Introduction

 We pay special attention to the protection of the privacy of visitors accessing the website www.efrmanagement.ro, as well as those provided to us by a third party or to which we have had access from another source, in accordance with EU Regulation 2016/679 approved by the European Parliament and the Council of Europe on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as GDPR), transposed into Romanian law by Law no. 190/ 2018, published in the Official Gazette no. 651 of 26^th of July 2018.

 

 GDPR is a set of rules based on complex principles, which is open to interpretation and contains numerous areas where Member States are invited to intervene. Currently, there is little guidance on the implementation of GDPR and Supervisory Authorities are likely to have different views than those expressed in this template. Despite our best efforts to provide the best service, we cannot accurately predict how the Supervisory Authority, or the courts will interpret the Regulation.

 

 In the following, we will show you the practices regarding the application of the GDPR provisions, as well as the rights you have for the processing of your personal data by EFREMCONS SRL.

 

Operator identification data

 EFREMCONS SRL has its registered office in Bucharest, Sector 6, str. Portocalelor nr. 2, postal code 060101, Romania, CUI 33640634, J40/11323/30^th of September 2014, phone 0771 072 683, email office@efrmanagement.ro

 

 Definitions of terms

 "Personal data" means any information that can identify you directly (first name, last name) or indirectly (through pseudonymous data, such as a unique identification number). Personal Data includes: email address, home address, telephone number, username, personal numerical code, ID card number and series, passport number, driver's license number, social health insurance number, profile photos, user-generated content, financial information and financial status information. It may also include unique numeric identifiers (IP address) of your computer, MAC address of your mobile device, cookies.

 

 "Data processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 

 The "personal data controller" is EFREMCONS SRL, hereinafter referred to as the "controller".

 "Consent/Agreement" is any specific, explicit, informed and unambiguous indication of your wishes whereby, by a clear affirmative statement or action, you agree to the processing of personal data relating to you.

 

 "Cookie" - www. efrmanagement.ro website uses cookies. These are text files that are stored in a computer system via an Internet browser and contain a cookie ID that allows the websites and servers concerned to differentiate your individual browser from other Internet browsers that contain other cookies. A particular Internet browser can be recognized and identified using the unique cookie ID.

 

 By using cookies, we can offer you more user-friendly services, information and offers presented on our website that can be optimized according to your needs.

 

 You can at any time prevent the setting of cookies, delete cookies already set.

 

 Categories of personal data processed

 EFREMCONS SRL collects, stores and uses the following types of personal information: first name, surname, personal number code, series and number of ID card, passport number, driving license number, social health insurance number, address, date of birth, gender; email address, landline or mobile phone number, user name, profile photos, academic details, occupation and marital status details, hobbies; financial-banking information (bank name, IBAN of the bank account, SWIFT code, bank card details, used to conclude contracts for the payment of your services and those of third parties as shown in the documents you will provide us with) and information on your financial situation; IP address, geographical location, browser type and version, operating system of your computer, MAC address of your mobile device; cookies; information about your use, viewing of our website pages including when, how often and under what circumstances you use them; the content of communications and their metadata from correspondence we have; any other personal information you send to us.

 

 Before disclosing another person's personal information to us, you must obtain that person's consent to both the disclosure and processing of personal information in accordance with this privacy policy.

 

 Purposes and basis of processing:

 We use your personal information to:

 -  the provision of services presented through our website, the negotiation and conclusion of legal contracts, in case we collaborate and/or develop business partnerships.

 

 Basis: the processing of your data for this purpose is based on the contract concluded between you and EFREMCONS SRL and your consent. The provision of your personal data is necessary for the performance of this contract. Refusal to provide your data may result in the impossibility of carrying out the contractual relationship between you and EFREMCONS SRL.

 

 -  sending them, to third party subcontractors or collaborators, to administrative authorities in order to provide the services that we are contractually obliged to provide to you.

 

 Basis: the processing of your data for this purpose is based on the contract concluded between you and EFREMCONS SRL and your consent. The provision of your personal data is necessary for the performance of this contract. Refusal to provide data may result in the impossibility of carrying out the contractual relationship between you and EFREMCONS SRL.

 

 -  fulfilment of the legal obligations incumbent on EFREMCONS SRL, in the context of the services provided through the site, including tax obligations as well as archiving obligations;

 

 Basis: the processing of your data for this purpose is a legal obligation. The provision of your personal data to investigation and prosecution bodies, courts, other state authorities (ANAF, ANFP, ITM, ANI, ANSPDCP), is mandatory (for example, accounting documents are kept for a period of 10 years, according to the accounting law). Refusal to provide data may result in EFREMCONS SRL not being able to comply with its own contractual obligations, and consequently will not be able to provide the service requested by you.

 

 -   sending commercial communications for information purposes, presentation and selection of EFREMCONS SRL offers, presentation and selection of offers from third parties and EFREMCONS SRL collaborators, regarding the choice of the land, the suitable construction project, the construction materials, the construction finishes, the request for the preparation of the documentation subject to the project approval, the urban planning certificate and the construction permits, the supervision of the construction execution by the site manager;

 

 Basis: the processing of your data for this purpose is based on the contract concluded between you and EFREMCONS SRL and your consent. The provision of your personal data is necessary for the performance of this contract. Refusal to provide your data may result in the impossibility of carrying out the contractual relationship between you and EFREMCONS SRL.

 

 - sending reports, invoices and payment notices to you and collecting payments from you.

 

 Basis: the processing of your data for this purpose is based on the contract concluded between you and EFREMCONS SRL and your consent. The provision of your personal data is necessary for the performance of this contract. Refusal to provide your data may result in the impossibility of carrying out the contractual relationship between you and EFREMCONS SRL.

 

 -  sending you marketing communications about our business and the benefits you can derive from working with us or our collaborators (third party companies or individuals) that we think may be of interest to you or where you have specifically consented, by email, sms or similar technologies, by post (you can inform us at any time if you no longer wish to receive marketing communications) and to tailor our offers to your needs; customising our website for you;

 

 Basis: the processing of your data for this purpose is based on your consent if you choose to provide it.

 

 You can express your consent to the processing of your data for this purpose through the Personal Data Processing Agreement - Annex 2 to the Service Agreement or by ticking the appropriate boxat the time of account creation or after account creation in the My Account Information section. To unsubscribe from receiving such commercial communications you can use the option at the end of each email, sms, other technologies, containing commercial communications. In addition, you can unsubscribe by going to the section.

 

 Providing your data for this purpose is voluntary. Refusal to provide consent to the processing of your data for this purpose will have no negative consequences for you.

 

 -  maintaining the security of our website and preventing fraud, including notification in the event of a breach of data and site security.

 Basis: the processing of your data for this purpose is based on the contract concluded between you and EFREMCONS SRL, your consent and legal obligations. The provision of your personal data is necessary for the performance of this contract. Refusal to provide your data may result in the impossibility of carrying out the contractual relationship between you and EFREMCONS SRL.

 

 Under no circumstances do we sell the data collected to third parties. Without your express consent, we will not provide your personal information to third parties for direct marketing by these third parties or any other third parties. If you submit personal information for publication on our website (we include in this category your comments and appreciations for our activity), we will publish and use this information in accordance with the scope of the consent you provide to us. Privacy settings may be used to limit the publication of your information on our website and can be changed using the privacy toggles on the website.

 

 - other uses.

 Data storage period.

 -   during the execution of the service contract between you and EFREMCONS SRL and the achievement of the investment objectives of any subsequent stage: acquisition of the land on which the construction is to be built, execution of the construction project, obtaining the urban planning certificate, the building permit and the approvals for the connection to utilities, ensuring the supervision of the execution of the construction site supervision, acquisition of construction materials at a reduced price; at the end of the contract execution, your personal data will be deleted, except for those that according to the legal obligations are to be archived;

 

 -   until such time as you exercise your right to have your data deleted ("right to be forgotten") in accordance with this Privacy Policy.

 

 -  EFREMCONS SRL deletes the data of visitors to the website www.efrmanagement.ro, periodically and within 24 hours from the date you choose to give up having a contractual relationship with us. We store your personal data only if we will carry out a contractual relationship, within the framework of a service contract.

 

 Disclosure of personal data.

 We may disclose your personal information to any of our employees, subcontractors and suppliers, collaborators, professional advisors, attorneys, our insurers, investigators and prosecutors, other state authorities, for the purposes set out in this policy as well as: if required by law; in connection with any potential or pending legal proceedings; to establish, exercise or defend our legal rights (including providing information to third parties for fraud prevention and credit risk reduction purposes).

 

 Except as provided in this policy, we will not provide your personal information to third parties.

 

 Transfer of personal data

 EFREMCONS SRL does not disclose or transfer your personal data to third parties outside the European Union or the European Economic Area.

 

 Your rights 

1.    The right to information and access to data, i.e. the right to obtain confirmation of the processing of personal data concerning you by EFREMCONS SRL, as well as access to such data. For any other copies requested by you, we have the right to charge a reasonable fee based on administrative costs. If you submit a request in electronic format, the information will be provided to you in electronic format.

 

2.    The right to rectification of data, the right to have inaccurate or incomplete personal data corrected without delay.

 

3.   The right to erasure of your personal data or the right to "be forgotten" without undue delay by EFREMCONS SRL, when:

-personal data are no longer necessary for the purposes for which they were collected or otherwise processed.

-  you withdraw the consent you have given for processing under Article 6(1)(a) and/or Article 9(2)(a) of the GDPR and there is no other legal basis for the processing.

-  you object to the processing under Article 21(2) of the GDPR and there are no legitimate grounds prevailing as far as the processing is regarded.

-  personal data have been unlawfully processed.

-  personal data must be deleted in order to comply with a legal obligation under European Union law or national law (Romanian legislation).

 

4.   Right to restrict processing - under this right, at your express request, we restrict the processing of your data if:

-  the processing is unlawful, and you object to the deletion of your personal data and request instead that their use be restricted.

-  EFREMCONS SRL no longer needs personal data for processing purposes, but you request them for the establishment, exercise or defence of a right in court.

-  you object to the processing (other than direct marketing), for the period of time during which it is verified whether the legitimate rights of the controller prevail over your rights.

 

      5.  The right to data portability, i.e. the right to receive personal data in a structured, commonly used and easily readable format and the right to have such data transferred by EFREMCONS SRL to another data controller, provided that the conditions laid down by law are met.

 

6.   The right to object to data processing can be exercised by submitting a request as follows:

-  at any time, justified by reasons relating to your particular situation, that the data concerning you are processed on the basis of the legitimate interest of EFREMCONS SRL or on the basis of the public interest, except in cases where EFREMCONS SRL can demonstrate that it has legitimate and compelling reasons which justify the processing, and which override your interests, rights and freedoms or that the purpose is the establishment, exercise or defence of legal claims.

-  at any time, free of charge and without any justification, in the event that the data concerning you could be processed for direct marketing purposes.

 

7.   The right not to be subject to a decision based solely on automated means, i.e. the right not to be subject to a decision taken solely on the basis of automated processing activities, such as profiling, if the decision produces legal effects concerning or affecting you to a significant extent. Profiling occurs when personal data (such as age, gender) is evaluated to make predictions about you or to categorise you. Exclusively automated decision making occurs when decisions about you are made by technological means and without any human involvement, and these decisions can be made without profiling. It should be mentioned that these decisions are allowed if you have given your explicit consent. Otherwise, these decisions can be challenged by you.

 

8.     The right to address the National Supervisory Authority for Personal Data Processing (ANSPDCP).

 

9.    The right to withdraw your consent at any time, without affecting the lawfulness of the processing of your data carried out by EFREMCONS SRL, on the basis of the consent given before its withdrawal.

 

For any requests you may have regarding the exercise of the above-mentioned rights, for restricting or withdrawing consent, as well as to address any other questions regarding the way personal data are processed, please contact us: at the email address:office@efrmanagement.ro; at the telephone number 0771 072 683, and in writing, at the address in Bucharest, sector 6, str. intr. Portocalelor nr. 2, contact person Radu Dragomirescu.