It’s important for you to read this policy together with any other policy we may provide on different occasions or with different purposes, that involves collecting any personal data about yourself, so that you are fully aware of the how and why we are using your data.
Who we are
Our full details are:
Full name of legal entity: Webs9 SRL
Email address: firstname.lastname@example.org
Postal address: 153-155 Bulevardul Dacia, 4th floor, Bucharest
Third party links
Webs9.com may include, but it is not limited to third party links, special plugins or apps. By accessing those links and/or enabling those connections you may allow third parties to collect or share data about you. It’s important for you to know that we do not control these third-party websites and are not, in any way, responsible for their privacy policies. You should pay attention to any consent you give to third party apps or software. At the moment you leave our website, we are not responsible for third parties’ privacy policies and we advise you to read them before accessing the website.
The data we collect about you
Personal data or personal information refers to any piece of information about an individual from which that person can be accurately identified and does not include any data from which the identity has been removed (anonymous data). Personal data or personal information could include, but it is not restricted to:
- name (may include first, last, maiden name, surname, username, avatar, marital status, job title, gender, date of birth);
- contact information (email address, postal address, business or personal, phone number);
- financial data (bank account and payment details);
- marketing data (communication preferences in receiving marketing data from us);
- special categories of data that you may provide when applying for a job with us (details about nationality, race or ethnicity, religious or philosophical beliefs, sexual orientation, political views, trade union membership, health, genetic or biometric data).
Any or all this information given via this website will only be used to provide the requested answer or service and will not, by any means, be provided to any other third party, under any circumstances, without your explicit permission or unless the law obliges us to do so.
Any non-personal information, such as usage data, IP address, accessed pages, downloaded resources, login information, browser type and version, time zone, browser plug-ins, operating system, mobile device or any other technology will only be used to determine how many individuals use our website and which pages are most-accessed. This piece of information does not reveal to us any personal information about your identity, being used only for us to monitor and improve our website and the services we provide.
If you fail to provide data
In case we need to collect personal data as instructed by the law or under the terms of a contract, we have with you and you fail to provide us with this data when requested, we may not be able to perform the articles of the contract we have or we intend to have with you. In this case we may have to cancel the services, but will make sure to notify you if this is the case, at any time.
How is your personal data collected
We use different methods of collecting data from and about you through:
- Direct interactions – you may give us your data (identity, contacts, financial data) by filling in forms from our website or by directly corresponding with us via email, phone, post or otherwise. This may include data you provide when you apply for our services, subscribe to our news or publications, request marketing info to be sent to you, enter a survey or promotion or give us feedback by using our website.
- Third parties or publicly available sources – we may receive personal data about you from different third parties and public sources (technical data from analytics providers, such as Google, based outside the EU, identity and contact information from publicly sources such as the internet based inside the EU, advertising networks and search information providers based inside or outside the EU, contact, financial and transactional data from aggregators based inside or outside the EU.
How we use your personal data
We will only use your personal data under the strict requirements of the law. Most commonly, we will use your data in the following circumstances:
- when we need to perform the contract we are about to enter or have entered into with you;
- when it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;
- when it’s necessary for us to comply with a legal or regulatory obligation;
- to carry out services we have agreed to provide to you.
You have the legal right to withdraw consent from marketing data at any time, by contacting us directly.
It’s important for you to know that we may process your data for more than one reason, depending on the specific purpose for which we are using your information. Please feel free to contact us if you require more details about the specific legal reasons.
|Purpose of use
|Type of data
|Lawful basis for processing, including basis for legitimate interest
|To register you as a new client
|Legal performance of a certain contract
|To process and deliver your order, including managing payments, fees, charges, collecting or recovering money owed to us
|Identity, contact info, financial, transactional, marketing and communications info
|Performance of a contract, necessary for our legitimate interests
|To provide specific services as underlined in the contract we have with you, to manage our relationship, that may include third parties to assist in the provision of those services. To continue providing you with the information you request, customer-satisfaction surveys, changes to our services or this privacy notice
|Identity, contact info, marketing and communications info.
|Performance of a contract, necessary for our legitimate interests. Keeping you updates and receive your feedback required to comply with a certain legal obligation.
|To manage and protect your business and this website (including data analysis, troubleshooting, testing, system maintenance, data handling and reporting).
|Identity, contact info, marketing and communications info.
|Our legitimate interests to run our business, provision of administration and IT services, network security, preventing fraud or prevent access to data we may hold, necessary to comply with a legal obligation.
|To deliver to you relevant website content and advertisements and to measure or understand the effectiveness of the advertising we serve.
|Identity, contact info, marketing and communications, technical information
|Our legitimate interests to run our business, keep our website and marketing relevant and updated, develop our business and inform about our marketing strategy.
|To respond to any job applications we receive
|Identity, contact, special categories
|Our legitimate interest to develop and grow our business.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We will get your express opt-in consent before we share your personal data with any company for marketing purposes, if this will ever be the case.
It is your choice to ask us or third parties to stop sending you any marketing messages at any time. When you opt out from receiving marketing messages, it’s important for you to know that this will not apply to personal data provided to us as a result of a service purchase, experience or other transactions made through our website.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get a detailed explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us directly.
Disclosures of your personal data
We may have to share your personal data with third parties for the purposes set out in the table above, with a prior notification. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third-party service providers to use your personal data for their own purposes and only allow them to process your personal data for specified purposes and in accordance with our specific instructions, if this will ever be the case.
Some of our external third parties may be based or may send personal data outside the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
We have established appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in any unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we are obliged to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers, for tax purposes. In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notifying you.
Your Legal Rights
Under certain circumstances, you have rights under the data protection laws in relation to your personal data.
Request access to your personal data – This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data – This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data – This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data – when we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing your personal data – This enables you to ask us to suspend the processing of your personal data in the following cases: if you want us to establish the data’s accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer of your personal data to you or a third party – We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to withdraw consent at any time – this will not affect the lawfulness of any processing carried out before you withdraw your consent. But, if you withdraw your consent, we will not be able to provide certain services to you any longer. You will be notified at the time of the withdrawal of consent.
If you wish to exercise any of the rights set out above, please contact us.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.