, availability, confidentiality and authenticity as regards the personal data processing. INTERNATIONAL ALEXANDER uses advanced security methods and technologies, together with policies applied to the employees in order to protect the personal data processing.
However, despite the efforts made for stocking the information collected in a safe operating environment, which is not available to the public, we cannot guarantee the absolute security of these information during the transmission or stocking in our systems. In case of infringing the security which endangers the confidentiality or the personal information, we engage to inform you of these aspect, either by the site or by other methods we have (email messages, phone calls).
THE ACCESS TO THE INFORMATION COLLECTED AND THE DISCLOSURE OF THE DATA
INTERNAȚIONAL ALEXANDER will not disclose any type of information personally identifiable about its users to third parties without firstly receiving the express acceptance of the users in this regard.
At the same time, INTERNAȚIONAL ALEXANDER may disclose personal information when the law expressly foresees this. In conclusion, when you access the site INTERNAȚIONAL ALEXANDER and you are asked to disclose information about you, you will disclose this information only to the site INTERNAȚIONAL ALEXANDER, except for the case when the respective service or information is offered in partnership with another site or service.
If you choose, however, to accept the sharing of the data, you must understand that the suppliers of the service in partnership may have distinct confidentiality and data collection policies. INTERNAȚIONAL ALEXANDER does not dispose of any control and cannot guarantee the legal aspects implied by the use of these distinct confidentiality policies.
INTERNAȚIONAL ALEXANDER may disclose the personal data to its own employees in accordance with the duties specific to their function and with internal personal data processing policies and only for the purpose in which they were notified or to the persons empowered by INTERNAȚIONAL ALEXANDER for the personal data processing. Exception from the mentioned rule is the situation in which the transfer/ accessing/ visualization of the data is requested by the bodies empowered in the cases, foreseen by the regulations in force on the date the event is produced.
INTERNAȚIONAL ALEXANDER will observe the confidential information which you supply and will assure the fact that it will not sell, transfer, rent and make barter with your email lists or personal data.
LOADING THE SOCIAL PLUGINS
Our site uses buttons for the following social networks:
Facebook, California Ave, Palo Alto, SUA
Linkedin, Sunnyvale, California, SUA
The buttons show the sigles of the individual social networks. Despite these, the buttons are not standard social plugins, namely plugins supplied by social networks, but links with buttons pictograms. These buttons are activated only by deliberate actions from you as User. As long as you don’t click on the buttons, the data will not be transferred in the social networks. By clicking the buttons, you accept the communication with the servers of the social network, activating thus the buttons and establishing the link.
Once you clicked, the button functions as a shared plugin. The social network obtains information about the site you visited, which you may share to your friends and contact persons.
When you activate the button, the social networks will also receive the information you accessed on the respective page of our site and when you took this action. Besides, there can be transmitted information such as the IP address, details about the browser you used and the language settings. If you click the button, your click will be transferred in the social network and used in accordance with the data policy.
Consult the information supplied by the following social sites for details about the purpose of collecting the data and the subsequent processing and use of data by the respective social network and about your confidentiality rights and settings:
If you do not wish that the social networks would obtain data about you, do not click on the button.
THE RIGHTS OF THE PERSONS CONCERNED IN THE ACTIVITY OF PERSONAL DATA PROCESSING
As persons concerned in the personal data processing activity supplied by the contact form, the Users of the site www.international-alexander.ro have the following rights:
1.The right to the data access, namely the right of the person concerned to obtain from the Operator upon request and for free, the confirmation of the fact that the personal data which concern it are or not processed by this. Depending on the answer offered, the person concerned has the possibility to exercise or not the other rights.
2.The right to the data rectification, namely the right of the person concerned to obtain from the Operator upon request and for free, to the extent to which the existent technical possibilities allow it, the rectification of the inexact data which concern it as well as the completion of the incomplete data.
The right to the data erasure, namely the right of the person concerned to obtain from the Operator upon request and for free, to the extent to which the conditions foreseen by the law are foreseen, the erasure of the personal data which concern that person.
The right to restriction processing, namely the right of the person concerned to obtain, upon request and for free, to the extent to which the conditions foreseen by the law are fulfilled, the marking of the personal data stocked, for the purpose of limiting their subsequent processing.
The right to data portability, namely the right of the person concerned to receive, upon request and for free, the personal data in a structured manner, usually used, and in a format easy to access as well as the right that these data would be transmitted to another data operator, to the extent to which there are fulfilled the conditions foreseen by the law.
The right to opposition, namely the right of the person concerned to oppose at any time, for grounded and legitimate reasons related to its particular situation, that the personal data which concern it would be subject to a processing to the extent to which there are fulfilled the conditions foreseen by the law.
7.The right to address the justice or National Authority for the Supervision of the Personal Data, the right of the person concerned to address a complaint to the National Authority for the Supervision of the Personal Data, with the premises in Bucharest, B-dul General Ghe. Magheru nr.28-30, sect.1, telephone: 0318059211, 0318059212, e-mail: firstname.lastname@example.org respectively to address to the justice in order to protect any rights guaranteed by the legislation applicable in the field of the personal data, which were infringed.
Moreover, as regards your requests sent by the contact form to the Operator and which are processed based on art. 6 par. 1, lett. a from GDPR, based on your free and previously expressed consent, we inform you that you have the possibility, during the processing of the personal data, to withdraw the consent awarded at any time, without affecting the legality of the processing carried out based on the consent awarded before its withdrawal, according to art. 7 par. 3 from GDPR, respectively art. 13 par. 2 lett. c from GDPR. For example, this right may be exercised regarding the standard personal data supplied on the occasion of sending a message to the Operator (name, telephone number and email). The consent given may be withdrawn by sending a new contact form in which you express your wish to withdraw your consent regarding the personal data processed following the use of the contact form from the site www.international-alexander.ro. In addition, you may send an email in this regard also at the address email@example.com.
Acting as persons concerned you may exercise the rights mentioned above, registering at the premises of the Operator a written and justified request, which will be solved in a term of maximum 30 days from its registration. Such a request may be sent also by email at the address: firstname.lastname@example.org
In addition, as person concerned you may formulate a complaint regarding the manner in which were processed the personal data by contacting in this regard The responsible with the Personal Data Protection: Iulian MAFTEI, Telephone 0746069727; e-mail: email@example.com who will investigate the topic complained and will notify to you an answer in a term of maximum 30 days.
MODIFICATION/COMPLETION OF THE PRESENT CONFIDENTIALITY POLICY
We reserve the right to modify/complete the present Confidentiality policy from time to time, following the legislative changes or those of the Site type. The updated confidentiality policy will be published on the Site and will enter in force at the time of the publication. By continuing to use the Site after the entering into force of certain modifications/completions, the User agrees to observe them. The User is advised to verify periodically the present Confidentiality policy in the situation of frequently accessing the site of the Operator.
LEGAL CHANGES IN THE COMPANY
In the situation in which we are involved in a reorganization process, fusion, merger or any other change of the control on us or transfer of assets, your data will be transferred as part of the respective transaction.
Any person concerned may, at any time, contact directly our legal responsible for the data protection with all the questions and suggestions regarding the data protection.
The person appointed as DPO – Responsible with the personal data protection within our company is Mr. MAFTEI IULIAN, who may be contacted directly at TELDPO-0746 069 727 or by e-mail firstname.lastname@example.org
For any unclear aspects regarding the protection of the personal data processed by the International Operator Alexander, you may contact us at any time also by the following means:
Address: Zona Industriala N-V str. IV nr. 4, Arad
Telephone: +40 372 711 811
Telephone: +40 357 421 821