SPIA

Privacy policy and processing of personal data

Browsing the pages of our site is possible without any declaration of personal data. However, for certain specific situations such as completing the Contact form, certain personal data may be collected and processed by data subjects.

If the processing of personal data is necessary and there is no statutory basis for such processing, we undertake to obtain the consent of the data subject.

The processing of personal data (such as name, surname, address, e-mail address, telephone number of the data subject) will be performed each time in accordance with the provisions of Regulation no. 679 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 (“the Regulation”) and in accordance with specific data protection regulations the country in which SC SPIA operates Secret Private Investigations Agency SRL.

Through this Policy, our company informs the general public about the nature, extent and purpose for which we collect and process personal data. In addition, the data subjects are also informed about the rights they enjoy, rights regulated by the Regulation. As an operator, SC S.P.I.A. Secret Private Investigations Agency SRL has already implemented numerous technical and organizational measures to ensure the complete protection of personal data.

Definitions

This Policy is based on the Regulation, as well as all applicable laws on the protection of personal data. The policy must be comprehensible both to the general public and to our customers and business partners. To ensure this, we will explain the terminology used. In this Policy we will use the following terms:

Personal data refers to any information that makes it possible to identify a natural person (data subject).

The data subject is an identified or identifiable natural person. An “identifiable” natural person is a person who can be identified, directly or indirectly, including by reference to an identification number or to one or more factors characteristic of his physical, physiological, mental, economic, cultural or social identity.

Processing is the performance of any operation or set of operations on personal data, with or without automatic means, such as collection, registration, organization, storage, adaptation or modification, retrieval, consultation, use, disclosure (by transmission, dissemination or provision) otherwise), align or combine, block, delete or destroy.

The processing restriction refers to the marking of personal data processed in order to limit their processing in the future.

Profiling refers to any authorized form of processing of personal data consisting in the use of personal data to assess certain personal aspects characteristic of an individual, in particular to analyze or predict aspects related to work performance, economic situation, health , personal preferences, interests, reliability, location or movements of an individual.

Pseudonymization is the processing of personal data in such a way that personal data can no longer be assigned to a data subject without the use of additional information, provided that such additional information is stored separately and is subject to technical and organizational measures to ensure that that personal data is not attributed to an identified or identifiable natural person.

The controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or with the help of third parties, determines the purposes or means of the processing of personal data; where the purposes and means of processing are determined by the legislation of the European Union or the Member States, the operator or the specific criteria for its designation may be provided by the legislation of the European Union or the Member States.

The recipient is a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether a third party or not. However, public authorities that may receive personal data in a particular investigation in accordance with European Union or Member State law will not be seen as recipients; the processing of such data by public authorities shall be in accordance with the rules applicable to data protection in accordance with the purposes of the processing.

A third party is a natural or legal person, public authority, agency or other body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

The consent of the data subject is any indication given freely, specific, informed and clear, which the data subject provides through a clear statement or affirmative action, signifying the consent for the processing of his personal data.

Name and address of the operator

SC S.P.I.A. Secret Private Investigations Agency SRL based in Bucharest, email: gdpr@spiaromania.com, Website: www. spiaromania.com.

Address of the data protection officer

Any data subject can contact us directly at any time with any questions or suggestions regarding the protection of personal data at the following e-mail address gdpr@spiaromania.com.

Possibility of contact through the website

The website www.spiaromania.com contains information that allows a short electronic contact with our company, as well as direct communication with us, by including a general email address. If a data subject contacts us by email or through the contact form, the personal data transmitted by him voluntarily are stored automatically. Such personal data, voluntarily transmitted by an data subject to the controller, are stored for the purpose of processing and contacting the data subject.

Routine deletion and blocking of personal data

SC S.P.I.A. Secret Private Investigations Agency SRL will process and store personal data of the data subject only for the period necessary to fulfill its storage purpose or for the period provided by the European legislator or by other applicable laws. If the purpose of the storage is not applicable or if the storage period provided for by the applicable legislation in force expires, the personal data are deleted, in accordance with legal requirements.

The rights of the data subject

Right of access of the data subject: in order to exercise the right of access, the data subject may at any time contact SC S.P.I.A. Secret Private Investigations Agency SRL with a request in this regard, through which to obtain a report of personal data.

Right of rectification: each data subject has the right to obtain the rectification of personal data when they are incorrect or have undergone certain changes or need to be completed.

Right of deletion: each data subject has the right to request the deletion of personal data as follows:

– when the data are no longer necessary for the purpose for which they were collected or processed,
– the data subject withdraws the consent on the basis of which the processing takes place,
– the data subject objects to processing in accordance with Article 21 (1) of the Regulation and there are no legal grounds for processing or the data subject objects to processing in accordance with Article 21 (2) of the Regulation,
– personal data have been processed illegally or a legal provision in force requires their deletion.

Right to a restriction on processing: each data subject has the right to obtain a restriction on the processing, where one of the following cases applies:

– the accuracy of personal data is contested by the data subject,
– the processing is illegal and the data subject objects to the deletion of personal data, but instead requests that their use be restricted,
– SC S.P.I.A. Secret Private Investigations Agency SRL no longer needs personal data in order to process them, but they are requested by the person concerned for the unit, in order to exercise certain rights,
– the data subject objected to the processing in accordance with Article 21 (1) of the Regulation until it was verified whether the legitimate grounds of SC S.P.I.A. Secret Private Investigations Agency SRL prevails over those of the data subject.

Right to data portability: each data subject has the right to request the transfer of personal data to a third party or to the data subject himself.

Right to object: each data subject has the right to object at any time, for reasons related to his / her particular situation, to the processing of personal data concerning him / her, which is based on points (e) and (f) of Article 6 (1) of the Regulation. This also applies to profile creation. SC S.P.I.A. Secret Private Investigations Agency SRL will no longer process personal data in the event of opposition, unless we can demonstrate convincing and legitimate grounds for processing, which override the interests, rights and freedoms of the data subject, or for establishing, exercising or defending legal rights. If SC S.P.I.A. Secret Private Investigations Agency SRL processes personal data for direct marketing purposes, where there is prior consent, the data subject will have the right to object at any time to the processing of his personal data for such marketing. This applies to profiling to the point where it is related to such direct marketing. If the data subject objects to the processing carried out by SC S.P.I.A. Secret Private Investigations Agency SRL for direct marketing purposes, then SC S.P.I.A. Secret Private Investigations Agency SRL will no longer process your personal data for these purposes. In addition, the data subject has the right, on grounds related to his particular situation, to object to the processing of his personal data by SC S.P.I.A. Secret Private Investigations Agency SRL for the purposes of scientific research or historical research or for statistical purposes, in accordance with Article 89 (1) of the Regulation, unless the processing is necessary to perform a task performed in the public interest.

Individual decision-making, including profiling: each data subject has the right not to be subject to a decision based solely on automatic processing, including profiling, which has legal effects on it or similarly significantly affects him or her, both as long as the decision is not based on the explicit consent of the data subject. SC S.P.I.A. Secret Private Investigations Agency SRL will implement adequate support measures to protect the rights and freedoms of the data subject and legitimate interests, at least the right to obtain human intervention from SC S.P.I.A. Secret Private Investigations Agency SRL, to express their point of view and to challenge the decision.

Right to withdraw consent: each data subject has the right to withdraw his or her consent to the processing of personal data at any time.

Right to lodge a complaint with the supervisory authority: if the data subject considers that his or her legitimate rights in relation to the processing of personal data have been infringed, he or she may lodge a complaint with the National Supervisory Authority. Personal Data, based in G-ral Blvd. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania.

If you wish to exercise your rights or send us a notification / request, please contact us at the contact details indicated in this Policy. SC S.P.I.A. Secret Private Investigations Agency SRL will reply you as soon as possible, but not later than 30 days. For any delays we will notify you and give you the justified reasons for the delay.

Legal basis for processing

Article 6 (1) letter of the Regulation serves as a legal basis for the processing of operations for which we obtain consent for a specific purpose of processing.

If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, when the processing operations are necessary for the supply of goods or any other service, the processing is based on Article 6. paragraph (1) letter b of the Regulation. The same applies to processing operations that are necessary to carry out pre-contractual measures, for example in the case of inquiries into our products or services.

Our company is subject to a legal obligation which requires the processing of personal data, such as the fulfillment of tax obligations, the processing is based on art. 6 (1) lit. c Regulation. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor has been injured in our company and the name, age, health insurance data or other vital information should be passed on to a doctor, hospital or other third party. Then, the processing will be based on Art. 6 (1) letter. d of the Regulation. Finally, the processing operations could be based on Article 6 (1) (f) of the Regulation. This legal basis is used for processing operations that are not covered by any of the legal reasons mentioned above, if the processing is necessary for the purpose of the legitimate interests pursued by our company or a third party, unless such interests are removed by the interests or fundamental rights and freedoms of the data subject who require the protection of personal data. Such processing operations are especially permitted because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is the customer of the operator (recital 47 of sentence 2 of the Regulation).

Legitimate interests pursued by the operator or a third party

If the processing of personal data is based on Article 6 (1) (f) of the Regulation, it is in our legitimate interest to conduct our business for the benefit of all our employees and shareholders.

The period for which personal data will be stored

Personal data will be kept only for the period necessary for the purpose for which they were collected. After the expiry of that period, the corresponding data shall be deleted. Only those personal data that are part of acts / documents for which the law provides for an archiving term will be kept. Upon expiration of the legal archiving term, they will be destroyed.

Provision of personal data as a legal or contractual requirement

We clarify that the provision of personal data is required in part by law (eg tax regulations) or may also result from contractual provisions (eg information on the contractual partner). Sometimes, it may be necessary to conclude a contract according to which the data subject provides us with personal data, which must be further processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her.

Protection of personal data

SC S.P.I.A. Secret Private Investigations Agency SRL applies an internal framework of policies and minimum standards regarding the protection of personal data. These policies and standards are regularly updated to comply with market regulations and developments. In accordance with the legal provisions in force, we take appropriate technical and organizational measures (policies, procedures, security, etc.) precisely to ensure the confidentiality and integrity of personal data, as well as to ensure the necessary framework for their processing.

By accessing our site, the user expressly declares that he has become aware of his rights and obligations in accordance with the provisions of these regulations and undertakes to comply with the terms and conditions of use of the site.

At the same time, the user expressly agrees that his personal data will be processed, within the limits and conditions described herein, by SC S.P.I.A. Secret Private Investigations Agency SRL based in Bucharest, (as an operator) directly or through a proxy (if applicable), for future commercial communications. The data will be kept by the operator until the time of unsubscription. At the time of unsubscribing, the data will be deleted from the database of the operator and the authorized persons (if applicable).

The user expressly declares that he / she has been informed that he / she can exercise free of charge the right to information, access, restriction, rectification, deletion, the right to data portability, opposition, not to be subject to an automated individual decision-making process, the right to the address of justice or to submit a complaint to ANSPDCP by a written request sent by email to gdpr@spiaromania.com. Withdrawal of consent at any time will not affect the lawfulness of the processing carried out on the basis of the consent before its withdrawal. The data will be kept by the operator for a maximum period of 3 years from the time of preparation of this declaration. At the end of the retention period, the data will be deleted from the database of the operator and the authorized persons (if applicable).