Global Mediator Concept Ltd., with the registered office in Romania, Bucharest, no.6-8, Calea Griviţei, 4th floor, district 1, hereinafter called GMC LTD, as controller of personal data, hereby presents the Policy regarding the processing of personal data carried out by GMC LTD , during its business activity, as well as your rights as Data Subject, as provided starting with 25th of May 2018 (enforcement date of GDPR).
DATA PROTECTION POLICY
PERSONAL DATA CATEGORIES
Depending on your role (as Data Subject) into the relationship developed with GMC LTD (e.g.: Natural person who is a beneficiary of our services/products, natural person representing or delegated by a legal person who is a beneficiary of our services, supplier, reporting or control authority, site visitor, potential employee, employee or former employee) and the object of such relationship, GMC LTD processes the following categories of personal data:
- identification data : name, surname, address, telephone, email, nationality, handwritten signature and digital signature, position held, necessary for the valid conclusion of the management contract or any other type of contract and the performance of the contractual relations related to the contract in question.
- contact information such as: home address, mailing address, e-mail, telephone.
- bank data: account number, issuing unit for payment of fees, fees
- personal data concerning: economic situation, civil status, family, dependents, education and professional experience, property held, location information, national identification number, religion only when the law requires this information to be provided for the provision of certain services of interest to you.
At the beginning of your relationship with GMC LTD, you will receive a specific information note, depending on your role and your capacity in relation with GMC.
HOW WE COLLECT YOUR PERSONAL DATA
Your personal data processed by GMC LTD is provided by you directly or indirectly, or generated/inferred by us, as a result of your interaction with GMC LTD through any communication channels.
We can also collect and process your personal data from other sources, such as:
- You have provided your personal data for the conclusion of a management contract.
- You have provided your personal data for entering into partnerships/other types of agreements with GMC SRL
- You have provided your personal data to a publicly accessible online platform
- You have been involved in previous communications with us or with our expert
- You have published your personal data in a social media advertising display
- You have provided your personal data in an event/meeting, etc.
- You have applied for a vacant position within GMC SRL /you are employed by GMC SRL /you were Employee of GMC SRL
WHY ARE WE PROCESSING YOUR PERSONAL DATA
The purposes for which we process your personal data are:
- The provision of management services, or of any other services specified in any agreement, including assistance related thereto.
- Processing of Data Subjects’ requests and claims
- Settlement of potential disputes before courts (ordinary or arbitral, national or abroad)
- Communications or reporting to the competent authorities, institutions or agencies of the state or government
- Recovery of claims, claims for reclaims.
- Improvement of GMC LTD services
- Communication of articles and information
- Improvement of the site’s content
- For recruitment, during employment relationship and postemployment relationships with former employees.
- Identification, analysis and remediation of technical deficiencies
- Compliance with the applicable regulation
- Fraud prevention and avoidance of involvement in fraudulent activities
THE LEGAL GROUNDINGS FOR PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSES MENTIONED ABOVE ARE:
- the conclusion and performance of the management contract and any other type of contract, and the carrying out of the pre-conclusion procedures upon your request;
- a legal obligation of GMC LTD;
- the legitimate interest of the GMC LTD in activities such as: conducting statistical analyses and internal reporting, fraud prevention, etc.;
- your consent.
TO WHOM DO WE DISCLOSE PERSONAL DATA
We may disclose your personal data to:
- State authorities (including tax authorities, mediation authorities, State bodies competent in civil and criminal matters) as a result of a legal obligation of GMC LTD.
- Subcontractors/Partners directly involved in the provision of our services (E.g.: lawyers, fiscal experts, evaluators etc.)
- Judicial or arbitral tribunals, public notaries, lawyers, bailiffs, translation offices, other authorized services, evaluators, experts.
- Providers of support and/or ancillary services for electronic communications (e.g. e-mail, SMS, etc.); IT services (e.g. maintenance, support, development); audit services; archiving services in physical and/or electronic format; courier services; legal, notary or other advisory services; Staff training, health and security services (SSM and PSI), specific to employment relationships.
FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA
GMC LTD shall process your personal data for the purposes mentioned above, during the relationship with you (Data Subject), and additionally for the period required by the applicable regulations, documented provisions of the Archive Nomenclature and the operational procedures applicable to each individual processing.
After completion of the data processing operations, for the purposes for which they were collected, the data will be archived by the GMC LTD for the term stipulated in the internal regulatory documents and, upon completion of the storage term, destroyed as specified in the applicable procedure.
YOUR RIGHTS REGARDING YOUR PERSONAL DATA
With regard to the personal data processing, based on the conditions specified, you may exercise any of the following rights:
(1) The right to information and access to the personal data
Allows you to be informed with regard to the processing of the personal data, to obtain from us a confirmation as to whether or not GMC LTD is processing personal data concerning you and what data are being processed. If the personal data concerning you are not collected from you, we shall provide you with any available information regarding their source, unless we are legally forbidden from disclosing such source.
(2) The right to rectification
You shall have the right to request the rectification or updating of inaccurate or incomplete personal data concerning you or the right to have such data completed, if they are incomplete.
(3) The right to erasure or “the right to be forgotten”
You shall have the right to request that the personal data concerning you be erased, under certain circumstances, such as (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, (ii) your data have been unlawfully processed, (iii) the data was processed based on your consent and such consent has been withdrawn.
(4) The right to withdraw your consent
Your consent can be withdrawn at any time, when the processing of the personal data concerning you was carried out based on your consent.
(5) The right to restriction of processing
You have the right to request and obtain the restriction of the processing of the personal data concerning you, under certain circumstances, such as (i) you contest the accuracy of the personal data, for a period enabling us to verify the accuracy of such data, (ii) the processing of your data was unlawful, and you oppose the erasure of such data and request the restriction of their use instead.
(6) The right to data portability
You have the right to receive the personal data concerning you and that you provided to us, with the right to transmit such data to another controller, if (i) the data processing was carried out either based on your consent or based on the contract concluded with us and the personal data processing was carried out by automated means. This right can only be exercised if the provided data were exclusively processed through automated means and only where the extraction of such data is feasible from the point of view of the technical capacities used by the GMC LTD.
(7) The right to object
You have the right to object at any moment, on grounds related to your particular situation, to the personal data processing in certain circumstances, such as (i) the processing was carried out in our legitimate interest or (ii) the purpose of the processing is direct marketing, including profiling based on the respective provisions.
(8) 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
You have the right to request human intervention on the part of the GMC LTD, to express your point of view and to contest the decision.
(9) The right file a complaint with us and/or with the competent data protection authority
(10) The right to refer the matter to the courts of law
(11) The right to be notified by GMC LTD with regard to data breaches that have/may have an impact on your personal data.
PERSONAL DATA PROCESSING PRINCIPLES
GMC LTD shall respect the principles of processing personal data in its operational activities, as follow:
- Lawfulness, transparency and fairness of the processing – the personal data of Data Subject will be processed lawfully, equitable and in a transparent manner;
- Proportionality of processing, scope’s limitation – the personal data will be collected for specific, explicit and legitimate purposes and not further processed in a way incompatible with those purposes. The data will be kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the data are processed; Personal data may be stored for longer periods in so far as they will be processed exclusively for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes, subject to the implementation of appropriate technical and organizational measures.
- The Accuracy (quality) of personal data – personal data shall be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- Responsibility of processing- ensuring that the processing of personal data is carried out in a manner that ensures the proper security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, by taking appropriate technical or organizational measures;
- Data minimisation – the personal data will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
GMC LTD shall ensure that processing of personal data will be carried out in compliance with the above principles.
- Integrity and confidentiality – protecting personal data against unauthorized and unlawful processing and against accidental loss, destruction and deterioration by taking appropriate technical and organizational measures.
Any information/request/complaint concerning the protection of personal data is sent by e-mail to the address: email@example.com or in written form to the address GLOBAL MEDIATOR CONCEPT SRL, district 1,no 6-8 Calea Grivitei, 4th floor, Bucharest, Romania, postal code 010107.
In order to exercise your data protection rights, you can address your request to GMC LTD , at e-mail to firstname.lastname@example.org .
In order to submit a notification/complaint to the National Supervisory Authority for Personal Data Processing, the contact data are: Website: http://www.dataprotection.ro/ Email: email@example.com Address: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, cod poștal 010336, Bucharest, Romania phone number: +40.318.059.211, +40.318.059.212; Fax +40.318.059.60
This information regarding personal data processing is subject to periodical review. In order to be informed of possible important modifications that may impact the processing of your personal data, we ask that you access the ”Personal Data Protection Policy” section of the GMC LTD’s website, www.globalmediator.eu from time to time. The most recent update to this information regarding the personal data processing was carried out 03.05.2020.