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Privacy Policy

May 2020

 

Your privacy is one of our fundamental commitments at Asociatia Transilvania IT  (referred to as “Transilvania IT Cluster” or “we”). 


Therefore, we take outmost care to process your personal data in accordance with the principles set forth in the data protection legislation applicable in Romania, including (EU) Regulation 2016/679 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 (“GDPR”). Personal data represents any information relating to an identified or identifiable natural person, and an identifiable person is that person that may be identified directly or indirectly, particularly by reference to an identification number or to one or more factors specific to its physical, psychological, mental, economic, cultural or social identity.


This privacy policy regards the personal data of our cluster members, business partners, other persons contacting and visiting us and of the representatives thereof, potential employees, interns, associates or persons attending events organized by or with the involvement of Transilvania IT Cluster and it applies to data collected through our website, transilvaniait.ro, as well as to all other personal data we collect through e-mail or other off-line contacts or in the context of events organized by or with the involvement of Transilvania IT Cluster. The privacy policy describes:

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  • the purposes for which we collect and use your personal data

  • the processing grounds for such purposes

  • the categories of personal data we collect from you and process

  • the duration of processing of such data

  • to whom we may disclose your personal data.

  • personal data transfer

  • how we protect your personal data

  • cookie policy

  • your rights as data subjects and the manner in which you may exercise them

 

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PURPOSES, GROUNDS FOR PROCESSING AND CATEGORIES OF PERSONAL DATA
 

In the context of your interaction with Transilvania IT Cluster, you, as a natural person, may be subject to the data processing activities that we perform. 

 

What personal information do we collect about you?
 

We may collect personal information from you in the course of our business, including through your use of our website, when you contact or request information from us, when you engage our services or as a result of your relationship with one or more of our staff.
 
The personal information that we process includes:


Basic information, such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person
 

Contact information, such as your postal address, email address and phone number(s)
 

Financial information, such as payment-related information
 

Technical information, such as information from your visits to our website or applications or in relation to materials and communications we send to you electronically
 

Information you provide to us for the purposes of attending meetings and events, including access and dietary requirements


Identification and background information provided by you or collected as part of our business acceptance processes


We may process some of your personal data in the context of taking photos / video recordings with the participants at the events organized by or with the involvement of Transilvania IT Cluster.


Any other information relating to you which you may provide to us.

 


Grounds for processing:


To perform a contract, such as engaging with an individual to provide our services.


To comply with legal and regulatory obligations.


For legitimate business purposes. 


The express consent.  For close-up photos/ video recordings, we base our processing on your consent, expressed including through gestures, behavior (e.g. your posture in the photo / video recordings). If you do not want to appear in such photos/ video recordings, you always have the possibility to address the photographer directly.


You can always withdraw your consent expressing thereby your option of not receiving our newsletters in the future by clicking “Unsubscribe” when you receive the respective e-mail or by writing at privacy@transilvaniait.ro

 


PROVIDING THE PERSONAL DATA


When the data are required directly from you, Transilvania IT Cluster kindly asks you to provide all categories of personal data we request in the aforementioned purposes, as otherwise we shall not be able to carry out our activity (including, among others, to provide you with our services).


If you provide to Transilvania IT Cluster the personal data of other natural persons, we kindly ask you to communicate to them before such disclosure the modality in which Transilvania IT Cluster intends to process their personal data, as described in this Privacy Policy.

 


DISCLOSURE OF YOUR PERSONAL DATA


While as a rule we shall not disclose your personal data to any third parties, we may:

 

  • disclose your contact details to our affiliates within Transilvania IT Cluster, to our contractual partners and to our service providers (including data processors);

  • disclose relevant personal data to the members who provided your personal data in the context of providing the services requested from us, if it is necessary to fulfill these purposes;

  • disclose photo/video image recorded in the context of events organized by or with the involvement of Transilvania IT Cluster (including in the context of organizing webinars), by publishing such images on our site, ________________ or on social platforms like Facebook, LinkedIn or YouTube

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DURATION OF PROCESSING


We intend to keep your personal data for the duration of the assistance agreement, as well as afterwards, according to our internal policies and the legal obligations incumbent upon us.


Your personal data is only stored as long as there is a need to save it to fulfill the purposes for which the data was collected in accordance with this data protection policy. We may save some information longer if needed to comply with other legal requirements. We store information about members / customers for a maximum of 12 months after the member / customer no longer has a valid, ongoing, relationship with us.

 


PERSONAL DATA TRANSFER


We do not transfer your personal data to EU/non-EU countries, unless expressly laid down by law or when necessary for the purpose of data collection. In case any changes occur, you will be duly informed.

 


HOW WE PROTECT YOUR PERSONAL INFORMATION
We use a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection laws.

 


COOKIE POLICY


When navigating the transilvaniait.ro website, data regarding your visit are automatically generated. They include your IP address, your browser, accessing time, accessed page or document and other technical data. The transilvaniait.ro website does not use cookies for tracing your browsing options, tracking your searches or other potentially intrusive elements.


The categories of data processed in this context are the hour and date of accessing the Internet website and the IP address from which our Internet website was accessed.    


We base this data processing activity on our legitimate interest in ensuring the proper functioning of our Internet website, as well as its improvement.

 


YOUR RIGHTS


In your capacity as data subjects, the GDPR provides you with a series of rights including:


Right of access (Article 15 of the GDPR)
You have the right to obtain from the Transilvania IT Cluster confirmation as to whether or not your personal data are being processed, and, where that is the case, access to the personal data.


Right to rectification (Article 16 of the GDPR)
You have the right to obtain from the Transilvania IT Cluster the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed.


Right to erasure (“right to be forgotten”) (Article 17 of the GDPR)
Where (1) personal data are no longer necessary in relation to the purposes for which they were collected, (2) you withdraw consent on which the processing is based and there is no other legal ground for the processing, (3) you object to the processing and there are no overriding legitimate grounds for the processing or (4) the personal data have been unlawfully processed, you have the right to obtain the erasure of personal data concerning you.


Right to restriction of processing (Article 18 of the GDPR)
You have the right to obtain the restriction of personal data processing by the Transilvania IT Cluster where one of the following applies:

  • accuracy of the personal data is contested by you, for a period enabling the controller to verify their accuracy;

  • processing is unlawful and you oppose the erasure of the personal data, requesting the restriction of their use instead;

  • Transilvania IT Cluster no longer needs your personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;

  • you have objected to processing pursuant to Article 21(1) of the GDPR, pending the verification whether the legitimate grounds of the Transilvania IT Cluster override yours.


Right to data portability (Article 20 of the GDPR)
You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the Transilvania IT Cluster, where:

  • the processing is based on your consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) of the GDPR or on a contract pursuant to point (b) of Article 6(1);

  • the processing is carried out by automated means.

 

The right to object (Article 21 of the GDPR)
You shall have the right to object, at any given time, to the processing of your personal data on grounds relating to your particular situation, to the operations of processing of personal data, necessary for the performance of a task carried out in the public interest, or which results from the exercise of an official authority invested in the Transilvania IT Cluster  and/or to the processing carried out for the purposes of the legitimate interests pursued by the Transilvania IT Cluster or by a third party, including profiling based on these provisions. If you have already exercised your right to objection, The Transilvania IT Cluster cannot process your personal data, but for the case when Transilvania IT Cluster proves that there are legitimate and imperative reasons which justify the processing and which prevail over the public interest, rights and liberties of the data subject or that the purpose of the processing is establishing, exerting or defending a right in the court of justice.


The right not to be subject to a decision based solely on automated processing (Article 22 of the GDPR)
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, such as your performance at work.


This right does not apply if the decision:

  • is necessary for entering into, or performance of, a contract between you and the Transilvania IT Cluster;

  • is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or

  • is based on your explicit consent.


Right to withdraw your consent (Article 7(3) of the GDPR)
Where processing is based on consent, you have the right to withdraw your consent at any time by submitting an express request. If you consider that your rights regarding personal data processing have been infringed, you have:

  • The right to lodge a complaint with the National Supervisory Authority for Personal Data Processing;

  • The right to bring the matter before a competent court.

 

​We are happy to ensure your exercise of these rights.

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You may exercise your aforementioned rights and find out more about such rights by filing with us, as data controller, a written request at Asociatia Transilvania IT, 4 Bld. Nicolae Titulescu Street, Cluj-Napoca, Cluj County, Romania or by e-mailing us at privacy@transilvaniait.ro.
 

You also have the right to file a complaint with the data protection authority, having its headquarters at 28-30 G-ral Gheorghe Magheru Bld. District 1, Bucharest, 010336, Romania.
 

We are committed to always treat your requests with the utmost attention and address any queries you may have in the shortest time possible.
 

 

VERSIONS TO THIS PRIVACY POLICY


This Privacy Policy is in force as of May 2020.


This Privacy Policy may be updated from time to time. Any updates will become applicable within 7 days as of the publication of the new version on Transilvania IT Cluster’s website.

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