Privacy policy and data protection

Last update: 23.04.2024

This policy details the Company’s practice regarding the processing of your personal data, as visitors/users of the domain https://proxitech-solutions.com (hereafter briefly, generically, the Site ) and aims to provide information on this subject.

By using the Site, the user acknowledges that a acknowledge and agree to this Privacy and Data Protection Policy , Cookie Policy , but also the Terms and Conditions published on the Site.

CONTENTS:

1. Identification of the data operator
2. Contact details in the field of personal data protection
3. Processing of personal data through the Site
4. The person concerned
5. Personal data processed
6. Purpose of data processing
7. Recipients of processing
8. Legal basis of processing
9. Type of processing
10. Duration of data processing and storage
11. Rights of the Data Subject
12. Obligations of the Company. Security measures of processed data
13. Liability of the Company
14. Transfer to third countries/international organizations
15. Final Provisions

1.       Identification of the data operator

COLLECTOR SRL (hereinafter referred to as COLLECTOR SRL or the Company )

Headquarters: Romania, Bihor county, Str. Romulus Guga 16, Oradea 410601

No. of registration J05/544/2015 

ID number 34338724

Email: office@proxitech-solutions.com

No. phone: +40 743 289 034

2.       Contact details in the field of personal data protection

The contact details that the visitor can use to send any requests, notifications or alerts regarding the Terms and Conditions, Cookie Policy or this Privacy and Data Protection Policy, as well as any other information published on the Site, policies or operations carried out by the Company, are indicated above.

The term in which the Company will send an answer is no more than 30 days after receiving the request.

3.       Processing of personal data through the Site

Processing is the performance of any operation or set of operations performed on personal data or sets of personal data, with or without the use of automated means.

The Company accesses, collects, uses and performs any other actions permitted by applicable law on personal data provided by visitors, as indicated in this policy.

COLLECTOR SRL collects information from users in the following ways: directly from the user, from the traffic reports recorded by the servers hosting the Site, as well as through cookies.

Information provided directly by the user:

• When the user fills in the columns in the “Contact” section, he indicates: name, surname, e-mail address and telephone (all of these are personal data).

This information is required by COLLECTOR SRL in order to be able to respond to the requests sent by the respective visitor, with the mention that only the columns containing the name, first name and email address are mandatory for sending the message, the communication of the phone number being optional (only if the visitor wishes to be contacted by the Company by phone, will also transmit the latter information).

Other personal data could be processed by the Company if such information will be included in the information/request sent by the visitor. COLLECTOR SRL did not request the respective data, but to the extent that they are absolutely necessary to be able to respond to those sent by the visitor through the “Contact” column, the processing of personal data will be carried out at the request of the Site user.

Completing the fields in the “Contact” section is not mandatory either for visiting the Site or for concluding a future service contract with COLLECTOR SRL . Moreover, all this information can be transmitted in another way (for example, submitting written requests to the Company’s headquarters or using the email address of COLLECTOR SRL instead of the form on the Website).

• When a person expresses his consent for the use of his e-mail address for marketing purposes by COLLECTOR SRL (newsletters) , for receiving information related to services, news, projects, organized events and the like.

The choice of registration in the list of beneficiaries of the newsletters sent by COLLECTOR SRL and implicitly the processing of data, can only be done after the user indicates it and the user ticks the “Subscribe” button, steps that represent the expression his consent.

The user who chose to receive newsletters from COLLECTOR SRL will be able to unsubscribe at any time, by simply clicking on the active link called “Unsubscribe” present at the end of each communication received from the Company.

• When a person consents to the use of his image, voice, name and first name/nickname chosen for social media platforms and links to them for marketing purposes by

The company confirms that none of the personal data indicated above will be used for purposes other than those expressly indicated, in particular they will not be processed for marketing purposes without complying with the legal provisions (including those related to obtaining the consent of the person concerned or justification of a legitimate interest of the operator, with full information of the person concerned).

Information from the server traffic report:

When a website is visited, users reveal certain information about themselves, such as the IP address, the time of the visit, the location from where the Website was accessed. COLLECTOR SRL , like other operators, records this information.

Information obtained through the use of cookies:

All details related to how data is processed in this context are indicated in the existing Cookie Policy on the site.

4.       The person concerned

Considering that the Company processes personal data of the visitors/users of the Site, they hold the status of Data Subject and declare that they are over 18 years old and that they can express their valid consent (where applicable), freely and without require prior approvals from a third party that have not been obtained by said visitors.

If the information/requests sent by visitors also include personal data relating to other persons (and they thus acquire the status of a data subject), the Company will process their data strictly in order to be able to respond to that information/request and does not assume no liability additional to that provided herein, the Terms and Conditions or applicable law.

5.       Personal data processed

Any information regarding an identified or identifiable natural person, respectively the Targeted Person, can be given in a personal way.

Related to the purposes of data processing indicated herein, the Company tries to minimize the personal data processed.

Thus, according to the Cookie Policy , the Data Subject will be able to check the types of cookies applicable where their use is not done automatically, in order to ensure a more complete and better experience when browsing the Site.

In order to send responses to requests/reports communicated by users using the “Contact” section and to promote the Company using the “Testimonials” and “Newsletters” sections, the Company processes the following personal data:

• Of the visitor/user:

• By collecting messages received on the “Contact” column from users and sending responses to them: name, surname, e-mail address and phone number (if this number is indicated by the user)

• By the express confirmation of the user by ticking the box corresponding to the agreement for data processing for marketing purposes, by on the first page of the Site by pressing the “Subscribe ” button : e-mail address

• By displaying testimonials embodied in pictures and text or video, in the headings called “Testimonials”: image, voice, name and surname/nickname chosen by the user for social media platforms and links to them, name of employer

• IP of the visitor/user

Depending on the cookie settings, other data may also be processed (especially those related to the visitor’s preferences and his behavior on the Site).

• Of persons other than the visitor:

Depending on the content of the messages sent by visitors/users through the “Contact” section, other data could be processed to the extent indicated, even though they were not requested.

The company undertakes to comply with the legislation regarding the protection of personal data and in relation to these third parties, but without being obliged to obtain any separate consent in this regard. The user who submitted that information is the one who assumes full responsibility in this regard and declares that they agreed to the processing carried out by COLLECTOR SRL being fully informed in this regard.

6.       Purpose of data processing

The Site Visitor is the person who accesses this page and regarding whom certain personal data are processed (respectively you), for various purposes, namely:

• In the case of data provided directly by the user:

• providing answers, clarifications and remedying problematic situations, in relation to the requests and notifications sent by the user through the “Contact” column ;
• sending information for marketing purposes;
• ensuring compliance with this Privacy Policy, the Termenii și condițiile and the Cookie Policy , as well as with applicable legal provisions to protect the rights, property or safety of the Site.

• In the case of data obtained through traffic reports:

• identifying the sections of interest of the Site;
• more secure administration of the IT system.

• In the case of data obtained through cookies:

• the operation of the Site
• depending on the settings set by the visitor, the data can be used for the proper functioning of the Site, obtaining statistical information that allows improving the services offered, saving preferences, etc. All details related to this type of data processing can be found in the Cookie Policy .

If the Company intends to subsequently process the personal data for a purpose other than those indicated above, it will provide the Data Subject prior to this further processing, relevant additional information regarding the secondary purpose, with the fulfillment of the necessary formalities according to the law.

7.       Recipients of the processing

The personal data of the Data Subject are processed by:

• the administrators and employees/collaborators of the Company who are in charge of the administration of the Site and who are involved in the activities regarding which the visitor addresses questions/reports sent through the “Contact” column – will process the name, surname and e-mail address of the visitor/ the user as well as any other personal data transmitted by him via message ;

• Company associates and employees/collaborators who are involved in the marketing process – will process the email address for newsletters, but also the image, voice, name, surname, nickname on social media and link to the social media platforms of the user and the name of the employer for Testimonials ;

• the support service providers contracted by the Company in order to fulfill its contractual or legal obligations, such as:

• the IT company – can access all the data recorded in the online records of the Company, including those of the users;
• the Company’s lawyers – can access all the data recorded in the Company’s records, in the event of legal issues that require their involvement;
• business consultants – can access all the data recorded in the online records of the Company, including those of the users.

The list of suppliers listed above is not exhaustive, but indicates the main such collaborating companies. They will have the capacity of independent operator, associated operator or authorized person in relation to the Company. Regardless of the capacity held, they undertake to maintain the confidentiality and security of the data subject’s personal data, adopting appropriate technical and organizational measures.

Although they do not have the capacity of recipients according to legal interpretations, public authorities (including ANPC and ANAF) and courts of law can process all/any of the visitor data obtained through the Site.

8.       The legal basis of the processing

• 6 lit. of the GDPR – the processing is carried out based on the consent of the visitor/user –> applicable situation when data processing is done in the context of cookies accepted by the visitor and which are not absolutely necessary for the operation of the Website; in the context of completing the data in the “Contact” section ; as well as when visitor/user data is processed for marketing purposes (the Newsletters and Testimonials headings);

• 6 lit. c GDPR – the processing is necessary in order to fulfill a legal obligation incumbent on COLLECTOR SRL –> applicable situation in the context of data processing in relation to the competent authorities;

• 6 lit. f GDPR – the processing is necessary for the purpose of achieving the legitimate interests pursued by the Company or a third party, provided that the fundamental rights and freedoms of the data subject are not violated -> applicable situation in the context of data processing for the normal operation and administration of the Site- ul, as well as in the context of data processing by providing access to service providers.

9.       Type of processing

The data processing activities carried out by the Company mainly refer to:

• collecting the data indicated by the user in the “Contact” form;
• use of data providing answers and feedback;
• the use of data for the purpose related to each category of cookies agreed by the user;
• the collection of other unsolicited data, but provided by the Data Subject in the context of a communication, request or complaint addressed to the Company, so that it can respond and resolve the request or remedy the incident;
• storing the aforementioned data in accordance with the law and within the limits necessary to achieve the purpose in the electronic and secure database owned by the Company;
• allowing access to data to certain employees and external collaborators who provide support services whose activity involves data processing under the condition of assuming the obligation of confidentiality;
• allowing access to data to the competent authorities to the extent that the law obliges in this regard.

10.   Duration of data processing and storage

The period of storage of personal data collected is:

• until the withdrawal of consent or the exercise of the right of erasure or erasure by the visitor for the processing of data based on the consent of the data subject;
• for 3 years from the receipt of the message from the “Contact” column, in order to be able to demonstrate the measures taken by the Company in consideration of it, related to the duration of the general limitation period for the right to action before the courts provided by the Romanian Civil Code;
• longer period of time than those mentioned above, when the law provides for this or when there is a well-justified reason for this (for example for the exercise of a right before the court in a dispute started before the expiration of the storage period indicated herein) .

Upon expiry of the aforementioned periods, all data will be deleted from the Company’s records.

11.   Rights of the Data Subject

1. The right to information

The Company’s policies are made available to the Data Subject at all times, being displayed on the Site. See in this regard this policy, the Cookie Policy and the Terms and Conditions .

The Company reserves the right to modify/update the content of the Site, including the referenced policies, at its sole discretion, at any time and for any reason (including but not limited to the appearance of legislative or jurisprudential changes that may affect the consequences those published on the Site). Future revisions to this policy will be indicated by changing the “Last Updated” date at the top. After the date on which the updated policy is published, accessing the Site will represent the user’s acceptance of those updated conditions.

However, if there will be significant changes that could affect the rights and freedoms of visitors or it is mandatory to obtain their consent, they will be informed about those changes through easily visible indications posted on the Site (pop-ups) or by sending emails to the addresses provided if applicable. Such significant changes will produce effects for visitors within 15 days from the moment of the display of the pop-up in question or the transmission of the e-mail by the Company (the way in which the information will be made being decided by the Company, by case by case).

However, regardless of the extent of the change, it is entirely the user’s responsibility to check the content of the Site (including the Terms and Conditions, as well as the policies displayed), to be aware of the most recent versions. Thus, STUDYING THE CONFIDENTIALITY AND DATA PROTECTION POLICY, THE TERMS AND CONDITIONS , AND THE COOKIE POLICY , REPRESENTS AN ACTION TO BE MADE BY VISITORS EACH TIME THE SITE IS ACCESSED AND BEFORE ANY REGISTRATION OR DATA SUPPLY IS MADE, SINCE CHANGES MAY OCCUR.

Upon request, the Data Subject will be informed of the essence of the contracts concluded with the above recipients where possible and of the source of the data.

1. Right of access to data

If the Data Subject wants information related to the way of processing, he can submit a request to the Company, and it will respond within 30 days from the date of its receipt.

1. The right to data rectification

If the Data Subject wants to rectify/complete the data, he can submit a request to the Company, which will be answered within 30 days from the date of its receipt.

1. The right to delete data

The exceptional cases provided for in art. 17 para. 3 of the European Regulation no. 679/2016 are applicable.

Some data are part of the Company’s records, which it keeps in relation to its legal obligations or its legitimate interest. Therefore, not all data can be deleted according to the law. However, any refusal to delete will be motivated by the Company and will have a clear legal basis.

1. The right to restrict processing or to object to processing

Restriction of processing may apply if the Data Subject finds that:

• the data is not accurate;
• the processing is illegal and the Data Subject opposes the deletion;
• The Company no longer needs the data but the Data Subject requests it for a court action and it has not yet been deleted;
• The data subject objects to the processing.

The company can continue processing the restricted data if it is necessary for establishing, exercising or defending a right in court, or protecting/defending a person, but only with the consent of the person concerned.

The company will communicate to the recipients the rectification, deletion or restriction of the data unless it is impossible or involves disproportionate efforts.

1. The right to data portability

The data subject or the person indicated by him can receive, upon request, the data processed by the Company. The company assumes no responsibility for the processing of data by that recipient.

The obligation to ensure the right to portability rests with the Company only if the processing of that data is based on the consent of the Data Subject or on the conclusion and execution of the contract. The steps will be taken within a maximum of 30 days from the receipt of the request.

1. The right of opposition

If possible, the Company will stop processing the data of the Data Subject who opposes the processing based on the legitimate interest of the Company or circumstances arise that determine the exercise of this right (including profiling).

However, the legitimate reason for fulfilling the Company’s legal obligations or processing for the purpose of ascertaining, exercising or defending a right in court will prevail.

1. The right to file a complaint

The data subject can submit:

• complaint/request to the Company address indicated in point 1 above;
• action in the competent court;
• complaint to the National Authority for the Protection of Personal Data ( www.dataprotection.ro ).

However, the company wants any conflict/difference to be resolved amicably and is fully available in this regard.

1. Right to withdraw consent

The data subject can withdraw his consent at any time, without affecting the legality of the processing before the withdrawal , nor that based on another basis.

1. The right not to be subject to a decision based solely on automated processing

The company does not practice making decisions based on automatic data processing.

12.   Obligations of the Company. Data security measures processed

The company complies with the provisions of the data protection legislation and has implemented appropriate technical and organizational measures, so as to ensure the security of the personal data processed and the respect of the rights of the Data Subjects. Thus, COLLECTOR SRL implemented measures such as:

• the conclusion of contracts with collaborators in which they have assumed the obligation of confidentiality of the information regarding the processed personal data, as well as that of compliance with the applicable legislation in the field of personal data protection;
• training employees and collaborators on the importance of protecting personal data, as well as limiting their access to data according to their duties;
• establishing internal procedures aimed at the protection of personal data;
• indication of a contact address for matters related to personal data (namely the one indicated in point 1 of this policy);
• implementation of information security measures;
• not installing structures that allow access to the Site only on the condition of creating a user account;
• not installing additional cookies to those necessary for the operation of the Site, without giving the user a possibility of choice that is permanently available.

Also, the Company will inform the competent data protection authority in the event of an incident concerning data security, without undue delay and, if possible, within no more than 72 hours from the date on which it became aware of it, with unless it is unlikely to pose a risk to the rights and freedoms of natural persons. If notification to the authority does not occur within 72 hours, it shall be accompanied by a reasoned explanation for the delay.

In the event of an incident concerning the security of personal data, COLLECTOR SRL will also inform the Data Subject without undue delay, if the violation of the security of personal data is likely to generate a high risk for his rights and freedoms. However, informing the above-mentioned Data Subject is not necessary if any of the following conditions are met:

• The company has implemented appropriate technical and organizational protection measures, and these measures have been applied in the case of personal data affected by the breach of personal data security;
• The Company has taken further measures to ensure that the high risk for the rights and freedoms of the Data Subjects is no longer likely to materialize;
• it would require a disproportionate effort. In this situation, public information is carried out instead or a similar measure is taken by which the Data Subjects are informed in an equally effective way.

Any Site/Application user traffic statistics that we will provide to third-party advertising networks or partner sites are provided as aggregate data only and do not include any identifiable information about any individual user.

Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. Consequently, despite COLLECTOR SRL’s efforts to protect users’ personal data, it cannot ensure or guarantee the security of the information transmitted by them through the Site. Users are therefore warned that any information sent through the online environment will be done at their own risk.

In order to limit this risk, MEC makes available to all interested parties the possibility of sending requests/requests/addresses/messages in physical form, at the Company’s headquarters and not necessarily by sending information by electronic means.

13.   Liability of the Company

The Company’s liability in relation to the Data Subject will be established in relation to the capacity held in the respective data processing operation, the reason and place of the incident, the security measures taken, the steps taken to avoid incidents and compliance with other legal obligations.

14.   Transfer to third countries/international organizations

The Company does not transfer outside the EU personal data of the Data Subject collected through the Site.

15.   Final provisions

This policy applies to the Company and visitors to the Site (including those who fill out existing forms on the Site).

This document is part of the Company’s set of security policies. Those indicated in this document and will be revised according to specific needs.