Updated August 10th, 2021
WHO WE ARE:
Ringhel Team SRL, registered and functioning under the laws of Romania, with headquarters in Bucharest, District 3, 8 Muresana Street, block 58A, 1st Entrance, 1st floor, app. 15, registered with Bucharest Trade Registry under no. J40/2629/2011, having fiscal code RO28139450, as Operator, processes your personal data when you use:
(hereinafter referred to as the “Platform” or “PROCESIO” and/or “website”)
Contact data: firstname.lastname@example.org.
Using the Platform and carrying on our contractual relationship mandatory requires the Subscriber to priory obtain the express and unequivocal consent of the Users, representative, Sub-customers and/or other individuals related to the use of their personal data if their personal data is likely that it shall be up-loaded on the Platform (hereinafter called “Data Subject”); thus, by accessing and using the Platform the Subscriber declares and guarantees that it holds the due consent of every and each individual whose data are up-loaded and/or used by the Platform and the Subscriber obliges itself to defend, indemnify and hold harmless PROCESIO from and against any loss, cost, fines, liability or damage, including attorneys’ fees, for which PROCESIO becomes liable in connection with the personal data of Data Subjects.
Read this policy carefully to understand our data practices and how we treat them. If you do not agree to any of these practices, do not access the services provided by this Platform.
Information we collect
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information; nevertheless, we generally collect the following type of data:
- If you contact us directly, we may receive additional information about you such as your name, email address, position in the company, IP, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.
- When you register for an Account, we may ask for your contact information, including items such as name, company name, address, position in the company, IP, email address, and telephone number.
You are not required to provide us with your personal data. However, if you choose not to provide us your personal data, certain functionalities of the PROCESIO will no longer be accessible to you and / or, as the case may be, we will no longer be able to facilitate and provide the PROCESIO services and you will not be able to interact with these services.
How we use your information/for what purposes
In order to allow you to use the Platform and to improve your Platform experience and to allow you to interact with PROCESIO services, we use the information we collect in various ways, including:
- Provide, operate, and maintain our website
- Improve, personalize, and expand our website
- Understand and analyze how you use our website
- Develop new products, services, features, and functionality
- Communicate with you, either directly or through one of our partners or third parties, including for customer service, to provide you with updates and other information relating to the website.
- Send you emails
- Find and prevent fraud
- Log Files: PROCESIO follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files include browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.
- We may process your personal data for direct marketing purposes based on your explicit expressed consent which is obtained through a consent form that is provided to you when you interact with us. Each direct marketing message we send to you includes an unsubscribe option that you may use to let us know that you no longer wish to receive such notifications from us for marketing purposes.
Legal Basis for Processing
PROCESIO processes your personal information on the bases set out below:
- Keeping to our agreement with you and securing its execution and enforcement of the rights and obligation therein included – We need certain personal information to provide our services and cannot provide them without this information.
- Legal obligations – In some cases, we have a legal responsibility to collect and store your personal information.
- Legitimate interests – We sometimes/occasionally collect and use your personal information because we have a legitimate reason to have it and this is reasonable when balanced against your right to privacy.
Personal Data Transfers
Keeping and processing your personal information as described above may require the transfer of such and / or storage to a destination outside your country of residence to countries within the European Union (the “EU “) Or the European Economic Area (” EEA “), for example, service providers.
Your data may be transferred outside the EEA /EU. Transferring your data outside of the European Union could mainly be due to the location of our subcontractors. In order to provide you with safe services, we have decided to outsource certain operations to specialized service providers who have a relevant experience in their areas (for example: IT hosting). Some of these providers are established outside the EEA / EU, for example the United States.
Before transferring your data, we will take the necessary steps to ensure that your personal information will benefit from adequate protection, in accordance with the relevant privacy laws and internal policies of PROCESIO.If personal information is transferred to a PROCESIO sub-contractor in a country that does not provide an adequate level of protection for your personal information, PROCESIO will take the necessary measures to adequately protect your personal information, such as ensuring that such transfers are subject to the conditions of the EU standard clauses. Thus, the additional measures that we have implemented in accordance with the provisions of art. 45 align. 1 of GDPR, together with the standard contractual clauses, following the analysis of each case and the circumstances of the transfer, ensures that U.S. law does not affect the adequate guaranteed protection level. PROCESIO will also be responsible for ensuring that third parties acting as an agent/sub-contractor on its behalf do the same.
EU-U.S. Framework. Privacy Shield
Commission’s Implementing Decision (EU) 2016/1250 of 12 July 2016 pursuant to Directive 95/46 / EC of the European Parliament and of the Council on the adequate protection offered by the EU-US Privacy Shield was published in the Official Journal of the European Union in August 2016. According to this decision, the United States guarantees an adequate level of protection of personal data transferred from the European Union to organizations in the United States under the EU-US Privacy Shield, provided that those entities process personal data in accordance with a strong set of principles and guarantees for the protection of privacy and personal data that are equivalent to those in the European Union.
Considering that on 16 July 2020, the Court of Justice of the European Union ruled in relation to Schrems II case, invalidating the decision on the Privacy Shield, we identified the alternative to the standard contractual clauses in order to maintain possible, the transfer of personal data to processors of the operator, which are established in third countries. Thus, as of July 16, 2020, we no longer rely on the Privacy Shield for data transfers from the EEA or the United Kingdom to the United States.
If the transfer of personal data will also take place to countries outside the European Economic Area and none of the following situations apply to you: you have explicitly agreed to the transfer of data, the transfer is necessary for the execution of a contract, the transfer is necessary for the conclusion of a contract or the execution of a contract concluded in your interest, it is important for reasons of public interest, necessary for the establishment, exercise or defense of a right in the court, necessary for the protection of a vital or other interests when you do not have the legal capacity to express your agreement, the transfer is made from a register intended to provide information to the public, the transfers will take place either on the basis of adequacy decisions issued by the Commission or if the state in which it will be transferred, offers adequate guarantees of protection.
We, therefore, inform you that your personal data may be stored and processed in countries outside the European Economic Area for one of the following reasons: the transfer is necessary for the execution of a contract between the Subscriber and PROCESIO, the transfer is necessary for the conclusion of a contract or performance of a contract concluded in your interest, it is important for reasons of public interest, necessary for the establishment, exercise or defense of a right in court, necessary to protect your vital interests or those of others when you do not have the required capacity to express your agreement, the transfer is made from a register that aims to provide information to the public.
When PROCESIO shall process the personal data or part of the personal data belonging to Data Subjects, through other persons, called sub-contractors and/or agents, the following principles shall apply:
By agreeing with this Policy, the Subscriber hereby expressly authorizes PROCESIO to process the personal data belonging to Data Subjects through the following sub-contractors for the following activities:
- Amazon Web Services (global), Digital Ocean (global) – for the main functionalities of the Platform,
- Cloudflare (global), Google Analytics (Global), Hotjar (Global) for backups and / or performance analysis;
- Getgist (Global) for marketing automations and support chatbot
Cookies and Web Beacons
Like any other website, PROCESIO uses ‘cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information.
By using our website, the following cookies shall be placed on your device:
- Strictly necessary cookies – which are indispensablemandatory for the functioning of this website. The erasure or disable of these cookies could lead to the impossibility of using this website. These cookies do not collect any personal data and do not storage information after leaving the website;
- Performance cookies – which are used solely with the aim of improving our website, representing the tool that helps us know how many visitors our website has. The information collected by these cookies are anonymous.
- Functional cookies – the disable of these cookies could cause ancause to an improper function or even impossibility of function of this website.
- Google analytics cookies – which permit us to know in an anonymous way about what are your favorite pages of our websites, how manyany visitors we have.
- Third party cookies – A third party cookie (third party) is placed by another Internet domain / website other than the one accessed by the user; Third party cookies are not strictly necessary for a user accessing a website because they are typically associated with a service distinct from the one explicitly requested by the user (by accessing the website).
The cookies settings may be changed as per your necessity by means of your browser settings. Please keep in mind that the disable of some types of cookies could lead to the impossibility of accessing some websites. For additional information about cookies, please see the help section of your browser`s settings.
Advertising Partners Privacy Policies
Note that PROCESIO has no access to or control over these cookies that are used by third-party advertisers, thus PROVIDER has no responsibility in this .regard.
Third-Party Privacy Policies
You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.
CCPA Privacy Rights (Do Not Sell My Personal Information)
Under the CCPA, among other rights, California consumers have the right to:
Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
Request that a business deletes any personal data about the consumer that a business has collected.
Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at email@example.com.
GDPR Data Protection Right
We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
- The right to be informed and of access – You have the right to inquire if we process your personal data and if the answer is positive, to request copies of your personal data.
- The right to rectification – You have the right to request that we correct any information you believe is inaccurate and you prove accordingly. You also have the right to request that we complete the information you believe is incomplete.
- The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
- The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
- The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
- The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
- If you make a request, we have one month to respond to you, if extended time is needed, we shall inform you in due time. If you would like to exercise any of these rights, please contact us at firstname.lastname@example.org.
The right to file a complaint with PROCESIO – the data subject may file a complaint if he / she is unhappy with the processing of his or her personal data or with the way of responding to its request.
Right to file a complaint with the Supervisory Authority – the data subject has the right to file a complaint with the National Supervisory Authority for Personal Data Processing if he is dissatisfied with the processing of his personal data.
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
PROCESIO does not knowingly collect any Personal Identifiable Information from children under the age of 18. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.