Privacy Policy (UE)

1. WHO WE ARE AND WHAT IS THE PURPOSE OF THIS DOCUMENT

This Privacy Policy has been prepared by AKCENT NAVIGAȚIEI S.R.L., a Romanian company, with headquarters in Bragadiru, 34E Verii Street, Ilfov County, registered at the Trade Register Office under no. J23/151/2022, with sole registration code 44457218 (hereinafter “we" or “Company" or “Akcent“), as owner of the akcentcity.ro website and administrator of relevant pages on various social networks (hereinafter “Akcent City Page" or “Website”).

This document is intended to detail why and how we collect personal data of visitors to our Website and people who interact with us through social networks. Our Privacy Policy applies to personal data obtained through the Akcent City Page, through email communications or within the framework of the Company’s general activities.

This Privacy Policy applies to visitors of https://www.akcentcity.ro/ website and users of our social media pages. Further details about the purposes of processing, legal grounds and categories of personal data processed can be found in Section 2 (Purposes, processing grounds and categories of personal data we process) of this Policy.

“Personal data" means any information relating to an identified or identifiable natural person and an identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more specific elements, specific to his physical, physiological, genetic, mental, economic, cultural or social identity.

This Privacy Policy contains important information regarding Company’s use of your data. Therefore, we recommend that you take the time to read this Privacy Policy completely and carefully before interacting with us. If you have any questions or concerns, do not hesitate to contact us using the information at the end of this document or on the Akcent City Page or through the contact section on the Website. It important fr us that you have a clear understanding of how and why we use your information, how we protect it and what rights you have in relation to your personal data.

This Privacy Policy mainly describes:

  • who we are;
  • the purposes for which we collect and use your personal data;
  • the legal grounds on which our data processing is based (respectively, the legal basis that allows us to process your data);
  • the categories of personal data we process;
  • the duration of the processing of such data;
  • your rights as data subjects and the manner in which you can exercise these rights; and
  • persons to whom we disclose or may disclose your personal data.

This Privacy Policy is drawn up by Company, as data controller, in accordance with the data protection legislation applicable in Romania, in particular Articles 13-14 of Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and their free movement, which repeals Directive 95/46/EC (“GDPR“).

2. THE PURPOSES, PROCESSING GROUNDS AND CATEGORIES OF PERSONAL DATA WE PROCESS

Depending on how you interact with the Company, we collect different categories of your personal data, used according to the purposes and grounds detailed below in this section.

    • If you are a visitor of our Website akcentcity.ro or wish to contact us

Purposes of processing

The data we collect from you during your use of our Website is processed primarily to facilitate your access to the Website and to ensure its functionality and security. We also use this data to monitor Website traffic and to optimise and improve the content offered. For this purpose, we use cookies, details of which are specified in our Cookie Policy, available in the footer of our Website.

Categories of Personal data

  • IP address used for the connection
  • Date and time of the connection
  • Details of equipment used for the connection
  • Connection location of the device (your Geolocation data)

Processing basis

  • Our legitimate interest in providing visitors with access to the Website (Art. 6 (1) (f) GDPR)
  • Your specific consent to the collection of data by the the Company through certain categories of cookies (Art. 6 para. 1 (a) of GDPR)
  • Your consent for the collection of geolocation data (Art. 6 para. 1 (a) of GDPR).
    • Contacting and interacting with you via the contact form on the Website akcentcity.ro, email or other means of communication

Purposes of processing

We process personal data for the purposes of communication with you on matters of interest related to the Company activity, providing information and details, or communicating with you to conclude agreements and other specific requests.

Categories of Personal data

  • Name, email address, phone number
  • Other data and information you submit via the contact form, email or other communication method (including other contact details).

Processing ground

  • Your consent (Art. 6 (1) (a) GDPR).
    • If you interact with us through our social media pages (e.g. Facebook, Instagram, LinkedIn)

When You interact with us through our social media pages, either directly through the social media buttons displayed on the Website or through Your personal accounts, we will collect certain information about You. This includes your name or nickname (social networking username), profile picture and any messages or attachments you send us. We will also have access to public information from your profile on the respective social network.

It is important for you to know that when you interact with our social media pages, your data is processed both by us, for the purpose to facilitate interaction, and by social media platforms, each of us acting as data controllers. However, we are not responsible for how social media platforms handle information you provide during interactions with us.

In order to better understand how your personal data is used by the social networking platforms associated with the Website-ul and Company’s activity, the rights you have towards these platforms and how you can exercise these rights, we recommend that you consult the information notes of each social network.

For more details on how social media providers use your data when you interact with us, please contact them at the contact details available in the privacy notes above.

The basis of our processing is our legitimate interest in the administration of our social networking pages (Art. 6(1)(f) GDPR) and your consent (Art. 6(1)(a) GDPR).

    • Interacting with you through posts or messages on our social media pages

Purpose of processing

Ensuring good interaction between us and you on our social media pages.

Categories of Personal data

  • Your name and image
  • Communication with you
  • Other data about you from your public social media profiles

Processing ground

  • Your consent (Art. 6 (1) (a) GDPR).
    • If you are a client or potential client of the Company

Purpose of processing

The Company will collect, process and use personal data: for the purpose of concluding and performing the agreement to which you will be a party; for the purpose of fulfilling the legal obligations of the Company; and for the purpose of defending the legitimate interests of the Company.

Categories of Personal data

  • contact and/or identification data, including: name and surname, nationality, address, number and serial number of the identification document, personal numerical code and the information contained in the identification document, telephone number, e-mail address
  • other data provided by you and necessary for the conclusion and performance of the agreement, including data relating to your authorized persons, spouse, heirs, correspondence between the parties
  • images and videos if you visit the building site.

Processing grounds

  • the conclusion and performance of the agreement to which you are a party (GDPR Art. 6 (1) (b))
  • our legitimate interests and/or the need to conclude or perform the agreement (GDPR Art. 6 (1) (f))
  • your consent (GDPR Art. 6 (1) (a))
  • the existence of a legal obligation for video monitoring (GDPR Art. 6 (1) (a)).
    • Newsletters and commercial communications

Purpose of processing

To send commercial communications in order to promote the Company and its activity.

Categories of personal data

  • Name, email address
  • In addition to the purposes indicated above and the data provided by you when subscribing to the newsletter, we will process a range of additional information (e.g. device information, open rate, interaction with the content in the newsletter) about your response to the newsletter and use this information to evaluate its success and ways to improve it.

The grounds for processing

  • your consent (Art. 6 (1) (a) of the GDPR)

You have the possibility to revoke this consent at any time and without having to provide reasons by using the unsubscribed link in each newsletter, with effect for the future

3. PROVISION OF DATA AND CONSENT BY YOU

When you provide us with personal data directly, it is essential that you provide us with all requested personal data. If you do not provide us with complete information, it is possible that we will not be able to properly carry out the activities for which you have contacted us, such as responding to your requests.

If the use of personal data is based on your consent as detailed in Section 2, you have the right to withdraw your consent at any time. With the withdrawal of consent, we will no longer use your data from that moment. However, any activity carried out prior to the withdrawal of consent, and involving your data, will remain valid.

To withdraw your consent where this is the basis for processing your data, as detailed in Section 2, please contact us using the information in Section 9 (Contact).

If you provide us with personal data belonging to other individuals, it is important that you inform them, before disclosing the data to us, about how we intend to use that information, for example, by submitting a link to this Privacy Policy. If it is necessary to obtain consent from these individuals for the use of their data, we will ensure that we provide them with this Privacy Policy when we contact them.

4. TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA

We disclose your personal data to our external service providers, including, but not limited to, IT service providers, consultants and marketing agencies. These providers only access and use the personal data strictly necessary to provide the services for which they have been engaged by us, relying on appropriate contractual documentation. The basis for this disclosure is our legitimate interest in engaging and benefiting from the services of these providers for the performance of our activities.

We may also disclose your personal data as follows:

  • we may disclose relevant personal data to our business partners, if this is necessary in the context of providing their services, when justified by our interaction with you;
  • to our auditors, consultants, lawyers or other providers of specialized professional services, if necessary for the provision by them of the services contracted by us, given our legitimate interest or our legal obligation to contract these services; and
  • public authorities and institutions, if we have a legal obligation to do so or at their express request, if permitted by law.

As a general rule, we transfer your personal data only to recipients in countries belonging to the European Union (EU) and/or the European Economic Area (EEA); we do not transfer your data to countries outside the EEA and we ask our service providers to do the same. Nevertheless, there are instances where we may transfer personal data outside the European Union (EU) and/or the European Economic Area (EEA). Such transfers are conducted in accordance with Articles 44-49 of Regulation (EU) 2016/679 (General Data Protection Regulation).

5. HOW WE PROTECT YOUR PERSONAL DATA

It is very important for us to protect your personal data. For this, we apply appropriate measures to ensure the security of personal data, including:

  • Dedicated policies
  • Specific technical measures
  • Staff training
  • Control of our service providers
  • Data minimization
  • Restricting access to data

We also undertake to adopt any further measures required by law in the field of personal data protection in connection with the use of your personal data.

6. HOW LONG DO WE KEEP YOUR PERSONAL DATA

We intend to keep your personal data for the period necessary to fulfil the purposes for which we process them. There are situations in which legislation requires us to retain certain personal information for periods defined by law, usually for archival purposes, such as 5 or 10 years for financial and accounting needs. We may also require retention of certain data to protect and support our legal interests; In these cases, we will not retain data for more than 3 years after the termination of our relationships, including communications.

For users of the the Website, your data will be kept for the duration of browsing the Website and thereafter, according to our Cookies Policy.

In the case of video recordings from building sites, the video recordings will be stored for a maximum period of 30 days, except in duly justified cases.

When we process data based on your consent, such as where you contact us via the contact form intermediary or social media interactions, we will retain the data until you decide to withdraw your consent.

7. YOUR RIGHTS

According to the law, you benefit from the following rights related to the processing of your personal data that we carry out:

    • Right of access: you can obtain from us confirmation that we process your personal data, as well as information on the specifics of processing such as: purpose, categories of personal data processed, recipients of data, period for which data are kept, existence of the right to rectification, erasure or restriction of processing. This right allows you to obtain a copy of the processed personal data free of charge, as well as any additional copies against payment.
    • The right to rectify data: you can ask us to modify your incorrect personal data or, as the case may be, to complete the data that is incomplete.
    • Right to erasure: 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 to the processing of personal data and we can no longer process it on other legal grounds; (iii) personal data are processed contrary to the law; i.e. (iv) personal data must be deleted in accordance with the relevant legislation.
    • Withdrawal of consent: you may withdraw your consent to the processing of personal data processed on the basis of consent at any time, without however affecting in any way the processing carried out prior to the withdrawal. You can withdraw your consent to the transmission of newsletters at any time by pressing the UNSUBSCRIBE button in each newsletter we send you or by sending us an email dpo@akcentcity.ro.
    • Right to object: you can object at any time to processing based on the legitimate interest of the Company by giving us reasons related to your specific situation. For details on the processing, we carry out in our legitimate interest, please see Section 2 above.
    • Restriction of data processing: you may request restriction of processing of your personal data by us if: (i) you contest the accuracy 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 oppose the deletion of personal data, requesting instead the restriction of their use; (iii) the data are no longer necessary for processing, but you request them for legal action; respectively (iv) if you have objected to the processing, for the period of time in which it is verified whether the legitimate rights of the Company as controller prevail over your rights as a data subject.
    • The right to portability: you can ask us, in compliance with applicable law, to provide you with your personal data that you have provided to us in a structured, frequently used and machine-readable form (for example, in CSV format). Also, if you expressly request us, we may transfer your personal data to another entity, if technically possible. You will only be able to exercise your right to portability if (cumulatively): (i) processing is carried out by automated means; and (ii) processing is carried out on the basis of your consent or to perform a contract concluded with you.
    • The right not to be subject to automated individual decision-making, including profiling: Currently, we do not process your personal data exclusively through automated individual decision-making processes. If we initiate such processing of personal data, we will supplement this Privacy Policy accordingly.
    • The right to lodge a complaint with the National Supervisory Authority for Personal Data Processing: you have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (www.dataprotection.ro) if you consider that your rights have been infringed, using the contact details of the authority provided below. However, we respectfully request that you contact us with any complaint or concern you may have before contacting the authority.

National Supervisory Authority for Personal Data Processing:

Blvd. G-ral. Gheorghe Magheru 28-30 Sector 1, postal code 010336 Bucharest, Romania anspdcp@dataprotection.ro.

You can exercise any of these rights by using the contact details in Section 8 (Contact) below.

If you exercise any of your rights as provided under applicable law, this will not affect: (i) data processing that has already taken place; or (ii) data processing not based on your consent. 

8. CONTACT

To exercise one or more of the rights set out above or to ask a question about these rights or about our processing of your personal data, please contact us by email at dpo@akcentcity.ro or by correspondence to the headquarters address.