Last updated: November 11, 2022
Read this information carefully so that you understand how we process personal data and what your rights are.
- Authorized Personnel means only those of the Controller employees, agents, advisors, or Subcontractors: (i) who need to know or to process the personal data for the Permitted Purpose; (ii) who are bound by legal obligations to protect the personal data they process which are no less rigorous than the obligations imposed on the Controller;
- Cookies are small files that are placed on your computer, mobile device, or any other device by a website, containing the details of your browsing history on that website among its many uses.
- Data Subject means the natural living person whose personal data is processed;
- Device means any device that can access the Website such as a computer, a cellphone, or a digital tablet;
- Controller means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;
- Permitted Purpose means processing personal data solely and exclusively to the extent necessary for the Controller to perform its obligations under the Agreement strictly in accordance with its terms and conditions;
- Process (or “Processing” or “Processed”) means any operation or set of operations which is performed on personal data, or sets of personal data, whether or not by automated means, such as accessing, capturing, collecting, extracting, recording, organizing, structuring, storing, adapting, retrieving, intercepting, using, disclosing by transmission, dissemination, or otherwise making available, modifying, aligning or combining, restricting, erasing, deleting, or destroying;
- Personal data is any information that relates to an identified or identifiable individual;
- Website Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Website, to provide the Website on behalf of the Company, to perform services related to the Website, or to assist the Company in analyzing how the Website is used;
- Usage data refers to data collected automatically, either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit);
- Website refers to AdTech, accessible from https://adtech.org;
2. General Information
Any personal data collected by us will be processed (i.e., used, stored, transmitted, etc.) in accordance with this Privacy Notice by us:
S.C. SEVIO SOLUTIONS S.R.L, a limited company duly incorporated under the laws of Romania, with company number 33470068, whose registered office is at Iași Municipality, Calea Chișinăului, No.104BIS-106, Iași County, Romania.
We act as a data Controller when we process your personal data.
If you have any questions or comments or want to exercise your rights, you may contact us via our registered office or via the following e-mail address: [email protected].
3. Categories of personal data processed
While using our Website, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:
- General data: First name, last name, e-mail address;
- Technical and usage data (any personal data we collect as part of your cookies setting, namely online identifiers): cookie identifier, IP address, browser type and version, time zone settings and location, operating system and platform, time zone settings, information about your visit (the webpages accessed while browsing our Sites, the links that redirected the visitor to our Website, the accessing dates and times, and other diagnostic data). When you access the Website by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers, and other diagnostic data.
- Marketing and communications data: your preferences in receiving marketing from our third parties and us, your communication responses, and messages and other types of data collected as a result of email tracking (frequency, reporting of how often, for how long, and what actions are taken on an email sent by us).
When you leave comments on the Website, we collect the data shown in the comments form, your IP address, and browser user agent string to help spam detection.
Google Analytics is also an element of the Website. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Website, the Internet Protocol address, and the type of device, operating system, and browser used to access the Website. By using a browser plugin available at http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics.
4. How we collect your data
- Through the contact form, when you communicate with us;
- Through the comment section;
- When you visit our Website; and/or
- When you provide us with your marketing preferences.
5. How we use your personal data
The Company may use personal data for the following purposes:
- To provide and maintain our Website and its services, including to monitor the usage of our Website. The lawful basis we rely on to use your personal data is our legitimate interest to ensure the quality of our Website and Content [Article 6 paragraph 1 letter f) GDPR].
- To ensure the protection of our users and Website against spam comments and other types of unwanted content. The lawful basis we rely on to use your personal data is our legitimate interest to protect our Website’s reputation and to support its proper functionality [Article 6 paragraph 1 letter f) GDPR].
- To contact you: To contact you by email or other equivalent forms of electronic communication. The lawful basis we rely on to use your personal data is your consent [Article 6 paragraph 1 letter a) GDPR].
- To manage your requests: To attend to and manage your requests or complaints to us. The lawful basis we rely on to use your personal data is our legitimate interest to manage our site users’ requests/complaints and keep adequate proof of such to defend our rights and interests [Article 6 paragraph 1 letter f) GDPR].
- To provide you with news and general information about AdTech’s content unless you have opted not to receive such information. The lawful basis we rely on to use your personal data is your consent [Article 6 paragraph 1 letter a) GDPR].
- To measure the success of our campaigns and site users’ interest: we use tracking technologies in our e-mails so that we can monitor when the e-mails are opened and also evaluate the performance of our campaigns. The lawful basis we rely on to use your personal data is your consent [Article 6 paragraph 1 letter a) GDPR].
- To receive feedback, interact, and share ideas through the comment section. The lawful basis we rely on to use your personal data is your consent [Article 6 paragraph 1 letter a) GDPR].
- For other purposes: we may use your information for other purposes, such as data analysis, identifying usage trends, evaluating and improving our Website and your experience, and for other marketing and advertising purposes. The lawful bases we rely on to use your personal data are: your consent [Article 6 paragraph 1 letter a) GDPR]; our legitimate interest to promote our activity; our legitimate interest to develop and improve our Website and to better know our site users [Article 6 paragraph 1 letter f) GDPR].
6. How your information is disclosed
We may share your personal information in the following situations and to the following parties:
- With our service providers: we may share your personal information with website providers, processors, agents, contractors, or other services that perform various tasks on our Website in our interest, respectively maintenance, data analysis, surveys, e-mail marketing, data hosting;
- With other users: when you share personal information or otherwise interact in public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
Additional information disclosures may be made for the following purposes:
- Business acquisitions or transfers. In case of our company’s acquisition or merger by/with another company, or if our business unit or assets are sold or transferred to another company, in the context of bankruptcy events or other business transmissions, we reserve the right to disclose and/or transfer information to the company in question.
- Law enforcement. Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
7. How long we will keep your personal data
We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website, or we are legally obligated to retain this data for longer time periods.
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
In the case of personal data processed based on your consent, they will be kept in our records only for as long as the consent is maintained.
8. Tracking Technologies: Cookies and Others
Depending on the categories of cookies, we rely on (i) our legitimate interest in ensuring that our Website functions properly (for “necessary cookies”), or (ii) users’ permission (for “performance cookies”).
We may also combine and correlate the data collected through cookies or other similar technologies with other data collected by us.
- Web Beacons. Certain sections of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
9. EEA data and Global data transfers
Your information, including personal data, is processed at the Company’s operating offices (Romania) by the authorized personnel and in any other places where the parties involved in the processing are located. This means that this information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
As mentioned above, in order to provide our services, we may disclose your personal data to our contractors, who may be located both in EU and outside of the European Economic Area (“EEA”). Most of our processors have servers located in data centers in the United States or even around the world.
Therefore, in order to prevent such discrepancies from affecting your personal information, we seek to comply with the guarantees listed below:
- the country to which we transfer your personal data has been deemed to provide an adequate level of protection for personal data by the European Commission;
- a specific contract approved by the European Commission which gives safeguards to the processing of personal data, the so-called Standard Contractual Clauses.
10. Rights on personal data
In accordance with applicable data protection laws, regulations, guidelines, and policies, you may exercise the following rights in connection with your personal data.
a) The right of access
You can obtain confirmation from us that we process your personal data, as well as information on the specifics of the processing such as: purpose, categories of personal data processed, recipients of the data, period for which the data is kept, the existence of the right of rectification, deletion, or restriction of processing.
You have the right to request a copy of the personal data that we hold about you.
To make this request please send it by e-mail to the address mentioned in Section 15. In order to exercise this right, please note that we may ask you for additional information in order to identify you, so as not to mislead essential information by mistake to third parties.
b) The right to rectify personal data
You have the right to rectify the data held about you if they are incorrect. If the data we hold about you needs to be updated or if you think it may be incorrect, you can contact us.
c) The right to restrict processing
In cases where the accuracy of the personal data is contested, the processing is unlawful, or where you have objected to the processing of your personal data, you may ask for the restriction of the processing of such personal data. This means that personal data will, with the exception of storage, only be processed with or for the establishment, exercise, or defense of legal claims, for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of an EU Member State. In case a processing is restricted, you will be informed before the restriction of processing is lifted.
d) The right to data portability
Where the processing of your data is based on consent or the execution of a contract with you and the processing is carried out by automated means, you also have the right to data portability for information you provided to us – this means that you can obtain a copy of your data in a commonly used electronic format so that you can manage and transmit it to another controller.
f) The right to revoke your permissions for marketing messages (commercial communications)
There are two ways to opt-out of receiving marketing messages (to oppose the processing of personal data for marketing purposes, including profiling):
• Contact us;
• Click the link at the end of an e-mail or marketing text to unsubscribe.
For any other processing carried out under your consent, you may withdraw your permission at any time by contacting us at any of our contact details listed in Section 15.
g) The right to object to the use of personal data
You may object to processing of your personal data which is based on the legitimate interests pursued by us or by a third party. In such a case we will no longer process your personal data unless we have compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
You also have the right to object at any time to the processing of your personal data for marketing purposes, which includes profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, your personal data will no longer be processed for such purposes. Your right to object is not bound to any formalities.
e) The right to make a complaint to a supervisory authority
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at the email address [email protected] and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to file a complaint with the competent data protection authority (the national supervisory authority from your country of residence) or another competent European data protection authority, in the event you have concerns on the processing of your personal data.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is manifestly unfounded or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
The statutory period under GDPR for us to reply to a legitimate request is one month. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.
11. Security of your personal data
The security of your personal data is important to us, so we have implemented proper technical and organizational procedures in order to prevent the data from being lost, altered, misused, accessed, or disclosed by unauthorized entities, destroyed, removed, or any other type of unofficial activities.
Please keep in mind that no method of transmission over the Internet, or method of electronic storage is 100% secure.
12. Children’s Privacy
Our Website and our Content does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us.
13. Links to Other Websites
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
15. Our Contact Information
If you have inquiries regarding the privacy aspects of our Website, regardless of whether you are a resident of the European Union or the EEA, please feel free to reach us at the following addresses:
SEVIO SOLUTIONS S.R.L
Headquarter Address: Calea Chișinăului 104Bis-106, Iași Municipality, Iași County, Romania;
E-mail: [email protected].