This privacy policy informs you about the information we collect from you when you use our website. In collecting this information, we act as a data controller and are required by law to provide you with information about us, why and how we use your data and what rights you have over your data. The purpose of this document is to describe how we collect, use and process your data when you use the site and your rights in relation to your data.

We assure you that we value your privacy and are committed to respecting the privacy and security of the information you provide when using the site. We are not interested in your personal data other than that which is necessary to achieve our purposes. We undertake not to forward your personal data to advertisers. Personal data refers to any information that tells us something about you or that we can link to you.

Who are we? Elian Solutions SRL with headquarters in Bucharest, Str. Sergent Ion Nutu, nr. 44, One Cotroceni Park, Corp A and B, 4th floor, sector 5, 050762, registration number at the Trade Register J40/255/2008 RO 23037351, a company hereinafter referred to as “the Operator”, defined as a personal data controller within the meaning of European Regulation 679/2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation or GDPR).

You can contact us by post at the above registered office addresses, by email at dpo@elian-solutions.ro or by telephone on 004 0726166179. We are not obliged to have a data protection officer, so any questions regarding the use of your personal data should be addressed to the contact details above.

What is personal data? According to Regulation 679/2016 “personal data”, as defined in Article 4(1), means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.

General provisions. You may consult the site without revealing your identity or providing any information about your personal data. However, information may be obtained automatically when you visit the site, as the web server records the name of your Internet service provider and the website from which you visit us, but it cannot be linked to any individual. Other personal data will only be stored if volunteered by you. At the time of account creation and/or newsletter subscription, as well as throughout the contractual term, we will inform you about:

• the identity and contact details of the operator;
• the contact details of the data protection officer;
• the purposes for which personal data are processed and the legal basis for the processing;
• the recipients or categories of recipients of the personal data;
• if applicable, the intention of the controller to transfer personal data to a third country or organisation;
• the period for which the personal data will be stored or, if this is not possible, the criteria used to determine this period;
• the existence of the right to request from the controller access to, rectification, erasure or restriction of the processing of personal data relating to the data subject or the right to object to the processing and the right to data portability;
• the existence of the right to withdraw consent at any time, without affecting the lawfulness of the processing carried out on the basis of consent prior to the withdrawal of consent;
• the right to lodge a complaint with a supervisory authority;
• whether the provision of personal data is a legal or contractual obligation or an obligation necessary for the conclusion of a contract, as well as whether the data subject is obliged to provide such personal data and what the possible consequences of non-compliance are;
• the existence of an automated decision-making process including the creation of user profiles.

What personal data does the Operator collect and process? The personal data we collect includes:
a). Name and surname, email address, telephone number, company you work for
b). Other data you mention in the contact form
c). data on your CV when you use the upload facility for employment purposes

When accessing the Site, certain data is automatically transmitted by your browser and is collected and stored by us. This data includes, but is not limited to:

IP addresses;
Browser type and version;
Type of device used and operating system;
Date and time of access to the Site;
Your location.

You agree that your data may be transferred for storage purposes to the server managed by the IT service provider or one of its affiliates and/or subcontractors, provided that technical, organizational and personal measures are maintained at the same level. We will also collect and store all correspondence you send to us, such as notifications, inquiries and requests.

Sensitive data and children’s data. We do not record sensitive data about your health, ethnicity, religious or political beliefs. We also do not collect data about your children.

Data collection. The operator collects your data through various specific methods and tools such as: professional traffic tracking software, application for managing communication with subscribers via various channels, by saving in databases the various contact forms available on the site that are filled in by you through the creation of your account on the Site, through online questionnaires, etc. Any information provided by you will be considered and will represent your express consent for your personal data to be used by Elian-Solutions SRL , as well as by its commercial partners, in accordance with the purposes mentioned above. If you do not want your data to be collected, you have the right not to provide them, but this implies the deletion from the system of your account and / or unsubscription from the newsletter and the impossibility to receive information on events and communications of the Operator.

What is the purpose of collection? We only use your personal data for legitimate business purposes. These include:

• to provide the requested information and to answer the correspondence received from you;
• to send you information about us, our promotions and our and our Partners’ activities and events;
• to manage customer relations. We may ask you for feedback about our products and services and communicate it to certain members of our staff in order to improve our offering;
• personalised marketing: we may send you letters, emails or text messages to offer you a product or service.

You may unsubscribe from offers of this kind. You have the right not to consent or object to commercial or direct marketing activities, including profile creation for the purpose of such activities; to comply with legal obligations and social responsibilities under Romanian and international laws.
You may unsubscribe from the Operator’s newsletter at any time by:

• directly from the newsletter e-mail sent by the Operator;
• by sending a request to the email address: dpo@elian-solutions.com.

What are the grounds for processing personal data? Our company collects and processes your personal data only with your consent, when it has a legal obligation or there is a legitimate basis.

How can you update your personal data? If any of the personal data you have provided to us changes, e.g. if you change your first name, last name or e-mail address or if you wish to cancel any request made to us, or if you become aware that we hold any incorrect personal data about you, please contact us by e-mail at: dpo@elian-solutions.ro. We will not be liable for any loss arising from incorrect, unauthentic, insufficient or incomplete personal data you provide to us.

Is your data secure at the Operator? Our company treats the security of your data very seriously by adopting and periodically reviewing technical and organisational security measures designed to protect data against unauthorised access, modification, disclosure or destruction. Access to data is only allowed to authorised persons who have previously agreed to confidentiality obligations.

To whom can the Operator transfer the data? Your data will be accessed by the Company’s employees, marketing department, contractors and partners of the operator only for the purposes mentioned above. These persons are obliged to maintain the confidentiality of this data and are trained in the protection of personal data.

Service providers /partners of the company. If we use other service providers, we only communicate personal data that is necessary for the performance of a specific task. Service providers support us with activities such as:

• performance of certain services and operations;
  designing and maintaining Internet-based tools and applications;
• marketing activities or events and customer communication management;
• preparation of reports and statistics, printing of materials and product design;
• placing advertisements within applications, websites and social networks.

Your personal data may be passed on to the relevant authorities upon request, in accordance with applicable legal provisions.

Google Analytics. The website uses Google Analytics cookies to collect information about how visitors use this website and to detect possible navigation problems. Google Analytics stores information about the pages visited, the time spent on the site, the way the site was accessed and the sections accessed within the pages. No personal information is stored, therefore this information cannot be used to identify the user. The site uses Google Analytics to track whether the site meets the requirements of users and to prioritise the improvement of the processes carried out. Google provides more information about cookies on the privacy policy and cookie policy page. Google also provides an “add-on” that offers the possibility to opt-out of Google Analytics regardless of the pages visited.If you want to know more about how Google uses and collects this data, please visit the link privacy policy https://support.google.com/analytics/answer/6366371?hl=en and the link https://support.google.com/analytics/answer/3379636 on the relationship between operator and data controller.

How long does the Operator keep the personal data collected? Your data will be stored for the duration of your account and/or newsletter subscription. The Company will delete your data related to either your account or newsletter subscription as soon as you decide to deactivate your account or, as the case may be, unsubscribe from the newsletter. However, the deletion of data may not be concurrent with the deletion of your account and/or unsubscription from the newsletter. We also reserve the right to withhold data if necessary to fulfil our legal obligations, resolve disputes, etc. In the event of deletion of personal data upon request or in the case of periodic deletions, the Operator will notify the third parties to whom it has provided the data.

What are your rights? We respect your rights as a customer to determine how your personal information is used. These rights include:

The right to access information. You have the right to request a report of your personal data that we process;

The right to rectification. If your personal data is incorrect, you have the right to ask us to rectify it. If we communicate corrected data to third parties at a later date, we will inform those third parties accordingly.

The right to object to data processing. You may object to the use of your personal data by Elian-Solutions SRL in legitimate interests. You can exercise this right online or by telephone. We will also consider your objection if the processing of your information has an unjustified impact on you that requires the cessation of the processing of that data. You may also object to receiving personalised commercial messages from us. If you become a subscriber and subsequently unsubscribe, you can opt-out of receiving messages by using the “unsubscribe” link in the footer of each commercial email.

Right to restrict processing. You have the right to ask us to restrict the use of your personal data if you believe that the information is inaccurate.

Right to data portability. You have the right to ask us to transfer your personal data directly to you or to another company. This applies to personal data that we process with your consent. Where technically possible, we will transfer your personal data.

Right to erasure. You can request us to delete your personal data if:

• the data is no longer needed for the purpose for which it was collected or processed;
• you withdraw your consent on the basis of which the processing takes place;
• Elian-Solutions SRL processes your personal data unlawfully, or
• a European Union or Romanian regulation requires Elian-Solutions SRL to delete your personal data.

Right to complain. If you are not satisfied with the way we have responded to your requests, you have the right to make a complaint. If you are still dissatisfied with our response to your complaint, you can forward it to the Elian Solutins Group Data Protection Officer. You can also contact the data protection authority in Romania.

Cookies policy. The www.elian-solutions.com website uses cookies. The information presented below is intended to provide the user with more details about the placement, use and management of cookies used by the www.elian-solutions.com website. There are also some useful links related to this topic. If you need more information and it is not provided below, you can contact us at +40 726166179 or dpo@elian-solutions.com.

This website uses both proprietary cookies to provide visitors with a better browsing experience and services tailored to their needs and interests. The cookies used on this site provide valuable feedback and help us in our attempt to improve the online experience. The information obtained from these cookies is not stored in the database and once you close your browser the cookies are deleted from your computer.

What is a cookie? An “Internet cookie” (also known as a “browser cookie” or “HTTP cookie” or simply “cookie”) is a small file of letters and numbers that will be stored on a user’s computer, mobile device or other equipment from which the Internet is accessed. The cookie is installed by a request issued by a web-server to a browser (e.g. Internet Explorer, Chrome) and is completely “passive” (contains no software, viruses or spyware and cannot access information on the user’s hard drive). A cookie consists of 2 parts: the name and the content or value of the cookie. Furthermore, the lifetime of a cookie is determined; technically, only the webserver that sent the cookie can access it again when a user returns to the website associated with that webserver. Cookies themselves do not require personal information in order to be used and, in most cases, do not personally identify Internet users.

There are 2 broad categories of cookies:

• Session cookies – these are temporarily stored in the web browser’s cookie folder for the browser to remember until the user exits the website or closes the browser window (e.g. when logging in/out of a webmail account or social network);
• Persistent cookies – these are stored on the hard drive of a computer or device (and generally depend on the default lifetime of the cookie). Persistent cookies also include those placed by a website other than the one the user is currently visiting – known as ‘third party cookies’ – which can be used anonymously to remember a user’s interests so that the most relevant advertising can be delivered to users.

What are the benefits of cookies? A cookie contains information that links a web-browser (the user) to a specific web-server (the website). If a browser accesses that web-server again, it can read the information already stored and react accordingly. Cookies provide users with a pleasant browsing experience and support the efforts of many websites to provide convenient services to users: e.g. online privacy preferences, site language options, shopping carts or relevant advertising.

What is the lifetime of a cookie? Cookies are managed by web servers. The lifetime of a cookie can vary significantly, depending on the purpose for which it is placed. Some cookies are used exclusively for a single session (session cookies) and are no longer retained once the user has left the website and some cookies are retained and reused each time the user returns to that website (‘permanent cookies’). However, cookies can be deleted by a user at any time via the browser settings.

What are third party cookies? Certain sections of content on some websites may be provided through third party providers (e.g. a news box, a video or an advertisement). These third parties may also place cookies through the site and they are called “third party cookies” because they are not placed by the owner of that website. Third party providers must also comply with applicable law and the privacy policies of the site owner are Google Analytics and Right Now.

How are cookies used by this site? A visit to this site may place cookies for the purposes of:

• Site performance cookies;
• Analytics cookies.

Visitor analytics cookies. Each time a user visits this site analytics software provided by a third party generates a user analytics cookie. This cookie tells us whether you have visited this site before. Your browser will tell us if you have this cookie, and if not, we will generate one. It allows us to track unique users who visit us and how often they do so.

Other third party cookies. On some pages, third parties may set their own anonymous cookies in order to track the success of an application, or to customize an application. Due to the way they are used, this site cannot access these cookies, just as third parties cannot access cookies held by this site.

Cookies used by this site may come from:

Google Analytics. The site uses Google Analytics cookies to collect information about how visitors use this site and to detect possible navigation problems. Google Analytics stores information about the pages visited, the time spent on the site, the way the site was accessed and the sections accessed within the pages. No personal information is stored, therefore this information cannot be used to identify the user. The site uses Google Analytics to track whether the site meets the requirements of users and to prioritise the improvement of the processes carried out. Google provides more information about cookies on the privacy policy and cookie policy page. Google also provides an “add-on” that allows you to opt-out of Google Analytics regardless of the pages you visit.If you would like more information on how Google uses and collects this data, please visit the privacy policy link (Google privacy policy).

What kind of information is stored and accessed through cookies? Cookies store information in a small text file that allows a website to recognise a browser. The web server will recognise the browser until the cookie expires or is deleted. The cookie stores important information that improves the web browsing experience (e.g.: the language settings in which you want to access a site; keeping a user logged into a webmail account).

Why are cookies important for the Internet? Cookies are central to the efficient functioning of the Internet, helping to generate a user-friendly browsing experience tailored to each user’s preferences and interests. Refusing or disabling cookies may make some sites unusable. Refusing or disabling cookies does not mean that you will no longer receive online advertising – it just means that it will no longer be able to take into account your preferences and interests as evidenced by your browsing behaviour. E.g. important uses of cookies (which do not require user authentication via an account):

• Content and services tailored to user preferences – news categories, weather, sports, maps, public and government services, entertainment sites and travel services;
• Offers tailored to user interests – password retention, language preferences (e.g. displaying search results in English);
• Retention of child protection filters on Internet content (family mode options, safe search functions);
• Limiting the frequency of ads – limiting the number of times an ad is displayed for a given user on a site;
• Providing more relevant advertising to the user;
• Measuring, optimizing and analytics features – such as confirming a certain level of traffic to a website, what type of content is being viewed and how a user gets to a website (e.g. via search engines, directly, from other websites, etc.). Websites perform these usage analytics to improve their websites for the benefit of users.

Security and privacy issues. Cookies are NOT viruses! They use plain text formats. They are not made up of pieces of code so they cannot be executed or run themselves. Consequently, they cannot be duplicated or replicated on other networks to run or replicate themselves again. Since they cannot perform these functions, they cannot be considered viruses. Cookies can however be used for negative purposes. Because they store information about users’ preferences and browsing history, both on a particular site and on many other sites, cookies can be used as a form of Spyware. Many anti-spyware products are aware of this fact and constantly mark cookies for deletion as part of anti-virus/anti-spyware deletion/scanning procedures. In general, browsers have built-in privacy settings that provide different levels of cookie acceptance, validity period and automatic deletion after the user has visited a particular site.

Other security issues related to cookies. As identity protection is very valuable and is the right of every internet user, it is advisable to know what possible problems cookies can create. Because cookies constantly transmit information back and forth between the browser and the website, if an attacker or unauthorised person intervenes in the data transmission path, the information contained in the cookie can be intercepted. Although very rare, this can happen if the browser connects to the server using an unencrypted network (e.g. an unsecured WiFi network). Other cookie-based attacks involve incorrect cookie settings on servers. If a website does not require the browser to use only encrypted channels, attackers can use this vulnerability to trick browsers into sending information through unsecured channels. Attackers then use the information to gain unauthorised access to certain websites. It is very important to be careful in choosing the most appropriate method of protecting personal information.

Tips for safe and responsible browsing based on cookies. Due to their flexibility and the fact that most of the most visited and largest sites use cookies, they are almost unavoidable. Disabling cookies will not allow the user access to the most popular and used sites including Youtube, Gmail, Yahoo and others. Here are a few tips that can ensure you can browse without worrying about cookies:

• Customize your browser settings for cookies to reflect a level of cookie security that is comfortable for you;
• If you don’t mind cookies and you are the only person using your computer, you can set long expiry times for storing browsing history and personal access data;
• If you share access to your computer, you may consider setting your browser to delete individual browsing data each time you close the browser. This is a variant of accessing sites that place cookies and deleting any visit information when you close your browsing session;
• Install and constantly update anti-spyware applications.

Many spyware detection and prevention applications include detection of attacks on websites. This prevents the browser from accessing websites that could exploit browser vulnerabilities or download dangerous software. Make sure your browser is always up to date. Many cookie-based attacks exploit weaknesses in older versions of browsers. Cookies are everywhere and cannot be avoided if you want to enjoy access to the best and biggest sites on the Internet – local or international. With a clear understanding of how they work and the benefits they bring, you can take the necessary security measures so that you can surf the internet with confidence.

How can I stop cookies? Disabling and refusing to receive cookies may make certain sites impractical or difficult to visit and use. Also, refusing to accept cookies does not mean that you will no longer receive/view online advertising. It is possible to set your browser not to accept cookies, or you can set your browser to accept cookies from a specific site. But, for example, if you are not registered using cookies, you will not be able to leave comments. All modern browsers offer the possibility to change cookie settings. These settings are usually found in the “options” or “preferences” menu of your browser.

Exercising your rights If you wish to exercise your rights or make a complaint, please contact us by sending an e-mail to dpo@elian-solutions.ro, by calling us on +40 726166179 or by filling in the form in the “Contact” section. We intend to respond to your request as soon as possible. In some cases, the response time may be up to one month. If we need more time to resolve your request, we will inform you how much more time is needed and give you the reasons for the delay. In some cases, we may reject your request. If permitted by law, we will inform you in good time why we have rejected your request.

You also have the right to lodge a complaint with the data protection supervisory authority in Romania if you consider that the processing of your personal data violates applicable laws.

The institution you can contact to file a complaint is: Autoritatea Nacionala de Supraveghere a Prelucrarii Datelor cu Caracter Personal, 28-30 General Gheorghe Magheru, district 1, postal code 010336, Bucharest, Romania, www.dataprotection.ro, anspdcp@dataprotection.ro, +40.318.059.211, +40.318.059.212.

Updates to this privacy policy. The most recent update to this Privacy Policy was made in October 2020. We reserve the right to periodically update and amend this Privacy Policy to reflect any changes in the way we process your personal data or any changes in legal requirements. In the event of any such changes, we will post the amended version of the Privacy Policy in the App and/or otherwise make it available to you.