Sibiu:
1. Introduction
Algeco respects your privacy and undertook to protect your personal data. Through this confidentiality notification, we inform you of the way we take care of your personal data when you visit our website (irrespective of the place you visit it from), of your rights to confidentiality and of the way the law protects you.
2. Important information and who we are
Algeco SRL is a Romanian legal entity with the registered office in Str. Turda nr. 30, 550052 Sibiu, registered with the Trade Register Office with no. J32/1094/2007, having the Sole Registration Code RO21970426 in the capacity of author, holder and administrator of the website algeco.ro respects the confidentiality and security of the processing of personal data.
3. The identity and the contact data of the personal responsible for the protection of the data (DPO)
Algeco SRL has appointed a data protection officer (“DPO”). Our DPO can be contacted at the e-mail address below: privacyquestions@algeco.com
DEFINITIONS:
· A.N.S.P.D.C.P. Represents the National Authority for the Surveillance of Personal Data Processing
· “Personal data” means any information regarding an individual identified or identifiable (“aimed person”); an identifiable individual is a person that may be identified, directly or indirectly, especially regarding an identification element, such as an identification number, localization data, an online identifier, or one or several specific elements, own to its physical, physiological, genetic, psychic, economic, cultural or social identity;
· “Processing” means any operation or set of operations performed on the personal data or on the personal data sets, with or without the use of automated means, such as the collection, the recording, the organization, the structuring, the storage, the adjusting or the alteration, the extraction, the consultation, the use, the revealing by sending, disseminating or making available in any other way, the alignment or the combining, the restricting, deleting or destruction;
· “Processing restriction” means the marking of the personal data stored for the purpose of limiting its future processing;
· “Operator” means any individual or legal entity, public authprity, agency or another body which, alone or together with others, establishes the purposes and means for the processing of the personal data; when the processing means and purposes are established through the law of the Union or through the internal law, the operator or the specific criteria for its appointment may be provided in the Union law or the internal law;
· “The person awarded power of attorney by the operator” means any individual or legal entity, public authority, agency or another body processing the personal data for the operator;
· “Recipient” means any individual or legal entity, public authority, agency or another body which receives the personal data, irrespective if it is a third party or not. However, the public authorities to whom the personal data can be sent during a certain investigation according to the Union law or to the internal law are not considered recipients; the processing of this data by the respective public authorities complies with the applicable norms regarding data protection, according to the processing purposes
· “Consent” of the aimed peson means any manifestion of free will, specific, informed and deprived of ambiguity of the aimed person through which it accepts, through a statement or through an unequivocal action, that the personal data regarding it be processed.
4. The purpose of this notification regarding confidentiality
This notification regarding confidentiality has the purpose of offering you information regarding the way Algeco collects and processes your personal data by your use of this website, including any data which you may use through this website, when you sign up for our news report, you purchase a product or a service or take part in a contest.
This website is not intended for children and we do not collect data about children intentionally.
It is important that you read this notification, together with any other notifications regarding confidentiality or the equitable processing which we comunicate in specific situations, when we collect or process personal data about you, in order to be fully informed of the way and the reasons why we use your data. This confidentiality notification supplements the other notifications and is not intended to replace them.
5. The data operator
Algeco is made up of different legal entities, about whom you can find details in the annex to this confidentiality notification. This confidentiality notification is issued on behalf of Algeco group, therefore, when we use the terms “Algeco”, “we” or “our/ours” in its content, we refer to the relevant company within Algeco Group, responsible for the processing of your data. We shall inform you which of the entities will be the operator of your data when you purchase a product or a service from us. The data operator and the responsible person for our local websites if the applicable local entity mentioned in the annex to this confidentiality notification, in this case, Algeco Romania.
If you have questions about this confidentiality notification, including requests for the exercise of your legal rights, contact privacyquestions@algeco.com
You have the right to submit a complaint at any time with the surveillance authority in the matter of data protection, respectively The National Authority for the Surveillance of the Personal Data Protection. However, we would appreciate the possibility of answering your concerns before you address the surveillance authority, so we are asking you to contact us first
Modifications of the confidentiality notification and your obligation to inform us about the modifications
This version was last updated on 1 June 2018.
It is important that your personal data we have on you be accurate and updated. Please inform us if your personal data changes during the performance of your relation with us.
Links to third parties
It is possible that our website contains links to websites, plugins or third-party applications. By clicking these links or by activating these connections you may allow third parties to collect or communicate data about you. We do not control these third-party websites and we are not liable for their confidentiality policy. When you leave our website, we encourage you to read the confidentiality notification on each website that yuo visit.
6. The data we collect on you
The personal data, or the personal information, means any information about a person that allows the identification of that person. It does not include the data from which the identity was removed (anonymous data).
We can collect, store and transfer different types of personal data about you, which we grouped as follows:
- The identification data includes the first name, name before marriage, last name, user name or similar identifier, civil status, title, date of birth and gender.
- The contact data includes invoicing address, delivery address, e-mail address and telephone numbers.
- The financial data includes the bank account and details about the card used for payment.
- The transaction data includes details about the payment towards and from you and other details about the products and services which you bought from us.
- The technical data includes the Internet protocol (IP) address, your connection data, browser type and version, time zone and location settings, types and versions of the browser plugins, the operating system and platform and other technologies from the devices you use in order to access this website.
- The profile data includes your user name and password, the purchases or the orders that you made, your interests, preferences and feedback and your replies to surveys.
- The usage data includes information about the way you use the website, our products and services.
- Marketing and communication data includes your preferences for the reception of marketing materials from us and from third parties associated to us and your communication preferences
We also collect, use and communicate aggregate data, as well as statistical or demographical data for any purposes. The aggregate data can derive from your personal data, but it is not considered personal data according to the law because this data does not reveal, directly or indirectly, your identity. For example, we cannot aggregate your usage data in order to calculate the users percentage that access a certain function of the website. However, if we combine or connect the aggregate data with/to your personal data so that it may identify you directly or indirectly, we treat the combined data as personal data, which will be used according to this confidentiality notification.
We do not collect data about you from any of the Special personal data categories (this includes details about race or ethnicity, religious confession or philosophical convictions, sex life, sexual orientation, political opinions, union adherence, information about health and genetic and biometric data). We do not collect any data about criminal and offence convictions.
If you do not supply personal data
When we have the obligation to collect personal data according to the law or to the terms of a contract we have concluded with you and you do not supply this data when it is required, it is possible we may not carry out the contract we have concluded or we are trying to conclude with you (for example, in order to supply goods or services). In this case, we may need to cancel a product or a service that you requested from us, but we will notify you if that is the case at the right moment.
7. How do we collect your personal data?
We use three ways in order to collect data from and about you, including by:
Direct interactions. You may supply your Identification, contact and financial data by filling in forms or having a correspondence with us by mail, telephone, by e-mail or in another way. This includes personal data that you supply when:
- You ask questions about our products or services; You create an account with us;
- You subscribe to our service or our publications; You request to be sent marketing materials;
- You enroll in a contest, a promotion or a survey; or You offer feedback.
Automated technologies or interactions When you interact with our website, it is possible that we may automatically collect Technical Data about you equipment and about the actions and surfing patterns. We collect this data using cooking modules, server logs and other similar technologies. We can also receive Technical Data about you if you visit other websites using our cookie modules.
Third parties or publicly available sources It is possible that we may receive personal data about you from different third parties [and public sources] as described below [like, without being limited to]
Technical data from the following parties:
- Analyses suppliers [like Coface, Keysfin, Termene.ro, ICAP Group, mfinante.ro ]
- Advertising networks [Google, Facebook, Twitter, Youtube, ]; and
- Information search suppliers [such as Google, Yahoo, Linkedin, eJobs, ]; and Contact, financial and transactions data from technical, payment and delivery services suppliers [PayU, Netopia, Ghiseul.ro, Google Adwords]
- Identification and contact data from intermediaries or collectors of data [Coface, KeysFin, victa.ro, listafirme.ro, verificaretva.ro, ICAP Group, BRD Asigurari de viata].
- Identification and contact data from publicly available sources [such as the Trade Register – portal.onrc.ro and Portal.just.ro, Buletinul Procedurilor de Insolventa (Bulleting of the Insolvency Procedures), The Official Journal, mfinante.ro].
8. How we use your personal data
We shall use your personal data only when the law allows us to. Most frequently, we shall use your personal data under the following circumstances:
- When we must execute the contract we are about to conclude or which we have concluded with you.
- When it is necessary for one of our lawful interests (or that of a thrd party), and your fundamental interests and rights do not prevail on the former.
- When we must comply with a legal or regulatory obligation.
Generally, we are not based on the consent as legal grounds for the processing of your personal data in other cases different from the sending of the notifications of the direct marketing communications of the third parties to you, by e-mail or text message. You have the right to withdraw your marketing consent at any time, by contacting us at privacyquestions@algeco.com.
The purposes for which we shall use your personal data
We have mentioned below, as a table, the description of all the ways in which we intend to use your personal data and what the legal grounds on which we are based for this purpose are. We have also identified, our lawful interests, as applicable.
Note that we can process your personal data based on several legal grounds, according to the specific purpose for which we use your data. Please contact us at privacyquestions@algeco.com if you need details about the specific legal grounds on which we are based in order to process your personal data when several legal grounds are mentioned in the table below.
Marketing
We try to offer you options regarding certain usages of the personal data, especially related to marketing and advertising.
Promotional offers from us
We can use your Identification, contact, technical, usage and profile data in order to outline an image of what we consider that you or the company you represent want or need or of what can be of interest to you or your company. This is the way we decide which are the products, services and offers potentially relevant (we call this activity marketing).
You will receive marketing communications from us if you requested information from us or if you purchased goods or services from us or if you supplied your data to us when you entered a contest or a promotion and, in each case, you have not waived the reception of that marketing content.
Third party marketing
We shall obtain your express consent before communicating your personal data to any company outside the Algeco companies group for marketing purposes.
Waiver
You can request us or third parties not to send you marketing messages, contacting us by e-mail at the address privacyquestions@algeco.com at any time.
When you waive receiving these marketing messages, this does not apply to personal data which you supplied following a purchase of products/services, guarantee record, experience with the product/services or following other transactions.
Cookie modules
You can set your browser to decline all or a part of the cookie modules or to alert you when the websites set or access cookie modules. If you deactivate or refuse the cookie modules, note that it is possible that some sections of this website may become unaccessible or not function correctly.
Modifications of the purpose
We shall use your personal data solely for the purposes we collected it, except for the cases when we reasonably consider that we need to use it for another purpose, compatible to the initial one.
If we need to use your personal data for a purpose unrelated to the initial one, we shall inform you and we shall explain to you the legal grounds which allow us to do so.
Note that it is possible that we may process your personal data without your knowledge or consent, according to the rules above, when the law imposes or allows that.
9. Revealing your personal data
It is possible that we may need to communicate your personal data to the parties mentioned below, for the purposes mentioned in table from point 4 above.
- Internal third parties, as explained in the Glossary. External third parties, as explained in the Glossary.
- The third parties we choose to conclude sale, transfer or merger transactions with of our activity or our assets. Alternatively, we may search to purchase other enterprises or merge with them. If changes occur in our enterprise, the new owners may use your personal data in the way described in this confidentiality notification.
We request all third parties to observe the safety of your personal data and to treat it according to the law. We do not allow the third-party services providers to use your personal data for own purposes and we only allow them to work with your personal data for the purposes mentioned and in compliance with our instructions.
10. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
11. Data safety
We apply appropriate safety measures in order to prevent accidental loss, unauthorized usage or accessing, damaging or revealing of your personal data. Moreover, we limit the access to your personal data to those employees, agents, contractors and other third parties which have a professional interest in order to know it. They will process your personal data only according to our instructions and comply with our confidentiality obligation.
We apply procedures in order to treat any suspected violation of the personal data and shall notify, you and any relevant regulatory authority, about the violation when we have the legal obligation to do so.
12. The period during which we keep the personal data
We shall keep your personal data for as long as it is necessary to comply with the legal purposes we collect it for, including for the purpose of the compliance with any legal, accounting or reporting requirements.
In order to establish the appropriate period for the keeping of your personal data, we take into consideration the volume, the nature and the sensitive character of the personal data, the possible prejudice risk for the unauthorized use or revealing of your personal data and if we can comply with these purposes through other means, as well as through the applicable legal requirements.
The details regarding the periods during which to keep the different aspects of your personal data are available in our policy regarding the keeping of the data, which you may request by contacting us at privacyquestions@algeoc.com
13. Your legal rights
Under certain circumstances, the legislation concerning data protection gives you rights related to your personal data. See the attached annex “Your legal rights” fo more details.
If you wish to exercise any of the rights mentioned above, contact us at privacyquestions@algeco.com.
Usually, no fee is applied
You do not have to pay any fee in order to access your personal data (or in order to exercise any of the other rights). However, we may charge a reasonable fee if the request is obviously ungrounded, repetitive or excessive. Alternatively, we may refuse to comply to your request in such circumstances.
What we can request from you
It is possible that we may need specific information from you in order to help us confirm your identity and in order to ensure your right of access to personal data (or the performance of any of your rights). This is a security measure in order to make sure that your personal data is not revealed to a person who does not have the right to receive it. We may also contact you in order to request more information about your request so that we may reply more quickly.
Deadline for the reply
We try to reply to all your lawful requests within a month. At times, it is possible that we may need more than a month if your request is especially complex or you have made several requests. In this case, we shall notify you and shall inform you regularly.
14. Glossary LEGAL GROUNDS
Lawful interest means the interest of our company in obtaining and managing our activity, in order to allow us to offer you the best service/product and an optimum experience, secured to the maximum. We make sure that we consider and balance any possible impact (both positive and negative) on you and on your rights before processing your personal data to our lawful interests. We do not use your personal data for activities in which the impact on you has priority before our interests (except for the cases when we have ypur consent or the law allows us to do so). You can obtain more information about the way we assess our lawful interests compared to any possible impact on you within some specific activities contacting us at privacyquestions@algeco.com.
The carrying out of the contract means the processing of your data when it is necessary to carry out a contract you are not part of or in order to perform action at your request before concluding such a contract.
Compliance with the legal or regulatory obligation means the processing of your personal data when it is necessary for the compliance with a legal or regulatory obligation to which we comply.
THIRD PARTIES
Internal third parties
Other companies within Algeco Group acting together as data operators or as persons appointed by the operator and supplying [IT & Data and system administration Services and having the obligation of reporting to the management].
External third parties
- Services suppliers [acting as persons appointed by the operator], with the registered office in Romania that supply [IT services & System administration Data]
- Professional consultants [acting as data operators or, together, as persons appointed by the operator] including attorneys, bankers, auditors and insurers, and that supply [HR, consultancy, controlling, banking, legal, insurance, labor medicine, security services etc.]
- ANAF (National Authority of Fiscal Administration), Trade Registry, CAS, CASS, National Statistics Institute, BNR, AJOFM which impose the reporting of the processing activities under certain circumstances,
- ITM which imposes the compliance with the norms according to the current legislation and may intervene at any time through unannounced controls.
- ICAP Group, Coface, victa.ro, listafirme.ro, verificaretva.ro, BRD Asigurări de viață (Life Insurances), The Commerce and Industry Chambers in Romania of different countries
- Legal Establishments of the state, according to specific cases and at accurate requests (police, court of law etc.)
YOUR LEGAL RIGHTS
You have the following rights:
- The right to request access to your personal data (known as the “right of access of the aimed person”). This right allows you to obtain a copy of the personal data we have on you and to check if we process it legally.
- The right to request the adjustment of the personal data we have on you. This right allows you to obtain the correction of any incomplete or inaccurate data we have about you, although it is possible that we may need to heck the accuracy of the new data you supply.
- The right to request the deletion of your personal data. This right allows you to request us to delete or remove personal data when there are no more legal grounds for the continuation of its processing by us. You also have the right to request us to delete or remove your personal data when you have successfully exercised the right to object the processing (see below), when it is possible that we may have processed your information unlawfully or when the local law requires us to delete your personal data. However, note that it is possible not to always be able to comply ypur request to delete for specific legal grounds, which we will notify to you, if applicable, on the date of your request.
- The right to object the processing of your personal data, when we are based on legal grounds (or on that of a third party) and some of your particular circumstances determine you to object the processing for this reason because you consider that it affects your fundamental rights and freedoms. You also have the right to object when we process your personal data for direct marketing processing. In some cases, we can prove that we have solid lawful grounds to process your information, which has priority before your rights and freedoms.
- The right to request the restriction of the processing of your personal data. This will allow us to request the suspension of the processing of your personal data under the following circumstances:
- (a) if you wish to establish the accuracy of the data;
- (b) when the usage of the data by us is unlawful, but you do not wish for us to delete the data;
- (c) when you need us to keep your data even if we do ot need it anymore because you need it in order to establish, exercise or defend actions in a court of law; or
- (d) you have objected to the usage of your data by us, but we need to check if we have priority lawful grounds to use it.
- The right to request the transfer of your personal data to you or to a third party. We shall supply, to you or to a third party you have chosen, your personal data in a structured form, currently used and which can be read automatically. Note that this right only applies to the automated information to whose usage by us you have agreed initially or when we used the information in order to carry put a contract concluded with you.
- The right to withdraw your consent at any time when we are based on the consent to process your personal data. But this will not affect the legality of the processing of the data processed before withdrawing your consent. If you withdraw your consent, it is possible that we are not able to supply certain products or services. We shall inform you in this sense if applicable when you withdraw your consent.
15. The confidentiality may be changed
We reserve the right to alter/supplement the Confidentiality Policy at any time, displaying the altered Confidentiality Policy on ww.algeco.ro
16. Contact data for the National Authority for the Surveillance of the Personal data processing (ANSPDCP)
Address: B-dul G-ral Gheorghe Magheru 28-30, Sector 1, cod poștal 010336, București, România e-mail: anspdcp@dataprotection.ro
Tel: +0318.059.211; +0318.059.212
ANNEX
LIST OF APPLICABLE ENTITIES WITHIN ALGECO GROUP
|
Algeco Global Sarl |
Luxembourg |
|
Algeco Investments B.V. |
The Netherlands |
|
Algeco Holdings B.V. |
The Netherlands |
|
Elliott Group Holdings (UK) Limited |
UK |
|
Elliott Group Limited |
UK |
|
MBM Mietsystem für Bau and Industrie GmbH |
Germany |
|
Algeco GmbH |
Germany |
|
Algeco s.r.o. |
Czech Rep. |
|
Touax s.r.o. |
Czech Rep. |
|
Touax SK s.r.o. |
Slovakia |
|
Algeco S.R.L. |
Romania |
|
Algeco Oy |
Finland |
|
Algeco Schweiz AG |
Switzerland |
|
Ristretto Investissements SAS |
France |
|
Algeco SAS |
France |
|
Algeco Belgium NV |
Belgium |
|
Algeco S.p.A. |
Italy |
|
Algeco Holdings, S.L. |
Spain |
|
Algeco Construcciones Modulares, S.L. |
Spain |
|
Algeco - Construcões Pré-Fabricadas, S.A. |
Portugal |
|
Touax Solutions Modulaires SAS |
France |
|
Touax Module Asset S.à r.l. |
France |
|
Touax Espana S.A. |
Spain |
|
Algeco Polska Sp. Zo.o. |
Poland |
|
Algeco LLC |
Russia |
|
Algeco B.V. |
The Netherlands |
|
Algeco Holdings (Austria) GmbH |
Austria |
|
A1 Container Austria GmbH |
Austria |
|
A1 Container Slovenia d.o.o. |
Slovenia |
|
Algeco Kft. |
Hungary |
