PRIVACY POLICY of AMUSNET ROMANIA
1. About the Privacy Policy
1.1. AMUSNET ROMANIA S.R.L., a company incorporated in Republic of Romania, registered within the Romanian Trade Registrar under number J40/5312/2023, with registered address at Romania, Bucharest, 1st District, Calea Floreasca, No. 165, Cladirea One Tower, 5th Floor, Office 5.03, e-mail: [email protected] (hereinafter referred to as the “Amusnet Romania”, “Company”, “we”, “our”, “us”) is a data controller and as a data controller complies with the rules and requirements of the Dutch and European legislation on personal data protection.
1.2. The present Privacy Policy aims to inform you about how Amusnet Romania processes the personal data related to the persons specified below, for what purposes Amusnet Romania collects and processes personal data, what are the grounds for processing personal data, the term of processing personal data, what are the rights of data subjects in relation to this processing, as well as other information aimed at ensuring transparent and conscientious processing of personal data by Amusnet Romania.
1.3. With respect to the processing of personal data relating to individuals who apply for employment with us, this Privacy Policy is applicable in addition to the Privacy Notice for Job Applicants available here.
2. What types of information do we collect and why?
2.1. Amusnet Romania processes various categories of personal data necessary for the lawful and normal conduct of the Company's business; the conclusion and execution of various contracts between the Company and third parties; the provision of services to the Company by suppliers; for the fulfilment of requirements established by a legal obligation to which the Company is subject; communication and provision of information and documents to the national and foreign public and regulatory bodies; as well as for other legal purposes related to the business activities carried out by the Company.
3. Which are the persons whose personal data is processed?
We process personal data related to the following persons (“You”):
3.1. Legal representatives, proxies, subcontractors, associates, and employees of our suppliers and business partners ("Contractors"), as well as personal data of data subjects of legal representatives, proxies, subcontractors, associates, and employees which may become our business partners;
3.2. Persons making inquiries, requests, and other messages to us by mail, e-mail, telephone, and other means of communication;
3.3. The processing of personal data about the abovementioned data subjects is necessary for Amusnet Romania for the conclusion, execution, and/or termination of contracts; identification of beneficial owners of legal entities – our suppliers and business partners, in view of our internal policies and rules. Without processing of the said personal data, Amusnet Romania cannot enter into contracts with its Contractors or fulfil its obligations under them.
4. Contractors
4.1. The personal data that may be collected and processed by Amusnet Romania within our relations with Contractors might be the following:
- Identification data of Contractors, their legal representatives and proxies – full name, citizenship, Personal Identification Number (PIN) or another identification number/code, ID card number, passport details, address, email address as well as identification data about the ultimate beneficial owners and representatives of the companies with which We are to enter into contractual relations;
- Business contact details - address, contact phone, e-mail;
- Other personal data that may be provided by our business contacts when filling out client/partner questionnaires;
- Other information related to the Contractors, their employees and representatives, provided or created in the context of our business relations and activities, including in negotiations and legal disputes.
5. Website visitors
5.1. When you visit our Website, we may process personal data relating to you through the use of cookies or similar technologies. For more information, please see our Cookie Policy here.
5.2. When you make requests, inquiries, and other communications to us, we may process your personal data, such as names and contact details, which you have provided to us voluntarily for the purposes of carrying out communication with you and to respond to your inquiry.
6. For what purpose does Amusnet Romania process your Personal Data?
Amusnet Romania processes personal data for the following purposes:
6.1. Processing of personal data necessary for taking actions before concluding a contract, as well as for concluding, performing, and terminating a contract with Contractors
- Identification of legal representatives, proxies, employees, and beneficial owners through publicly available channels, as well as when these data are provided by the Contractors of Amusnet Romania before the conclusion of the contract;
- Preparation of offers, contracts, and all other documents accompanying the contract, as well as any other documents created in the context of business relations with the business partners of the Company;
- Notices related to our products and services.
6.2. Processing of personal data needed for compliance with a legal obligation
- Personal data necessary for compliance with a legal obligation of Amusnet Romania, including, but not limited to: (i) legal obligations established in the tax and accounting legislation, gambling legislation, customs legislation etc, (ii) obligations provided for by regulations in terms of proper and legal bookkeeping, (iii) obligations for the provision of information to all state commissions and regulatory authorities, (iv) provision of information to courts and law enforcement institutions.
6.3. Processing of personal data based on legitimate interest
- Provision of data by you in our client/partner questionnaires, such as data about politically exposed persons;
- Verification of the existence of licenses, permits, concessions, and/or other rights related to the exercise of regulated activities by our business partners;
- Exercising and protecting the legal rights and interests of the Company.
7. То whom may Amusnet Romania disclose your Personal Data?
7.1. Amusnet Romania may use third parties to support certain contractual activities or with regard to the performance of a legal obligation. Amusnet Romania does not provide personal data to third parties before the requirements for disclosure of personal data to third parties provided for in the applicable legislation are met.
7.2. Recipients of personal data may be third-party legal and individuals, such as:
- service providers and their subcontractors;
- postal and courier service providers;
- external consultants in various fields providing services to the Company, such as, but not limited to, banks, financial auditors, legal advisers, security companies, and other service providers;
- service providers which on assignment and on behalf of the Company maintain equipment, software, and hardware used to support the activities of Amusnet Romania, as well as hosting companies and sales agents, etc.;
- state and municipal bodies, including, but not limited to, regulatory bodies, state commissions, institutions and agencies, tax department, law enforcement authorities and others, to which Amusnet Romania should provide information that may contain personal data under the applicable legislation.
8. What technical and organizational measures for data protection do we apply?
8.1. In accordance with applicable law, Amusnet Romania implements all necessary technical and organizational measures to protect personal data from accidental loss and unauthorized access, use, alteration, or disclosure. The Company has adopted and ensured the implementation of internal policies and procedures designed to protect information from loss, misuse, and improper disclosure.
8.2. In addition, Amusnet Romania implements information security measures, including, but not limited to, access control, strict physical protection, and robust practices for collecting, storing, and processing information, such as encryption, pseudonymization, and anonymization of the collected personal data.
9. When do we delete your Personal Data?
9.1. Amusnet Romania stores personal data within the statutory time limits, and if there are not explicitly defined statutory time limits, within the time limits set by the Company in order to achieve the purposes of the personal data processing listed above. The Company deletes personal data after the expiration of the statutory deadlines for their storage and/or achieving the purposes of data processing, but in any case, not before the final settlement of all our financial relations.
9.2. Amusnet Romania stores personal data for the following periods:
- Invoices and other financial information - 6 /six/ years, starting from the beginning of the year following the year in which the payment of the debt for the respective year is due;
- Information contained in contracts and work orders - for the period of the contract and up to 5 /five/ years from the termination of the contract, except in cases where this information is related to tax and social security control - then the term is 10 /ten/ years, starting from the beginning of the year following the year in which the payment of the debt for the respective year is due;
- Information contained in correspondence with you - up to 5 /five/ years from the end of the correspondence. In cases where the correspondence relates to a valid contract, the term begins from its termination;
9.3. The personal data may also be processed for a longer period than the above-mentioned terms, if such processing is necessary to achieve the purposes set out therein or to protect the rights and/or legitimate interests of Amusnet Romania, or if the applicable legislation provides for the processing of such data for a longer period.
10. Do we transfer personal data outside EU/EEA?
10.1. The transfer of personal data is secured by modern technical means. In principle, Amusnet Romania does not transfer personal data to persons outside the EU / EEA. In the event that such transfer is necessary for the fulfilment of some of the above purposes, the transfer will be carried out in compliance with the requirements of applicable law.
11. What are Your rights in relation to the protection of your Personal Data?
11.1. In order to fulfil the obligations of Amusnet Romania as a Data Controller, it is important for the Company to process and maintain your Personal Data accurate and up-to-date; if necessary, you may request an update of your Personal Data, correction, and/or supplementation, for which purpose you should send an application/request to the Company in compliance with the terms and conditions provided for in the legislation on Personal Data protection.
11.2. You have certain rights related to the processing of your Personal Data provided in the GDPR, including:
- Right to information and free and open access to your Personal Data, as well as the right to request a copy of your personal data stored or otherwise processed by Amusnet Romania;
- The right to request correction of your personal data in case it is inaccurate, not up-to-date, or incomplete;
- In the presence of the conditions set out in the GDPR or national law, you also have the right to request the deletion of your Personal Data or the restriction of their processing, as well as to exercise your right to the portability of your Personal Data (when applicable);
- Right to object, as well as rights related to automated decision-making - you have the right to object at any time, on grounds relating to your specific situation against the processing of your Personal Data, including in the event that your Personal Data is used for profiling;
- If you have any doubts that your Personal Data is not being processed lawfully by Amusnet Romania, you have the right to file a complaint to the competent data protection supervisory authority listed below in this Policy, or to seek the protection of your rights judicially.
11.3. Please note that Amusnet Romania does not use your Personal Data for profiling or automated decision making.
11.4. The terms and conditions for exercising your rights related to the protection of Personal Data are regulated in detail in the GDPR and the Romanian General Data Protection Regulation Implementation Act. You may exercise your rights by making a written request to Amusnet Romania on the contact details provided in this Policy in accordance with the requirements of applicable law. If necessary, Amusnet Romania will provide you with full assistance in exercising the rights granted to you.
11.5. All personal data requests mentioned in Article 12.2. shall be made in writing, signed by the data subject and submitted to [email protected] or the management address of the Company.
11.6. The Company will respond to such requests by no later than 30 (thirty) calendar days (with the possibility to extend this period for particularly complex requests in accordance with applicable law), implements them if there are grounds for doing so or makes a reasoned refusal if there are reasons for doing so, indicating the right of the data subject to follow.
12. Failure to provide the information
12.1. You are under no statutory or contractual obligation to provide your personal data to the Company during the recruitment process. However, if you fail to provide us with the information needed to go through the necessary steps prior to entering into a contract with you, we may not be able to process your application properly, in full or in part.
13. Competent national supervisory authority for Personal Data Protection
National Supervisory Authority For Personal Data Processing
Address: 28-30 G-ral Gheorghe Magheru Bld., District 1, post code 010336, Bucharest, Romania
Phone number: +40.318.059.211
Website: https://www.dataprotection.ro
14. Changes to the present Personal Data Protection Policy
14.1. This Data Protection Policy may be amended over time, and the changes made to it shall become effective promptly after being announced on the Company’s website.
