Privacy policy and personal data protection
The Privacy and Personal Data Protection Policy aims to provide information regarding the collection, use and disclosure to third parties of personal data by SC HOTEIT BRAND SRL, a Romanian company, with registered office in Voluntari, Ilfov County, Erou Iancu Nicolae Street No. 75A, building 1, room C, floor 3, apartment 10, Romania, registered with the Trade Register in accordance with, J23/1610/2014, unique registration code 33236165 (hereinafter referred to as "Cedrelle").
Your privacy is very important to us. Therefore, we strive to process your personal data in accordance with the principles set out in the data protection legislation applicable in Romania, including Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("GDPR"). Personal data means any information relating to an identified or identifiable natural person, and an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the physical, psychological, mental, economic, cultural or social identity of that person.
Your privacy is very important to us. Therefore, we strive to process your personal data in accordance with the principles set out in the data protection legislation applicable in Romania, including Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("GDPR"). Personal data means any information relating to an identified or identifiable natural person, and an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the physical, psychological, mental, economic, cultural or social identity of that person.
This privacy and data protection describes:
• The categories of personal data we collect and process;
• The purposes for which we collect and use your personal data;
• The reasons for processing for such purposes;
• Duration of processing this data
• Your rights as data subjects and how you can exercise them;
• To whom we may disclose personal data.
I. CATEGORIES OF PERSONAL DATA. PURPOSE AND BASIS OF PROCESSING
In the context of your interaction with Cedrelle, you as a natural person may be subject to the data processing activities we carry out. We inform you that we use your personal data in the following cases:
1. If you are a customer or potential customer of Cedrelle
1.1. Purposes of processing
1.1.1. Providing the products and services requested from us
We use your relevant personal data to provide the products you have requested. For example, in delivering products to you, we may rely on your personal data (e.g. delivery address) to fulfil our contractual obligations. Also, in order to process payments made when purchasing products online through our website, we may process your bank card details.
In this case, we rely on the performance of the contract (in the broad sense) as the basis for processing (including making deliveries, processing payments).
1.1.2. Communication with you
You may send us comments, suggestions or questions related to our website and our products and/or services as well as the processing of your personal data through our website www.cedrelle.com.
In this case, we use your contact details to communicate with you regarding your requests. The purpose of the processing in this case is to analyze your requests and provide answers to them.
1.1.3. Data processing as an obligation imposed by law
We may process some of your data in the context of providing services and products based on obligations imposed by law (for example, the obligation to comply with tax laws). In this case, the basis for processing is the fulfillment of a legal obligation.
1.1.4. Sending newsletters
We may also use your contact details to provide you with specialist newsletters about our products and services in electronic form, but only if you have subscribed and therefore expressed your express consent to such processing. You can withdraw your consent at any time, expressing your option not to receive newsletters in the future by clicking "Unsubscribe" when you receive the respective email or by writing to us at contact@cedrelle.com.
1.2. Categories of data processed in the context of our relationship with you
a) In the event that you purchase products through our website (regardless of whether you have an account on the site or not) – the data we process are: your name, e-mail address, telephone number, your address (or addresses, if you indicate multiple delivery addresses, for different deliveries).
If you wish to pay for products purchased from Cedrelle by credit or debit card, you will be asked to provide information on these credit or debit cards exclusively for the purpose of processing your payment using this method.
All relationships established between Cedrelle and each customer through the website for or after submitting an order will be carried out in accordance with the Terms and Conditions of the website and this Privacy Policy.
b) If you have an account on our website - the data we process are: your name, email address, telephone number, your address (or addresses, if you indicate multiple addresses).
Creating an account on the website is not conditional on submitting an order. However, creating an account can make ordering products easier, as once your details are entered when creating the account, they will not need to be re-entered for each order.
Thus, by creating an account you can save the desired products in a list, view previous orders submitted through the site, and have your data automatically filled in when you place an order.
You will also need to set a password to access your account. Please ensure that you keep your password and any other information related to your account confidential.
Your data will be stored for the purpose of registering and operating the account opened on our website, in order to provide you with the opportunity to efficiently manage your orders.
2. If you are a representative or contact person of a client or potential client of Cedrelle
2.1. Purposes of processing
2.1.1. Providing services and products requested from us
We use your personal data to prepare and provide the services and/or products you have requested. For example, we may use your personal data to manage the relationship with the client you represent. We rely on our legitimate interest in providing our products in line with our business and in managing our client relationships.
2.1.2. Communication with you
We use your contact details to communicate with you regarding your requests and any other relevant aspects related to our collaboration or potential collaboration. In this case, we also rely on our legitimate interest in providing our services and products in accordance with our field of activity.
2.1.3 Data processing as a legal obligation
We may process some of your data in the context of providing services and products based on a legal obligation, if applicable. In this case, the basis for the processing is the fulfillment of a legal obligation.
1.1.4. Sending newsletters
We may also use your contact details to provide you with specialized newsletters about our services and products in electronic form, but only if you have subscribed and therefore expressed your express consent to such processing. You can withdraw your consent at any time, expressing your option not to receive newsletters in the future by clicking "Unsubscribe" when you receive the respective e-mail or by writing to us at the e-mail address contact@cedrelle.com.
1.2. Categories of data processed in the context of our relationship with you
The categories of data processed in the context of our relationship with you are: name, email, telephone, as well as other personal data provided to Cedrelle, if necessary to fulfill the above purposes.
In all cases, the data is provided either directly by you.
3. If you are an employee or other collaborator of a Cedrelle client or potential client
3.1. Purposes of processing
3.1.1. Providing services and products requested from us
We use your relevant personal data to prepare and provide the services and/or products requested. For example, we may use your personal data to manage the relationship with the client you represent. In this case, we also rely on the legitimate interest in providing our products and/or services in accordance with our field of activity.
3.1.2. Communication with you
We use your contact details to communicate with you regarding your requests and any other relevant aspects related to our collaboration or potential collaboration. In this case, we rely on the legitimate interest in providing our services and products according to our field of activity.
3.1.3. Data processing as an obligation imposed by law
We may process some of your data in the context of providing services and/or products based on obligations imposed by law, if applicable. In this case, the reasons for the processing are the fulfillment of a legal obligation.
3.1.4. Sending newsletters
We may also use your contact details to provide you with specialized newsletters about our services and products in electronic form, but only if you have subscribed and, therefore, expressed your express consent for such processing. You can always withdraw your consent, expressing your option not to receive newsletters in the future by clicking "Unsubscribe" when you receive the respective email or by writing to us at contact@cedrelle.com.
3.2. Categories of data processed in this context
The categories of data processed in this context are: name, position, email, telephone, as well as other personal data provided to Cedrelle, usually by you, if necessary to fulfill the above purposes.
In all cases, the data is provided either directly by you or by the client.
4. If you are a Cedrelle business partner or supplier
4.1. Purposes of processing
4.1.1. Maintaining our contractual relationship with you
We use your relevant personal data to maintain our contractual relationship with you. In this case, we rely on the performance of the contract as the basis for processing.
4.1.2. Communication with you
We use your contact details to communicate with you regarding any relevant aspects of our contractual relationship. In this case, we also rely on the performance of our contract as the basis for processing.
4.1.3. Data processing as a legal obligation
We may process some of your data in the context of providing services and products based on the fulfillment of a legal obligation, if applicable. In this case, the basis for the processing is the fulfillment of a legal obligation.
4.2. Categories of data processed in the context of our relationship with you
The categories of data processed in the context of our relationship with you are: your name, email address, telephone number, your address, as well as other personal data that you may provide to us directly.
5. If you are a representative, contact person, employee or other collaborator of a Cedrelle business partner
5.1. Purposes of processing
5.1.1. Maintaining our contractual relationship with our business partner
We use your relevant personal data to maintain the contractual relationship with our business partner (including a supplier). In this case, we rely on the legitimate interest of ensuring that the contractual relationship is managed appropriately.
5.1.2. Communication with you
We use your contact details to communicate with you regarding any relevant matters relating to our partnership relationship. In this case, we rely on the legitimate interest of ensuring that the contractual relationship is managed appropriately.
5.1.3 Data processing as a legal obligation
We may process some of your data in the context of providing our services and products on the basis of compliance with a legal obligation. In this case, the basis for processing is compliance with a legal obligation.
5.2. Categories of data processed in this context
The categories of data processed in this context are: name, position, email, telephone, address, as well as other personal data provided to Cedrelle, usually by you, if necessary to fulfill the above purposes.
In all cases, the data is provided either directly by you or by the business partner.
6. If you are applying for a job
We use the personal data contained in the CVs we receive from you to assess the qualifications of applicants for a position within Cedrelle. We rely on this in order to carry out the steps taken for the purpose of concluding and executing a contract.
The categories of data processed in the context of our relationship with you are your name, email address, telephone number, address, personal data included in CVs, details about education and training, professional qualifications, as well as other personal data that you may provide directly.
7. If you are a visitor to our premises
We use your personal data to ensure the security of our premises, assets and personnel.
To this end, we have installed cameras that are located in a visible location and are accompanied by pictograms. The cameras have been placed in a way that minimizes the impact on individual privacy and we conduct periodic assessments to ensure that their use remains justified.
The recorded images will be kept for as long as necessary for an incident to be discovered and for the incident to be investigated. With this in mind, all recordings are deleted after a period of one month.
Except for the competent authorities, the images will not be provided to third parties.
In this case, the data processing is based on Cedrelle's legitimate interest, namely the protection of these spaces, goods and people.
The categories of data processed in this context are your name, images (obtained as mentioned above) as well as other personal data that you can provide us directly.
8. If you are a visitor to our website
We use the personal data we collect from you when you visit our website, www.cedrelle.com, to process and respond to your questions submitted through our website, as well as to send the newsletters you have subscribed to while visiting our website.
We base this data processing activity on our legitimate interest in providing the requested information in relation to our activity, services and products. The categories of data processed in this context are your name, email address and telephone number.
We use Google Analytics to analyze information collected from website visitors, whether or not they have created an account. This information allows Cedrelle to better understand website users and how they use the website. No personally identifiable information is included in this type of reporting.
II. PROVISION OF PERSONAL DATA
When data is requested directly from you, Cedrelle asks you to provide the categories of personal data that we request for the purposes mentioned above, as otherwise we will not be able to carry out our activity (including, among other things, to offer you services and products).
If you provide Cedrelle with the personal data of other individuals, please inform them prior to such disclosure of the manner in which Cedrelle intends to process the personal data, as described in this privacy and personal data protection policy.
III. DISCLOSURE OF PERSONAL DATA
Although we will not generally disclose your personal data to third parties, we may:
• If necessary, transfer your data by disclosing or providing remote access, only through secure applications, to third parties, such as Cedrelle's business partners, who act as data processors for and on behalf of Cedrelle (e.g. for hosting, legal and financial assistance, suppliers or service providers providing shipping assistance), with whom Cedrelle has concluded the necessary contractual agreements, required by EU and national regulations. We will transfer data to third parties exclusively to the extent necessary to serve the applicable processing purposes for which your data is collected and processed.
• Disclose data to comply with the law or in response to a request from a court or other legal authority, such as a warrant or subpoena. Cedrelle may also share information in the good faith belief that it is necessary to prevent or manage fraud or to protect Cedrelle.
• If necessary, to disclose relevant personal data to the competent authorities, in the context of providing the products and services you have requested from us.
IV. PROCESSING DURATION
We intend to retain your personal data for the duration of the contract concluded with you, as well as thereafter, in accordance with our internal policies and the legal obligations to which we are subject.
If data is not collected in the context of an agreement, such data will be retained for as long as necessary to achieve the purpose of the intended data collection or any longer period required by law, a record retention regulation or public authorities.
Immediately after the end of the applicable archiving period, the data must be:
• Deleted or securely destroyed; or
• Transferred to an archive (unless prohibited by law or record retention regulations).
Personal data collected and used for subscribing to our newsletter will be deleted immediately if you unsubscribe from our newsletter service.
V. YOUR RIGHTS
As data subjects, GDPR gives you a number of rights, including:
• Right of access - allows you to obtain confirmation that your personal data is being processed by us and, if so, the relevant details of these processing activities;
• Right to rectification - allows you to rectify your personal data if it is inaccurate;
• Right to erasure - allows you to obtain the deletion of your personal data in certain cases (for example, if the data is no longer necessary in relation to the purposes for which it was collected, or you have withdrawn your consent when the processing was based on your consent or the data has been processed unlawfully);
• Right to restriction - allows you to obtain restriction of the processing of your personal data in certain cases (for example, when you contest the accuracy of your personal data, for a period that allows us to verify such accuracy);
• The right to object - allows you to object to the further processing of your personal data under the conditions and limits established by law;
• The right to data portability - allows you to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and automatically readable format or to transmit this data to another data controller.
We are happy to ensure the exercise of these rights.
You can freely and at any time exercise your rights mentioned above and learn more about these rights by submitting a written request to us, as the operator, at SC Hoteit Brand SRL, at the address: Str. Erou Iancu Nicolae No. 75A, bl 1, sc C, 3rd floor, ap 10, Voluntari, Ilfov or by e-mail at contact@cedrelle.com.
You also have the right to file a complaint with the data protection authority.
We encourage you to contact us immediately if you believe that your personal data has been provided without consent. We are committed to always treating your requests with the utmost care and to addressing your questions as soon as possible.
VI. SECURITY
As part of the administration of our website, we have taken technical and organizational measures to ensure a level of security appropriate to the risks presented by processing, in particular due to incorrect use or destruction, loss, alteration, disclosure, acquisition or access, intentional or accidental manipulation, access by third parties, deletion and modification.
You will be notified of a data breach within a reasonable time after becoming aware of such breach, unless a competent official determines that notification would impede a criminal investigation or harm national security. In such case, notification will be delayed as directed by the competent official. We will respond promptly to your requests regarding such a data breach.
VII. MODIFICATIONS
This Privacy and Personal Data Protection Policy is effective as of May 25, 2018. This Privacy and Personal Data Protection Policy may be updated.
When we do so, we will post those changes on our website so that you always have access to details about the information we collect, how and under what circumstances we use it and, if applicable, disclose it. Any such change, material or otherwise, will be effective upon posting the new version on our website.
If, at any time, we decide to use your personal data in a manner different from that stated at the time of collection, we will notify you by email. You will have the opportunity to choose whether or not we can use your data in this different way. Otherwise, if possible, we will use the data in accordance with the Privacy Policy and the Personal Data Protection Policy under which the data was collected.
VIII. OTHER WEBSITES
Our website contains links to other websites. This privacy and data protection policy applies only to this website, so when you link to other websites, you should read their own privacy policies.
IX. CONTACT INFORMATION
If you have any further questions about how we process your personal information or if you would like to exercise any of your rights under this policy, please send us a written request, using the following contact details: contact@cedrelle.com.
We will ensure that appropriate measures are taken to respond to your request without undue delay and, in any case, within 30 (thirty) days of receipt of the request. The information will be provided electronically, if possible, unless you expressly request it to be transmitted in writing.