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Confidentiality

1.      WHO ARE WE?

1.1.  This Privacy Policy explains how we, Edenred Digital Center S.R.L., with registered office in Bucharest, 2nd Oltenitei Road, 2nd Floor, 4th District,  Unique Identification Code 41026768, registered with the Trade Register under no. J40 / 5640/2019, Share Capital 10,000 lei (hereinafter referred to as “EDC” or “We”) process your personal data and act as a personal data controller for the performed processing.

1.2.  We invite you to read carefully this privacy policy in order to be adequately informed about how We, as personal data controllers, process your data and respect your rights as a data subject. 

 

2.      WHAT INFORMATION DO WE COLLECT ABOUT YOU?

2.1.  EDC limits the personal data it collects to the data that is necessary for the purpose for which it is collected. Please inform us of any changes or updates that occur regarding your personal data.

2.2.  If you are a visitor of the website www..edenred-digitalcenter.com, we will process your personal data that you provide directly in the context of using this website, such as the data you provide in the contact form, to the extent that you complete such a form. We also process data generated by accessing and using the website (information about the used device - computer, phone, tablet - log information, such as IP address, search queries, browser type, language, hardware settings, date and time of the request), including data about your preferences or other data collected through user activity analysis technologies on websites (such as cookies; we recommend that you also read our Cookies Policy). 

2.3.  If you apply for a job at EDC as a candidate, by accessing the Careers section available on www..edenred-digitalcenter.com or in any other way, we will process your personal data that you provide in this context, such as name, surname, e-mail address, telephone, experience and any other data included in the documents you choose to provide us.

2.4.  If you are the contact person of the Partners (Customers, Partners, Suppliers) or potential Partners, we will process your contact details, such as name and surname, e-mail and telephone address, position/function, place of work, information that you provide in the context of initiating or developing the contractual relationship with the Partners or potential Partners.

2.5.  Through our website, will not be collected and disclosed data on racial or ethnic origin, political, religious, philosophical or similar beliefs, trade union membership or personal data on health or sexual life.  

3.      WHAT IS THE PERSONAL DATA USED FOR AND WHAT ARE THE BASIS OF THE PROCESSING?

3.1.  If you apply for a job at EDC as a candidate, we will process the personal data received through the "Careers" section from www..edenred-digitalcenter.com for recruitment purpose, as detailed within the Notice Regarding Personal Data Protection in Recruitment.

Basis for processing: The processing of your data for this purpose is based on the steps for concluding a contract at your request. If you apply for a specific position but you are not selected for the position for which you applied, we will continue to process your data in considering you for other vacancies similar to those for which you applied, based on your consent, unless you request that your personal data be no longer processed for this purpose. 

Providing your data for this purpose is voluntary. Refusal to provide data may result in EDC's inability to consider you in the recruitment process for various positions.

3.2.  If you are a visitor of the website www..edenred-digitalcenter.com, we process your personal data as follows:

a)      to solve complaints, requests, grievances and to monitor traffic and improve your experience on this website.

Basis for processing: The processing of your data for this purpose is based on EDC’s legitimate interest to ensure proper functioning of the website, as well as to permanently improve visitors’ experience to this website, including by solving various questions or complaints. In the absence of this data, we will not be able to help you solve the problem you are facing.

b)     only if you expressly request us through the Contact form - for marketing activities, respectively for the transmission, through the means of distance communication (for example, e-mail), of commercial communications regarding the products and services offered by EDC.

Basis for processing: We will only send you these communications if you request such communications from us and we have obtained your consent. You may request such communications from us and you may consent to the processing of data for this purpose by completing and expressly requesting such communications through the Contact form on www..edenred-digitalcenter.com. Providing your data for this purpose is voluntary. Refusal to provide consent for the processing of your data for this purpose will have no consequences for you.

3.3.  If you are the contact person of the Partners (Customers, Partners, Suppliers) or potential Partners, EDC processes your personal data as follows:

a)      for the initiation or development of the contractual relationship between EDC and Partners or potential Partners.

Basis for processing: The processing of your data for this purpose is based on both the need to conclude and execute a contract, and EDC’s legitimate interest to initiate and conduct contractual relations in the context of providing the services provided by Us. Refusal to provide data for this purpose may result in EDC being unable to conduct its business.

b)     for marketing activities, respectively for the transmission, through the means of distance communication (for example, e-mail), of commercial communications regarding the products and services offered by EDC.

Basis for processing: The processing of your data for this purpose will be based on EDC’s legitimate interest to transmit communications to professionals designed to ensure the promotion and development of EDC’s business and to facilitate, at the same time, the access of its clients / partners to the services offered by EDC that may be useful / interesting for their business.

c)      for the transmission, through the means of distance communication (email and telephone), of communications regarding improvement of our services.

Basis for processing: Because we have a legitimate business interest in keeping in touch with our partners in order to improve the services and products we offer, we will send you communications related to your degree of satisfaction regarding your relationship with our company (e.g.: satisfaction surveys related to the orders placed), because we are in a contractual relationship with the company you represent and you are the most able person to communicate feedback on the interaction with EDC.

d)     for marketing activities, respectively for the transmission, through the means of distance communication (for example, e-mail), of commercial communications regarding the products and services offered by EDC’s partners.

Basis for processing: For this purpose, we will process your data based on your consent, expressed directly, and based on indirect consent, collected through the contract, for persons who by the nature of their function may receive such communications. 

4.      TO WHOM DO WE DISCLOSE YOUR DATA?

4.1.  From case to case, we may disclose your personal data, exclusively to fulfil the processing purposes, to:

a)      companies within Edenred Group;

b)     our service providers (acting either as operators or as our processors) and whom we contract for administrative and processing services, for marketing, other service providers (e.g. IT service providers); 

c)      market research agencies conducting market research for Us;

d)     other companies with which we can develop joint programs for offering our products and services on the market;

e)     public authorities, if the disclosure is necessary to comply with an obligation stipulated by the applicable law. 

4.2.  Disclosure of your personal data to the above recipients will be done only on the basis of a confidentiality agreement and ensuring an adequate level of security on their level, which guarantees that personal data is kept secure and that its disclosure is done in accordance with the legislation in force. 

5.      TRANSFER OF PERSONAL DATA 

5.1.  The personal data provided to us may be transferred outside Romania, but only to European Union countries.  

6.      DURATION OF PROCESSING 

6.1.  Generally, we will process your personal data to the extent necessary to achieve the processing purposes mentioned above, unless the legal provisions provide or oblige us otherwise. Therefore:

·        regarding commercial communications sent by EDC or its partners, we will keep your e-mail address or telephone number in the database as long as your subscription is active; from the moment we receive your unsubscribe request, we will disable the sending of such communications to your e-mail address or telephone number;

·        regarding the Contact form from our website and the request form for a personalized offer, we will keep your personal data for the period necessary to provide answers to your messages and requests and to prove the correspondence with you; 

·        regarding the applications received through the form from the “Careers” section on our website, in case we do not accept these applications, if you have given your consent, your data will remain in EDC database to participate in recruitment programs that will be carried out in the future, but not more than one year from the date of their collection;

·        regarding the analysis of the navigation on our website and your interactions with the website, we will keep the data for a period of up to 3 years. 

6.2.  EDC may delete your personal data when it considers that it is no longer necessary for the purposes for which it was collected. 

6.3.  In any case, if you withdraw your consent and there are no longer legal grounds for processing or you object to the processing and there are no legitimate and compelling reasons for processing to prevail, we will stop processing the data.  

7.      WHAT ARE YOUR RIGHTS?

7.1.  In connection with this data processing, you have the right to request access to your personal data (you have the right to obtain from EDC confirmation that it processes your personal data, as well as information on the specifics of processing), rectification (modification) or deletion or restricting the processing, the right to object to the processing within the limits and conditions provided by law, as well as the right to data portability (you have the right to request us to provide personal data in a structured, frequently used and automated legible form, for example in Excel format). Also, if you choose to give your consent, you have the right to withdraw it at any time, without affecting the processing carried out by EDC on the basis of the consent expressed by you before its withdrawal.  

In addition, you have the right to submit complaints to the National Supervisory Authority For Personal Data Processing (Website: http://www.dataprotection.ro/; Postal address: 30 G-ral. Gheorghe Magheru Boulevard, 1st district, Bucharest; E-mail: anspdcp@dataprotection.ro; Telephone: + 40.318.059.211 / + 40.318.059.212).

The rights that apply to you depend on the legal basis and purpose of processing your personal data. 

7.2.  For any further questions regarding the way in which personal data is processed and to exercise your rights mentioned above, please contact: gdpr-ro@edenred.com. You can also send a personalized request, signed and dated with your personal data that you want us to update or delete, at our addresses, in attention of the person responsible for processing personal data:

Edenred Digital Center SRL registered office: 2nd Olteniței Road, 2nd Floor, 4th District, Bucharest, Romania

7.3.  Monitoring of compliance with legal requirements in this area is ensured by the data protection officer appointed within Edenred Group, with the following contact details: dpo.romania@edenred.com 

 8.      UPDATING THE INFORMATION INCLUDED IN THIS POLICY 

8.1.  EDC may periodically update this Policy as its business and services expand or change, or where EDC is required by law to make changes. If EDC does this, it will display the latest version on its own website. Therefore, please check regularly for updates. If EDC makes major changes to the practices specified in this Policy, We will notify you using available contact information.