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Privacy and personal data processing policy

GENERAL PRIVACY POLICY

WHO WE ARE

ECOTIC ASSOCIATION and ECOTIC BAT SRL are associated operators of personal data.

ECOTIC ASSOCIATION is an organization specialized in waste management of electrical and electronic equipment, and ECOTIC BAT SRL is an organization established out of the legal need to organize separately and efficiently a component complementary to the basic activity of ECOTIC: collection and recycling of waste batteries and portable accumulators and industrial.

For this reason, the processing of personal data is carried out jointly within the two organizations that are only formally distinct and all applicable principles, policies and practices regarding the ECOTIC ASSOCIATION apply to ECOTIC BAT SRL and each other.

ECOTIC ASSOCIATION, headquartered in Str Turturelelor, no. 48, Sector 3, Bucharest and correspondence address: Splaiul Unirii, Nr 86, floor 4, Sector 4, Bucharest, Telephone: 031.805.57.43, Fax: 021.332.32.38, https://www.ecotic.ro ; e-mail: [email protected]; Data Protection Officer email address: [email protected] , is the controller of personal data collected in the course of its legitimate business activity.

ECOTIC BAT SRL, headquartered in Splaiul Unirii, No. 86, floor 4, Sector 4, Bucharest, Phone: 031.805.57.43, Fax: 021.332.32.38, https://www.ecotic.ro ; e-mail: [email protected]; Data Protection Officer email address: [email protected] , is the controller of personal data collected in the course of its legitimate business activity.

ECOTIC and ECOTIC BAT, as associated operators, collect data in many ways and in many ways: when you contact us by email, when you visit our website, when your employers conclude new transfer contracts. responsibilities regarding the achievement of the annual objectives for WEEE and DBA collection or when formulating a request for collaboration addressed to us. We also collect data when you visit us at one of our offices, as well as when you send us CVs or job applications.

DEFINITIONS

Personal data (Data) - any information concerning an identified or identifiable natural person (data subject); an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identification element such as a name, an identification number, location data, an online identifier or one or more elements specific, their own physical, physiological, genetic, mental, economic, cultural or social identities.

Special categories of personal data - any information revealing racial or ethnic origin, political opinions, religious beliefs or philosophical beliefs or trade union membership, genetic data, biometric data for the unique identification of a natural person, health data or data on sexual life or sexual orientation of to an individual.

Processing of personal data (Processing) - any operation or set of operations performed on personal data or personal data sets, with or without the use of automated means, such as the collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation , use, disclosure by transmission, dissemination or otherwise made available, alignment or combination, restriction, deletion or destruction.

The target person - a natural person who can be identified, directly or indirectly, in particular by reference to an identification element such as a name, an identification number, location data, an online identifier or to one or more specific, own elements his physical, physiological, genetic, mental, economic, cultural or social identities.

Operator - the natural or legal person, public authority, agency or other body which, alone or together with others, determines the purposes and means of the processing of personal data; where the purposes and means of processing are determined by Union or national law, the controller or the specific criteria for its designation may be laid down in Union or national law.

Associated operators - two or more operators who jointly establish the purposes and means of processing, set out in a transparent manner their responsibilities with regard to the fulfillment of their obligations under the GDPR, in particular with regard to the exercise of data subjects' rights and duties each of them for the provision of the information provided for in Articles 13 and 14, by agreement between them, and shall designate a single point of contact for the data subjects.

Person Powered by the Operator (Power of Attorney / Processor) - the natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Third Party - a natural or legal person, public authority, agency or body other than the data subject, the controller, the controller and the persons who, under the direct authority of the controller or controller, are authorized to process personal data.

Consent - any manifestation of the free, specific, informed and unambiguous will of the data subject by which he or she consents, by an unequivocal statement or action, that the personal data concerning him or her be processed.

Pseudonymisation - means the processing of personal data in such a way that they can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is stored separately and is subject to technical measures and organizational to ensure that such personal data is not assigned to an identified or identifiable natural person. The principles regarding the processing of personal data apply to pseudonymised data, as they represent personal data.

Anonymization - means the processing of personal data in such a way as to be irreversible and to transform the data so that they can no longer be attributed to a specific data subject. The principles on the processing of personal data do not apply to anonymised data, as they no longer represent personal data.

ANSPDCP - means the independent public supervisory authority in Romania, respectively the National Authority for the Supervision of Personal Data Processing.

GDPR - 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 and repealing Directive 95/46 / EC.

OUR VISION OF PERSONAL DATA PROCESSING AND THE COMMITMENTS OF THE ECOTIC AND ECOTIC BAT ASSOCIATION

The processing of personal data in the ECOTIC and ECOTIC BAT ASSOCIATION is always subject to the following principles:

  • All data processing has a valid legal basis
  • All data processing is done fairly
  • We inform data subjects about what data we process, why, how and how long we process it, if and to whom we transfer it, as well as what rights they have regarding their data.
  • Data is collected for specific, explicit and legitimate purposes and is not further processed in a manner incompatible with those purposes.
  • The data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
  • We are concerned to use only accurate data and, if necessary, will ensure that they are updated.
  • The data shall be kept in a form which permits identification of data subjects for a period not exceeding the period necessary to fulfill the purposes for which the data are processed; personal data may be stored for longer periods to the extent that they are processed exclusively for archiving purposes in the public interest, for scientific or historical research or for statistical purposes, subject to the implementation of technical measures. and organizationally adequate
  • The data shall be processed in a manner that ensures adequate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, by taking appropriate technical or organizational measures.

ECOTIC AND ECOTIC BAT ASSOCIATION will ensure that it complies with these principles both in terms of its current activities and if it introduces new data processing technologies in the future, such as, but not limited to, new systems. IT.

WHAT PERSONAL DATA WE PROCESS

ECOTIC AND ECOTIC BAT ASSOCIATION specifically inform data subjects about personal data collected and processed in each case (for example, when submitting a request for collaboration or a response to a request for collaboration, upon receipt of a requests for the collection of waste electrical and electronic equipment (WEEE) and / or waste batteries and accumulators (DBA), upon receipt of a CV, etc.).

For example, if you send us a request for collaboration / WEEE collection through the website or directly to the e-mail address [email protected], we will collect personal data regarding: e-mail address and contact details of the person or representative of the company who contacts us, included in the request (example: name, surname, telephone number).

WHY AND HOW WE USE YOUR DATA PERSONAL CHARACTER

Your personal data is used to carry out our WEEE / DBA management activity, to conclude contracts for the transfer of responsibilities regarding the achievement of the annual WEEE and DBA collection objectives, to process WEEE / DBA collection requests. (in which case we need to clarify the facts and carry out additional verifications in a strictly legal framework), in order to comply with the requests made by the competent authorities that supervise and regulate our activity.

We process data to provide you with the services and information you request.

We also process personal data and to ensure the security of the spaces in which we operate, the goods we use for this purpose, the safety of our employees and the data and information we manage.

Your personal data is processed through the collection, registration, organization, storage, modification, consultation, use, disclosure by transmission, provision, combination, restriction, deletion, destruction, etc. Your personal data is not subject to an automated decision-making process (including profiling) than in exceptional cases, in which case the data subject is informed of its existence, as well as of the details of this particular mode of processing.

ECOTIC AND ECOTIC BAT ASSOCIATION specifically inform data subjects about the purposes and methods of processing in each case (for example, when submitting a request for collaboration or a response to a request for collaboration upon receipt of a CV). etc.).

WHAT ARE WE USING YOUR DATA ON? PERSONAL CHARACTER

ECOTIC AND ECOTIC BAT ASSOCIATION aims to perform data processing taking into account at least one of the legal grounds listed below:

  1. a) Consent - If no other basis of legality of processing provided below applies, the ECOTIC and ECOTIC BAT ASSOCIATION always obtains the consent of the data subject for the processing of his personal data for one or more specific purposes.
  2. b) Execution / Conclusion of a contract - The processing is necessary for the execution by the ECOTIC and ECOTIC BAT ASSOCIATION of a contract to which the data subject is a party or to take steps at the request of the data subject before concluding a contract.
  3. c) Legal obligation - The processing is necessary in order to fulfill a legal obligation incumbent on the ECOTIC and ECOTIC BAT ASSOCIATION.
  4. d) Legitimate interest - The processing is necessary for the purpose of the legitimate interests pursued by the ECOTIC and ECOTIC BAT ASSOCIATION or by a third party, in accordance with the law. For example, in case of registration of WEEE / DBA collection requests, the ECOTIC AND / or ECOTIC BAT ASSOCIATION has a legitimate probative interest or to improve the services offered.
  5. e) Vital interest - Processing is necessary to protect the vital interests of the data subject or another natural person.
  6. f) Public interest - The processing is necessary for the performance of a task which serves a public interest or which results from the exercise of the public authority with which the operator is vested.

In the case of special categories of personal data, the ECOTIC AND ECOTIC BAT ASSOCIATION shall refer to the applicable legal provisions in order to always ensure a valid legal basis for processing.

TO WHOM WE TRANSMIT YOUR DATA PERSONAL CHARACTER

Your personal data may be passed on to third parties - competent authorities, operators of collection, transport services, etc., accounting and auditing firms, etc. Whenever we do so, we ensure that there is a justification. thorough, that we will transmit only the data strictly necessary to achieve the purpose of the transmission and we will try to ensure that the recipient ensures a high standard of protection of personal data.

In case of data processing activities performed by a third party provider / supplier / partner / intermediary for the operator of ASOCIATIEI ECOTIC or ECOTIC BAT, based on a service contract of any type concluded between ASOCIATIA ECOTIC or ECOTIC BAT and the respective third party (which has the quality personal data processor from the GDPR point of view), these contracts are concluded in writing and include a series of specific clauses, by which the respective third parties provide to the ECOTIC AND / or ECOTIC BAT ASSOCIATION sufficient guarantees for the implementation of certain appropriate technical and organizational measures so that the processing complies with the requirements of the GDPR and ensures the protection of the rights of the data subject.

The transfer of personal data to an international organization or to a third country vis-à-vis the EU and the EEA (the EEA includes both the EU and Iceland, Liechtenstein and Norway) can only take place if the organization or state to which it intends to make the transfer, can ensure an adequate level of protection in accordance with the requirements of the GDPR.

The transfer of data to an international organization or to a State whose legislation does not provide for an adequate level of protection, recognized by an adequacy decision issued by the European Commission, is possible only if there are sufficient guarantees regarding the protection of the fundamental rights of data subjects. and provided that there are enforceable rights and effective remedies available to the data subjects. These guarantees are established by the ECOTIC AND / or ECOTIC BAT ASSOCIATION, in compliance with the GDPR, in contracts / agreements concluded with the providers / service providers to whom the data is transferred or in other legal ways, as the case may be.

HOW LONG AND HOW WE STORE YOUR DATA PERSONAL CHARACTER

We retain your personal data only for as long as we need or as required by applicable law.

All this time, we ensure that the data is kept safe and, in case of security breaches, we are prepared to apply all technical, organizational and legal measures to limit the possible consequences and inform the ANSPDCP, as well as the data subjects, if there are risks to them.

To the extent possible, we will anonymize data that we no longer need in a manner that allows the identification of data subjects or apply pseudonymization to limit the risks regarding the personal data processed.

WHAT RIGHTS DO YOU HAVE WITH REGARD TO YOUR DATA? WHICH WE PROCESS

The right to access Data

Any data subject has the right to obtain from the ECOTIC and / or ECOTIC BAT ASSOCIATION, when they act as operator, upon request and free of charge for one application per year, confirmation that the data concerning him are or are not processed. therefore, and if so, information will be provided on: the purposes of the processing; the categories of data concerned; the recipients or categories of recipients of the data, in particular recipients from third countries or international organizations, as well as the appropriate guarantees offered in the event of such data transfer; where possible, the period for which personal data are expected to be stored or, if this is not possible, the criteria used to establish this period; the existence of the right to request to the ECOTIC and / or ECOTIC BAT ASSOCIATION the rectification or deletion of the data or the restriction of their processing or of the right to oppose the processing; the right to file a complaint with the ANSPDCP; if the data are not collected from the data subject, any available information on their source; the existence of an automated decision-making process, including profiling, as well as relevant information on the logic used, the meaning and the expected consequences of such processing for the data subject.

Right to rectification

The data subject has the right to obtain from the ECOTIC and / or ECOTIC BAT ASSOCIATION, as data controller, without undue delay, the rectification of inaccurate personal data concerning him.

Taking into account the purposes for which the data were processed, the data subject has the right to obtain the completion of personal data which are incomplete, including by providing an additional statement.

Right to erasure of data ("right to be forgotten")

The data subject has the right to obtain the deletion of personal data concerning him / her without undue delay, and the ECOTIC and / or ECOTIC BAT ASSOCIATION will have the obligation to delete the data without undue delay if:

  1. a) the data are no longer necessary for the purposes for which they were collected or processed;
  2. b) the data subject withdraws his consent on the basis of which the processing takes place and there is no other legal basis for the processing;
  3. c) personal data have been processed illegally
  4. d) the data subject exercises his right to oppose under the conditions of GDPR;
  5. e) the data must be deleted in order to comply with a legal obligation of the operator;
  6. f) personal data were collected in connection with the provision of information society services to minors under the conditions of GDPR;
  7. g) personal data were collected in connection with the provision of information society information to children under the GDPR.

ECOTIC AND / or ECOTIC BAT ASSOCIATION, as data operator, may refuse the request to delete the data under the following conditions:

  1. a) the processing is necessary for the exercise of the right to free expression and information;
  2. b) the processing is necessary for compliance with a legal obligation applicable to the operator;
  3. c) the processing is necessary for reasons related to the public interest in the field of public health, under the respective conditions imposed by the GDPR;
  4. d) the processing is necessary for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes, under the conditions of GDPR, insofar as the exercise of the right may make it impossible or seriously affect the achievement of the processing objectives;
  5. e) the processing is necessary for the ascertainment, exercise or defense of a right in court.

The right to restrict processing

The data subject has the right to obtain from the ECOTIC AND / or ECOTIC BAT ASSOCIATION, as data controller, the restriction of processing in the following cases:

  1. a) the data subject disputes the accuracy of the data, for a period that allows the operator to verify the accuracy of the data;
  2. b) the processing is illegal, and the data subject opposes the deletion of personal data, requesting in return the restriction of their use;
  3. c) The ECOTIC and / or ECOTIC BAT ASSOCIATION no longer needs the personal data for the purpose of processing, but they are necessary for the ascertainment, exercise or defense of a right in court;
  4. d) the data subject has objected to the processing, for the period of time in which it is verified whether the legitimate rights of the operator prevail over those of the data subject.
  5. e) the data subject who obtained the processing restriction is informed by the ECOTIC and / or ECOTIC BAT ASSOCIATION before the processing restriction is lifted.

    The right of opposition

    The data subject has the right to the ECOTIC and / or ECOTIC BAT ASSOCIATION:

    1. a) to oppose at any time, for reasons related to its particular situation, that the data concerning it be subject to processing based on the public interest or the legitimate interest. In the event of opposition, the processing may no longer concern the data in question unless there are legitimate and compelling reasons justifying the processing which prevail over the rights of the data subject or if the purpose is to establish, exercise or defend a right in court.
    2. b) to oppose at any time, free of charge and without any justification, that the data concerning it be processed for the purpose of direct marketing, including the creation of profiles for this purpose.

      The right to data portability

      The data subject has towards the ECOTIC and / or ECOTIC BAT ASSOCIATION. the right to receive - in a structured, commonly used and automatically readable format - personal data concerning him and which he has provided to the Company and to transmit them to another operator in the event of which:

      1. a) the processing is based on consent or a contract; and
      2. b) the processing is performed by automatic means.

      In exercising his right to data portability, the data subject has the right to have his data transmitted directly from the ECOTIC AND / or ECOTIC BAT ASSOCIATION to another operator when this is technically feasible.

      The right not to be subject to an automatic decision (including profiling)

      In this respect, the data subject has the right to the ECOTIC and / or ECOTIC BAT ASSOCIATION not to be subject to a decision based only on automatic processing (including profiling) and which would produce legal effects towards the data subject or which would affect it. significantly.

      This right shall not apply in the following exceptional cases where the automatic decision:

      1. a) it is necessary for the conclusion or execution of a contract between the data subject and the ECOTIC and / or ECOTIC BAT ASSOCIATION;
      2. b) is authorized by Union or national law applicable to the ECOTIC and / or ECOTIC BAT ASSOCIATION and which also provides for appropriate measures to protect the rights, freedoms and legitimate interests of the data subject; or
      3. c) is based on the explicit consent of the data subject.

      In the situations referred to in letters a) and c) of this paragraph, the ECOTIC and / or ECOTIC BAT ASSOCIATION has the obligation to implement the appropriate measures to protect the rights, freedoms and legitimate interests of the data subject, at least his right to obtain human intervention from part of the operator, to express his point of view and to challenge the decision.

      The right to withdraw consent

      If the processing of data is based on your consent, you may withdraw your consent, in which case we will immediately stop processing your personal data. Withdrawal of consent will not affect the processing until then.

      To exercise any of these rights, please contact Data Protection Officer of ECOTIC ASSOCIATION and ECOTIC BAT, at the email address [email protected] or by sending a request to the e-mail address [email protected], correspondence address: Splaiul Unirii, Nr 86, Etaj 4, Sector 4 Bucuresti, phone number 0318055743 Fax 021 3323238.

      The right to go to court and / or ANSPDCP

      The data subject whose personal data are processed by the ECOTIC and / or ECOTIC BAT ASSOCIATION has:

      1. a) the right to file a complaint with ANSPDCP (National Authority for the Supervision of Personal Data Processing, headquarters: Bucharest, 28-30 Gen. Gheorghe Magheru Blvd., sector 1, CP 010336; Telephone: +40.318.05.92.11 , Fax: +40.318.05.96.02 email: [email protected], website: dataprotection.ro) if the data subject considers that the processing of his data is done in violation of the GDPR;
      2. b) the right to take legal action if the data subject considers that the processing of his data is done in violation of the GDPR.