Information Notice on the Processing of Personal Data

Viviana Nitu Art

Bulevardul Tomis, no. 289, Bloc T13, Scara A, Apartament 10, Constanta, Romania

Company registration number: F13/475/2022

Unique Identification Code: RO4434956

For Viviana Nitu Art, the security and confidentiality of your personal data are of significant importance. Therefore, we will take all necessary and reasonable measures to ensure the security and confidentiality of your personal data, as well as to process them in accordance with the applicable legal provisions and solely for the purposes specified below.

I. Personal data processed through our website

1. The personal data we process:

  • name;
  • email address;
  • phone number;
  • employer’s name;
  • other data, depending on the form in question, completed by you.
  • information obtained through the use of cookies;

 

2. Purposes and legal grounds for processing

When you contact us, including through the use of the contact forms on our website, we will collect your identification data and contact data in order to be able to respond to your requests. We will only process the personal data that is necessary for responding to your requests and for the proper administration of these.

Any processing of your personal data in this purpose is based on your implicit consent, expressed by completing the identification and/or contact data fields on the website or by providing them to us voluntarily in any other way.

We will also process personal data for statistical and analytical purposes with regard to website traffic using cookies.

 

3. Data retention period

Your personal data will be stored for the period necessary to communicate and subsequently for a maximum period of 6 months, except in the case of you having been included in our database as a result of establishing a business relationship or if you have opted to receive marketing communications from Viviana Nitu Art. In any case, we will continue to process your personal data in cases where this is necessary on the basis of legal provisions or if we are otherwise entitled to continue processing. We will also retain your personal data for a longer period of time if necessary, in the event that immediate deletion would require overwriting our backup systems and disaster recovery.

 

4. Third parties

Currently, the company does not transfer your personal data to any natural or legal person outside the company, other than as mentioned in this Information Notice.

In any case, you will be informed of any future transfer of your personal data, except in the case where such a transfer or disclosure is expressly provided for by Union law or national law, on the basis of our obligations to comply with the relevant legal provisions.

To process personal data, we can use authorized persons necessary for the administration of our business, for example, IT solution providers. We will conclude data processing agreements with all these persons to ensure that they process your personal data in accordance with the applicable legal provisions and provide an adequate level of protection for your personal data.

 

II. Personal data processed in the context of contract conclusion and execution

The conclusion and execution of contracts with our business partners requires the processing of personal data belonging to representatives and/or contact persons from clients, partners, affiliates, suppliers, etc., without which the smooth running of contractual relations would not be possible.

1. The personal data we process:

  • identification data;
  • contact data;
  • any other personal data necessary for the performance of the relationship, depending on the specific nature of the relationship.

Some of the calls you make to our team are recorded, in addition to the data mentioned above, and your voice, as well as any other data that may be disclosed during the phone calls.

2. Purposes and legal grounds for processing

The purpose of the processing is to ensure the smooth running of the contractual relationships, including communication between the parties, providing information necessary in connection with the subject of the contract or with facilities that Viviana Nitu Art is developing and from which you can benefit, or to ask you for feedback on the way in which the relationships with Viviana Nitu Art are developing, in a context related to the quality of the products and services we offer.

For the purposes of verifying the preparation, experience, and general compatibility of a candidate within the company, we process the data of the candidates who applied for a position within the company.

In the event of a job interview or other form of assessment at our headquarters, you will be recorded by the video surveillance system installed in the monitored areas, as indicated.

3. Data retention

We will store personal data for a limited period of time after the termination of the contractual relationship, which may be determined depending on the circumstances, but not more than 5 years.

Telephone conversations recordings will be kept for a maximum of one year.

4. Third parties

For the processing of personal data, we may use authorized persons necessary for the administration of the business, for example, IT solution providers. With all authorized persons, we will conclude data processing agreements with appropriate clauses to ensure that the authorized persons assume obligations to process personal data (including their deletion) in full compliance with the applicable laws and which provide an adequate level of protection for your personal data.


III. Processing of personal data in the context of recruitment

You can apply for a position at Viviana Nitu Art by e-mail, by sending or submitting your application in physical format to our headquarters, or through recruitment agencies or platforms.

1. Personal data we process

We collect at least the following personal data necessary in the recruitment process, in order to assess whether you are suitable for a position within the Company:

  • Personal data: name, surname, date of birth, address, phone number, e-mail address, etc.
  • Contact data: phone number, e-mail address, etc.
  • Data included in your CV: education, professional experience, skills, abilities, psychological traits, any information you consider important to communicate to us.
  • Results of competency, aptitude, and personality tests.
  • Other information you provide during interviews and evaluations (if applicable).
  • Professional profile determined by recruitment agencies, through the use of personality, psychological, or aptitude tests, as appropriate.

In addition, if you are scheduled for an interview or evaluation at our headquarters, you will be recorded by the video surveillance system installed in the supervised areas, which are appropriately marked.

2. Purposes and legal grounds for processing

We collect the personal data that you provide to us voluntarily, when you submit your application, as well as later, at the time of the interview and/or evaluation. We inform you that you are free to decide whether to provide us with this personal data. However, the process of recruitment, in the absence of certain data necessary for this process and requested by the Company, data processed for the evaluation and conclusion of an employment contract, is not possible. We also collect personal data necessary for recruitment through recruitment agencies or platforms, in the event that you have been selected for employment through such a platform.

The collection of personal data is limited to what is necessary for the conduct of recruitment activities. These activities related to the conduct of the recruitment process may consist of:

  • Evaluation of your professional training, experience, and general compatibility within the Company and for the desired position;
  • Contacting you regarding your application, including regarding positions that become available later and for which we believe you have the right professional profile;
  • Record of any previous recruitment processes of ours in which you have participated and the reasons why you have been offered or not offered an offer or why the offer has been refused;
  • Any other activities that are related to the good administration of the recruitment process, if they are compatible with those mentioned.

Also, in order to ensure security within the Company, we video-monitor access points to the building and certain internal spaces, in accordance with applicable legal provisions, so we can also process video images of you.

The processing of your data for the purpose of verifying your professional training, experience, and general compatibility within the Company is carried out on the basis of the prefiguration of the conclusion of a contract, and if you will be declared rejected after the recruitment process, we will keep your data for a period of 6 months on the basis of our legitimate interest to be able to respond to any complaints or requests made in connection with the conduct of the recruitment process.

Also, contacting you later, as a rejected candidate, in order to inform you about other career opportunities within the Company, is only carried out with your consent expressed in this sense to keep the data for 2 years.

3. Data retention

Personal data will be stored for a limited period of time, taking into account the end of the recruitment process and the Company’s legitimate interest in keeping the data of rejected candidates for the eventual resolution of any complaints or requests. The option you express, in the event that you will not be recruited for the position you have in mind, to be contacted again in the future to be informed of other career opportunities within the Company, will also be taken into account. In this case, we will keep your data for a period of 2 years from the end of the recruitment process. Otherwise, your personal data will be deleted 6 months after the end of the recruitment process in which you were declared rejected, unless you have expressly requested that your data be kept for a longer period of time.

As for video images, they will be deleted after no more than 30 days from the date of recording, unless the Company has legitimate reasons to keep them for a longer period of time.

In any case, we will continue to process your personal data in cases where this is necessary on the basis of legal provisions or if we are otherwise entitled to continue processing. We will also retain your personal data for an additional period of time if deleting them immediately would require overwriting our backup and disaster recovery systems.

4. Third parties

Currently, the Company does not transfer your personal data to any natural or legal person outside the Company, other than as mentioned in this Privacy Notice.

In any case, you will be informed of any future transfer of your personal data, except in the case where such a transfer or disclosure is expressly provided for by the European Union or national law, on the basis of our obligations to comply with the relevant legal provisions.

For the processing of personal data, we may use authorized persons necessary for the transmission of the results of the recruitment process to candidates, as well as for the administration of the organizational processes of the Company, for example, IT solution providers, including contact management solution providers. With all authorized persons, we will conclude data processing agreements with appropriate clauses to ensure that the authorized persons assume obligations to process personal data (including deleting them) in full compliance with applicable laws and which provide an adequate level of protection for your personal data.

 

IV. Personal data processed for marketing purposes

1. Personal data we process:

  • Name
  • Contact information: phone number, email address
  • Information collected through cookies
  • Job title and position
  • Images
  • Opinions about Viviana Nitu Art services

2. Purposes and legal grounds for processing

We collect the personal data that you provide to us:

(i) Voluntary, directly from you, in the context of subscribing to marketing communications or providing answers to our surveys or by accepting the publication of a testimonial about Viviana Nitu Art services,

(ii) From contracts concluded with you as a representative of a contractual partner,

(iii) From public sources, or

(iv) Through the use of professional databases that you are a member of.

You may be contacted by the Company for marketing purposes, based on your consent, or we may send you marketing communications if we have obtained your personal data in the context of a negotiation or when placing an order through our website, based on our legitimate interest to present you with products and services similar to those for which you have expressed initial interest. Both at the time of placing an order and through each email message, you will have the opportunity to unsubscribe.

If you are a representative of one of the companies with which we wish to collaborate, we may collect your professional contact information either from the contracts concluded with the company you represent, or from public sources or using professional databases, when a contractual relationship has not yet been established, for the purpose of sending a marketing communication of our presentation by email and/or text messages or we can call you to present information that may be of interest to your company’s profile. In this sense, we rely on our legitimate interest, in order to develop, maintain or, where appropriate, establish business relationships. In the same sense, we can send you congratulations or various materials in the context of legal or religious holidays.

We rely on our legitimate interest to contact you, as a contact person or representative of a contractual partner, in order to answer our questions and surveys, to establish your level of satisfaction, and to ensure the permanent improvement of the products and services offered by Viviana Nitu Art. We also believe that this is a subsequent purpose to that of maintaining the best possible contractual relationship with your company and thus of constantly improving the products and services we offer you. In any case, the results of the satisfaction studies will take the form of statistics.

Also, with your consent, we process your image and testimonials to publish them on our website, for the purpose of promoting Viviana Nitu Art services and increasing confidence in their quality.

3. Data retention

If at any time you decide that you no longer want to receive marketing communications from the Company, we will respect your decision and will no longer process your personal data for this purpose.

Your personal data processed for marketing purposes will be stored for a period of 2 years, or, if you do not agree to receive commercial messages, until the withdrawal of consent, when the processing is carried out on the basis of your consent. At the end of the 2-year period, we may ask you for your consent again in order to continue sending you such messages.

With regard to the conduct of surveys, when they contain personal data, we will keep this data for the duration of the contractual relationship between us and the company you represent.

Your image and testimonial will be kept on our website for a period of 2 years from the time you gave your consent for this processing. However, if you withdraw your consent, we will remove this data from the website and delete it from our database.

In any case, we will continue to process your personal data in cases where this is necessary on the basis of legal provisions or if we are otherwise entitled to continue processing. We will also retain your personal data for an additional period of time if deleting them immediately would require overwriting our backup and disaster recovery systems.

4. Third parties

In order to carry out the marketing activities mentioned above, your personal data may be processed on our behalf by marketing agencies, courier services, market research services, as well as other similar companies, acting as authorized persons vis-à-vis the Company. With these companies, Up Romania concludes a data processing agreement that ensures the processing of your data in accordance with applicable legal provisions.

In any case, you will be informed of any other transfer of your personal data, except in the case where such a transfer or disclosure is expressly provided for by the law of the European Union or the national law, on the basis of our obligations to comply with the relevant legal provisions.

 

V. Personal data of beneficiaries of Viviana Nitu Art products

1. Personal data we process

  • Identification data;
  • Contact information;
  • CNP;
  • Username and password;
  • Workplace;
  • Number of working days;
  • Data transmitted by you in your conversations with our chatbot;
  • Phone calls.

2. How we collect personal data

We collect the personal data that your employer provides to us, necessary for the issuance of tickets, vouchers, cards or other Viviana Nitu Art products, as well as personal data necessary for the provision of additional services, depending on your employer’s option, such as notification by SMS regarding transactions made. Also, in order to ensure the assistance of the beneficiaries of our products with regard to the use of these products, we will also process any other data that you provide to us for this purpose.

3. Purposes and legal grounds for processing

The collection of your personal data is strictly limited to:

  • Issuing the Viviana Nitu Art products you benefit from;
  • Creating a user account or sending notifications regarding transactions made by you, depending on your employer’s option;
  • Assistance with the use of Viviana Nitu Art products.

Thus, we process your name, contact details, CNP, place of employment and number of working days on the basis of our legal obligation as issuers of tickets and/or vouchers, in order to carry out and manage the Viviana Nitu Art products you benefit from.

On the basis of our legitimate interest to offer you a range of additional benefits depending on your employer’s option, we may use your contact details to send you notifications regarding transactions made. In addition, we can create a user account and password for you so that you can access your balance and transactions.

Interactions with our chatbot involve the processing of personal data. Thus, we will process on the basis of your implicit consent any personal data entered by you in the conversation. Your login to the chatbot, as well as the responses provided by us by the chatbot, are based on personal data about you that we process in accordance with the other sections.

Telephone calls are recorded on the basis of our legitimate interest to document your complaint, as well as the way in which it has been handled by the Viviana Nitu Art team, for evidentiary and quality improvement purposes.

4. Data retention

Personal data will be stored as long as you benefit from the Viviana Nitu Art products, as well as for a subsequent period, if necessary, for the resolution of any complaints or requests made.

Conversations with our chatbot will be kept for a maximum period of 6 months, after which they will be deleted.

Telephone calls will be kept, as a rule, for a maximum period of one year.

In any case, we will continue to process your personal data in cases where this is necessary on the basis of legal provisions or if we are otherwise entitled to continue processing. We will also retain your personal data for an additional period of time if deleting them immediately would require overwriting our backup and disaster recovery systems.

5. Third parties

Currently, the Company does not transfer your personal data to any natural or legal person outside the Company, other than as mentioned in this Privacy Notice. However, our affiliates may have access to a range of personal data that belongs to you, for the purpose of processing payments made using Viviana Nitu Art products. In addition, the suppliers we use in the manufacture of Viviana Nitu Art products may have access to your personal data necessary to be printed on these products. Also, your data may be accessed by storage, maintenance or other similar service providers.

We have concluded a data processing agreement with these companies that ensures that your data is processed in accordance with applicable legal provisions.

In any case, you will be informed of any transfer of your personal data, except in the case where such a transfer or disclosure is expressly provided for by the law of the European Union or the national law, on the basis of our obligations to comply with the relevant legal provisions.

Security of personal data

Since the security, integrity and confidentiality of your personal data are very important, the Company will take all organizational and technical measures considered necessary in this regard.

If we discover an incident with regard to the security of personal data that presents a risk to your rights and freedoms, we will notify the National Supervisory Authority for the Processing of Personal Data (ANSPDCP) within 72 hours. You will also be personally informed about the security incident if it is of a nature to pose a high risk to your rights and freedoms.

Your rights

You have the following rights with regard to the processing of your personal data:

  • Right of access to personal data. You have the right to request access to the personal data that the Company processes.
  • Right to obtain rectification or erasure of personal data. You have the right to request rectification of inaccurate, incomplete or outdated personal data, as well as erasure of your personal data, for example, in the case where processing is not necessary or is illegal or when you withdraw your consent for the processing of those data for which you have previously consented.

You have the possibility to withdraw your consent with regard to those processing activities based on your consent, withdrawal that can be expressed at any time and which leads to the elimination of your personal data from our database as soon as possible, but not later than 30 days. With regard to those personal data collected on the basis of a legal obligation or on the basis of a legitimate interest of the Company, the withdrawal of consent does not produce any effect.

  • Right to obtain restriction of the processing of personal data. In the situations provided for by law, you may request restriction of the processing of your personal data.
  • Right to portability of your personal data. You may request the transmission, either to you, or to another data controller, of a copy of the personal data that the Company processes with regard to you, when the processing is based on your consent or on the execution of a contract that you have entered into with the Company.
  • Right to object to the processing of your personal data. You may exercise this right in relation to the personal data processed by the Company, on the basis of its legitimate interests, in the event that your rights prevail over the interests of the Company.

In addition, you have the absolute right to object to the processing carried out by the Company for direct marketing purposes.

Exercise your rights

If you consider that we have not resolved all of your requests or are dissatisfied with our answers, you may file a complaint with ANSPDCP. The supervisory authority will inform you of the status and the solution of the complaint, within a reasonable period of time.

You may also apply directly to the competent courts.

Changes to the Privacy Notice

If we decide to modify this Privacy Notice, we will publish a new version on our website, which will replace this one.

Thank you for entrusting us with your personal data and for taking the time to read our privacy notice on the processing of personal data. Please do not hesitate to contact us if you have any further questions about your personal data and how we process them.