1. Introduction

We treat the confidentiality of personal data seriously and responsibly, and its security is a priority for us. That is why we are committed to complying with the rules set out in European Regulation no. 2016/679 (the “Regulation”) on the processing of personal data and the free movement of such data.

Through this policy we explain what personal data we process, how we collect it, how we use it and, above all, how we protect it.

We also inform you about the rights you have and guide you on how to exercise them.

2. About us

Our registered office is located at Romania, Alba County, Drambar, 28 Calea Alba Iulia, postal code 517241, Tax ID (CUI) 11319570, Trade Register no. J1998000542013.

The legal representative of the company can be contacted at Romania, Alba County, Drambar, 28 Calea Alba Iulia, postal code 517241 and at the e-mail address: [email protected].

Under EU Regulation 679/2016, TOBIMAR SRL is a personal data controller and has appointed a person responsible for data protection, who can be contacted at:

• E-mail address: [email protected];
• Our postal address is: Romania, Alba County, Drambar, 28 Calea Alba Iulia, postal code 517241, for the attention of the PERSON RESPONSIBLE FOR PERSONAL DATA.

3. What data we collect and how we collect it

Contact form

Available on the page: https://www.tobimar.ro/en/contact/.

We use your personal data in order to take up your enquiry, so that we have all the information needed to contact you and reply to you. Data collected:

• Last name;
• First name;
• Phone number;
• E-mail address;
• The message and the details of your enquiry.

Newsletter subscription form

Available in: the website footer, on all pages.

If you subscribe to our newsletter, we collect your e-mail address in order to send you news and information about our activity and services. Processing is based on your consent, and you may unsubscribe at any time.

• E-mail address.

Provision of contracted services

If you become our client and we conclude a contract, in order to perform it we also collect:

• Company details (name, tax ID, Trade Register number, registered office address, bank account), for corporate clients;
• The details of the technical and administrative contact persons within your company;
• The documents and technical information required to carry out the order or project;
• The data required for invoicing, delivery and commercial correspondence throughout the collaboration.

Automatic data capture

Automatic data capture takes place through:

• cookie technology: a cookie is a small piece of information sent from a web page and saved by your browser on your device, which we can access later. It stores information a website needs in order to personalise your browsing session, such as previously visited pages or display preferences.

The most common types of cookies are:

• Technical: absolutely necessary to ensure the technical efficiency of the website;
• Functional: they remember your choices and help us improve your experience on our website;
• Performance: they help us measure the performance of the website using information about how visitors navigate it;
• Targeting: they help us place advertisements on other websites you use;
• Social media plug-ins: to connect our visitors to various social media channels.

We collect and process the data provided by cookie technology only if you allow us to do so.

Standard web server log files provide us with statistical information on the number of visitors and allow us to assess the technical capacity of our website. Through them we collect some information relating to the IP address, but this is not capable of identifying you directly; it only provides us with statistical data about traffic on the website.

Google Analytics

Our website uses the web analytics service “Google Analytics” provided by Google Inc., for statistical purposes. The information generated by the cookie about your use of the website will be transmitted to and stored on Google’s servers.

Where IP anonymisation is enabled, your IP address will be truncated within the territory of the Member States of the European Union or of other parties to the Agreement on the European Economic Area. Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website and compiling reports on website activity.

You may refuse the use of cookies by selecting the appropriate settings in your browser; however, in that case you may not be able to use all the features of the website. You may also opt out of Google Analytics in the future by downloading and installing the Google Analytics Opt-out Browser Add-on for your browser: https://tools.google.com/dlpage/gaoptout?hl=en.

Advertising tools and social networks

In order to measure the effectiveness of our communication and to present you with relevant content, the website also uses the following technologies provided by third parties:

• Meta Pixel (Facebook) – helps us measure the results of our campaigns on Facebook and Instagram and display relevant content to people interested in our activity;
• LinkedIn Insight Tag – gives us information about how visitors reach the website from LinkedIn and allows us to measure the effectiveness of our professional communication;
• Google Tag Manager – centrally manages the scripts listed above.

To give or withdraw your consent regarding automated processing through the programs or technologies mentioned above, set this option in the welcome message you receive when accessing the website, or make the appropriate settings in your browser. For more details, see our cookie policy. If you choose to browse without these technologies, some functions or features of the website may not work. If you accept the full use of automatic capture programs and technologies, we will collect the following data:

• identity data: last name, first name;
• contact data: e-mail address, phone;
• technical data: connection data, including IP, operating system and platform, browser identification, location, technologies used on the devices from which the website is accessed;
• usage data: of the website and of our services.

4. Purpose of collection and legal basis

We collect information containing personal data mainly for:

To the extent that we use the information held for purposes other than those declared above, we will expressly ask for your consent and explain what new rights you have in that situation.

5. Inability or refusal to provide certain personal data

If you do not provide us with the requested information, it is very likely that we will not be able to take up and process your enquiry, which would prevent us from replying to you or providing you with our services.

6. Recipients

Your data is used by TOBIMAR SRL (tobimar.ro) and we will never share your personal information with a third party for purposes other than those described in this Policy.

We may transmit your personal information to our trusted partners, who are able to provide guarantees regarding the security and confidentiality of your data and who process the data only in accordance with our instructions.

Our partners are generally third-party service providers we work with, active in areas such as: web hosting and database services, behavioural analytics services (Google Analytics), advertising platforms (Meta, LinkedIn), the agency that administers the website, accounting and taxation, legal consultancy and assistance, suppliers and partners involved in fulfilling orders, transport and logistics services, or public authorities.

7. Place of storage

Both the website and the physical and electronic database containing personal information are hosted and stored on secure servers in Romania and the European Union.

To the extent that we transfer certain personal data to entities located within the European Union or outside it, including to countries for which the European Commission has not recognised an adequate level of personal data protection, we will take measures to protect your rights and interests.

Transfers will be protected by the standard contractual clauses approved by the European Commission or by other appropriate safeguards provided for by the GDPR.

8. Security measures

Although your data is collected online, some of it is also stored on paper (e.g. contracts, invoices, commercial documents).

TOBIMAR SRL (tobimar.ro) is particularly and constantly concerned with implementing effective security measures to protect your personal data and to prevent security breaches, both for information stored online and for information held physically.

Regardless of the storage method, your data is kept in secure environments protected against unauthorised access, use, disclosure, alteration or destruction.

We have also implemented specific measures for network and data transfer security, infrastructure auditing and testing, trained staff, and data transfers outside Romania carried out only to entities able to ensure a similar level of protection.

9. Storage period

Where we process your data for the performance of pre-contractual or contractual obligations, we will store the data for as long as necessary to perform the contract and for an additional subsequent period.

Where we process your data under a legal obligation or in the public interest, we will store the data for as long as necessary to comply with the legal obligations or for as long as the interest is qualified as being of public utility.

Where we process your data to protect our legitimate business interests, we will store the data until you ask us to stop, unless we can demonstrate that the reason for which we collect and store it overrides your interests, rights and freedoms.

Where we process your data on the basis of your express consent, we will store the data until you ask us to stop.

• Data associated with contracts, orders and invoices: 10 years, in accordance with Accounting Law no. 82/1991.
• Data collected through the contact form: 24 months from the last interaction.
• Data collected through the newsletter subscription: until you unsubscribe or withdraw your consent.
• Data collected through cookies: according to the duration of each cookie, as described in the cookie policy.

10. Automated decision-making

TOBIMAR SRL (tobimar.ro) does not use automated processes capable of producing legal effects concerning you or of significantly affecting you.

You may request at any time not to be subject to a decision based solely on automated processing, if that decision produces legal effects concerning you or similarly significantly affects you.

You cannot benefit from this option if the decision taken as a result of automated data processing is necessary for us to enter into or perform a contract, or if it is permitted by law and appropriate safeguards for your rights and freedoms exist.

If you have given us your consent regarding automated processing and later change your mind, you may withdraw that consent at any time by submitting a written request to us.

11. Your rights

1. The right to be informed – you have the right to know whether your personal data is processed, what data is collected, where it is obtained from and why, by whom it is processed, for what period, and whether that data is subject to automated processing capable of producing legal effects or of significantly affecting you.
2. The right of access – you have the right to access, free of charge and at reasonable intervals, the data collected from you or about you. This includes your right to request and obtain a copy of the personal data collected.
3. The right to rectification – you have the right to request the rectification or updating of your personal data where it is inaccurate or incomplete.
4. The right to erasure – where you have withdrawn your consent, you object to the processing, the processing does not comply with the provisions of the Regulation, or it is no longer necessary for the purposes for which the data was collected and processed, you may request that your personal data be deleted from our records.
5. The right to restrict processing – where certain conditions apply, you have the right to restrict the processing of your personal data.
6. The right to object – in certain cases you have the right to object to the processing of your personal data, for example in the case of direct marketing.
7. The right to object in relation to automated processing – where your personal data is subject to automated processing, including profiling, which may produce legal effects or significantly affect you, you are entitled to ask us to exclude your data from any automated individual decision-making process.
8. The right to data portability – you have the right to obtain your personal data in a suitable format or, where possible, by direct transfer from one processor to another.
9. The right to assistance from the supervisory authority – you have the right to seek the assistance of a supervisory authority and the right to other remedies, such as claiming damages.
10. The right to withdraw consent – you have the right to withdraw your consent at any time. Withdrawing consent does not affect the lawfulness of processing carried out before its withdrawal.
11. The right to lodge a complaint – if you wish to raise a complaint about the way we process your personal data, please contact us:
    • E-mail address: [email protected];
    • Our postal address is: Romania, Alba County, Drambar, 28 Calea Alba Iulia, postal code 517241, for the attention of the PERSON RESPONSIBLE FOR PERSONAL DATA.

We assure you that all your complaints and notifications will be handled seriously, professionally and in full confidentiality.

If you are nevertheless dissatisfied with the way we have responded to your complaints, you may address the authorities that supervise our activity in relation to personal data.

In Romania, this authority is the National Supervisory Authority for Personal Data Processing (ANSPDCP), whose contact details are: