Data protection notice

Notificare de protecție a datelor

DATA PROTECTION NOTICE

The protection of your personal data is very important to us. This notice describes our practices regarding the collection and use of your personal data — for example, what data we collect, why, and for what purposes — and explains your rights concerning your personal information.

In this document, you will 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
SECURITY
YOUR RIGHTS
CHANGES TO THIS NOTICE
CONTACT INFORMATION

1. WHO WE ARE

Vouchers Depot is a joint-stock company headquartered at Str. Siriului no. 42–46, 3rd floor, Sector 1, Bucharest, Romania, registered with the Bucharest Trade Registry under number J40/17010/2022, tax code RO46745101.

We collect and process various categories of your personal data, which, under the European Union data protection legislation, qualifies us as a data controller for such data.

2. HOW WE COLLECT YOUR PERSONAL DATA

Personal data may be collected or accessed in several ways, including:

• directly from you (for example, by signing a contract, filling in a form on our website, or contacting us by phone);

• automatically (for example, data observed when you browse our website https://vouchersdepot.com/

2.1. Data provided directly by you

We may collect data that you provide directly. This usually happens when you:

• purchase our products or services;

• contact us via contact forms on our website, by email, by phone, via chat, or through social media platforms;

• enter into an agreement with us to supply products or services;

• enter into an agreement with us for us to supply products or services to you;

• participate in an event organized by us;

• register to receive marketing communications from Vouchers Depot;

• visit our headquarters or other offices.

2.2. Data collected automatically

We may collect data about you automatically. This usually happens when you:

• visit our headquarters or other offices (e.g. through video recordings (CCTV) and building access logs);

• communicate with us (for example, via social media platforms);

• make public posts on social media platforms that we monitor (for example, to respond to inquiries regarding Vouchers Depot products and services).

We may also automatically collect data about you through the use of cookies and similar tracking technologies.

Our use of tracking technologies (such as cookies or non-cookie technologies like web beacons) on our website is described in our Cookie Policy section.

2.3. Data provided by third parties

Where permitted by law, we may obtain information about you from third parties — for example, publicly available profile information (such as your preferences and interests) from third-party social media websites (e.g., Facebook).

We may also collect data in other contexts, which will be communicated to you at the time of collection.

What data do we collect about you?

• Data necessary to provide you with our services and products;

• Data you provide to us in forms and contracts;

• Data about your visits to our offices and work points;

• Data you provide during phone calls;

• Data you provide in the emails you send us;

• Data you provide in chat requests or messages;

• Data about your preferences and interests;

• Data necessary to respond to your inquiries and complaints;

• Data necessary to manage and administer our relationship with you, your employer, or your representative;

• Data required for the purchase of products or services;

• Data necessary for selling or providing consultancy regarding our products or services;

• Information about your activity that relates to our clients, our products and services, or our company.

The data we collect directly from you will be evident from the context in which you provide it. For example:

• If you request information about one of our services using the forms on our website, you provide us with your name, contact details, company name, and the services you are interested in;

• If you are a supplier, in order to manage our relationship with you or your employer, you provide us with your name, contact details, billing information, and details about the products/services, so that we can fulfill our contractual obligations;

• You may also provide us with information about your preferences and interests so we can invite you to events that may be of interest to you.

The data we collect automatically will generally include:

• Details about your visit or call (such as the time and duration, for example);

• How often you visit our offices or work points, which areas you access/visit, and for how long;

• Information about your device (for example, your IP address or unique device identifier, details about any cookies we have stored on your device, etc.).

The data we collect from third parties will generally consist of publicly available information (such as job title, preferences, and interests), for example, obtained from posts on social media platforms.

For what purpose do we use your personal data and on what legal basis?

Depending on the nature of our relationship with you, we may use your information for the following purposes:

• To comply with legal obligations, such as data archiving according to applicable legislation or the payment of taxes and fiscal contributions;

• To sell our products and services to you;

• To send you offers for relevant products/services, based on advanced analyses of your interests;

• To defend our rights and interests in legal proceedings;

• To manage the contractual relationship with you or your employer;

• To ensure compliance with applicable laws, such as those concerning the retention and use of your records in connection with any anticipated litigation, for the purpose of obtaining legal advice from lawyers or other consultants;

• To purchase products or services from you or your employer, including to contact you in order to maintain our business relationship, obtain services related to sales operations, and pay for goods, services, or reimburse expenses (where applicable);

• To sell our products and services to you, including processing your payments;

• To respond to your requests for information;

• To inform you about our products, services, promotions, and events;

• To defend our rights and interests in legal proceedings;

• For other purposes that we will notify you of, or that will be clear from the context at the time your information is first collected.

The legal basis for using your data is one of the following:

• Compliance with a legal obligation to which we are subject;

• Performance of a contract to which you are a party;

• Our legitimate interest, which is not overridden by your interests in protecting your personal data;

• Your consent, which we will request before processing your data.

The purposes for which we use your information, along with the corresponding collection methods and legal bases, are as follows:

Purpose

Method of collection and legal basis for processing

Compliance with regulatory obligations

Tax and accounting obligations
Health and safety management
Requests for disclosure of information in accordance with laws and regulatory requirements
Conflict of interest management
Retention of contracts and related documents in which you may be referenced

This information is generally provided directly by you when a relationship is established between us or when you interact with us.

We use this information as it is necessary for conducting our business in compliance with applicable laws (including company and tax regulations), maintaining financial and accounting records, complying with trade sanctions, adhering to health and safety legislation (which may include maintaining incident records), preparing reports, responding to information requests from competent authorities, and managing any conflicts of interest.

Purchasing products or services

Establishing contact with you or your employer while you provide us with products or services
Processing payments
Managing the relationship

We generally receive this information either directly from you or through your employer (typically including your name, position, company address, business email address, orders, services, payment information, and, where applicable, expense details and correspondence).

We use this information to perform the contract concluded with you or your employer as the purchaser of our products or services, or as our client. Where no such contractual obligation exists, we process this information based on our legitimate interest in conducting our business — for example, to contact you in relation to the products or services we receive from you or your employer, or those we provide to you, to process payments, and to manage our relationship with you or your employer. This legitimate interest is not overridden by your interests, rights, or freedoms regarding the protection of your personal data.

Marketing and sale of our products and services

Establishing contact with you or your employer while we provide you with products or services
Fulfilling orders (including issuing invoices)
Processing your payments
Managing the relationship

This information is generally provided to us directly by you or, as applicable, by your employer (typically including your name, position, company address, business email address, orders, payment information, and correspondence).

We use this information to fulfill our contractual obligations to you or your employer as the purchaser of our products.

Commercial promotion and relationship management (where permitted by law)

Sending you information about relevant updates, promotions, and events
Managing our relationship

This information is generally provided to us directly by you or, where applicable, by your employer (typically including your name, position, company address, and business email address).

We use this information based on our legitimate business interest in managing our relationship with you and keeping you informed about our activities, products, and events—an interest that is not overridden by your rights and freedoms to protect your personal information.

Business administration

• General organizational management and maintenance of business records

• Administration and record-keeping of visitors

• Organization and administration of events

• Correspondence related to our relationship with you or your employer, including handling your requests for information or inquiries

• Development, implementation, operation, and maintenance of IT systems

• Ensuring the security of systems, devices, and buildings

• Operating a safe working environment

• Maintaining the safety and security of Vouchers Depot personnel, clients, suppliers, visitors, and property

In general, we receive this information either directly from you or from your employer.

We use this information based on our legitimate business interest in conducting our operations, managing our relationship with you, and maintaining the security and integrity of our buildings and IT systems—an interest that is not overridden by your rights and freedoms to restrict the use of your personal information.

Security and system monitoring

• Control systems and authentication/access logs, where applicable

• Monitoring of systems, devices, internet, and email to which you are granted access

• Monitoring access to Vouchers Depot premises and security-related processes at our locations

This information is collected automatically through various means, such as automated systems, device monitoring, and CCTV recording within our premises.

We use this information based on our legitimate business interest in ensuring the confidentiality, integrity, and security of our physical and digital infrastructure and premises—an interest that is not overridden by your rights and freedoms to protect your personal information.

Support in achieving all of the above purposes

• Corresponding with you

• Improving your experience

• Administration and troubleshooting

These are generally a combination of information you provide to us (for example, contact details) and information we collect automatically (for example, information about your device and cookies or similar tracking technologies).

We use this information based on the legal grounds that correspond to the purpose for which we use the information to provide support.

In some cases, we may use information about you in ways not described above. In such instances, we will provide an additional privacy notice explaining that use.

3. HOW WE SHARE YOUR DATA

We may share information about you with:

Third parties that provide products or services to us or to you (such as your employer, advisors, payment service providers, courier services, retailers, information service providers, etc.);
Third-party service providers, such as couriers, IT system providers and related support services, including telecommunications, data backup and disaster recovery providers, cybersecurity service providers, and other outsourced service providers such as off-site or cloud storage services;
Third parties where required or permitted by law, for example: regulatory authorities, government departments, in response to requests from law enforcement or other public officials, when disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity, and in the context of organizational restructuring.

4. TRANSFERS OF DATA OUTSIDE THE EUROPEAN UNION

As a general rule, personal data will not be transferred outside the EU. However, if a transfer of personal data to countries outside the EEA is necessary, we will take the necessary measures to ensure an adequate level of protection and security in accordance with applicable laws, including by incorporating standard contractual clauses into agreements covering such transfers.

5. SECURITY

How do we protect your data?
We implement appropriate technical and organizational measures to protect the personal data we hold against unauthorized disclosure, use, alteration, or destruction. Where applicable, we use encryption technologies and other methods that can help secure the information you provide. We also require our service providers to comply with strict data confidentiality and security requirements.

How long will your information be retained?
We will retain your information for as long as necessary to fulfill the purposes for which it was collected. After that, it will be deleted. The retention period may vary depending on the purposes for which the information was collected. In certain circumstances, you have the right to request that we delete your information. Additionally, we may be 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:

Retention of Information

Type	Typical Retention Explanation/Criterion
Information recorded in databases	If you have provided services (either directly or via your employer), most information about you is retained for the duration of our relationship; for example, as long as you continue to provide services or respond to our communications. Certain elements, such as purchase history, will naturally expire after a defined period, and will be automatically deleted according to the purpose for which they were collected.
Commercial and payment records	We retain records of invoices, sales, purchases, payments made and received, and related documents (such as contracts and emails) in accordance with corporate law and tax code requirements, usually for 11 years. We also retain records of supplier checks as long as necessary to comply with legal and regulatory obligations.
Visitor logs	If you visit our premises, visitor logs are usually retained for only a few months.
CCTV	If you visit our premises, CCTV recordings are usually retained for a few days up to a few weeks, depending on the purpose of the recording.
Purchases	If you purchase services, we retain the details of the transaction as long as necessary to execute the contract and comply with any legal obligations (e.g., for tax and accounting recordkeeping).
System audit logs	System audit logs are usually retained for only a few months.

6. YOUR RIGHTS

Under the law, you have the following rights regarding your personal data that we process:

Right of access: You can obtain confirmation from us as to whether we process your personal data, as well as information about the specifics of the processing. This right allows you to receive a free copy of the personal data processed, with any additional copies provided for a reasonable fee.
Right to rectification: You may request that we correct inaccurate personal data or, where applicable, complete incomplete data.
Right to erasure (“right to be forgotten”): You can request the deletion of your personal data when:
1. The data are no longer necessary for the purposes for which we collected and processed them;
2. You have withdrawn your consent for data processing and we have no other legal basis to process the data;
3. The personal data have been processed unlawfully; or
4. The personal data must be deleted in accordance with applicable law.
Right to object and withdraw consent (where applicable): You may object to the processing of your data for reasons related to your particular situation, or you may withdraw your consent at any time for processing based on consent, without affecting the lawfulness of processing carried out before the withdrawal.
Right to restriction of processing: You may request the restriction of your personal data processing if:
1. You contest the accuracy of the data for a period that allows us to verify the data;
2. The processing is unlawful and you oppose the erasure of the data, requesting restriction instead;
3. The data are no longer necessary for processing, but you require them for legal claims; or
4. You have objected to processing while we assess whether our legitimate interests override your rights.
Right to data portability (where applicable): You may request, under applicable law, that we provide your personal data that you have given us in a structured, commonly used, machine-readable format. Upon your explicit request, we may also transmit your personal data to another entity, where technically feasible.
Rights regarding automated decisions and profiling: Vouchers Depot does not carry out automated profiling that leads to legal effects or similarly significant impacts on the data subject.
Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing if you consider your rights have been violated. Contact details: B-dul G-ral Gheorghe Magheru 28-30, Sector 1, Postal Code 010336, Bucharest, Romania, anspdcp@dataprotection.ro

7. CHANGES TO THIS NOTICE

We may update this notice (and any additional privacy notices) from time to time. We will notify you of changes whenever required by law.

8. CONTACT INFORMATION

If you have any questions about this notice or wish to exercise your rights as described above, you can contact us using the following details:

Mailing Address: Strada Siriului, No. 42-46, 3rd Floor, Sector 1, Bucharest, Romania
Email: helpdesk@vouchersdepot.com

Telefon: +40212070097

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