Privacy policy

Respecting your privacy is one of our fundamental commitments and, therefore, we pay the utmost attention to the processing of your personal data, in accordance with applicable law.

INTRODUCERE

We recognize the importance of maintaining the confidentiality, integrity and security of your personal information ('Personal Data') and have written this privacy policy (“Policy”) to explain how your Personal Data is collected, stored, used and disclosed by Turing Tech S.R.L., a company incorporated under the Romanian law, having its headquarters at 126, Vasile Lascar Street, Bucharest, Tax Code 43037054, registered with the Trade Registry under no. J40/11479/2020 (‘StartGDPR’, ‘us’), as a data controller, with respect to (i) your access and use of our website available at the URL [www.startgdpr.com](https:// startgdpr.com/) ('Platform') and to (ii) the provision of our Services through our Platform and outside of the Platform.

CATEGORIES of PERSONAL DATA, PURPOSES of PROCESSING, and LEGAL GROUNDS

1. Browsing data

Computer systems and software procedures used for the Site’s operation acquire, during their normal operation, some Personal Data (so-called log files), the transmission of which is implicit in the use of internet communication protocols. This information is not collected in order to be associated to identified persons, but due to its nature can, by means of processing and integration with data held by third parties, allow users to be identified. Such information includes the IP addresses, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, and other parameters concerning the user’s operating system and computer environment. Insofar such information leads to the identification of a user, the provisions of this Policy shall become applicable. Purpose of processing We use this data for the sole purpose of obtaining anonymous statistical information concerning the use of the Platform and to check its correct operation.

Legal ground

  • Our legitimate interest in the improvement of our Site and in managing the server capacities, and in the bug-free preservation of our Platform (art. 6 para. 1, let. f GDPR);
  • Compliance with our legal duties concerning the security aspects of our systems, including without limitation those resulting from the StartGDPR obligation to take appropriate technical and organizational measures for the processing of Personal Data (art. 6 para. 1, let. c GDPR).

2. Creating an account

In our Platform you have the possibility to register and create an account. In such a case, we will process your e-mail address.

Purpose of processing: The purpose of this processing is to create the account, to provide our Services through the Platform and to provide help in using the Platform.

Legal ground: Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (art. 6 para. 1, let. b GDPR).

3. Contacting StartGDPR

You can contact us in different ways: by e-mail or, by phone, by support form, or by chat. In this case, in general, we will process the following Personal Data: first name, last name, email, telephone number, company and any other information you voluntarily provide when you contact us.

Purpose of processing: In this situation, we will use your Personal Data only to contact you in connection with the requested offer or in connection with the resolution of the problem.

Legal ground: Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (art. 6 para. 1, let. b GDPR).

4. Feedback

You can give us suggestions for improving the Platform through the feedback feature or other contact method. In this case, we will process the following Personal Data: e-mail and any other information we willingly provide when you give us feedback.

Purpose of processing: In this situation, we will only use your Personal Data to contact you in the related to the resolution of the problem indicated.

Legal ground: Your consent. (art. 6 para. 1, let. a GDPR).;

At the same time, when you use the feedback feature, you can give us access to the browsing data of your session (collected anonymously and only if you have agreed to the use of analytics cookies). In this case, the relevant data (anonymous to date) will be associated with you and become Personal Data.

Purpose of processing: In this situation, we will use your Personal Data only to better understand your feedback.

Legal ground: Your consent. (art. 6 para. 1, let. a GDPR).;

5. Contractual and service notifications

During the provision of our services, we will use your email address and your phone number to notify you of any changes in the terms of the Platform and in connection with any other issues related to the performance of the contract between you and StartGDPR (e.g., aspects related to the use of the Platform, modification of documentation, possible technical problems, etc.). Purpose of processing: In this situation, we will use your Personal Data to contact you in related to the performance of the contract between startGDPR and you and in relation to the provision of services.

Legal ground: Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (art. 6 para. 1, let. b GDPR).

6. Marketing messages

You can opt in to receive marketing messages via email and telephone.

Purpose of processing: If you opt to receive such marketing messages, we will use your e-mail and/or telephone number to send you marketing messages about our activities and promotions.

Legal ground: Your consent. (art. 6 para. 1, let. a GDPR). You can revoke your prior consent at all times and without any costs, with altering consequences for the future.

7. Invoicing

When using our Platform, we will issue invoices for the fee payment. In this case, we will process your first name, last name and address.

Purpose of processing: The purpose of this processing is to issue the invoices for the payment of the fee. Legal grounds:

  • Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (art. 6 para. 1, let. b GDPR);
  • Processing is necessary for compliance with a legal obligation to which the controller is subject (art. 6 para. 1, let. c GDPR);

PROVIDING PERSONAL DATA

You may refuse to provide certain Personal Data (indicated above) but, in such a case, you may not be able to benefit from services specific to the contractual relationship described in this Policy.

AUTOMATIC PROCESSING of PERSONAL DATA

Your Personal Data will not be processed for taking decisions based solely on automatic processing that would result in legal effects concerning you or could similarly significantly affect you.

DURATION

As a rule, we will process your Personal Data during the existence of your account in our Platform. In certain circumstances, we may retain your Personal Data for longer periods of time, for example if we are obliged to do so in accordance with the legal, regulatory, tax or accounting requirements. We may also keep your Personal Data for longer periods of time so that we have accurate records of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

TRANSFER of PERSONAL DATA

We may transfer Personal Data, as far as necessary, to the following categories of recipients:

  • Contractual partners;
  • subcontractors;
  • payment processors;
  • companies offering IT services;
  • marketing companies;
  • public authorities, courts of law or arbitral tribunals, and authorities competent to investigate criminal offence. These recipients can be located in the European Union and/or in the European Economic Area. Where recipients are located outside the European Union and the European Economic Area, including in countries not recognized as ensuring an adequate level of protection, the transfer of Personal Data shall be carried out only if there are appropriate guarantees, in accordance with applicable law. In this respect, we rely on several guarantees, such as the standard contractual clauses issued by the European Commission. You may receive from us a list of recipients from third countries, as well as a copy of the agreed provisions that ensure an adequate level of protection of Personal Data. For any request to this effect, please contact us at the contact details mentioned below. .

SECURITY of PERSONAL DATA

The security of your Personal Data is important to us. Your Personal Data will therefore be processed by applying reasonable technical and organizational measures to protect Personal Data, such as limiting access to Personal Data, encryption or anonymization of Personal Data, storage on secure environments. However, despite our efforts, we cannot always guarantee the effectiveness of the security measures implemented, and therefore we cannot guarantee the security of Personal Data at any time.

RIGHTS in CONNECTION WITH the PROCESSING of YOUR PERSONAL DATA

Your rights

You have the following rights in connection with the processing of your Personal Data: Access right: You have the right to obtain from us confirmation that your Personal Data is processed by us, as well as information on the specific processing, such as: the purposes of processing, categories of processed Personal Data, recipients of Personal Data, the period for which Personal Data is stored, if we transfer the Personal Data abroad and how we protect it, your rights, the right to lodge a complaint before the supervisory authority, the source of your Personal Data. Right to rectification: You have the possibility to request rectification of your Personal Data, provided that the applicable legal requirements are met. In the event of errors, after notification, we will immediately correct your Personal Data. Right to erasure: In certain cases, you have the possibility to request the deletion of Personal Data, namely when: (i) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent on which the processing is based according and where there is no other legal ground for the processing; (iii) you exercise the right to object to the processing; (iv) the Personal Data have been unlawfully processed. We are not obliged to comply with your request when the processing is necessary (among others) for compliance with a legal obligation or for the establishment, exercise or defense of legal claims. There are also other circumstances in which we are not obliged to comply with this request for the deletion of Personal Data. Restriction of processing: You may request us to restrict the processing of your Personal Data in the following circumstances: (i) you contest the accuracy of the Personal Data, for a period enabling us to verify the accuracy of the Personal Data; (ii) the processing is unlawful and then you oppose to the erasure of the Personal Data and request the restriction of their use instead; (iii) we no longer need the Personal Data for the purposes of the processing, but you require them for the establishment, exercise or defense of legal claims; (iv) you have objected to processing, pending the verification whether our legitimate grounds override yours. However, we can continue to process your Personal Data (i) when you consent; (ii) for the establishment, exercise or defense of legal claims or (iii) for the protection of the rights of another natural or legal person. Right to data portability: Insofar the Personal Data is processed based on your consent or on the execution of the agreement and the processing is carried out by automated means, you have the right to have your data Personal Data provided to you in a structured format, which is currently used and can be read automatically and you have the right to request us to transfer this Personal Data to another controller. This right shall not adversely affect the rights and freedoms of others. Right to opposition: In certain situations, such as when we process your Personal Data on the basis of a legitimate interest, or for the purpose of sending marketing messages, you have the right to object to the processing of your Personal Data by us. In the event of unjustified objection, StartGDPR is entitled to continue processing Personal Data. Revocation of consent: Insofar you consented to the processing of your Personal Data, you can at all times revoke your consent, without affecting the lawfulness of processing based on consent before its withdrawal. Right not to be subject to any automatic individual decisions: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Such right cannot be exercised when the decision: (i) is necessary for entering into, or performance of, a contract between you and us; (ii) is authorized by law which lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (iii) is based on your explicit consent. Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with The National Supervisory Authority for Personal Data Processing (“DPA”) in relation to any breach of your rights regarding the processing of your Personal Data. The contact details of the DPA are: 28-30 Gheorghe Magheru Boulevard, District 1, Postal Code 010336, Bucharest, Romania; e-mail: [email protected]

How to exercise your rights

To learn more about the manner in which you may exercise the aforementioned rights, please contact us at [email protected] Identity verification: We take utmost care of the confidentiality of all Personal Data and we reserve the right to verify your identity if you make a request in relation to your Personal Data Fees: As a rule, you can exercise your rights free of charge. However, we reserve the right to request a reasonable fee if your claims are manifestly unfounded or excessive, in particular because of their repetitive nature. Response Time: We make every effort to respond to your request within one month of receiving the request. This period may be extended by two further months where necessary, taking into account the complexity and number of the requests, in which case we will inform you of any such extension and of the reasons for the delay

CONTACT

If you have any questions or concerns about this Policy or its implementation, you may contact us at [email protected].