WHO ARE WE?
ESOLUTIONS GRUP SRL and our existing or future affiliates (collectively “eSolutions” or “we”) are the controllers or processors with respect to your data. This means that we determine the purpose and manner in which your personal data is processed, as specified in this Policy.
ESOLUTIONS GRUP SRL is a legal entity organized and existing under the laws of Romania, with registered office at 28C General Constantin Budisteanu Street, 4th floor, 1st district, Bucharest, Romania and is the contact entity for any questions regarding how your personal data is being processed.
WHAT IS THE SCOPE OF THIS POLICY?
- Website visitors or users of our websites;
- Current and potential customers of eSolutions Services and Produsts;
- Service providers, contractors and business partners;
- Job applicants;
- Participants to eSolutions or our partners events;
- Visitors of our premises;
- Other third-parties that we interact with.
WHAT DO WE UNDERSTAND BY PERSONAL DATA?
Personal data is the information related to a person and which can be used to identify that person such as name, email address, telephone number, social media usernames, location data or business titles.
Personal data is data about you which you provide to us when interacting with eSolutions through our website and by using our Products and Services and which help us know who you are.
WHAT PERSONAL DATA IS PROCESSED?
The personal data we process, as well as the purposes and legal basis for such processing, will differ depending on your relationship with eSolutions.
We may process:
- Contact details, usually that data that you can find on a business card, such as your name, job title, email, telephone, postal addresses;
- Your correspondence with us, such as emails, tickets, physical correspondence;
- Your account data, such as transactional information about the services you use, how you interact with us and the services, dates of payment owed or received, subscriptions you use, logs, service use history, account numbers or other information related to or included in your contract;
- Credential data, such as passwords, hints and similar security information used for authentication and access to accounts and services provided by eSolutions;
- Traffic data, such as IP address, User-Agent header value, IP packet headers;
- Cookies and other similar technologies, such as data from your web browser – browser type and language, IP address, the operating system and version, your general geographic location, and your activity on eSolutions websites (the web pages viewed, the links accessed, number of visits, domain name, language information, mails opened, links clicked inside the e-mail etc.);
- Images, such as photographs, video, voice recordings when you participate to our events; CCTV recordings when you visit our premises;
- Data we obtain from other sources, such as Trade Registry, public authorities and other data providers. This includes public data, demographic data, interest-based data and internet browsing behavior;
- Recruiting data, such as details of your qualifications, skills, experience and employment history, information about your current level of remuneration, including benefit entitlements;
We do not process any sensitive information such as any information regarding your medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs or other such private information which is considered sensitive information and we will not intentionally collect or maintain or provide such information to third parties.
HOW DO WE PROCESS PERSONAL DATA?
We collect information about you when you provide it to us, when you use our Services or Products, and, in some cases, from third parties, as further described below:
Information you provide to us
We collect information about you when you input it into the Services or otherwise provide it directly to us, for example when you submit an order, conclude an agreement, apply for a job, use our services, communicate with eSolutions via phone calls, support platform, email, web forms, chat, social media and other such methods of communication, subscribe to eSolutions marketing newsletter or blog posts, attend our events or provide us services, access eSolutions websites.
Information we collect automatically
We collect information about you when you use our Services or Products, including browsing our websites and taking certain actions within the Services. We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use; the links you click on, as well as device and connection data: information about your computer, phone, tablet, or other devices you use to access the Services, including your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.
Information we receive from other sources
We receive information about you from other sources, for instance, for instance, from third parties such as partners and / or customers, providing us with certain information in order for us to be able to contact you, or if one of our third-party partners we work closely with (such as business partners, service providers, sub-contractors, resellers, etc.) shares your personal data with eSolutions in order for us to be able to contact you. In this case we receive minimum information about you (the information that you usually find on a business card) and we will remove it at any time upon your request. We also collect information from certain organisations, where appropriate and to the extent we have legal grounds to do so.
We may receive information about you from third party providers of business information and publicly available sources, like social media platforms, public databases, and from our business and channel partners. We may combine this information with information we collect through other means described above. This data may include physical mail addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses and social media profiles for the purposes of targeted advertising of products that may interest you, delivering personalized communications, event promotion, and profiling. This helps us to update and improve our records, identify new customers, create more personalized advertising and suggest services that may be of interest to you.
We may engage the services of third-party partners which, in the process of supplying services to eSolutions, may collect personal data about you, data that may include your name, email address and online activity. For example, when organizing events, we use the services of different contractors which are data processors on our behalf, or which are data controllers themselves. Please check their privacy policies when registering to our events. When eSolutions is a sponsor or partner at events organized by third parties, we may receive your personal data, such as name, email, company name, if you agreed to receiving communications and having your data shared with eSolutions. We encourage you to familiarize yourself with those third-party privacy policies to understand how they will handle your personal data.
HOW DO WE USE PERSONAL DATA?
How we use the information we collect depends in part on which Services and Products you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you:
To communicate with you
We use your contact information for reasons such as to get in touch with you, communicate with you about your orders or the services you use, subscriptions reminders, providing customer support, responding to your inquiries or comments, sending security updates, technical notices, administrative messages, sending announcements about our services/newsletters, informing you about upcoming events organized or sponsored by eSolutions, promotional activities, communication with you in the recruiting processes. Most of these communications are part of the Services and in most cases you cannot opt out of them. If an opt out is available, you will find that option within the communication itself or in your account settings.
If you correspond with us by chat, email, support tickets, postal service, or other form of direct communication, we may retain such correspondence and the information contained in it and use it to respond to your inquiry.
To market, promote and drive engagement with our Services and Products
We use your contact information to recommend products and services that might be of interest to you, to send you marketing and advertising messages such as newsletters, marketing communications, announcements or special offers, to personalize your experience or to inform you of upcoming events. You may always opt-out from receiving such communications, and this decision will not affect your ability to continue receiving services from us or visiting our websites.
In order to send you information about our products, events, news and activities, tailored to your interests we build individual profiles from the personal data you provided to us (such as name, company, job title, social media), from navigational information, information regarding the use of our services and information provided by our partners about you. Based on our legitimate interest to promote our products and services, we may also use third party platforms such as LinkedIn, in accordance with their own terms and conditions of use. We do this in order to maximize your experience with our Services and Products and to make available to you personalized offers of your liking. You can oppose this anytime by writing at firstname.lastname@example.org.
For statistical purposes and aggregated data insights
We use personal data for statistical purposes and to produce aggregated data insights. For example, we may use data to generate statistics about the number of users, event participants, the number of clicks on a website, or the demographic distribution of visitors to one of our websites.
eSolutions websites use Google Analytics to track how often people gain access to or read our content or access our website. We use this information as aggregated data to understand what content, information or services our users find useful or interesting, so we can produce the most valuable content to meet your needs. We do not track individuals but look at information in the aggregated form only. We may use these aggregated statistics for marketing purposes, in order to help us improve the way we promote our products.
Providing and improving our services and customer support
When you become our client, we collect personal data about you including contact details, communications, correspondence, feedback, your account information, credential information, traffic data, payment information for processing orders (including payments history).
We use the personal data (which can include your correspondence, traffic data, logs) needed to investigate, respond to and resolve complaints and service issues or downtime.
We process your personal data for creating and maintaining your account, controlling the access to it, contract administration, providing services, processing orders and payments and enabling other benefits or opportunities associated with our services, including certain features of our solutions.
Managing job applications
As part of any recruitment process, eSolutions collects and processes personal data relating to job applicants. We need to process data to take steps at your request prior to establishing a contract with you. In some cases, we need to process data to ensure that we are complying with the legal obligations. eSolutions has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.
Protecting ourselves and our clients
We use the personal data, such as information about you including contact details, your correspondence with us, your account information, credential information, traffic data, payment information to prevent and to detect fraud or abuses of eSolutions websites and services, to prevent and detect any attack and to be able to identify, to assure your account and your data security and to protect our business from fraudulent transactions.
When you visit our premises, we may also collect information about you on CCTV as part of our security prevention measures.
Managing the business needs
eSolutions may use this personal data to refine our services and to understand your needs and interests, to better tailor our services to meet your needs and to communicate with you about other services offered by eSolutions.
We use personal data, including your feedback, to conduct research and development for the further development with regards to our services in order to provide a better experience to our clients and to grow our business.
Collecting data in this manner allows us to collect statistics about the usage and effectiveness of our websites, personalize your experience and tailor our interactions with you.
Your personal data may be processed as a participant to our events, conferences, training sessions, workshops, webinars, demonstrations, and other physical or online events.
eSolutions may host or participate in many events throughout the year. In order to register to these activities, and to contact you to provide useful information in relation thereto (venue, speakers, agenda etc.) we process the personal data you provide via the form available on our websites or registration page (if different than our websites) such as your name, surname, email address, telephone number, location, social media account, job title, company, voice, image, based on your acceptance to participate and your agreement with our event terms and conditions; we will store this information in our database(s) and use them in order to provide you with information and services associated with the event.
In order to provide you with follow-up information after an event you have attended or to ask for your feedback, we process your email, based on your agreement to participate in our events; we may also contact you in relation to similar events, webinars and workshops that we organize (you may at any time chose not to receive this type of information).
When eSolutions is a sponsor or partner at events organized by third parties, we may receive your personal data, such as name, email, company name, if you agreed to receiving communications and having your data shared with eSolutions.
We encourage you to familiarize yourself with those third-party privacy policies to understand how they will handle your personal data.
As a participant in our Events, you will be issued a name badge that you might be asked to show at the entry in the various areas of our Events. We do this in our legitimate interest to manage the access to our Events.
These badges usually contain a barcode or QR code that provides personal data that you made available during the registration process (name, title, company, email, etc.). Events partners or sponsors may directly request information about you at their conference booths or presentations or may scan your badge (if you allow them to do so). Allowing them to scan your badge is entirely optional and they may use your personal data to contact you after the Event or for other purposes that you agree with them. The use of your personal data in this case will be subject to the privacy policies of those companies and we take no responsibility for such use. We recommend that you review these privacy policies before providing your data or accepting to have your badge scanned.
Badge scanning is entirely optional, and you can at any time refuse to have your badge scanned. In all cases, if you allow other Event participants (including eSolutions delegates), sponsors or partners to scan your badge, these participants may contact you about their products and services. eSolutions also provides an attendee list to sponsors, co-sponsors and exhibitors of our events. eSolutions may also allow sponsors, co-sponsors and/or exhibitors to send you material by mail once per sponsored event, in which case eSolutions engages a third-party mailing house and does not share your mailing address directly with the sponsor/exhibitor. If you do not wish to have your information included in an attendee list or to receive information from sponsors, co-sponsors and/or exhibitors, you can express your preferences when you register for events or you may contact us directly at email@example.com.
Photos and videos at our events - We may be taking pictures and video recordings in our Events (including Events organized by third parties where we have booths or presentations). Given that these Events are public areas and that we do not intend to focus on you as an individual (unless you are a special guest, such as a speaker), we do this based on our legitimate interest to document our Events and market their success.
If you have any concerns regarding the photos/recordings of you from an Event or if you want us to stop using photos/recordings of you in new material, please contact us at firstname.lastname@example.org. We will then no longer use your personal data in new information material. We will also remove you from already published material wherever possible. You can always object to being photographed or recorded during the Event by reaching out to our photographers or organizing staff.
Testimonials - We may process your personal information to post testimonials on our websites or social networks but will first obtain your consent to use your name and testimonial.
Speakers - We will process your image and voice (photos, videos), name, title, company, information about your professional life and education, as well as your presentation slides (if the case) if you attend one of our Events as a speaker. We may make this data public through our website, social media or other channels. We will ask for your consent to do so, however since our intention is to market our Events, we may refuse to appoint you as a speaker if you do not agree to such use. We may also collect information provided by event attendees who evaluated your performance as a speaker. We may also make and store photos, video and audio recordings.
We do not deliver third party online advertisements on our websites, but we advertise our services on other websites. Please familiarize yourself with those website operators’ or network advertisers’ privacy statements to understand their practices relating to advertising.
What happens if you don’t give us your data
You can use eSolutions websites without providing your personal data. The information on our websites is available even if you are not providing us with any personal data. However, if you want to order eSolutions services or products, certain personal data is necessary so that we will be able to provide the services you have purchased or requested, as well as to authenticate you so that we know it is you and not someone else.
If you refuse to have your personal data processed, depending on your relationship with us, we might not be able to provide you with our products or services, send you newsletters, information about our events or other offerings, we won’t be able to enter into a contract with you, or otherwise interact with you as described in this policy.
You may manage your account and you may opt-out of receiving marketing communication at any time.
WHAT IS THE LAWFUL BASIS FOR DATA PROCESSING?
We will process your personal data based on the following legal grounds:
- To enter into the agreement and the performance of your agreement and to take action in accordance with on your requests.
- eSolutions legitimate business interests, e.g. fraud prevention, maintaining the security of our network and services and improvement of our services. Whenever we rely on this lawful basis to process your data, we assess our business interests to make sure they do not override your rights. Additionally, in some cases you have the right to object to this processing. For more information please see below section regarding data subject rights.
- Compliance with a mandatory legal obligation, including for example accounting and tax requirements, which are subject to strict internal policies (such as retention periods), procedures and your rights under GDPR.
- Consent you provide where eSolutions does not rely on another legal basis. Consent may be easily withdrawn at any time. When you give your consent, you will also receive information on how to change your mind. For more information please see below section regarding data subject rights.
TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?
The personal data we gather is for internal use only, and we will not authorize the release of this data to anyone outside eSolutions, without your consent for such disclosure, except for the limited circumstances described in this Privacy Notice, in your applicable agreement or permitted by law. Shall we ever need to provide the personal data to third parties, we will only share it to the reasonably necessary extent.
We may disclose your personal data as described below:
To eSolutions group companies or affiliates
All of the personal data we collect about you may be transferred or accessed by our companies. We will protect the privacy and the security of the personal data that we collect in accordance with the terms of this Privacy Notices and the applicable law.
To third-party business partners and providers
To the necessary extent of providing the services, we may disclose your personal data to third party service providers, if needed/required. Also, please note that our third-party service providers and channel partners may be located in a different country than yours, so your personal data might be transferred across borders. We assure you that we require our third-party service providers and business partners to keep all the data we share with them confidential and to use it only to perform their obligations resulting from the agreements we have in place with them. They are required to maintain a proper level of privacy and security. Please note that any information you independently share with these third parties is subject to their respective privacy practices and policies. In the event of a reorganization, merger, sale, joint venture, transfer as a going concern or any such act, we may provide the personal data to a third party.
Example of type of third-party business partners and providers:
- Third parties for joint promotions. They’ll be responsible for their own compliance with applicable privacy laws;
- Other third parties, when you are signing up to their service and your personal data is used by them for authentication and fraud-prevention purposes;
- Third parties that we advertise with such as Facebook in order to serve you advertisements online;
- Third parties that we use to serve you sales and/or marketing emails, for example, MailChimp;
- Companies who are engaged to perform services for, or on behalf of eSolutions;
- Debt collection agencies or other debt-recovery organisations.
To public authorities, auditors or other bodies
If we are under a legal obligation to share your personal data, we may disclose the information to the relevant authority. We may release the personal data in order to comply with the law, to protect our rights, property, the safety of our business, to enforce our rights and to assist with the control of fraud, spam or other undesirable conduct, and to support auditing.
Example of authorities or other bodies:
- Law enforcement agencies, government bodies, regulatory organisations, courts or other public authorities if we have to, or are authorised to by law;
- A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.
- Such public authorities or institutions may be relevant data protection authorities or authorities for consumer protection;
To third parties’ acquirers
If eSolutions’ business would be subject to a change of control or other similar procedure or acquisition and your personal data would be part of the transaction we may disclose this information to the respective parties.
Disclosure when you have given your consent
We may disclose your personal data if we have your consent to do so.
Disclosure of anonymous or aggregated data
We may share information that does not identify any individual without restriction.
DO WE TRANSFER YOUR PERSONAL DATA ABROAD?
Personal data collected by us may be stored and processed in Romania, or in any other country where our affiliates, subsidiaries or service providers maintain facilities. We make sure that your data is kept and transferred safely, by respecting European legal requirements for data transfers.
In the context of completing the purposes presented to you in this policy, your personal data may be transferred abroad to states in the European Union (“EU”), European Economic Area (the “EEA”) or to third countries.
Any transfer performed by eSolutions will respect the legal requirements laid down by the European data protection legislation. In what concerns data transfers to third countries, we make sure that appropriate safeguards are in place in order to keep your data secure.
FOR HOW LONG DO WE STORE YOUR PERSONAL DATA?
eSolutions will store your data only for the period of time necessary or required by law. We will retain and use your personal data in order to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements.
We will store your personal data only for the period of time necessary in order to achieve the purposes described to you in this policy and in accordance with our legal obligations, our contractual obligations or the industry practices.
We will make sure not to keep excessive or irrelevant data, such as data which is out of date. We will also constantly review the periods of time for which the different categories of data we process are retained.
After the duration of the processing expires and eSolutions no longer has legal or legitimate reasons to process your personal data, the data will be deleted in accordance with its procedures, which may involve archiving, anonymizing or destroying it.
If you are our client, we will keep all collected data needed to perform our agreements or to provide you the contracted services, meaning during the contractual period and for a period of 3 years after the termination of the agreement, except otherwise stated by the law.
For using eSolutions products and services we store your data up to 3 years from the termination of our agreement with you, except for the cases when legal requirements state otherwise.
We will retain your contact details and account data for as long as your account is active.
We will retain your personal data, collected automatically via cookies or other similar technologies for as long as we deem it necessary to enable you to use the website, but no more than 26 months.
We will retain job applicants’ personal data for a maximum period of 2 years.
HOW DO WE KEEP YOUR DATA SECURE?
When it comes to prevention of data loss, alteration, misuse, unauthorized access or unlawful processing of the collected personal data, we are committed to industry best practices. Therefore, we:
- Use encryption technology as appropriate;
- Require to our suppliers to protect personal data from unauthorized access, use, and disclosure;
- Limit the access to the systems on which the personal data is stored;
- Monitor for possible attacks and vulnerabilities.
However, we cannot guarantee that the measures taken will prevent every security threat. In the event of a security breach which results in an unauthorized disclosure of information, we will notify you as soon as possible.
We have teams who constantly review and improve our measures to protect your personal data from unauthorised access, accidental loss, disclosure or destruction.
You can only access services management interface through the use of a dedicated user name and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please notify us immediately if you believe your password has been misused. You should always log out and close your browser when you finish your session. Please note, we’ll never ask for your secure personal data or account information by unsolicited means of communication. You’re responsible for keeping your personal data and account information secure and not sharing it with others.
Our websites may provide links to third-party websites. We cannot be responsible for the security and content of such third-party websites. So, make sure you read that company’s privacy and cookies policies before using or putting your personal information on their website.
You may choose to disclose your personal data in certain ways such as social plug-ins (including those offered by Google, Facebook, Twitter) and to use third-party services that allow you to post reviews or other information publicly, and a third party could use that information.
WHAT ARE YOUR RIGHTS?
When we process your personal data, it is very important to know that you have the following rights:
The right to access the personal data we process about you: you have the right to obtain a confirmation whether or not we process your personal data, and, if so, to have access to the type of personal data and to the conditions of processing, by sending us a request in this regard.
The right to correct personal data: you have the right to obtain the rectification of inaccurate personal data concerning you. If your data needs to be updated you also have the possibility to correct, delete inaccuracies and/or update the data.
Right to erase the personal data we process about you: we strive to only process and retain your data for as long as we need to. In certain circumstances stipulated by GDPR you have the right to request us to erase your personal data that we hold. As always, if you wish eSolutions to erase your personal data from our records, please contact us at email@example.com and we will respond within a reasonable time. If necessary, given each particular case, we may be required to retain certain information for performing the agreement, legitimate business purposes and by law.
The right to request the restriction of processing: you have the right to ask for the restriction of processing in cases where: (i) you consider that the personal data processed is inaccurate, for a period enabling us to verify the accuracy of the personal data; (ii) the processing is unlawful, however you don’t want us to erase your personal data, but to restrict the use of data; (iii) in case we no longer need your personal data for the purposes we described in this policy, but you are requiring the data for establishing, exercising or defending a legal claim or (iv) you have objected to processing pending the verification whether our legitimate grounds prevail.
The right to withdraw your consent for processing, when the processing is based on your consent, without affecting the lawfulness of processing undertaken until that moment.
The right to object to the data processing on grounds related to your particular situation, when the processing is based on legitimate interest and to object at any moment to the data processing for direct marketing purposes, including profiling.
The right to data portability, meaning the right to receive your personal data, which you provided us in a structured, commonly used and machine-readable format and the right to transfer those data to another controller, where: the processing is based on consent or on a contract and the processing is carried out by automated means, in accordance with GDPR.
The right to opt out of marketing messages, meaning if you no longer want to receive marketing messages from eSolutions, you can elect to opt out of all marketing communications. There are various ways to opt out:
- Contact our marketing team - email us at firstname.lastname@example.org
- Click the link at the end of a marketing email to unsubscribe;
- Tell the sales representative if you receive a call;
- Email us at email@example.com;
Opting out does not mean that you won’t receive messages related to the services provided any longer, if you have an agreement with us. You will still receive such messages, unless we have indicated otherwise.
We reserve the right to retain your personal data for a reasonable amount of time, in accordance with industry standards and applicable laws.
The right to file a complaint with the Data Protection Authority (ANSPDCP) and the right to address to the competent courts of law.
You may exercise your rights at any time.
For any questions regarding your rights please write to us at firstname.lastname@example.org.
OTHER IMPORTANT PRIVACY INFORMATION
We take reasonable steps to help ensure that the data we collect is accurate, complete and up-to-date, for it to be reliable for its intended use.
Information about children
We will never intentionally collect or maintain information about individuals defined as minors in local law or regulation. However, if you believe that we are in possession of such information, please contact us at email@example.com, and we will make necessary inquiries and investigations and, if applicable, delete that information.
eSolutions is liable for third parties processing personal data on its behalf. However, eSolutions reserves the right to prove that the non-compliance was not a result of eSolutions’ actions or was not in eSolutions’ control.
How to submit a complaint or an inquiry
Please be assured that we will promptly investigate the matter and that we are committed to resolving any privacy concerns that you may have.
If you are not satisfied with our response or believe we are not processing your personal data not in accordance with the law, you can complain to the National Data Protection Authorities - Romanian Data Protection Authority: Autoritatea Naţională de Supraveghere a Prelucrării Datelor cu Caracter Personal, www.dataprotection.ro.