Privacy Policy

The confidentiality of your personal data is one of the main concerns of EXGHTS S.R.L.

This information is intended to inform you about the processing of personal data and your rights as a data subject, in accordance with General Data Protection Regulation (EU) 2016/679 (“GDPR”).

We consider ensuring the right to personal data protection as a fundamental commitment exghts, therefore we will dedicate all necessary resources and efforts to process your data in full compliance with Regulation (EU) 2016/679 (“General Data Protection Regulation” or “ GDPR ”), as well as with any other legislation applicable on the territory of Romania. As one of the key principles of this legal framework is transparency, we have prepared this document to inform you about how we collect, use, transfer and protect your personal data when you interact with us about products and services. including our website or mobile applications. 

We reserve the right to periodically update and modify this Privacy Policy to reflect any changes to the way we process your personal data or any changes to legal requirements. In the event of any such changes, we will display the modified version of the Privacy Policy on our website, for which reason please check the contents of this Privacy Policy periodically.

Who we are and how you can contact us?

Exghts – S.C. EXGHTS S.R.L., legal person of Romanian nationality, having its registered office in Brasov, Bulevardul 15 Noiembrie 44, Brasov county, with serial number in the Trade Register J08 / 2315/2018, unique fiscal registration code RO39980015. For the purposes of data protection legislation, we are the operator when we process your personal data.

As we are always open to hearing your views, as well as providing you with any additional information you may need regarding the processing of your data, we encourage you to contact the exghts Data Protection Officer at info @ exghts. com– with the mention: in the attention of the Data Protection Officer. 

What categories of personal data do we process?

We generally collect your personal data directly from you so that you have control over the type of information you provide to us. By way of example, we receive information from you as follows:

When you fill in a contact form or subscribe to the newsletter, send us: e-mail address, name and surname; 

In the contact form you can add additional information, such as: mobile phone number, landline number;

If you apply for one of the open positions in the company, in the Careers section, send us: e-mail address, name and surname, telephone number, date of birth, place of residence.

We also offer you the possibility to register your CV by authenticating your Facebook or Google account. If you opt for one of these options, you will be directed to a page managed by Facebook Inc / Google LLC, where they will inform you about the transfer of your data to exghts. You can view the privacy policies of Facebook and Google, respectively, using the following links:

https://www.facebook.com/about/privacy

https://policies.google.com/privacy

We may also collect and further process certain information about your behavior while visiting our exghts.com website, in order to personalize your online experience and provide you with information tailored to your profile. find out more in this regard by consulting the section on the purposes of processing below.

On our website we may store and collect information in cookies and similar technologies, in accordance with the Cookies Policy. We do not collect or otherwise process sensitive data, included by the General Regulation on data protection in special categories of data with personal character. We also do not want to collect or process data on minors under the age of 16.

What are the purposes and grounds of data processing? 

EXGHTS S.R.L. processes personal data through the following operations: collection, registration, organization, storage, modification, extraction, consultation, use, transmission, combination, blocking, restriction, deletion, destruction, archiving of personal data.

We will use your personal data for the following purposes: 

  1. To provide exghts services for your benefit.

This general purpose may include, as appropriate, the following:

a) Creating and managing the client account within the exghts CRM platform;

b) Processing of offers, including their validation and invoicing;

c) Solving cancellations or problems of any kind related to the purchased products or services;

The purposes of processing are:

 providing assistance regarding the conclusion of a contract to the products with EXGHTS S.R.L., through all available channels in this regard (e.g., physical locations, internet, telephone, etc.), before concluding the contract or in connection with its execution;

 iyour identification by means of communication (e.g., telephone, e-mail, post, internet), including by video and audio recording of your presence in physical locations (in order to maintain a high level of security). Video monitoring is marked accordingly by displaying warning messages in visible places;

 performing economic, financial and / or administrative management activities within EXGHTS S.R.L.;

 providing support services for your requests (e.g., resolving requests, complaints and petitions made by customers), both in physical locations and through the media (e.g., telephone, e-mail, post);

 analysis of preferences, interests, history of contractual relations and / or customer behavior for direct marketing activities (ie, communication by any means – mail, telephone, fax, e-mail, SMS / MMS of directly addressed advertisements and specific to a certain person), or for carrying out any other types of promotion of the products / services of  EXGHTS S.R.L., in case the data subject has chosen in this respect;

 carrying out general marketing or advertising activities, as well as loyalty activities of the data subject (eg promotional events, special offers);

✓ analyzing the behavior of the data subject / any person who accesses the page regarding the activity / products / services offered by EXGHTS S.R.L. from the site www.exghts.com, by using cookies, both of EXGHTS S.R.L. and of the contractual partners of EXGHTS S.R.L., in order to provide a content, both general and advertising, adapted to the user’s preferences, adapted offers to the interests of users, password retention, language preferences, child protection filters, limitation of the frequency of advertising;

 conducting internal analyzes (including statistical analyzes) both on services and on the customer portfolio, for the improvement and development of services, as well as conducting studies and market analyzes on the activity / products / services offered by EXGHTS S.R.L. to improve them;

 generating reports on the activity of EXGHTS S.R.L., in order to facilitate the management of all operational processes;

 archiving both in letter and electronic format of the documents that are concluded regarding the relationship with the data subject, the creation of a registration service regarding the documents / envelopes that are addressed by EXGHTS S.R.L. regarding the existing contractual relationship, carrying out courier activities regarding documents / envelopes containing your personal data;

 settlement of disputes, investigations or any other petitions / complaints to which EXGHTS S.R.L. is a party, including debt recovery.

The processing of your data for these purposes is in most cases necessary for the conclusion and performance of a contract between exghts and you. Also, certain processing subject to these purposes is required by applicable law, including tax and accounting law.

  1. To improve our services

We always want to offer you the best online browsing experience. For this, we may collect and use certain information related to your User behavior, we may invite you to complete satisfaction questionnaires, directly or with the help of partners, studies and market research. We base these activities on our legitimate interest to carry out commercial activities, always making sure that your fundamental rights and freedoms are not affected.

  1. For marketing

We want to keep you up to date on the latest information about the products / services you are interested in. In this regard, we can send you any type of message (such as: e-mail / SMS / telephone / mobile push / webpush / etc.) Containing general and thematic information, information on products similar or complementary to those that You have purchased them, information on limited offers (promotions), and other commercial communications such as market research and opinion polls. In order to provide you with information of interest to you, we may use certain data about your buyer behavior (eg products viewed / purchased) to create a profile for you. We always ensure that such processing is carried out in compliance with your rights and freedoms and that the decisions taken on the basis of them have no legal effect on you and do not affect you in a similar way to a significant extent.

In most cases, we base our marketing communications on your prior consent. You can change your mind and withdraw your consent at any time by:

– Accessing the unsubscribe link displayed in the messages you receive from us; or through

– Contacting exghts using the contact details described above.

In certain situations, we may base our marketing activities on our legitimate interest in promoting and developing our business. In any case where we use information about you for our legitimate interest, we take care and take all necessary measures to ensure that your fundamental rights and freedoms are not affected. However, you can ask us at any time, by the means described above, to stop the processing of your personal data for marketing purposes, and we will process your request.

  1. To defend our legitimate interests

There may be situations in which we use or transmit information to protect our rights and business. These may include:

– Measures to protect the exghts.com website from cyber attacks:

– Measures to prevent and detect fraudulent attempts, including the transmission of information to the competent public authorities;

– Measures to manage various other risks.

The general basis of these types of processing is our legitimate interest in defending our commercial activity, it being understood that we ensure that all the measures we take guarantee a balance between our interests and your fundamental rights and freedoms.

Also, in certain cases we base the processing on legal provisions such as the obligation to ensure the protection of goods and values ​​provided by the applicable legislation in this matter.

How long do we keep your personal data?

As a general rule, we will store your personal data for a period of 12 months. You may request the deletion of certain information from us at any time, and we will comply with such requests, subject to the retention of certain information, including subsequent termination of any communication or contract, where applicable law or our legitimate interests so require.

To whom we transmit your personal data?

Where applicable, we may transmit or provide access to certain personal data of yours to the following categories of recipients:

– exghts partners;

– courier service providers;

– payment / banking service providers;

– other companies with which we can develop joint programs to offer our products and services on the market.

If we have a legal obligation or if it is necessary to defend a legitimate interest, we may also disclose certain personal data to public authorities upon request.

We ensure that access to your data by third parties under private law is made in accordance with the legal provisions on data protection and confidentiality of information, based on contracts concluded with them.

Parts of the content of the site may be provided by third parties with whom exghts has concluded contracts for the supply of content. Also, inside the content of the site may be included advertising sections in which there will be advertising messages of third parties. exghts is in no way responsible for the content provided by third parties, whether advertising or not. Also, exghts is not responsible for the content of pages that link to or link to the site.

In which countries we transfer your personal data?

We currently store and process your personal data in Romania.

However, we may transfer certain of your personal data to entities located in or outside the European Union, including in countries that the European Commission has not recognized.

We will always take steps to ensure that any international transfer of personal data is carefully managed in order to protect your rights and interests. Transfers to service providers and other third parties will always be protected by contractual commitments and, where appropriate, other guarantees, such as standard contractual clauses issued by the European Commission or certification schemes, such as the Privacy Shield for the protection of personal data. transferred from within the EU to the United States.

You can contact us at any time, using the contact details set out above, to find out more about the countries in which we transfer your data, as well as the guarantees we have put in place regarding these transfers.

How we protect the security of your personal data?

We are committed to ensuring the security of personal data by implementing appropriate technical and organizational measures, according to industry standards.

The transmission of your personal data is done using state-of-the-art encryption algorithms and stored on secure servers, while ensuring data redundancy.

Despite the measures taken to protect your personal data, we warn you that the transmission of information via the Internet, in general, or through other public networks, is not completely secure, there is a risk that the data may be viewed and used by third parties. unauthorized parties. We cannot be held responsible for such vulnerabilities in systems that are beyond our control.

What rights do you have?

The General Data Protection Regulation gives you a number of rights in relation to your personal data. You may request access to your data, correct any errors in our files and / or object to the processing of your personal data. You may also exercise your right to complain to the competent supervisory authority or to go to court. Where applicable, you may also have the right to request the deletion of your personal data, the right to restrict the processing of your data and the right to data portability.

In order to exercise your rights, you can contact us using the contact details listed above. Please note the following if you wish to exercise these rights:

Identity. We take seriously the confidentiality of all records that contain personal data. We reserve the right to verify your identity by requesting additional information for the purpose of confirming your identity.

Fees. We will not charge you a fee to exercise any rights with respect to your personal data, unless your request for access to information is unfounded, repetitive or excessive, in which case we will charge a reasonable amount. in such circumstances. We will inform you of any fees applied before resolving your application.

Response time. We intend to respond to any valid requests within a maximum of 30 days, unless this is particularly complicated or if you have made several requests, in which case we will respond within a maximum of 45 days. We will let you know if we need more than 30 days. We may ask you if you can tell us exactly what you want to receive or what worries you. This will help us act faster and shorten the response time to your request.

Third party rights. We must not comply with a request if it would adversely affect the rights and freedoms of other data subjects.

Target rights Description
Access

You can ask us:

 

· To confirm if we process your personal data;

· Provide you with a copy of this data;

· Provide you with other information about your personal data, such as the data we have, what we use it for, to whom we disclose it, if we transfer it abroad and how we protect it, how long we keep it, what rights you have, how can you make a complaint, where we got your data from, to the extent that the information has not already been provided to you by this information.

Rectification You may ask us to rectify or complete your inaccurate or incomplete personal data. We may try to verify the accuracy of the data before rectifying it.
Data deletion

You can ask us to delete your personal data, but only if:

 

· They are no longer necessary for the purposes for which they were collected; or

· You have withdrawn your consent (if the data processing was based on consent); or · Exercise a legal right to oppose; or

· They have been processed illegally; or

· We have a legal obligation in this regard. We are not obligated to comply with your request to delete your personal data if the processing of your personal data is necessary:

· For the observance of a legal obligation; or · For the establishment, exercise or defense of a right in court.

There are certain other circumstances in which we are not required to comply with your request to delete data, although these are the two most likely circumstances in which we may deny this request.

Restricting data processing

You can ask us to restrict the processing of personal data, but only if:

 

· Their accuracy is challenged, to allow us to verify their accuracy; or
· The processing is illegal, but you do not want the data to be deleted; or
· They are no longer needed for the purposes for which they were collected, but you need them to establish, exercise or defend a right in court; or
· You have exercised your right to object, and verification that our rights prevail is ongoing.
We may continue to use your personal data following a request for a restriction if:
· We have your consent; or · To ascertain, exercise or ensure the defense of a right in court; or
· To protect the rights of exghts or other natural or legal persons.
Data portability

You can ask us to provide you with personal data in a structured, commonly used and automatically readable format, or you can request that it be “ported” directly to another data controller, but in each case only if:

 

· The processing is based on your consent or on the conclusion or execution of a contract with you; and the processing is done by automatic means.

Opposition

You may object at any time, for reasons related to your particular situation, to the processing of your personal data under our legitimate interest, if you consider that your fundamental rights and freedoms prevail over this interest.

 

You may also object at any time to the processing of your data for direct marketing purposes (including profiling), without giving any reason, in which case we will terminate such processing as soon as possible.

Automatic decision making

You can request not to be subject to a decision based solely on automatic processing, but only when that decision:

 

· Produces legal effects on you; or

· Affects you in a similar way and to a significant extent. This right shall not apply where the decision reached following the automatic decision-making:

· We are required to enter into or enter into a contract with you;

· Is authorized by law and there are adequate guarantees for your rights and freedoms; or

· Is based on your explicit consent.

Claims
You have the right to lodge a complaint with the supervisory authority regarding the processing of your personal data. In Romania, the contact details of the data protection supervisory authority are the following:
National Authority for the Supervision of Personal Data Processing
B-dul G-ral. Gheorghe Magheru no. 28-30, Sector 1, postal code 010336, Bucharest, Romania.
Phone: +40.318.059.211;
e-mail: anspdcp@dataprotection.ro
Without prejudice to your right to contact the supervisory authority at any time, please contact us in advance, and we promise that we will make every effort to resolve any issue amicably.

We remind you that you can contact at any time the exghts Data Protection Officer by sending your request in any of the following ways: by e-mail to: info@exghts.com or by mail / courier to the address: EXGHTS S.R.L., Bulevardul 15 Noiembrie 44, Brasov County.