Privacy Policy

Updated 25.05.2018

PREAMBLE AND CONTACT

BY USE OF THE SITE, YOU DECLARE YOU AGREE WITH COLLECTION, STORAGE, USE AND DISTRIBUTION OF YOUR DATA AS DESCRIBED IN THIS POLICY AND FOR THE PURPOSE OF COMPLIANCE WITH THE CONTRACTS CONCLUDED BETWEEN OUR COMPANY AND YOU, IF APPLICABLE. IF YOU DO NOT AGREE WITH THIS POLICY, PLEASE DO NOT USE THE SITE IN ANY WAY.

The purpose of this document is to inform you about collection, storage, use and distribution of your data (“Data”) as a result of using this Site and your rights in this regard.

Read this page carefully before you start using this Site. If you do not wish to be bound by this Policy, then you do not have to access this Site.

Data may be used by our company and by all entities in Prime Kapital Group (“We”, “The Company”). They can also be used by the Trading Partners of the Company.

For us, your Data Security is very important and we make every effort to ensure a confidential and secure framework.

The Company’s contact person, namely the DPO responsible (Data Protection Officer) is Andrei Velio and can be reached by email at gdpr@primekapital.com. The DPO can also be contacted at Globalworth Tower, floor 11, 201 Barbu Vacarescu Blvd, 020276 Bucharest, Romania, PK DEVELOPMENT SRL, J40/3162/2007, CUI 21103980.

If you have any questions about this Policy or any complaints regarding the use of data, please contact the DPO and we will do our best to deal with your complaint or your questions as soon as possible.

DATA WE COLLECT AND USE

The data we collect is the one you choose to provide us with. Site visit involves automatic data collection regarding: your IP address, operating system and browser type, for system administration and for security reasons, and to collect aggregate information. These are statistical data about our users’ actions and patterns of navigation. Types of personal information we collect and process include:

  • The information you provide by filling in the registration form on our Site. This may include, among other things, your name, e-mail address, telephone number.
  • The correspondence with you including, but not limited to, notices, requests, questions, etc.

Also, when you access our Site, we collect and store a series of personal data automatically transmitted by your browser, such as:

  • Internet Protocol (IP) addresses;
  • The type of browser and its version;
  • The type of device used and the operating system;
  • Date and time of accessing the Site;
  • Your location.

By using the Site you agree to your personal data being transferred for storage to the server managed by the IT service provider or one of its affiliates and/or subcontractors, the technical, organizational and personal measures being maintained at the same level.

WHAT WE DO WITH THE DATA

We may use the personal data you provide us in our Site to:

  • Provide the requested information and to respond to the correspondence received from you;
  • Send you marketing information about us, about our projects / campaigns / events / activities, etc;
  • Let us know about any activities we do and we think might be of interest to you;
  • Bring you content from our Site in the way we consider most effective;
  • For other specific uses within campaigns, promotions, or local activations (see specific regulations made available in these cases);
  • Contact you when necessary.

Your personal data will be stored for the entire duration of your Account and/or subscription to the Newsletter. We will delete the data associated with your account or your subscription to the Newsletter once you decide to disable your Account or, as the case may be, unsubscribe from the Newsletter. However, data deletion may not be concurrent with deleting your Account and/or unsubscribing the Newsletter. We also reserve the right to retain the data if it is necessary to comply with our legal obligations, solve disputes, etc.

TRANSMISSION OF PERSONAL INFORMATION OUTSIDE EEA

The information you provide can be submitted by us to our group companies, from countries outside of the European Economic Area. Countries outside the European Economic Area can not always have strong data protection laws. However, we will always take steps to ensure your information is used in accordance with this Policy and is securely kept. If you do not agree with this transfer, please do not register on our Site.

DISCLOSURE TO THIRD PARTIES

The data you provide us is treated with maximum confidentiality. However, in some cases, we may be required to disclose your data in order to comply with legal requirements. We may also disclose the data to our group companies or third party companies:

  • Which offers us services, if we need to provide any information you have requested. For example, we may need to disclose your personal data to our agents or PR advisers;
  • If this third party is a professional counselor for us or any of our group companies;
  • The data we collect at the time you fill out the newsletter subscription form or the contact form can be transferred to our service and maintenance service provider.

Our Site may contain links to third-party sites. We do not control the privacy practices of these websites. Therefore, if you access the Site, you must ensure you have read the privacy policy of that site.

UNREQUESTED INFORMATION

If we receive any personal data we have not requested directly from you and we settle we could have obtained this data from you to the extent we have requested it, we will take the necessary steps to notify, within a reasonable time, that we have collected those data. To the extent we could not have collected these data from you by requesting them, we will proceed to destruction or denomination thereof. Any unrequested provided information will be used for the purposes stated in this Policy and with respect for the purpose for which you have been submitted.

YOUR RIGHTS RELATED TO PERSONAL DATA

Right of access

During the processing of your data, you may, without being compelled to pay any fees or costs of any kind, obtain from us, based on your request, the following information:

  • Confirmation that we process or do not process your data;
  • Access to data and the following information:
  • Purposes of the processing;
  • The categories of personal data concerned;
  • The recipients or categories of recipient to whom these data have been or will be disclosed;
  • The period for which these data are expected to be stored;
  • The right to request us to rectify or delete the data, or to restrict the processing thereof, and the right to object the processing;
  • The right to lodge a complaint with the National Supervisory Authority of Personal Data, Bucharest, 28-30 Gh. Magheru, district 1;
  • If the data are not collected directly by us, any available information regarding their source;
  • The existence of an automated decision-making process, including profiling;
  • Where data are transferred to a third country, the guarantees relating to that transfer;
  • Right to obtain a copy of your data.

Right to rectification

During the processing of your data, you may, without being compelled to pay any fees or costs of any kind, obtain from us within 30 days of receipt of a written request from you, rectifying such data which are inaccurate, or completing incomplete data.

Right to erasure

For the entire processing of your personal data, you are entitled, without being compelled to pay any fees or costs of any kind, to obtain from us, or, as the case may be, we will proceed ex officio to delete your data, in the following cases:

  • Data are no longer required in relation the purposes for which they were collected or otherwise processed;
  • Data subject withdraws consent you have submitted for processing the data and there is no other legal basis for processing;
  • You will objects to the processing of your data and there are no overriding legitimate grounds regarding the processing;
  • Personal data has been illegally processed;
  • Data must be erased to comply with a legal obligation.

The right to restriction of processing

During the processing of your data, you may, without being compelled to pay any fees or costs of any kind, obtain from us within 30 days of receipt of a written request from you, restriction of processing in the following cases:

  • Defend the accuracy of your data – the restriction will occur during the period we verify the accuracy of the data;
  • Data processing is unlawful, and you will oppose the erasure of your data, requesting instead the restriction of your use;
  • We no longer need your data for processing, but you ask us for establishment, exercise or defense of a right in court;
  • During the period when we verify that our legitimate rights as a collector prevail your rights as data subject, if you oppose to data processing.

In this case where processing has been restricted, data may, except for storage, be solely processed with your consent or be processed for the purpose of establishing, exercising or defending a right in court or for protecting the rights of another individual or legal entity for reasons of public interest.

Right to be informed regarding rectification or erasure of personal data or restriction of processing

During the processing of your data, you may, without being compelled to pay any fees or costs of any kind, obtain from us within 30 days of receipt of a written request from you, information about the recipients of personal data who have been informed about rectification, deletion of personal data or restriction of processing.

The right to data portability

During the processing of your data, you may, without being compelled to pay any fees or costs of any kind, obtain from us within 30 days of receipt of a written request from you, any data concerning you and which you have provided to us in a structured and automatically readable format, as well as the right to transmit these data to another operator, if:

  • The processing is based on your consent or a contract, and
  • the processing is carried out by automatic means.

Transmission to another operator may be made directly by us, to the extent that you request it, and if it is technically feasible.

Right to object and automated decision-making

You may, at any time, object to data processing, including profiling, and the right to object to data processing for the purpose of direct marketing.
Your right to object may be exercised by submitting a request in writing to us.

Considering the above, you can directly address to our Data Protection Officer.

PERIOD OF DATA PROCESSING AND STORAGE

Your data is to be processed and stored with your consent until such consent is withdrawn.

CONFIDENTIALITY AND SECURITY

Data Protection is very important to us. We will take all necessary security measures to protect your data against unauthorized access or to modify, disclose or destroy unauthorized data. This requires internal revisions of data collection, storage and processing practices and security measures, as well as physical security measures to protect against unauthorized access to systems where we store personal data.

We have implemented technical and organizational security measures to protect your data against unauthorized access to, loss, destruction or accidental or intentional alteration. These measures are constantly updated and adapted to ensure the highest level of protection.

All personal information will be processed using secure pages, the SSL encryption system, marked with a lock symbol, located at the bottom of the browser window.

AMENDMENTS TO THE PRESENT POLICY

The present Policy may be unilaterally amended at any time by us. To the extent that such a change occurs, it will be valid from the date of publication of the updated version on our website.

LEGAL CHANGES WITHIN THE COMPANY

In the event the Company is involved in a process of reorganization, merger, acquisition, or any other change in management or transfer of assets, your data may be transferred as part of that transaction, at which point we will notify you in this regard.

COOKIES USE POLICY

This policy refers to the cookies and webpages of this Site.

What are Cookies?

The cookie is a small file of letters and numbers that will be stored on your computer, mobile terminal, or other equipment of a user accessing the Internet. The cookie is installed via a web browser request from a browser (e.g. Internet Explorer, Chrome) and is completely “passive” (does not contain software, viruses or spyware and can not access the information regarding the user’s hard drive).

What are Cookies used for?

These files make it possible to recognize the user’s terminal and present the content in a relevant way, adapted to the user’s preferences. Cookies – are used to prepare aggregated anonymous statistics that help us understand how a user benefits from our web pages, allowing us to improve their structure and content, excluding personal identification of the user.

What Cookies do we use?

We use two types of cookies: per session and fixed. The latter are temporary files remaining in the user’s terminal until the end of the session or closing the application (the web browser). Fixed files remain on the user’s terminal for a while in the Cookie’s parameters or until they are manually deleted by the user.

How are cookies used by this Site?

A visit of this Site may place cookies for purposes of:

  • Site performance cookies
  • Visitor analysis cookies
  • Cookies for geotargetting
  • Recording cookies
  • Cookies for advertising
  • Advertisers cookies

Do Cookies include personal data?

Cookies themselves do not require personal information to be used and, in most cases, do not personally identify Internet users. Personal data collected by using Cookies can only be collected to facilitate certain user functions. Such data is encrypted in a way that makes unable any unauthorized persons to access them.

Delete cookies

In general, an application used to access web pages allows you to save your Cookies in the terminal by default. These settings can be changed in such a way that the automatic administration of Cookies is blocked by the web browser or the user is informed whenever cookies are sent to his or her terminal. Detailed information about the possibilities and ways of managing cookies can be found in the application settings area (the web browser). Restricting the use of Cookies may affect certain features of the web page.

Why are Internet Cookies important?

Cookies are the central focus of the efficient Internet, helping to generate a friendly browsing experience and customized to the preferences and interests of each user. Refusing or disabling cookies can make some sites unusable.
Refusing or disabling cookies does not mean you will not receive online advertising – but it will no longer be able to keep track of your preferences and interests highlighted by your browsing behavior.

Examples of important uses of cookies (which do not require authentication of a user into an account)

  • Content and services customized to user preferences – product categories and services.
  • Offers customized for user interests – remember the passwords.
  • Retain filters of child protection regarding Internet content (family mode options, safe search functions).
  • Limiting ad frequency – limit the number of displays of an ad for a particular user on a site.
  • Providing more relevant advertising to the user.
  • Measurement, optimization, and analytics features – such as confirming a certain level of traffic on a website, what kind of content is viewed, and how a user reaches a website (e.g. by search engines, directly from other websites, etc.). Websites run these analyzes of their use to improve sites for the benefit of users.

Security and privacy (confidentiality) issues

Cookies use plain text formats. They are not made up of pieces of code so they can not be executed or auto-run. Consequently, they can not be duplicated or replicated on other networks for running or replicating again. Because they can not perform these functions, they can not be considered viruses.

Cookies can still be used for negative purposes. Because it stores information about user preferences and browsing history, both on a particular site and on several other sites, cookies can be used as a form of Spyware. Many anti-spyware products are aware of this and consistently mark cookies to be deleted in anti-virus / anti-spyware removal / scanning procedures. In general, browsers have built-in privacy settings that provide different levels of cookie acceptance, valability and automatic deletion after the user has visited a particular site.

Other security issues related to cookies

Since identity protection is very valuable and is the right of every internet user, it is advisable to know what issues can create cookies. In order to send constant information in both ways between the browser and the website, if a hacker or unauthorized person intervenes during the data transmission, the information contained in the cookie can be intercepted. Although very rarely, this can happen if the browser connects to the server using an unencrypted network (e.g. an unsecured Wi-Fi network).

Other cookie-based attacks involve bad cookie settings on servers. If a website does not require the browser to use only encrypted channels, hackers can use this vulnerability to prevent browsers from sending information via insecure channels. Hackers then use information for the purpose of unauthorized access to certain sites. It is very important to be careful in choosing the most appropriate method of protecting personal information.

Tips for safe and responsible cookie-based navigation.

Due to their flexibility and the fact that most of the most visited sites and the biggest ones use cookies, they are almost inevitable. Disabling cookies will not allow the user to access the most popular and used sites including Youtube, Gmail, Yahoo and others.
Here are a few tips that can help you to safely navigate with cookies:

  • Customize your browser settings for cookies to reflect a comfortable level for you regarding cookie security.
  • If you do not mind cookies and you are the only person using your computer, you can set long expiration dates to store your browsing history and personal access data.
  • If you share access to your computer, you can consider the browser setting to delete individual browsing data each time you close your browser. This is a way to access sites that place cookies and delete any business information when you close the browsing session.
  • Constantly install and update your antispyware applications.

Many of the applications for detection and prevention of spyware include the detection of site attacks. This prevents the browser from accessing websites that could exploit browser vulnerabilities or download dangerous software.

Make sure your browser is always up-to-date.

Many of the cookies attacks are carried out by exploiting the weaknesses of the old versions of browsers. Cookies are everywhere and cannot be avoided if you want to enjoy access to the best and largest internet websites – local or international. With a clear understanding of how they work and the benefits they bring, you can take the necessary security measures so you can browse with confidence on the internet. Disabling and refusing to receive cookies can make some sites unfeasible or difficult to visit and use. Also, refusing to accept cookies does not mean you will not get / see online advertising anymore.

It is possible to set up the browser so that these cookies are no longer supported or you can set the browser to accept cookies from a particular site. But for example, if you are not registered using cookies, you will not be able to leave comments. All modern browsers offer the ability to change cookie settings. These settings are usually found in your browser’s “options” or “preferences” menu. To understand these settings, the following links may be useful otherwise you can use the browser’s “help” option for more details.

Useful Links

If you want to know more about cookies and what they are used for, we recommend the following links:

Globalworth Tower, 11th Floor
201 Barbu Vacarescu Street
020276 Bucharest, Romania
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