The protection of your personal data is very important to us. This notification describes our practices regarding the way we collect and use your personal data. For example: what data we collect, why and for what purpose, and explains your rights regarding personal data.
In this document, you can find information on the following topics:
- WHO WE ARE
- HOW WE COLLECT YOUR PERSONAL DATA
- HOW WE SHARE INFORMATION
- TRANSFERS OF INFORMATION OUTSIDE THE EUROPEAN UNION
- YOUR RIGHTS
- CHANGES OF THIS NOTIFICATION
- CONTACT INFORMATION
- WHO WE ARE
Vouchers Depot SRL is a company with the registered office at Bucharest, Romania, Str. Siriului 42-46, Et. 3, registered with the Trade Register under no. J40/17010/2022, Fiscal Registration no. RO46745101. We collect and process various categories of personal data from you, which, in accordance with European Union legislation on the protection of personal data, gives us the status of data controller for such data.
- HOW WE COLLECT YOUR PERSONAL DATA
Personal data can be collected or accessed in several ways, including:
- directly from you (for example, by signing a contract, filling out a form on the website or calling us on the phone);
- from third parties (e.g. employer, representative).
- Data provided directly by you
We may collect data that you have provided directly. This will usually happen when:
- you purchase our products or services;
- you contact us through the contact forms on our website, by e-mail, by phone, by chat or through social platforms.
- you conclude an agreement with us to provide products or services;
- Data collected automatically
We may collect your data automatically. This will usually happen when:
- You communicate with us (for example, through social platforms);
- You make public posts on the social media platforms that we follow (for example, to respond to requests for Create Direct products and services).
- Data provided by third parties
If permitted by the law, we may obtain data about you from third parties, for example, publicly available profile information (such as your preferences and interests) from third-party social media sites (such as Facebook).
We may also collect data in other contexts that are brought to your attention at that time.
What data do we collect about you?
- data necessary to provide you with our services and products;
- data you provide us in forms and contracts;
- data you provide us in phone calls;
- data you provide us in the emails you send us;
- data that you provide to us in the chat requests that you send us;
- data about your preferences and interests;
- data necessary to respond to your requests and notifications;
- data necessary for the management and administration of our relationship with you, your employer or your representative;
- data necessary for the purchase of products or services;
- data necessary for marketing or consulting in connection with our products or services;
- information about what you do through your activity that is related to our customers, our products and services or us.
The data we collect directly from you will be obvious from the context in which you provide it. E.g.:
- if you request information about one of our services, using the forms on our website, provide us with your name, contact details, company name and the services you are interested in;
The data we automatically collect will generally cover:
- details about your call (such as time and duration);
The data we collect from third parties will generally consist of publicly available information (such as function, preferences, and interests), for example, obtained from posts on social media platforms.
For what purpose do we use your data and on what legal basis?
Depending on the nature of our relationship with you, we may use the information about you for the following purposes:
- To comply with legal obligations, such as archiving data in accordance with applicable law or paying taxes and tax contributions;
- To sell you our products and services;
- To send you offers of relevant products/ services, based on an advanced analysis of your interests;
- To defend our rights and interests in court;
- To manage the contractual relationship with you or your employer;
- To ensure compliance with applicable laws, such as those regarding the keeping and use of your records in connection with any anticipated litigation, for the purpose of obtaining legal advice from lawyers or other consultants;
- To sell our products and services to you, including processing your payments;
- To respond to requests for information;
- To inform you about our products, services, promotions, and events;
- For other purposes that we bring to your attention or that will be clear from the context at the time the information about you was first collected.
The legal basis for the use of your data is one of the following:
- compliance with a legal obligation to which we are subject;
- execution of a contract to which you are a party;
- our legitimate interest which is not removed by your interests in protecting your personal data;
- your consent, which we will request before processing the data.
The purposes for which we use the information about you, together with the appropriate collection methods and the legal basis for its use, are:
Collection method and legal basis for processing
Compliance with regulatory obligations
This information is generally provided to us directly by you, when a relationship is established between us or you interact with us.
We use this information because we are required to conduct business in accordance with the law (including company law and tax code), maintain financial and tax records, comply with trade sanctions, to comply with applicable law. In health and safety (which may include keeping records of incidents), preparing reports, responding to requests for information from the competent authorities, and managing any conflicts of interest.
Marketing our products and services
In general, we will receive this information directly from you (usually your name, job email address, orders, services, and payment information).
We use this information to fulfill the contract with you as our customer or, where there is no such legal obligation, we use this information because we have a legitimate interest in carrying out our business or in connection with the products and services that we provide you, to process payments and to manage the relationship with you, an interest that is not undermined by your interests, rights, and freedoms to protect information about you.
Business promotion and relationship management (where allowed by the law)
This information is generally provided to us directly by you (usually your name, or business email address).
We use this information because we have a legitimate business interest in managing the relationship between us and informing you about our business and products, which is not ineligible for your interests, rights, and freedoms to protect your information.
In general, we will receive the information directly from you.
We use this information because we have a legitimate business interest in conducting business, managing our relationship with you, and maintaining the security and integrity of our buildings and IT systems. This interest is not invalidated by your interests, rights, or freedoms to restrict the use of your information.
Support to achieve all the above goals
In general, we will receive the information directly from you.
We use this information on the basis that it is for the purpose for which we use the information, for which we provide support.
In some cases, we may use data about you in ways not described above. In this case, we will provide an additional privacy notice explaining this use.
- HOW WE SHARE DATA
We may share data about you with:
• Third parties providing products or services to us or to you (such as your employer, payment service providers, courier service providers, retailers, etc.);
• Third parties providing products or services, such as couriers, IT system providers and related service providers, including telecommunications service providers, backup and disaster recovery, IT security services and other providers outsourced services, such as off-premises storage and cloud storage service providers;
• Third parties, if required or permitted by law, for example: regulators, government departments, in response to a request from law enforcement or other government officials, when disclosure is necessary or appropriate to prevent injury physical or financial losses or in connection with an investigation of a suspected or actual illegal activity, and in the context of organizational restructuring.
- DATA TRANSFERS OUTSIDE THE EUROPEAN UNION
As a rule, personal data will not be transferred outside the EU. However, if the transfer of personal data to non-EEA countries is necessary, we will take the necessary measures to ensure the appropriate level of protection and security in accordance with applicable laws, including the introduction of standard contractual clauses in the contracts concerned that transfer.
How do we protect your data?
We implement appropriate technical and organizational measures to protect the personal data we hold against unauthorized disclosure, use, modification, or destruction. If necessary, we use encryption and other technologies that can help secure the information you provide. We also ask our service providers to comply with strict data privacy and security requirements.
How long will the information about you be kept?
We will keep the information about you for as long as is necessary to fulfill the purposes for which the information was collected. After that, we will delete them. The period will vary depending on the purposes for which the information was collected. In certain circumstances, you have the right to ask us to delete the information. We are also sometimes legally required to retain information, for example, for tax and accounting purposes.
Normally, we retain data based on the criteria described in the table below:
Typical storage explanation / criterion
We keep records of invoices, sales, purchases, payments made and received and related documents (such as contracts and emails) in accordance with the requirements of company law and the tax code, usually for 11 years. We will also keep records of supplier inspections for as long as is necessary to comply with our legal and regulatory obligations.
If you purchase services, we will retain the details of this transaction for as long as it takes to perform the contract and to comply with any legal obligations (for example, for the purpose of keeping tax and accounting records).
Systems audit logs are usually kept for only a few months.
- According to the law, you have the following rights regarding your personal data that we process:
- Right of access: you can obtain confirmation from us that we process your personal data, as well as information on the specifics of the processing. This right allows you to obtain a free copy of the personal data processed, as well as any additional copies for a fee.
- Right to rectify data: you can ask us to modify your incorrect personal data or, if necessary, to fill in data that is incomplete.
- Right of deletion: you may request the deletion of your personal data when: (i) they are no longer necessary for the purposes for which we collected and processed them; (ii) you have withdrawn your consent for the processing of personal data and we can no longer process them on other legal grounds; (iii) personal data are processed unlawfully (iv) personal data must be deleted in accordance with the relevant legislation.
- Right of opposition and withdrawal of consent (if applicable): you may object to the processing for reasons related to your situation, or you may withdraw your consent at any time regarding the processing of personal data that are processed based on consent, without, however, this affecting in any way the processing carried out previously.
- Right of restriction: you may request the restriction of the processing of your personal data if: (i) you challenge the correctness of the personal data, for a period that allows us to verify the accuracy of the data in question; (ii) the processing is illegal, and you object to the deletion of personal data, requesting in return the restriction of their use; (iii) the data is no longer necessary for our processing, but you request it from us for a court action (iv) if you objected to the processing, for the period of time in which it is verified whether the legitimate interests of the company as an operator prevail over your rights as a data subject.
- The right to portability (if applicable): you may request us, in accordance with the law, to provide you with your personal data which you have provided to us in a structured, frequently used and legible form. automatically. Also, if you expressly request us, we may pass on your personal data to another entity, if technically possible.
- Rights of automated decisions including profiling, which produce legal effects on the data subject or similarly affect them to a significant extent: Create Direct does not make such profiling to be followed by automated decisions with significant legal or similar effect for the person concerned.
- The right to file a complaint with the supervisory authority: you have the right to file a complaint with the National Supervisory Authority for the Processing of Personal Data in case you consider that your rights have been violated. Contact details: B-dul G-ral Gheorghe Magheru 28-30, Sector 1, postal code 010336 Bucharest, Romania, email@example.com.
Consent may be withdrawn at any time. This withdrawal of consent does not affect the lawfulness of the processing up to that point, but upon withdrawal of consent, Create Direct will stop processing that data.
To exercise your rights, please contact us using the contact details mentioned in section 8 below.
- CHANGES TO THE NOTIFICATION
We may update this notice from time to time (and any additional privacy notices). We will notify you about the changes, when required to do so, by the law.
- CONTACT INFORMATION
If you have any questions about this notification, or you wish to exercise your rights as mentioned above, you may contact us using the following contact information:
Correspondence address: Strada Siriului, no. 42-46, 3rd floor, sector 1, Bucharest.