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Privacy policy

Date of last update May 31, 2024

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

This Privacy Policy was prepared by the Company SQUARE MANAGEMENT S.R.L. Romanian legal entity with headquarters in Bucharest, Strada Gheorghieni, no. 19-25, et. 3, ap 13, sector 5 registered at the Bucharest Trade Registry under no. J40/11766/2015, unique registration code RO35053601 (hereinafter, "us" or "Society" or " Square Management"), as the owner of the website https://www.squaremanagement.ro/ and administrator of relevant pages on various social networks (“Platform Square Management”).

This document is intended to tell you why and how we collect the personal data of our website visitors and people who interact with us through social media. Our Privacy Policy applies to personal data obtained through the Square Management Platform, through email communications or within the general activities of the Company.

This Privacy Policy is applicable in relation to website visitors https://www.squaremanagement.ro/ (“Site”) and with users of our social media pages. Further details about the processing purposes, legal bases and categories of personal data processed can be found in Section 2 (Purposes, processing bases 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, data location, an online identifier, or to one or more specific elements of his physical, physiological, genetic, psychological, economic, cultural or social identity.

This Privacy Policy contains important information regarding Square Management'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, please feel free to contact us using the information at the end of this document or on the Square Management Platform. It is important to us that you clearly understand 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 are we;
  • the purposes for which we collect and use your personal data;
  • the legal basis on which the data processing carried out by us is based (ie, the legal basis that allows us to process your data);
  • the categories of personal data we process;
  • the duration of the processing of these data;
  • your rights as data subjects and the manner in which you can exercise these rights; and
  • the persons to whom we disclose or may disclose your personal data.

This Privacy Policy is drawn up by Square Management, as a data operator, in accordance with the data protection legislation applicable in Romania, in particular art. 13-14 of Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and their free movement, which repeals Directive 95/46/EC ("GDPR”).  

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

Depending on how you interact with Square Management, we collect different categories of personal data about you, used according to the purposes and grounds detailed below in this section:


2.1 If you are a visitor to our website https://www.squaremanagement.ro/

Goals:

Datele pe care le colectăm de la dumneavoastră în timpul utilizării site-ului nostru sunt prelucrate în principal pentru a vă facilita accesul la Site, precum și pentru a asigura funcționalitatea și securitatea acestuia. De asemenea, utilizăm aceste date pentru a monitoriza traficul pe Site și pentru a optimiza și îmbunătăți conținutul oferit. În acest scop, folosim cookie-uri, ale căror detalii sunt specificate în Politica noastră de Cookies, disponibilă pe Site. 

Categories of Personal Data:

The IP address used to connect

Login date and time

Details of the equipment used to connect

Details regarding interaction with the Site

Processing grounds:

Our legitimate interest in providing visitors with access to the Square Management Platform (Art. 6 para. 1 letter f of the GDPR);

Your specific consent regarding the collection of data by the Square Management Platform through some categories of cookies (Art. 6 para. 1 letter a of the GDPR);

Your consent regarding the data and information included in the contact form (Art. 6 para. 1 letter a of the GDPR);


2.2 If you interact with us through our social media pages:


When you interact with us through our social media pages, either directly through the social media buttons displayed on the Square Management Platform or through your personal accounts, we will collect certain information about you. This includes your name or nickname, profile picture, and any messages or attachments you send us. We will also have access to public information from your profile on that social network.

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

We also have access to aggregated statistics provided by social networks about users who interact with our accounts, and we can sometimes define the categories of recipients of our pages using the tools available through these platforms. In these cases, we do not have access to personal data that directly identifies individuals, but only to general and aggregated information. They are not responsible for the methodology by which social media platforms collect this data.


To better understand how your personal data is used by social media platforms, the rights you have vis-à-vis these platforms and how you can exercise these rights, we recommend that you consult the information notes of each social network, accessible via the link the following:


  • Facebook: http://www.facebook.com/policy.php
  • Instagram: https://help.instagram.com/155833707900388?cms_id=155833707900388
  • YouTube: https://policies.google.com/privacy
  • LinkedIN: https://www.linkedin.com/legal/privacy-policy 


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


Activity

1. Interacting with you through posts or messages through our social media pages

Scope

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

Categories of Personal Data

Your name and picture

Communication with you

Other data about you from your public social media profiles

Processing themes

Your consent (Art. 6 para. 1 letter a of the GDPR)

Activity

2. Carrying out statistical analyzes on the use of our social media pages (including the use of statistical analyzes provided by social media operators)

Scope

Statistical analyzes of the use of our social media pages

Categories of Personal Data

Aggregate User Data (may include name, age category, etc.)

Processing themes

Our legitimate interest in improving the interaction with users of our social network pages (Art. 6 para. 1 lit. f GDPR)

You can always object to the processing based on our legitimate interests described above for reasons related to your specific situation. For more details about your rights, please see Section 8 (Your Rights) of this Privacy Policy.

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, there is a chance 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 before the withdrawal of consent, and which involves your data, will remain valid.

To withdraw your consent where this is the basis of processing Your data as detailed in Section 2, please contact us using the information in Section 8 (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, how we intend to use that information, for example by providing a link to this Privacy Policy. Privacy. If it is necessary to obtain the consent of these individuals for the use of their data, we will ensure that we provide them with this Privacy Policy when we contact them.

4. WHO WE DISCLOSE YOUR DATA TO. PERSONAL CHARACTER

We disclose Your personal data to our external service providers, including but not limited to training course providers, training venue owners, 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, based on the appropriate contractual documentation. The basis for this disclosure is our legitimate interest in engaging and benefiting from the services of these providers to carry out 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 through the Square Management Platform;
  • to our auditors, consultants, lawyers or other specialized professional service providers, if necessary for their provision of the services contracted by us, having regard to our legitimate interest or our legal obligation to contract these services; and
  • to public authorities and institutions, if we have a legal obligation to do so or at their express request, if permitted by law.

As a rule, we only transfer your personal data to recipients from 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. However, there are cases where we may transfer personal data outside the European Union (EU) and/or the European Economic Area (EEA). Such transfers are carried out in accordance with Articles 44-49 of Regulation (EU) 2016/679 (General Data Protection Regulation).

5. HOW WE PROTECT YOUR 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 data.

However, although we take all reasonable steps to ensure the security of Your data, we cannot guarantee the absence of any security breach or the impossibility of penetration of our security systems. In the unfortunate event that such a breach does occur, we will follow legal procedures to limit the effects and inform the data subjects.

6. HOW LONG WE KEEP YOUR DATA

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

For users of the Square Management Platform, your data will be kept while browsing the platform and afterwards, according to our Cookies Policy, which can be accessed on our website.

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

7. YOUR RIGHTS.

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

  1. Right of access: you can obtain from us confirmation that we are processing your personal data, as well as information regarding the specifics of the processing such as: the purpose, the categories of personal data processed, the recipients of the data, the period for which the data is kept, the existence of the right to rectification , deletion 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 for a fee.
  2. The right to data rectification: you can ask us to change your incorrect personal data or, as the case may be, to complete data that is incomplete.
  3. The right to erasure: you can request the deletion of your personal data when: (i) it is no longer necessary for the purposes for which we collected and process it; (ii) you have withdrawn your consent for the processing of personal data and we can no longer process them on other legal grounds; (iii) personal data are processed against the law; respectively (iv) the personal data must be deleted according to the relevant legislation.
  4. Withdrawal of consent: puteți să vă retrageți oricând consimțământul cu privire la prelucrarea datelor cu caracter personal prelucrate pe bază de consimțământ, fără însă ca aceasta să afecteze în vreun fel prelucrările realizate anterior retragerii. 
  5. The right of opposition: you can object to processing based on Square Management's legitimate interest at any time by presenting us with reasons related to your specific situation. For details of the processing we carry out in legitimate interest, please see Section 2 above.
  6. Restriction of data processing: you can request the restriction of the processing of your personal data by us if: (i) you dispute the correctness of the personal data, for a period that allows us to verify the accuracy of the data in question; (ii) the processing is unlawful and you object to the deletion of the personal data, requesting instead the restriction of its use; (iii) the data are no longer necessary for us to process, but you request them for a court 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 Square Management Platform as an operator prevail over your rights as a data subject.
  7. The right to portability: you can request us, as required by 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 transmit your personal data to another entity, if technically possible. You will be able to exercise your right to portability only if (cumulatively): (i) the processing is carried out by automated means; and (ii) the processing is carried out based on your consent or to execute a contract concluded with you.
  8. The right not to be subject to automated individual decision-making, including profiling: în prezent, nu vă prelucrăm datele cu caracter personal exclusiv prin procese decizionale individuale automatizate. În cazul în care vom iniția asemenea prelucrări de date cu caracter personal, vom suplimenta această Politică de Confidențialitate în mod corespunzător. 
  9. The right to lodge a complaint with the National Supervisory Authority for the Processing of Personal Data: aveți dreptul de a depune o plângere la Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (www.dataprotection.ro) în cazul în care considerați că v-au fost încălcate drepturile, folosind detaliile de contact ale autorității prevăzute mai jos. Vă solicităm însă respectuos să ne contactați pe noi cu orice plângere sau preocupare pe care o aveți înainte de a lua legătura cu autoritatea. 


The National Authority for the Supervision of the Processing of Personal Data

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

You can exercise any of these rights with us using the contact details in Section 8 (Contact) de mai jos. 

If you exercise any of your rights under the law, this will not affect: (i) data processing that has already taken place; or (ii) data processing that is 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 gdpr@squaremanagement.ro. 

9. VERSIONS OF THIS PRIVACY POLICY

This Privacy Policy is valid from May 31, 2024.

We may change this Privacy Policy to reflect our activities in which we use your personal data. We will indicate any changes to this Privacy Policy by indicating the date on which it was last updated.