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Privacy Policy
Effective Date: June 27, 2024
Who We Are
Through this privacy policy, THE ENGINE MARKETING S.R.L. (Sat Ucea de Jos, Comuna Ucea, No. 117 A, Str. LUNGĂ, Braşov County) aim to inform you about the personal data we collect and use (i.e., process and utilize) during your visit to our websites. Personal data refers to any information related to an identified or identifiable individual that you provide to us or that we receive or collect, such as your name, contact details (e.g., address, phone number, email address), information about your requests and professional relationship with us, participation with us, and information regarding the time, purpose, and, if applicable, location of your use of our websites and other electronic services. We collect and use personal data only as permitted by law or with your prior consent.
Processing of Personal Data
We process your personal data exclusively in accordance with legal provisions regarding personal data protection in Romania. These include the provisions of Law No. 677/2001 for the protection of individuals regarding the processing of personal data and the free movement of such data, as well as Law No. 506/2004 regarding the processing of personal data and the protection of privacy in the electronic communications sector. Our employees and agents are required to comply with data protection regulations according to legal standards.
For all requests related to your data, data protection within THE ENGINE MARKETING SRL , or any questions/complaints, please contact: gdpr@1616.ro.
Purpose of Data Processing
The purpose of data processing includes:
- Advertising, marketing, and publicity
- Website operation (account creation)
Below we inform you about the methods, volume, and purposes of personal data processing and usage.
Your Rights and How to Exercise Them
According to Law 677/2001, you have the right to access, intervene on the data, and the right not to be subject to an individual decision, as well as the right to address the justice system. You also have the right to oppose the processing of your personal data and request the deletion of the data collected by us.
Right to Information
- When personal data is obtained directly from the data subject, the operator must provide at least the following information, unless the person already has this information:
- The identity of the operator and its representative, if applicable;
- The purpose of data processing;
- Additional information such as data recipients or categories of recipients; whether the provision of all requested data is mandatory and the consequences of refusing to provide them; the existence of the rights provided by this law for the data subject, especially the right of access, intervention on the data, and opposition, as well as the conditions under which they can be exercised;
- Any other information required by the supervisory authority, considering the specific processing.
- If the data is not obtained directly from the data subject, the operator must provide the data subject with the following information at the time of data collection or, if the data is intended to be disclosed to third parties, no later than the time of the first disclosure:
- The identity of the operator and its representative, if applicable;
- The purpose of data processing;
- Additional information such as data categories, data recipients or categories of recipients, the existence of the rights provided by this law for the data subject, especially the right of access, intervention on the data, and opposition, and the conditions under which they can be exercised;
- Any other information required by the supervisory authority, considering the specific processing.
- The provisions of paragraph 2 do not apply when data processing is done exclusively for journalistic, literary, or artistic purposes if applying them would reveal the sources of information.
The provisions of paragraph 2 do not apply when data processing is done for statistical, historical, or scientific research purposes, or in other situations where providing such information is impossible or would involve disproportionate effort relative to the legitimate interest that could be harmed, as well as in cases where data recording or disclosure is expressly provided by law.
Right to Access Data
- Any data subject has the right to obtain from the operator, upon request and free of charge for one request per year, confirmation whether personal data concerning them is being processed. If the operator processes personal data about the applicant, it must communicate at least the following:
- Information on the purposes of the processing, the categories of data concerned, and the recipients or categories of recipients to whom the data is disclosed;
- Communication in an intelligible form of the data being processed and any available information about the data’s source;
- Information on the functioning principles of the mechanism through which any automated processing of data concerning the person is carried out;
- Information on the existence of the right to intervene on the data and the right to oppose, as well as the conditions under which they can be exercised;
- Information on the possibility to consult the register of personal data processing, to file a complaint to the supervisory authority, and to address the court to challenge the operator’s decisions, in accordance with this law.
- The data subject may request the information specified in paragraph 1 from the operator through a written, dated, and signed request. The request may indicate whether the information should be communicated to a specific address, which may be an electronic address, or through a correspondence service that ensures delivery only to the person.
- The operator is obliged to communicate the requested information within 15 days from the receipt of the request, respecting any option expressed by the applicant according to paragraph 2.
- In the case of personal data related to health, the request specified in paragraph 2 may be submitted by the data subject either directly or through a medical professional who will indicate in the request the person on whose behalf it is submitted. At the request of the operator or the data subject, the communication specified in paragraph 3 may be made through a medical professional designated by the data subject.
- If personal data related to health is processed for scientific research purposes and there is no apparent risk to the rights of the data subject, and the data is not used for decision-making or measures against a specific person, the communication specified in paragraph 3 may be delayed until the research is concluded. In such cases, the data subject must have given express and unequivocal consent for data processing for scientific research purposes and the possible delay of the communication specified in paragraph 3.
- The provisions of paragraph 2 do not apply when data processing is done exclusively for journalistic, literary, or artistic purposes if applying them would reveal the sources of information.
Right to Intervene with Data
- Any data subject has the right to obtain from the operator, upon request and free of charge:
- Rectification, updating, blocking, or deletion of data whose processing does not comply with the law, especially incomplete or inaccurate data.
- Conversion to anonymous data for data whose processing does not comply with the law.
- Notification to third parties who have received the data about any operations performed according to a) or b), if this notification is not impossible or does not involve a disproportionate effort relative to the legitimate interest that could be harmed.
- To exercise the right provided in paragraph 1, the data subject will submit a written, dated, and signed request to the operator. The request may indicate if the information should be communicated to a specific address, which may be an email address, or through a correspondence service that ensures delivery only to the person.
- The operator is obliged to communicate the measures taken pursuant to paragraph 1 and, if applicable, the name of the third party to whom the personal data related to the data subject was disclosed, within 15 days from the date of receiving the request, respecting the possible option expressed by the applicant according to paragraph 2.
Right to Object
- The data subject has the right to object at any time, for justified and legitimate reasons related to their particular situation, to the processing of data that concerns them, except in cases where there are legal provisions to the contrary. In case of a justified objection, the processing may no longer concern the relevant data.
- The data subject has the right to object at any time, free of charge and without any justification, to the processing of data concerning them for direct marketing purposes, in the name of the operator or a third party, or to the disclosure of such data to third parties for such purposes.
- To exercise the rights provided in paragraphs 1 and 2, the data subject will submit a written, dated, and signed request to the operator. The request may indicate if the information should be communicated to a specific address, which may be an email address, or through a correspondence service that ensures delivery only to the person.
- The operator is obliged to communicate to the data subject the measures taken pursuant to paragraphs 1 or 2, as well as, if applicable, the name of the third party to whom the personal data related to the data subject was disclosed, within 15 days from the date of receiving the request, respecting the possible option expressed by the applicant according to paragraph 3.
Exceptions
- The provisions of Articles 12, 13, 14 paragraph 3, and 15 do not apply in the case of activities provided in Article 2 paragraph 5, if their application would prejudice the effectiveness of the action or the objective pursued in fulfilling the legal duties of the public authority.
- The provisions of paragraph 1 are applicable strictly for the period necessary to achieve the objective pursued by the activities mentioned in Article 2 paragraph 5.
- After the situation justifying the application of paragraphs 1 and 2 ceases, the operators performing the activities provided in Article 2 paragraph 5 will take the necessary measures to ensure respect for the rights of the data subjects.
- Public authorities keep records of such cases and periodically inform the supervisory authority about how they are resolved.
Right Not to Be Subject to an Individual Decision
- Any person has the right to request and obtain:
- a) Withdrawal or cancellation of any decision that produces legal effects concerning them, made exclusively based on personal data processing, conducted by automatic means, intended to evaluate certain aspects of their personality, such as professional competence, credibility, behavior, or other similar aspects.
- b) Reassessment of any other decision taken concerning them, which significantly affects them, if the decision was made exclusively based on data processing meeting the conditions set out in a).
- Respecting the other guarantees provided by this law, a person may be subject to a decision of the nature referred to in paragraph 1 only in the following situations:
- a) The decision is made in the course of concluding or executing a contract, provided that the request for concluding or executing the contract, made by the data subject, has been satisfied or that some appropriate measures, such as the possibility of expressing their point of view, guarantee the defense of their legitimate interest.
- b) The decision is authorized by a law that specifies measures guaranteeing the defense of the legitimate interest of the data subject.
Right to Appeal to Justice
- Without prejudice to the possibility of filing a complaint with the supervisory authority, data subjects have the right to appeal to the justice system for defending any rights guaranteed by this law that have been violated.
- Any person who has suffered damage as a result of illegal personal data processing can appeal to the competent court for redress.
- The competent court is the one in whose territorial jurisdiction the claimant resides. The legal action is exempt from stamp duty.
Contact
To exercise the above-mentioned rights to revoke, inform, delete, or correct your data, please send a written request via email to gdpr@1616.ro.
Data Stored by THE ENGINE MARKETING SRL
1.1 Storage and Processing of Non-Personal (Anonymous) Data for Internal System and Statistical Purposes
When accessing our website, your internet browser automatically transmits data (e.g., date and time of access, URL of the referring website, accessed file, amount of data transmitted, browser type and version, operating system) to our server based on technical settings. These data are collected and used exclusively for statistical and analysis purposes, such as improving our offerings. Certain traffic data (such as IP addresses or other identifiers of the devices you use to access our site) may be considered personal data under certain circumstances and will be treated as such.
1.2 Storage and Processing of Personal Data
1.2.1 Data for the Newsletter Service
When registering for our newsletter service, your data is used by THE ENGINE MARKETING SRL for promotional and marketing purposes. The use ceases as soon as you unsubscribe from the newsletter. You can unsubscribe from the newsletter at any time.
1.2.2 Use of Cookies
Cookies are small text files saved by your internet browser that serve to make our website overall more user-friendly, efficient, and secure. Cookies do not damage your computer and do not contain viruses. You can prevent the installation of cookies by appropriately setting your browser.
Our online site contains cookies that save your chosen settings and are used for statistical purposes. We inform you that by preventing the installation of cookies, you may not be able to use all the functions of our website.
We use cookies to personalize content and ads, provide social media features, and analyze traffic. We also share information about how you use our site with our social media, advertising, and analytics partners, who may combine it with other information you’ve provided or that they’ve collected from your use of their services.
For information or requests based on data subject rights under GDPR, you can contact the Data Protection Officer at gdpr@1616.ro or access the page where you can express your consent regarding each specific cookie file.
1.2.2.1 Cookies are categorized as follows:
Internal Cookies
Visiting this site may place cookies for purposes such as:
- Essential Cookies: Necessary for the operation of the site. We may use essential cookies to authenticate users, prevent fraudulent use of user accounts, or provide specific site features.
- Traffic Measurement Cookies: Allow us to recognize and count the number of visitors and see how visitors move around the site when using it. This helps us improve the way the site works.
- Functionality Cookies: Used to recognize you when you return to the site. This allows us to personalize our content for you, greet you by name, and remember your preferences (e.g., choice of language or region).
- Targeting Cookies: Record your visit to the site, the pages you have visited, and the links you have clicked. We will use this information to make the site more relevant to your interests. These information may also be shared with third parties for the same purpose.
Third-party (Third-Party) Cookies
In addition to our own cookies, we may also use third-party cookies to report usage statistics of the site and improve marketing efforts.
- Tracking Cookies: Track behavior on the site and connect it to other metrics to better understand usage habits.
- Optimization Cookies: Allow real-time tracking of user conversion from various marketing channels to assess their effectiveness.
- Partner Cookies: Provide our partners with conversion metrics to optimize their paid marketing efforts.
Update or Deletion of Your Personal Data
You have certain rights concerning your personal information. You can access your personal information, ensure it remains accurate, update it, or choose whether to receive materials from us or some of our partners.
If you want more information about your rights or wish to exercise any of the above rights, you can contact us via gdpr@1616.ro. Exercising your rights mentioned above is free of charge. If you live or are in the European Economic Area (EEA), you have the right to request:
- Access: To be provided with access to any personal identifiable information that we hold about you.
- Prevention of Processing for Direct Marketing: To prevent the processing of your personal information for direct marketing purposes.
- Update: To update any outdated or incorrect personal identifiable information we hold.
- Deletion: To delete all personal identifiable information we hold about you.
- Restriction: To restrict the way we process your identifiable personal information.
- Transfer to Third-Party: To provide your personal identifiable information to a third-party service provider.
- Copy: To provide a copy of any identifiable personal information we have about you.
We strive to respond to each email promptly and to provide our response within the time frame set by applicable law. However, please note that there will be residual information that will remain in our databases, access logs, and other records, which may or may not contain personal information. Also, certain identifiable personal information may be exempt from such requests in certain circumstances, which may include the need to continue processing your personal information to comply with a legal obligation.
When you send us an email with a request, we may ask you to provide necessary information to confirm your identity.
When Do Third Parties Have Access to Your Data?
- Transmission to Public Authorities
In special cases, we may be required to provide information about personal data to competent authorities (e.g., in the case of a court order) as necessary for criminal investigation, public safety, fulfilling legal duties of intelligence services or military counterintelligence, or for the enforcement of intellectual property rights.
- Social Network Plugins
Our website uses plugins from social network operators (e.g., www.facebook.com). All social network plugins on our website are clearly marked. When you access our web pages containing a social network plugin, your browser establishes a direct connection to the server of the social network operator. The content of the plugin is transmitted directly to your browser and integrated into the website. Through the integration of the plugin, the social network operator receives the information that you have accessed our site. If you are logged into a social network during your visit to our website, the visit can be attributed to your user account. If you interact with the plugin, the corresponding information is transmitted to the social network operator and saved there. If you want to prevent the collection of your data by the social network operator through our website, you must log out of the social network before visiting our website.
You can also opt-out of data transmission to each type of plugin from our site through the Cookie Usage Policy page.
For information on the purpose and scope of data storage, further processing, use, and your rights, as well as setting options, please refer to the social network operator’s data protection statements, which are independent of this data protection declaration. For Facebook, these directives can be found at http://www.facebook.com/policy.php.
THE ENGINE MARKETING SRL does not assume responsibility for the data protection guidelines and procedures of partner websites.
- Web Analysis Service Google Analytics
Our website uses the “Google Analytics” web analysis service of Google Inc. for statistical purposes. This web analysis service uses so-called “cookies” (see above under Use of Cookies). Cookies generate only anonymous information about the use of our website. This information is transmitted to a server of Google Inc. in an EU member state or outside the EU (e.g., in the USA) and stored there. Google Inc. provides adequate data protection in the USA through participation in the Privacy Shield project – see details at https://www.privacyshield.gov/participant?id=a2zt0000000GnaNAAS.
Google Inc. may transfer information to third parties if required by law or if third parties process these data on behalf of Google Inc. Neither we nor Google Inc. will connect your IP address with other data saved by Google Inc. or us.
THE ENGINE MARKETING SRL does not assume responsibility for the data protection guidelines and procedures of partner websites.
- CXENSE Web Analytics Service
Our website uses the “Cxense” web analytics service provided by Cxense ASA, Norway, for statistical purposes and to tailor our offerings based on user preferences. This web analytics service uses “cookies” (see above under Use of Cookies) to generate only anonymous information about the usage of our website. This information is transmitted to and stored on servers operated by Cxense ASA, Norway, in an EU member state.
Cxense ASA, Norway, may eventually transmit this information to third parties as required by law or if third parties process this data on behalf of Cxense ASA, Norway. Neither we nor Cxense ASA, Norway, will connect your IP address with other data saved by Cxense ASA, Norway, or us.
THE ENGINE MARKETING SRL . does not assume responsibility for the data protection guidelines and procedures of partner websites.
- Enreach Online Advertising Service
Our website uses the “Enreach” online advertising service provided by Cxense ASA, Norway, for statistical purposes and to tailor our offerings based on user preferences. This online advertising service uses “cookies” (see above under Use of Cookies) to generate only anonymous information about the usage of our website. This information is transmitted to and stored on servers operated by Cxense ASA, Norway, in an EU member state.
Cxense ASA, Norway, may eventually transmit this information to third parties as required by law or if third parties process this data on behalf of Cxense ASA, Norway. Neither we nor Cxense ASA, Norway, will connect your IP address with other data saved by Cxense ASA, Norway, or us.
THE ENGINE MARKETING SRL . does not assume responsibility for the data protection guidelines and procedures of partner websites.
- Google AdSense Online Advertising Service
Our website uses the “Google AdSense” online advertising service provided by Google Inc. to serve online ads. This ad-serving service uses “cookies” (see above under Use of Cookies) to generate information about the usage of our website. This information is transmitted to and stored on servers operated by Google Inc., in an EU member state or outside the EU (e.g., in the USA).
Google Inc. provides adequate data protection in the USA through participation in the Privacy Shield project – see details at https://www.privacyshield.gov/participant?id=a2zt0000000GnaNAAS.
Google Inc. may eventually transmit this information to third parties as required by law or if third parties process this data on behalf of Google Inc. Neither we nor Google Inc. will connect your IP address with other data saved by Google Inc. or us.
THE ENGINE MARKETING SRL . does not assume responsibility for the data protection guidelines and procedures of partner websites.
To manage whether you want to allow cookies to be sent to Google AdSense, you can access the page where you can give your consent for each cookie file separately. Please note that blocking cookies to Google may have various implications unrelated to our site (e.g., when you click on an ad from the Google.ro search engine to reach our site, Google.ro may not allow the site to load).
Refusing or disabling cookies does not mean that you will no longer receive online advertising – it simply means that such advertising will no longer be tailored to your preferences and interests as indicated by your browsing behavior.
- Google DoubleClick Online Advertising Service
Our website uses the “Google DoubleClick” online advertising service provided by Google Inc. to serve online ads. This ad-serving service uses “cookies” (see above under Use of Cookies) to generate information about the usage of our website. This information is transmitted to and stored on servers operated by Google Inc., in an EU member state or outside the EU (e.g., in the USA).
Google Inc. provides adequate data protection in the USA through participation in the Privacy Shield project – see details at https://www.privacyshield.gov/participant?id=a2zt0000000GnaNAAS.
Google Inc. may eventually transmit this information to third parties as required by law or if third parties process this data on behalf of Google Inc. Neither we nor Google Inc. will connect your IP address with other data saved by Google Inc. or us.
THE ENGINE MARKETING SRL . does not assume responsibility for the data protection guidelines and procedures of partner websites.
To manage whether you want to allow cookies to be sent to Google DoubleClick, you can access the page where you can give your consent for each cookie file separately. Please note that blocking cookies to Google may have various implications unrelated to our site (e.g., when you click on an ad from the Google.ro search engine to reach our site, Google.ro may not allow the site to load).
Refusing or disabling cookies does not mean that you will no longer receive online advertising – it simply means that such advertising will no longer be tailored to your preferences and interests as indicated by your browsing behavior.
- Gemius AdOcean Online Advertising Service
Our website uses the “Gemius” online advertising service provided by Gemius. to serve online ads. This ad-serving service uses “cookies” (see above under Use of Cookies) to generate information about the usage of our website. This information is transmitted to and stored on servers operated by Gemius in an EU member state.
Gemius may eventually transmit this information to third parties as required by law or if third parties process this data on behalf of Gemius. THE ENGINE MARKETING SRL . does not assume responsibility for the data protection guidelines and procedures of partner websites.
To manage whether you want to allow cookies to be sent to Gemius, you can access the page where you can give your consent for each cookie file separately.
Refusing or disabling cookies does not mean that you will no longer receive online advertising – it simply means that such advertising will no longer be tailored to your preferences and interests as indicated by your browsing behavior.
- Zontera Online Advertising Service
Our website uses the “Zontera” online advertising service provided by Zontera to serve online ads. This ad-serving service uses “cookies” (see above under Use of Cookies) to generate information about the usage of our website. This information is transmitted to and stored on servers operated by Zontera in an EU member state.
Zontera may eventually transmit this information to third parties as required by law or if third parties process this data on behalf of Zontera. THE ENGINE MARKETING SRL . does not assume responsibility for the data protection guidelines and procedures of partner websites.
To manage whether you want to allow cookies to be sent to Zontera, you can access the page where you can give your consent for each cookie file separately.
Refusing or disabling cookies does not mean that you will no longer receive online advertising – it simply means that such advertising will no longer be tailored to your preferences and interests as indicated by your browsing behavior.
Data Security
Our website and other information systems are protected by technical and organizational measures against unauthorized access, alteration, or dissemination of your data, as well as against loss or destruction of your data.
It is necessary to treat your access data with confidentiality at all times and to close the browser window when you finish visiting our website.
For the transfer of personal data, we use technical encryption procedures. You can identify encrypted data transmission (https) by the display of a closed symbol, such as a key or padlock icon in your browser’s status bar.
Questions, Suggestions, and Complaints?
Do you have questions regarding data protection, cookie policy, or our website? No problem, we are happy to assist.