Personal data processing policy on the Avangardia Translate website

Art. 1. General Information

In carrying out its activity, Avangardia Translate ("the Company") processes your personal data when you access the avangardia.eu site ("Website").

The Company ensures, at all times, the observance of all the principles and legislation regarding the protection of personal data, regarding the processing, collection, processing, storage and transfer of personal data, as they are regulated by the legislation in force, as well as through the provisions of Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (“GDPR”).

This policy sets out the key principles regarding data protection and how the Company manages the personal data you transmit to us by accessing the Website. The company will ensure the updating of this policy and will publish on the website the latest version of it.

DEFINITIONS

The following definitions of terms used in this document are taken from Article 4 of the GDPR:

Personal data: Means any information about an identified or identifiable natural person ("Targeted Person") that 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 elements specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual.

Processing: Means any operation or set of operations performed on personal data or personal data sets, 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 otherwise making available, alignment or combination, restriction, deletion or destruction of data.

DPO: Means the person responsible for data protection, more precisely the person responsible for data protection.

Art. 2. Personal data categories

We know the importance of your personal data and are committed to protecting your privacy and security. Therefore, it is important for us to inform you about the processing of your personal data as a user of our Website, through this policy.

The categories of personal data processed by the Company vary depending on the interaction and reports that you register on the Website. Thus, your personal data may be provided by you in the various sections of the Website, especially in the following situations: when you subscribe to the Company's newsletter, when you fill in the contact form of the Website avangardia.eu.

Art. 2.1. Data categories that can be processed:

When filling in the contact form available on the Website: name, surname, telephone number, e-mail address, documents attached to the contact message that may contain personal data;

The data provided by you must be real, accurate and up to date, and you must have the right to provide it. The data mentioned above are provided by you voluntarily when interacting with the Company depending on the purpose transmitted by you. You are thus responsible for the data you provide on the website, both to us and to any third party who may be harmed by the provision of the data.

The website may also collect certain information about your browsing and interactions with various sections of it. We will store or access information and cookies in your terminal equipment (computer, phone, tablet, etc.) only under the conditions described in the corresponding Cookies section. The categories of personal data that are processed concern: the time and date of accessing the site, as well as the IP address of the terminal from which the website was accessed.

Art. 2.2. The company may process the data mentioned in art. 2.1, above, for the following purposes:

Marketing: sending newsletters to subscribers through means of communication such as e-mail, telephone; the processing of this personal data is done based on your consent;
For recruitment purposes: data processing for the recruitment and employment process; the processing of this personal data is done based on your consent; also, the legal basis is the conclusion and execution of the contract, in the case of candidates proposed for employment;
In order to manage requests, complaints, suggestions: data processing to complete the contact form; the processing of these personal data is carried out based on your consent, as well as in the legitimate interest of the Company in order to resolve complaints, improve services, manage suggestions and requests sent to the Company;

In the context of processing the data of the visitors of the Website, in order to ensure a good functioning of the Company's website; the legal basis of the takeover is represented by the legitimate interest of the Company in order to improve the services offered

Art. 3. Basic principles for the processing of personal data

The processing and management of your personal data is carried out in compliance with the following principles:

It is open and transparent about what it does with the data and why it uses it;
Keep your data safe;
Ensures that it always has a legal basis for managing the data;
Collects and uses the minimum necessary data, thus respecting the principle of minimization;
Keep the data up to date, correct and complete;
Do not store data longer than necessary, ensuring the implementation of data retention periods, where there is no mandatory period provided by law;
Respects the legal rights of data subjects with regard to their personal data;
Do not transfer data abroad without taking the necessary measures to transfer the data, and not before informing the data subjects.

Art. 3.1. Fairness and transparency

Personal data is processed lawfully, fairly and transparently in relation to the data subject. This is the basic principle and means that we use personal data only to the extent that the persons entrusting it to the Company have been informed in advance about how to use it. You may request information from the Company at any time on the following principal matters:

What kind of data will be collected;

What they will be used for;
Who they will be shared with (if applicable);
If they will be transferred to other countries;
How long they will be kept;
What rights do individuals have regarding their personal data;
Indication of the contact channels through which the data subjects can exercise these rights.

Personal data will be processed only for the purpose communicated to the data subject. Subsequent changes to the purpose of the processing will be communicated to the data subject, prior to the use of his personal data.

Art. 3.2. Legality

The Company understands to perform all processing activities both for a purpose well determined and related to its activity, but also limited to an appropriate legal justification, as well as in order to fulfill the legitimate interests of the Company in the context the performance of its object or activity, as follows:

subscribing to the Company's newsletter through which we will send launches of new products or services, commercial communications regarding the promotions and campaigns carried out by the Company
independently or in collaboration with one or more partners, useful information about the services offered, etc .;
providing answers when completing the contact form;
participation in competitions and campaigns organized online by the Company;
managing the applications received through the form in the "Careers" section;

Art. 3.3. Consent of the data subject

Obtaining the consent of the person whose data we are going to collect and process is another legal basis provided by GDPR, and the Company will process personal data, only based on your express and unequivocal consent, in all situations where it is required its need.

Art. 3.4. Data minimization

Personal data will only be used when absolutely necessary and relevant to a particular process or project task.

If the use of personal data cannot be avoided, the Company will use only the minimum data necessary to fulfill that purpose.

Art. 3.5. Data accuracy

Data protection legislation requires that personal data be kept accurate, complete and up to date. The Company will ensure the correction, supplementation, updating or deletion, as the case may be, of inaccurate or incomplete data.

Art. 3.6. Data retention period and storage

We will keep your personal data for a period not exceeding the period necessary to fulfill the purposes for which the data are processed, except where the legal provisions provide or oblige us otherwise.

This

regarding the Company's newsletter, we will keep your e-mail address in the newsletter database as long as your subscription is active; from the moment we receive your unsubscribe request,
We will disable sending newsletters to your email address; at which point, the e-mail address will be deleted from the newsletter subscriber database;
regarding the contact form, we will keep your personal data for the period necessary to provide answers to your messages and requests and to prove the correspondence with you, but not more than 1 year from their receipt;
regarding the booking form, we will keep your data in our database for a period of 3 months from the last booking.
in order to participate in the contests and campaigns organized online by the Company, we will keep your personal data for the period necessary to carry out these programs and to prove your participation in these programs, according to the Regulations communicated for each event;
regarding the applications received through the form in the "Careers" section, your data will remain in the database for as long as is necessary to complete the position for which you applied within the Company, but not more than 2 years from the date of their collection;
Regarding the analysis of website browsing and user interactions with the website, we will keep data about your interactions for a period of up to 3 years.

The Company may delete your personal data when it considers that it is no longer necessary for the purposes for which it was collected.

We do not store information or access information stored on your terminal equipment (computer, phone, tablet, etc.) except with your prior consent or when these operations are performed solely for the purpose of transmitting a communication over an electronic communications network. , or are strictly necessary in order to provide an information society service expressly requested by you (for example, to store information about your activities on the website or in the mobile or tablet application, so that you can easily use website or mobile or tablet application for later access).

For the use of cookies for which your prior consent is required, the website or will request your consent through a banner displayed on the website when accessing them. This banner contains a link to this Personal Data Protection Policy and gives you the option to accept cookies as well as the option to refuse them. If you have given your consent but change your mind later, you can use the settings of your internet browser (browser) to delete the stored information or to refuse cookies.

Art. 3.7. Data security

The Company ensures and implements the technical and organizational security measures imposed by law and industry standards, to protect your personal data against accidental or unlawful destruction, loss, alteration, disclosure or unauthorized access, as well as against any other form of illegal processing. We also take steps to ensure that we use your personal data exactly as described in this Policy and to respect your choices regarding the processing of your personal data.

Art. 3.8. Disclosure to third parties

Except as described below, we will not disclose any information about your data without authorization. Based on your express and unequivocal consent, offered in this way and only within the limits of the legislation in force or for the purpose of fulfilling a legal obligation and / or protecting a legitimate interest, we may transmit your personal data to:

Service providers in the following areas: marketing, administrative and transaction processing services;
State and government agencies, if required by law;
Other authorities and bodies, in order to fulfill our legislative obligations and / or protect our legitimate interests;

The transmission of your personal data to the above-mentioned recipients will only be done on the basis of a commitment of confidentiality and ensuring an adequate level of security on their part, which guarantees that personal data is kept secure.

Art. 4. The rights of individuals

According to the legal provisions in force, the data subjects benefit from the following rights:

The right to be informed about the manner and reason for the use of personal data;
The right to request copies of personal data held by an entity (including information contained in e-mails, instant messages, notes, etc.);
The right to request the correction of any inaccuracies in their personal data;
The right to order the deletion of personal data (including the permanent deletion of the Company's systems and any systems of an outsourcing provider to which the Company has granted access);
The right to request the Company to stop processing personal data;
The right to object to the use of their personal data for the purposes of direct marketing;
The right to have any personal data that has been provided to the Company transferred to another party (for example, another banking service provider) "in a structured, frequently used and automatically readable format";
The right not to be subject to a fully automated decision-making process (ie a decision generated by the system without a human contribution), if the result has a significant legal or similar effect on the person concerned;
The right to withdraw consent when it has been given for processing;
The right to address the National Authority for Supervision of Personal Data Acquisition, if deemed necessary.

If the Company receives a request from you in the exercise of any of the above rights, we will respond to the request within 30 days, with the possibility of extending this period, only after informing the data subject and provided there is a good reason to justify the impossibility of formulating a response within 30 days.

Art. 5. Data security breach

If personal data is lost, damaged, stolen, compromised or as a result of a complaint about the way the Company has managed personal data, the Company will report the breach to the National Authority for the Supervision of Personal Data Processing. within 72 hours of the finding of the infringement and to notify the relevant persons without delay if they are likely to be affected by the incident. In addition, the Company will make reasonable efforts to limit the damage caused by data security breaches.

Art. 6. Organization and responsibilities

The responsibility for ensuring the proper processing of personal data rests with any person who works for or finds himself in a form of collaboration with the Company and who has access to the personal data processed.

Art. 6.1. DPO contact information

If you have a question about the exercise of any of your rights mentioned above or any request for an address, you should contact your local DPO at the following email address: contact@avangardia.eu. You can also address requests, in writing, to the Company's mailing address, detailed in the "Contact us" section of the website.