PIA Digital Services
The responsible body is:
PIA Digital Services SRL p/a
87-99, Soseaua Oltenitei, Etaj 2,
Sector 4, Bucharest, Romania,
Chamber of Commerce No. J40/13558/2019
The data protection declaration of the PIA-DS is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and undermbandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used. In this data protection declaration, we use, inter alia, the following terms:
a) Personal data
Personal data 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 the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated 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.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
j) Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
1. Collection and Use of Data
This Policy describes the types of information we may collect from you or that you may provide when you visit our Site or use our Services, and describes our practices for collecting, using, maintaining, protecting and disclosing that information.
This Policy applies to information we collect:
- On our Site;
- In e-mail, text and other electronic messages between you and us;
- When you use our Services.
This Policy does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by any third party;
- Any third party, including through any application, product, service or content (including advertising) that may link to or be accessible from the Site or via the Services.
Personal data will be exclusively used by PIA-DS and only given to other companies who have complied with the terms you have agreed to. Furthermore, your data will not be transferred, sold, exchanged or given to third parties without your consent, except as expressly provided by this Policy, including requests by a court or other governmental body.
You can revoke your consent at any time by sending an email email@example.com.
PIA-DS is using information that we collect about you or that you provide to us, including any personal data:
- To provide you with information, products or services that you request from us;
- To present the Site, its content and our Services correctly to you;
- To fulfill any other purpose for which you provide it, such as sending you e-mails, news or alerts;
- To evaluate an application to use our Services;
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing, payment and collection;
- To notify you about changes to our Site or our Services;
- To help us carry out analyses of usage patterns of our Site and Services in order to continually better our services, to develop new services and to improve and personalize user experiences, understand customer interest and market trends;
- To contact you about our Services that may be of interest to you;
- To respond to inquiries, send notices and provide customer support;
- For any other purpose with your consent;
- For audits, regulatory purposes, such as providing law enforcement authorities with the information necessary for criminal prosecution, e.g. in case of a cyber-attack.
2. Children Under the Age of 16
Our Site and Services are not intended for children under 16 years of age. No one under age 16 may provide any information to us. We do not knowingly collect information from children under 16. If you are under 16, do not use or provide any information on our Site or on or through any of its features/register on the Site, use any of the interactive or public comment features of this Site or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact via e-mail at firstname.lastname@example.org.
3. Information We Collect About You, that You Provide, and How We Collect It
We collect several types of information from and about users of our Site or Services, including information:
- By which you may be personally identified, such as name, postal address, e-mail address, telephone number or any other identifier by which you may be contacted online or offline (“personal information”); and/or
- About your internet connection, the equipment you use to access our Site or Services and their usage details.
We collect this information:
- Directly from you when you provide information to us, such as:
- Through filling in forms on our Site;
- Records and copies of your correspondence with us;
- Details of transactions you carry out through our Site;
- Details of Site searches and button clicks are also recorded.
- Automatically as you navigate through the Site or use our Services we may use automatic app monitor technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Information about your computer and Internet connection, including your IP address, operating system and browser type;
- Details about your visits to our Site and use of our Services, including traffic data, location data, logs and other communication data and the resources that you access and use on the Site and from the Services.
- From third parties, for example, our business partners.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Site, or transmitted to other users of the Site or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
We ask that you not send us, and you not disclose, any sensitive personal data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, sexual orientation, criminal background or membership in past organizations, including trade union memberships) on or through the Services or the Site or otherwise to us.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt-out of receiving targeted advertising, see: “Choices About How We Use and Disclose Your Information”.
5. Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal data that we collect or you provide as described in this Policy:
- To our affiliates and partners for the sole purpose of providing our Services;
- To contractors, service providers and other third parties we use to support our business;
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some, or all, of PIA-DS’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by PIA-DS about our Site and Services users is among the assets transferred;
- To fulfil the purpose for which you provide it;
- For any other purpose disclosed by us when you provide the information;
- With your consent.
We may also disclose your personal data:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request;
- To enforce or apply our General Terms and Conditions and other agreements, including for billing and collection purposes;
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of adjust, our customers or others.
6. Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your information:
- Opt-out. You may “opt-out” of receiving emails from us by following the instructions in those emails. If you opt-out, we may still send you non-promotional e-mails, such as e-mails about your account;
- We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
7. How we protect Your Data
PIA-DS uses industry standard security measures to protect the information under our control, including firewalls and other security measures. Although the inherent dangers of the Internet mean we cannot guarantee the protection of your (personal) data against loss, misuse, or alteration, PIA-DS takes steps to protect your (personal) data.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site or Services, you are responsible for keeping this password confidential. We ask you not to share your password(s) with anyone.
Transfer between entities: We may transfer user and customer information to our affiliates and to third party providers for the sole purpose of providing our Services. By using any of the Services or providing us you’re your data you consent such transfers.
8. Data Retention
We will retain your information for as long as your account is active or as needed to provide you our services. If you wish to cancel your account or request that we no longer use your information to provide you services, then contact us at email@example.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
9. Jurisdiction and Cross-Border Transfer
Our Services are global and data (including personal data) may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer data to countries outside of your country of residence, which may have data protection rules that are different from those of your country. By using any of the Services or providing us you’re your data you consent such transfers. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your data remains protected to the standards described in this Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal data.
10. Access to Your Data
We have no direct relationship with our customers’ users whose information we may process. A user of a customer’s app or services, who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to our customer directly as they are the body collecting the data and therefore the data controller. If a user wishes us to remove the collected information stored with us (if any) please send us an e-mail to firstname.lastname@example.org and we will get back to you as soon as possible.
11. Routine erasure and blocking of Personal Data
We shall process and store your personal data only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
12. Rights of the Data Subject
a) Right of confirmation
Each data subject (you) shall have the right granted by the European legislator to obtain from us the confirmation as to whether or not personal data concerning you is being processed. If you wish to avail yourself of this right of confirmation, you may, at any time, contact us.
b) Right of access
You have the right granted by the European legislator to obtain from us free information about your personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grants you access to the following information:
- the purposes of the processing; o the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations. Where this is the case, you shall have the right to be informed of the appropriate safeguards relating to the transfer;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from PIA-DS rectification or erasure of personal data, or restriction of processing of personal data concerning you, or to object to such processing;
- the existence of the right to lodge a complaint with us;
- where the personal data are not collected from you directly, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
c) Right to rectification
You shall have the right granted by the European legislator to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If you wish to exercise this right to rectification, you may, at any time, contact us through our contact details.
d) Right to erasure (Right to be forgotten)
You have the right granted by the European legislator to obtain from us the erasure of personal data concerning you without undue delay, and we shall have the obligation to erase your personal data without undue delay where one of the following grounds applies: o The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- You withdraw consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
- You object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed. o The personal data must be erased for compliance with a legal obligation in the European Union or Member State law to which PIA-DS is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR (i.e. a child younger than 13 years old).
If one of the aforementioned reasons applies, and you wish to request the erasure of personal data stored by PIA-DS, you may at any time contact us. We shall promptly ensure that the erasure request is complied with full in accordance with the GDPR regulations.
Where PIA-DS has made personal data public and is obliged pursuant to Article 17(1) to erase the Personal data, PIA-DS, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. We will arrange the necessary measures in individual cases.
e) Right of restriction of processing
You have the right granted by the European legislator to obtain from PIA-DS restriction of processing where one of the following applies: o The accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the Personal data.
- The processing is not lawfull and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
- The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the PIA-DS, he or she may at any time contact us. We will arrange the restriction of the processing.
f) Right to data portability
You have the right, granted by the European legislator, to receive the personal data concerning yourself, which was provided to PIA-DS, in a structured, commonly used and machine-readable format. You have the right to transmit those data to any other controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, you have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, you may at any time contact us through our contact details.
g) Right to object
You have the right granted by the European legislator to object, on grounds relating to your particular situation, at any time, to processing of personal data concerning yourself, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
PIA-DS shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If PIA-DS processes personal data for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If you object to PIA-DS to the processing for direct marketing purposes, we will no longer process your personal data for these purposes.
In addition, you have the right, on grounds relating to your particular situation, to object to processing of personal data concerning yourself by PIA-DS for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, you may directly contact us. In addition, you are free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to your right to object by automated means using technical specifications on the Site.
h) Automated individual decision-making, including profiling
You have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between you and PIA-DS, or (2) is not authorised by the European Union or Member State law to which PIA-DS is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or (3) is not based on your explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between you and PIADS, or (2) it is based on your explicit consent, PIA-DS shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of PIA-DS, to express your point of view and contest the decision.
If you wish to exercise the rights concerning automated individual decision-making, you may at any time directly contact us.
i)Right to withdraw data protection consent
You have the right granted by the European legislator to withdraw your consent to processing your personal data at any time. If you wish to exercise the right to withdraw the consent, you may at any time directly contact us.
13. Data protection for applications and the application procedure
PIA-DS shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the Site. If PIA-DS concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by PIA-DS, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of PIA-DS are opposed to the erasure. Other legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act.
14. Links to Other Websites and Third Parties
PIA-DS’s Services may contain links or references to third-party owned or operated websites or online services. PIA-DS is not responsible for the collection of (personal) data or the security or privacy of such data on any such third party’s sites or services.
Likewise, PIA-DS is not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any personal data you disclose to such other entities through or in connection with our Site, Services, and other (mobile) interactive features.
This section provides more information on some of the third parties and PIA-DS’s cooperation with them.
a) Data protection provisions about the application and use of LinkedIn
PIA-DS has integrated components of the LinkedIn Corporation on their website (Site). LinkedIn is a webbased social network that enables users with existing business contacts to connect and to make new business contacts.
With each call-up to one of the individual pages of our Site, which is operated by PIA-DS and on which a LinkedIn component (LinkedIn plug-in) was integrated, the Internet browser on the information technology system of you is automatically prompted to the download of a display of the corresponding LinkedIn component of LinkedIn. Further information about the LinkedIn plug-in may be accessed under https://developer.linkedin.com/plugins. During the course of this technical procedure, LinkedIn gains knowledge of what specific sub-page of our website was visited by you.
If you are logged in at the same time on LinkedIn, LinkedIn detects with every call-up to our website by you—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page you visited. This information is collected through the LinkedIn component and associated with the respective LinkedIn account of you. If you click on one of the LinkedIn buttons integrated on our Site, then LinkedIn assigns this information to the personal LinkedIn user account of you (in case you have a LinkedIn account) and stores your personal data.
LinkedIn receives information via the LinkedIn component that you visited our Site, provided that you are logged in at LinkedIn at the time of the call-up to our website. This occurs regardless of whether you click on the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable for you, then you may prevent this by logging off from your LinkedIn account before a call-up to our Site is made.
b) Data protection provisions about the application and use of Facebook
This website uses social plugins (“plugins”) from the social network facebook.com which is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). The plugins are identified by one of the Facebook logos or the amendment “Facebook social plugin”.
If you are a Facebook member and do not want Facebook to collect data on you via our website and to combine such data with your Facebook membership data, you need to log off from Facebook before accessing our website. Furthermore, you may also block social plugins by downloading and installing add-ons for your browser, such as the Facebook blocker: http://webgraph.com/resources/facebookblocker/
c) Data protection provisions about the application and use of Twitter
PIA-DS has integrated components of Twitter on their Site. Twitter is a multilingual, publicly-accessible microblogging service on which users may publish and spread so-called ‘tweets,’ e.g. short messages, which are limited to 140 characters. These short messages are available for everyone, including those who are not logged on to Twitter. The tweets are also displayed to so-called followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter allows you to address a wide audience via hashtags, links or retweets.
The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, UNITED STATES.
With each call-up to one of the individual pages of our Site, which is operated by PIA-DS and on which a Twitter component (Twitter button) was integrated, the Internet browser on the information technology system of you is automatically prompted to download a display of the corresponding Twitter component of Twitter. Further information about the Twitter buttons is available under
https://about.twitter.com/de/resources/buttons. During the course of this technical procedure, Twitter gains knowledge of what specific sub-page of our Site was visited by you. The purpose of the integration of the Twitter component is a retransmission of the contents of our Site to allow our users to introduce this web page to the digital world and increase our visitor numbers.
Twitter receives information via the Twitter component that you visited our Site, provided that you are logged in on Twitter at the time of the call-up to our Site. This occurs regardless of whether you click on the Twitter component or not. This information is collected through the Twitter component and associated with the respective Twitter account of you (if you have a Twitter account). If you click on one of the Twitter buttons integrated on our Site, then Twitter assigns this information to the personal Twitter user account of you and stores your personal data. If such a transmission of information to Twitter is not desirable for you, then you may prevent this by logging off from your Twitter account before a call-up to our Site is made.
15. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
16. Third party sites
In general, the Services and the Site access third party information (such as your PayPal account information) through interfaces. We may provide links to third-party Web sites or services, such as PayPal, as a service to our users. When you click on links of third parties, you may leave the Services or the Site. We are not responsible for the privacy practices of Web sites operated by third parties, whether they are linked to or otherwise accessible from our Services or the Site. The inclusion of a link or accessibility of third party Websites does not imply endorsement of such third-party Website by us.
17. Users with whom you share your information
We cannot control the actions of other users with whom you share your information. We cannot, and do not, control the information you share with other Users using the Services or the Site (including via Forums) or how such other users will use or share such information. We are not responsible for third party circumvention of our security measures.
If you do not agree to any modifications to this Policy, your sole recourse is to immediately stop all use of the Services and the Site. Your continued use of the Services or the Site following the posting of any modifications to this Policy will constitute your acceptance of the revised Policy. Please note that none of our employees or agents has the authority to vary any of our Policies.
If you have any questions or comments about this Policy or our privacy practices, or to report any violations of the Policy or abuse of the Services or the Site, please contact us at email@example.com.
We consider it important to repeat that your consent in relation to the collection and saving of your personal data by PIA-DS can be revoked at any time by sending an email to firstname.lastname@example.org.
Our contact details:
PIA Digital Services SRL
87-99, Soseaua Oltenitei, Etaj 2, Sector 4, Bucharest