PRIVACY AND PERSONAL DATA PROCESSING POLICY
WHO WE ARE
DANCE-REGISTRATION.COM, with the company GROZEA GLOBAL SRL, Registration number: 34048631, J40/1115/2015, Address: Str. Prof. Gheorghe Costaforu 5, Bucharest, Romania, Phone: +40721494755, e-mail: grozeaglobal@gmail.com
GROZEA GLOBAL SRL collects data in many ways and in several ways: when you contact us by email, when you visit our website, when you fill out a contact form and when you fill out a registration request. We also collect data when you visit us at our location.
DEFINITIONS
Personal data (Data) – any information regarding an identified or identifiable natural person (data subject); an identifiable natural 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 one or more specific, own physical, physiological, genetic, psychological, economic, cultural or social identities.
Special categories of personal data – any information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data for the unique identification of a natural person, health data, or data regarding a natural person’s sexual life or sexual orientation.
Processing of personal data (Processing) – any operation or set of operations performed on personal data or sets of personal data, with or without the use of automated means, such as collection, recording, organization, structuring, storage, adapting or modification, extract, consult, use, disclose by transmission, disseminate or otherwise make available, align or combine, restrict, delete or destroy.
Data subject – a natural person who can be identified, directly or indirectly, in particular by reference to an identification element such as a name, an identification number, location data, an online identifier, or to one or more specific elements, its own physical, physiological, genetic, psychological, economic, cultural or social identities.
Operator – natural or legal person, public authority, agency, or other body that, alone or together with others, establishes the purposes and means of personal data processing; when the purposes and means of processing are established by Union law or domestic law, the operator or the specific criteria for its designation may be provided for in Union law or domestic law.
Associated operators – two or more operators who jointly establish the purposes and means of processing, establish in a transparent manner the responsibilities of each in relation to the fulfillment of their obligations under the GDPR, in particular in relation to the exercise of data subjects’ rights and the obligations of each to provide the information provided for in articles 13 and 14, by means of an agreement between them, and designate a single point of contact for the data subjects.
The person authorized by the Operator (Authorized/Processor) – natural or legal person, public authority, agency or other body that processes personal data on behalf of the operator.
Third Party – a natural or legal person, public authority, agency or body other than the data subject, the operator, the person authorized by the operator and the persons who, under the direct authority of the operator or the person authorized by the operator, are authorized to process personal data.
Consent – any manifestation of free, specific, informed and unambiguous will of the data subject by which he accepts, through a statement or an unequivocal action, that the personal data concerning him be processed.
Pseudonymization – means the processing of personal data in such a way that it can no longer be attributed to a specific data subject without the use of additional information, provided that this additional information is stored separately and subject to measures of a nature technical and organizational to ensure the non-assignment of said personal data to an identified or identifiable natural person. The principles regarding the processing of personal data apply to pseudonymised data, as they represent personal data.
Anonymization – means the processing of personal data in such a way that it is irreversible and that transforms the data so that they can no longer be attributed to a specific data subject. The principles regarding the processing of personal data do not apply to anonymized data, as they no longer represent personal data.
ANSPDCP – means the independent public supervisory authority in Romania, respectively the National Authority for the Supervision of Personal Data Processing.
GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 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.
OUR VIEW ON THE PROCESSING OF PERSONAL DATA AND THE COMMITMENTS OF GROZEA GLOBAL SRL
The processing of personal data by GROZEA GLOBAL SRL is always subject to the following principles:
- All data processing has a valid legal basis;
- All data processing is done fairly;
- We inform data subjects about what data we process, why, how and for how long we process it, if and to whom we transfer it, as well as what rights they have regarding their data;
- The data is collected for specific, explicit and legitimate purposes and is not further processed in a way incompatible with these purposes;
- The data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- We are concerned to use only accurate data and, where necessary, we will ensure that it is updated;
- The data are kept in a form that allows the identification of the data subjects for a period that does not exceed the period necessary to fulfill the purposes for which the data are processed; personal data can be stored for longer periods to the extent that they will be processed exclusively for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes, subject to the implementation of technical measures and organizationally adequate;
- Data are processed in a way that ensures adequate security of personal data, including protection against unauthorized or illegal processing and against accidental loss, destruction or damage, by taking appropriate technical or organizational measures;
GROZEA GLOBAL SRL will ensure that it respects these principles both in terms of its current activities, as well as in the event that in the future it will introduce new data processing technologies, such as, but not limited to, new IT systems.
WHAT PERSONAL DATA WE PROCESS
GROZEA GLOBAL SRL specifically informs the data subjects about the personal data collected and processed in each case in which this happens (for example, when completing a registration request).
For example, if you send us a registration request through the website or directly to the e-mail address grozeaglobal@gmail.com, we will collect personal data regarding: the e-mail address and contact details of the person or of the representative contacting us, included in the request (example: first name, last name, e-mail address and telephone number).
WHY AND HOW WE USE YOUR DATA. PERSONAL CHARACTER
Your personal data is used to carry out our activity, to respond to registration requests, to respond to requests made by the competent authorities that supervise and regulate our activity.
We process data to provide you with the services and information you request.
We also process personal data to ensure the security of the premises where we operate, the assets we use for this purpose, the safety of our employees and the data and information we manage.
Your personal data is processed through collection, registration, organization, storage, modification, consultation, use, disclosure by transmission, provision, combination, restriction, deletion, destruction, etc. Your personal data is not subject to automated decision-making (including profiling) except in exceptional cases, in which case the data subject is informed of its existence, as well as of the details of this special way of processing.
GROZEA GLOBAL SRL specifically informs the persons concerned about the purposes and methods of processing in each case in which this happens (for example, when sending a request for collaboration or a response to a request for collaboration when receiving a CV, etc. ).
WHAT ARE WE USING YOUR PERSONAL DATA FOR?
GROZEA GLOBAL SRL seeks to carry out data processing in consideration of at least one of the legal grounds listed below:
- Consent – In the event that no other basis of legality of the processing provided below applies, GROZEA GLOBAL SRL always obtains the consent of the data subject for the processing of his personal data for one or more specific purposes.
- Execution/Conclusion of a contract – Processing is necessary for the execution by GROZEA GLOBAL SRL of a contract to which the data subject is a party or to take steps at the request of the data subject before concluding a contract.
- Legal obligation – The processing is necessary in order to fulfill a legal obligation that belongs to GROZEA GLOBAL SRL
- Legitimate interest – The processing is necessary for the purpose of the legitimate interests pursued by GROZEA GLOBAL SRL or by a third party, in accordance with the law. For example, in the case of registering requests to join the courses offered, GROZEA GLOBAL SRL has a legitimate interest in proving or improving the services offered.
- Vital interest – Processing is necessary to protect the vital interests of the data subject or another natural person.
- Public interest – Processing is necessary for the performance of a task that serves a public interest or that results from the exercise of public authority with which the operator is vested.
In the case of special categories of personal data, GROZEA GLOBAL SRL refers to the applicable legal provisions to always ensure a valid legal basis for processing.
WHO DO WE TRANSMIT YOUR PERSONAL DATA TO?
It is possible that your personal data will be transmitted to third parties – competent authorities, operators of collection services, transport, etc., accounting and auditing firms, etc. Whenever we do this, we ensure that there is a good justification, that we will only transmit the data that is strictly necessary to achieve the purpose of the transmission, and we will try to ensure that the recipient ensures a high standard of personal data protection.
In the case of data processing activities carried out by a third party provider/supplier/partner/intermediary for the operator GROZEA GLOBAL SRL, on the basis of a service provision contract of any type concluded between GROZEA GLOBAL SRL and the respective third party (which has the capacity of data processor personal in terms of the GDPR), these contracts are concluded in writing and include a series of specific clauses, whereby the respective third parties provide GROZEA GLOBAL SRL with sufficient guarantees for the implementation of appropriate technical and organizational measures, so that the processing must comply with the requirements set out in the GDPR and ensure the protection of the data subject’s rights.
The transfer of personal data to an international organization or to a third country vis-a-vis the EU and the EEA (the EEA includes both the EU and Iceland, Liechtenstein and Norway) can only take place if the organization or country to which it is intended carry out the transfer, they can ensure an adequate level of protection according to the requirements of the GDPR.
The transfer of data to an international organization or to a state whose legislation does not provide for an adequate level of protection, recognized by an adequacy decision issued by the European Commission, is only possible if there are sufficient guarantees regarding the protection of the fundamental rights of the data subjects and provided that there are effective countervailing rights and remedies available to data subjects. These guarantees are established by GROZEA GLOBAL SRL, in compliance with the GDPR, in contracts/agreements concluded with the suppliers/service providers to which the data is transferred or in other legal ways, on a case-by-case basis.
HOW LONG AND HOW DO WE KEEP YOUR PERSONAL DATA?
We keep your personal data only for as long as we need it or as required by applicable law.
All the while, we ensure that the data is kept safe and, in case of security breaches, we are prepared to apply all technical, organizational and legal measures to limit the possible consequences and inform the ANSPDCP, as well as the data subjects, if there are risks to them.
As far as possible, we will anonymize the data that we no longer need in a way that allows the identification of the data subjects or apply pseudonymization to limit the risks regarding the personal data processed.
WHAT RIGHTS DO YOU HAVE REGARDING THE DATA WHICH WE PROCESS
Right of access to Data
Any Data Subject has the right to obtain from GROZEA GLOBAL SRL, when they act as an operator, upon request and free of charge for one request per year, confirmation of the fact that the data concerning them are or are not processed by it, and if so, the information will be provided regarding: the purposes of the processing; categories of targeted data; the recipients or categories of recipients of the data, in particular recipients from third countries or international organizations, as well as the appropriate guarantees offered in the case of such data transfer; where possible, the period for which the personal data is expected to be stored or, if this is not possible, the criteria used to establish this period; the existence of the right to request from GROZEA GLOBAL SRL the rectification or deletion of the data or the restriction of their processing or the right to oppose the processing; the right to file a complaint before the ANSPDCP; if the data is not collected from the data subject, any available information on its source; the existence of an automated decision-making process, including profiling, as well as pertinent information regarding the logic used, the meaning and expected consequences of such processing for the data subject.
The right to rectification
The data subject has the right to obtain from GROZEA GLOBAL SRL, as a data operator, without undue delay, the rectification of inaccurate personal data concerning him.
Taking into account the purposes for which the data were processed, the data subject has the right to obtain the completion of personal data that are incomplete, including by providing an additional statement.
Right to erasure (“right to be forgotten”)
The data subject has the right to obtain the deletion of personal data concerning him/her without undue delay, and GROZEA GLOBAL SRL will have the obligation to delete the data without undue delay if:
- the data are no longer necessary to fulfill the purposes for which they were collected or processed;
- the data subject withdraws the consent on the basis of which the processing takes place and there is no other legal basis for the processing;
- personal data were processed illegally
- the data subject exercises his right to opposition under the terms of the GDPR;
- the data must be deleted to comply with a legal obligation of the operator;
- personal data were collected in connection with the provision of information society services to minors under GDPR conditions;
- personal data was collected in connection with the provision of information society information to children under GDPR conditions.
GROZEA GLOBAL SRL, as a data operator, can refuse the data deletion request under the following conditions:
- the processing is necessary for the exercise of the right to free expression and information;
- the processing is necessary to comply with a legal obligation applicable to the operator;
- the processing is necessary for reasons related to the public interest in the field of public health, under the restrictive conditions imposed by the GDPR;
- the processing is necessary for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes, under the terms of the GDPR, to the extent that the exercise of the right may make it impossible or seriously affect the achievement of the objectives of the respective processing;
- the processing is necessary for establishing, exercising or defending a right in court.
The right to restriction of processing
The data subject has the right to obtain from GROZEA GLOBAL SRL, as a data operator, the restriction of processing in the following cases:
- the data subject contests the accuracy of the data, for a period that allows the operator to verify the accuracy of the data;
- the processing is illegal and the data subject opposes the deletion of personal data, requesting instead the restriction of their use;
- GROZEA GLOBAL SRL. no longer needs the personal data for the purpose of processing, but they are necessary for establishing, exercising or defending a right in court;
- the data subject has opposed the processing, for the time interval in which it is checked whether the legitimate rights of the operator prevail over those of the data subject.
- the data subject who obtained the restriction of processing is informed by GROZEA GLOBAL SRL before the lifting of the restriction of processing.
The right of opposition
The data subject has the right to GROZEA GLOBAL SRL:
- to oppose at any time, for reasons related to his particular situation, that the data concerning him be the subject of a processing based on public interest or legitimate interest. In case of opposition, the processing can no longer concern the data in question unless there are legitimate and compelling reasons that justify the processing and that prevail over the rights of the data subject or if the purpose is to establish, exercise or defend a right in court.
- to oppose at any time, free of charge and without any justification, that the data concerning her be Processed for direct marketing purposes, including the creation of profiles for this purpose.
The right to data portability
The data subject has the right to GROZEA GLOBAL SRL to receive – in a structured format, currently used and which can be read automatically – the personal data concerning him and which he has provided to the Company and to transmit to another operator if:
- the processing is based on consent or a contract; and
- the processing is carried out by automatic means.
In exercising his right to data portability, the data subject has the right to have his data transmitted directly from GROZEA GLOBAL SRL to another operator when this is technically feasible.
The right not to be subject to an automated decision (including profiling)
In this regard, the data subject has the right to GROZEA GLOBAL SRL not to be subject to a decision based solely on automatic processing (including profiling) and which produce legal effects against the data subject or which significantly affect him.
This right will not apply in the following exceptional situations, where the automatic decision:
- it is necessary for the conclusion or execution of a contract between the data subject and GROZEA GLOBAL SRL;
- is authorized by Union law or internal law that applies to GROZEA GLOBAL SRL and that also provides for appropriate measures to protect the rights, freedoms and legitimate interests of the data subject; or
- is based on the explicit consent of the person concerned.
In the situations from letters a) and c) of this paragraph, GROZEA GLOBAL SRL is obliged to implement the appropriate measures to protect the rights, freedoms and legitimate interests of the data subject, at least his right to obtain human intervention from the operator, express their point of view and appeal the decision.
Right to withdraw consent
If the data processing is based on your consent, you have the possibility to withdraw your consent, in which case we will immediately stop processing your personal data. The withdrawal of consent will not affect the processing up to that point.
To exercise any of these rights, please contact us by sending a request to the e-mail address grozeaglobal@gmail.com or to the correspondence address: Strada Prof. Gheorghe Costaforu, no. 5, room 3, Bucharest, Phone: +40721494755.
The right to address the court and/or ANSPDCP
The data subject whose personal data is processed by GROZEA GLOBAL SRL has:
- the right to file a complaint with ANSPDCP (National Supervisory Authority for Personal Data Processing, headquarters: Bucharest, Bdul Gen. Gheorghe Magheru no. 28-30, sector 1, CP 010336; Phone: +40.318.05.92.11, Fax : +40.318.05.96.02 email: anspdcp@dataprotection.ro, website: dataprotection.ro) if the data subject considers that the processing of his data is done in violation of the GDPR;
- the right to file legal action if the data subject considers that the processing of his data is done in violation of the GDPR.
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