This policy aims to present how the personal data of persons concerned are processed by TODAY ADVERTING S.R.L.
This policy also informs the data subjects about the rights they have under REGULATION (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (hereinafter referred to as the GDPR) and the national legislation on the protection and security of personal data, in force, which are hereinafter referred to as GDPR legislation.
By processing will be understood any operation or set of operations carried out on personal data or on sets of personal data, with or without the use of automated means, such as collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, disclosure by transmission, dissemination or making available in any other way, alignment or combination, restriction, deletion or destruction.
TODAY ADVERTISING S.R.L. is a personal data operator, based in Romania, Bucharest, Calea Vitan nr. 108, bl. V35, sc. 1, ap. 33, sector 3, J40/91/2007, Sole Registration Code RO20362099, telephone number 031 405.11.00, fax 031 405.11.00, email address: firstname.lastname@example.org. In this document, Today Advertising SRL will be referred to as ”Today” or ”Operator”.
In accordance with the GDPR legislation in force, Today is obliged to administer safely and only for the purposes specified, the personal data provided to it. Today processes personal data in legitimate conditions, implementing appropriate technical and organizational measures to ensure the integrity and confidentiality of data under GDPR legislation.
For any questions, referrals or communications related to your personal data, please contact us at the contact details specified above.
In principle, any information that identifies or can identify, directly or indirectly, a natural person is a personal data.
Today processes the following categories of personal data:
a) identification information: name, surname;
b) contact details: telephone number, email address, home address, contact address;br> c) other information necessary for the provision of Today's products/contractual/business relationship: products purchased/ordered/returned, delivery address;
d) data collected in the past on the basis of currently repealed legal provisions, the retention period of which has not expired: PIN, ID series and number for issuing tax invoices, etc.;
e) e) data from communications, referrals, requests of data subjects made in writing or verbally, through the Operator's website, Operator's accounts on the social networks, telephone, fax, e-mail: for example, names and surname, address, e-mail, phone, other data provided in communications/referrals/requests/discussions.
f) data on the device used to access the Operator's website: the type and unique identification number of the device (IP), the operating system used, the preferred language of the device;
g) cookies and similar technologies (e.g. pixels): details on them, the operating and inactivation mode found in the Cookies Policy.
Today reserves the right to request other data necessary for the conduct of its business, strictly in accordance with applicable legal provisions.
In the context of this Policy, the term data subjects refer to the visitors of the website www.todayadvertising.ro and of social networking accounts whose user is Today (e.g. Facebook, Instagram, Twitter etc.), as well as to persons whose data are provided to the Operator by other persons concerned. Data subjects may provide personal information both in their own name and as representatives of legal entities.
The Operator collects personal data obtained either directly from the data subject or indirectly from third parties (such as other data subjects, legal entities for which the data subject acts as a representative/contact person/ private or public operators, including state authorities) or from public documents, as appropriate.
Where a data subject provides Today personal information about other persons, it shall be obliged to inform those persons concerned of the processing of personal data.
If you choose to communicate with us through social networks, we specify that data operators managing these platforms also process the content of messages transmitted through these means, according to the policies of personal data processing/privacy.
In order to benefit from Today's products and services or to have access to certain features or services of
In the case of commercial communications/marketing activities, we will process personal data only if you have expressed the express consent for this purpose.
Each legal basis under which we process personal data is established in agreement with the purpose for which this data is processed.
The purposes and legal grounds for processing personal data are as follows:
|Item no.||Purpose of processing||Legal basis||Further clarifications|
|1.||Registration of the data subject as a client or client representative on Today's website||Article 6 comma 1) letter b) of GDPR.||Personal data are processed to take action at your request in order to conclude the contract of sale of the products of the Operator according to the terms and conditions of sale of Today.|
|2.||Trade, marketing activities||Article 6 comma 1) letter a) of GDPR.||Personal data shall be processed solely on the basis of the consent given, irrespective of the manner in which such consent has been expressed: physically or online.|
|3.||Îndeplinirea unei obligaţii legale care revine Operatorului||Articolul 6 alineatul 1) litera c) din GDPR.||Datele cu caracter personal sunt prelucrate de exemplu pentru întocmirea și păstrarea evidențelor contabile, îndeplinirea obligațiilor fiscale, furnizarea de date către autoritățile competente etc., având în vedere legislația aplicabilă (ex. legea nr.82/1991 a contabilității, Codul Fiscal, Codul de Procedură Civilă/ Penală etc.).|
|4.||Conclusion and execution of the contract of sale-purchase of products/performance of services||Article 6 comma 1) letter b) of GDPR.||Personal data are processed for example to deliver the product, to provide and benefit from the contract guarantee, to make any returns, etc., according to the contract concluded.|
|5.||Solving requests, applications, complaints received by Today”||Article 6 comma 1) letter b) or f) of GDPR.||Personal data are processed, for example, to contact the data subject in order to obtain details regarding its request.|
|6.||Analysis of the use of the website for the purpose of analysing the functionality of the site, improving our services and the experience of the data subject on Today's website||Article 6 comma 1) letter a) of GDPR.||Personal data are processed, for example, to understand how you browse Today's web pages and to optimize their use. Thus, we will keep and evaluate information about your recent visits to our site, as well as how you move through the various sections of our site for analysis purposes, to understand how people use our site, so we can make it more intuitive.|
Personal data are processed for a limited period of time, as is necessary to carry out Today's activity in relation to the purpose of processing and the applicable legal provisions. For example, for the purpose of fulfilling the obligations in the matter of archiving, we will process personal data for a maximum period of 10 (ten) years after the end of the financial year during which were drawn up financial-accounting documents containing that personal data
If processing is carried out for commercial communications/marketing activities, personal data are stored during the validity of marketing consent, plus a period of 3 (three) years – the general term of limitation period – from its withdrawal. If you withdraw your consent, your personal data will no longer be processed for this purpose from the moment of withdrawal of consent.
Subsequently, after the retention deadlines expire, we will proceed with the deletion of personal data.
Personal data are intended for use by Today as a data operator and is communicated to the following recipients, where appropriate:
a) central and local institutions/authorities in order to fulfill the legal obligations of Today (e.g. ANAF, court executors, public registers, police, prosecutor's office, etc.);
b) courts for the purpose of formulating actions, defenses and representation in court;
c) collaborators/service providers used by Today in its work including but not limited to areas such as: IT, accounting, training, auditing, legal services, insurance, newsletter forwarding and commercial communications, etc.
Disclosure of data to third parties shall be made in accordance with the legal provisions for previously specified categories of recipients, who have taken appropriate protection measures, in accordance with the legal provisions, to ensure that they comply with their obligations Protection of personal data.
Personal data may be transferred (e.g. accessed, consulted, etc.) also to other entities for the initiation and conclusion of other business contracts/relationships.
Today may transfer personal data to countries outside the European Union or the European Economic area (so-called third countries) recognized by the European Commission with an adequate level of protection of personal data or, if not, only if a level of protection of personal data appropriate to that of the European Union is contractually guaranteed by beneficiaries located in the third country (e.g. by signing the standard contractual clauses laid down by the European Commission). Additional information may be requested in writing to the e-mail address email@example.com.
According to applicable legal provisions (articles 12-22 GDPR), the data subject has the following rights:
a) the right of access, that is, the right to obtain confirmation that personal data are processed or not by Today, and if so, to obtain access to them, as well as certain information, including by providing a copy of the processing of personal data processed;
b) the right to rectification, namely the right to obtain the correction of inaccurate personal data and the completion of incomplete ones;
c) the right to deletion of data (' right to be forgotten '), which may be exercised in situations expressly governed by the law (e.g. in the case of withdrawal of consent or where it is found that the processing of personal data has not been legal);
d) the right to restriction of processing, which may be exercised in the situations expressly governed by the GDPR (e.g. where the accuracy of the personal data is challenged for the period necessary to clarify the situation or where the processing is illegal, and it is not desirable to erase the data, but merely restrict their processing);
e) the right to data portability, pursuant to which the person concerned may receive his personal data which Today processes by automated means, in the performance of a contract or on the basis of the consent of the data subject, in a format which can be read automatically, or may require that personal data be transmitted to another data operator;
f) the right to opposition, pursuant to which the data subject may oppose at any time, on grounds relating to his particular situation, to the processing based on the legitimate interest of Today (including profiling) or carried out in the exercise of public interest or authorization with which the operator is invested;
g) the right to request and obtain the withdrawal, cancellation or re-evaluation of any decision taken in respect of you, which produces legal effects and is based solely on automatic processing;
h) the right to withdraw your consent to the processing of personal data based on this legal basis at any time without affecting the legality of the processing carried out on the basis of consent before its withdrawal;
i) the right to address the National Supervisory Authority for the processing of Personal data or to a competent court; If you believe that your rights as a data subject have been violated, you can always address, with a complaint or a referral to this effect, to the National Supervisory Authority for the processing of Personal data, with headquarters in B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, cod postal 010336, Bucharest, Romania (fax: +40 318 059 602, email: firstname.lastname@example.org). You can also formulate a legal action on the role of the competent courts.
For the exercise of the rights provided for by the GDPR, please contact us at the following contact details: TODAY ADVERTISING S.R.L., Romania, Bucharest, Calea Vitan nr. 108, bl. V35, sc. 1, ap. 33, sector 3, to the attention of Mrs. Georgiana Petrescu, e-mail: email@example.com. Today will respond to your request within one month after the receipt of the request, according to the GDPR, which can be extended by two months when necessary, taking into account the complexity and number of applications resolved by Today. Today will send you a notification in this regard.