Privacy policy

Compliance with personal data processing requirements is very important to us. Therefore, TDP PARTNERS SRL (hereinafter referred to as “TDP Partners”) processes your personal data securely, in compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation – GDPR), with Law no. 190/2018 on measures implementing the GDPR and/or with any other decisions that the National Supervisory Authority for the Protection of Personal Data (ANSPDCP) may issue in its capacity as the supervisory authority for the protection of personal data (hereinafter referred to as the “Applicable Legislation on the Processing of Personal Data”).

This Data Protection Policy (hereinafter referred to as the "Policy") applies to data processing carried out by TDP Partners in relation to your personal data, whether you are a client or potential client of TDP Partners, a visitor to our website or a visitor to our registered office.

Our policy covers both the protection aspects regarding the processing of personal data carried out by TDP Partners at its registered office, as well as the aspects related to data protection on our website, for the processing operations carried out through our website www.tdppartners.ro.

Within the Policy, we cover:

• the purposes for which we collect and process your personal data, as well as the grounds for processing that we have;

• the categories of personal data that we collect from you and that we process;

• the source of the personal data we process;

• the storage period of your personal data;

• the recipients of your personal data;

• the rights you have as a data subject, according to the applicable legislation regarding the processing of personal data;

• the measures taken to protect your personal data.

1. IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER:

TDP Partners SRL

Registration number at the Trade Register: J40/3644/2007, Unique Registration Code 21165737

Registered office: 34 Capâlna Street, block 16I, 1st floor, apt. 17, sector 1, Bucharest, Romania.

Phone: +40 314 382 576 (normal rate call) E-mail: office@tdppartners.ro.

2. PURPOSES, GROUNDS FOR PROCESSING AND CATEGORIES OF PERSONAL DATA PROCESSED

Depending on the capacity you have in your relationship with us as a data subject, we may process your personal data for various processing purposes, but always on the basis of a legal basis.

2.1 If you are a potential client or customer of TDP Partners

We process your personal data for the following purposes and on the basis of the applicable legal grounds, as follows:

• for the purpose of concluding and executing the consultancy contract, as well as for the purpose of providing other services in connection therewith. The legal basis is the conclusion and execution of the consultancy contract with you;

• for statistical and research purposes, including for the design, development, testing and use of new information systems/improvement of those already implemented or for the creation of other information systems;

• in order to develop business analyses, compliance operations, internal control, etc. The legal basis is the legitimate interest of TDP Partners to improve and diversify the products and services offered to its clients, as well as to fulfill legal obligations;

• for archiving purposes, the legal basis being the fulfillment of TDP Partners' legal obligations;

• for marketing purposes, such as promotional activities, sending directly addressed offers/commercial correspondence in relation to the services provided by TDP Partners through any means of communication (telephone, SMS, mail, e-mail). The legal basis is your consent.

The categories of personal data processed by TDP Partners to achieve the above purposes may be the following:

• Identification data: Name, surname, etc.

• Contact details: home/residence address, email address, mobile phone number, etc.

• Data about professional life – employer name, employer CUI, employer type.

• Data about your behavior as a customer – data from online activity (on the internet), areas of interest;

2.2 If you are a potential candidate for a job at TDP Partners

If you wish to apply for a job within our team, we inform you that we will process the personal data from your CV, as well as any other data submitted subsequently, if applicable, strictly for the purpose of recruiting for the open position announced through this job advertisement. The basis on which we will process the data is our legitimate interest to cover our organizational needs, taking into account our object of activity and the specifics of the position.

For the purpose of selection and recruitment, we may process the following categories of personal data:

• Identification data – name, surname, address, identification document number, photograph, etc.

• Contact details – email address, telephone number, home address/residence, etc.

Data about professional life – employer, experience, position, education, etc.

• Digital data – public information posted on professional activity websites and other publicly available data on the Internet, etc.

2.3 If you are a visitor to the registered office of TDP Partners

If you visit us at our registered office, we will process your personal data (name and surname, image, as well as other data you provide to us) for the purpose of ensuring the security of our premises, personnel and assets, through the use of video surveillance. The legal basis for this processing is our legitimate interest in ensuring the security of TDP Partners premises and assets/equipment or the fulfillment of a legal obligation, where applicable.

2.4 If you are a visitor to our website or if you access it to register your data

If you visit our website www.tdppartners.ro, we collect your personal data when you access the website (date and time of accessing the website, IP address from which the website was accessed) and process it for the following purposes:

• to ensure that our website and its sections are relevant to the needs of our customers/potential customers;

• publishing content accessible to our customers/potential customers in relation to their preferences;

• to provide social media features and to analyze and monitor website traffic. We base the above processing on our legitimate interest in ensuring the proper functioning of the website and improving the experience of its users. We also collect your personal data when you access certain sections of the website and register your personal data to be contacted by TDP Partners for various purposes, such as:

– by filling out the forms in the "Services" sections, if you wish to be contacted by TDP Partners to provide those types of services requested; – by filling out the form in the "Contact" section to be contacted by TDP Partners to provide you with additional details about our services.

We use cookies on our website, temporarily storing personal data to improve the security of access and traffic on the website, as well as to adapt the services to meet the needs of our customers. You can find more information in this regard by accessing our Cookie Policy published on the website.

2.5 If you are a person submitting a request/complaint/claim to TDP Partners

If you are not the client/potential client/employee of TDP Partners and you send us a request/complaint/claim regarding TDP Partners products or regarding any other aspect regarding TDP Partners' activity, we will process your personal data (name and surname, contact details, as well as any other data you provide to us) in order to resolve the request/complaint/claim made. Our basis for this processing is the legitimate interest of TDP Partners to resolve the request/complaint/claim according to your request.

2.6 If you are a representative, contact person or employee of a supplier or business partner of TDP Partners.

We process your personal data (name and surname, email address, mobile phone number, as well as any other relevant contact details) for the purpose of carrying out the contractual/commercial activity we have with our service provider or our commercial partner.

The basis for such processing is our legitimate interest in managing the contractual/commercial relationship we have initiated with the service provider/commercial partner of TDP Partners.

3. WHERE DO WE GET YOUR DATA?

Depending on your status as a visited person and the purposes of the processing, we collect your personal data in various ways:

• when you provide it to us directly (for example, when you register your data on our website so that we can contact you;

• when you contact us by phone or email to request a quote;

• when you provide us with your CV for recruitment for a specific position;

• when you contact us to register a request/complaint/claim, etc.);

• from the employer, through the recruitment platforms of our contractual partners or from external companies that provide us with candidate suitability assessment services during the recruitment process (if you are a potential candidate).

4. HOW LONG DO WE KEEP YOUR DATA?

Your personal data is retained by TDP Partners only for as long as and to the extent necessary to achieve the processing purposes mentioned above or if we have a legal obligation to process it. For personal data processing where we need your consent, we will process your data until you withdraw your consent. If you are a potential client and request a service/product from TDP Partners, but you voluntarily withdraw the request, or if the request is rejected by TDP Partners, your personal data will be deleted from our databases after a period of 6 months from the date of data collection, except for processing operations for which you have given your consent (which will be processed until the date of withdrawal of consent). If you are our client, in order to fulfill the legal documentation and retention obligations under the legislation for the prevention and fight against money laundering and terrorist financing, TDP Partners has the legal obligation to retain the customer knowledge documentation (which contains your personal data) for a period of 5 (five) years from the termination of the contractual relations with you. Also, your data personal data found in any supporting documents that form the basis of financial accounting records are kept in the TDP Partners archive for 10 years from the closing date of the financial year in which the supporting documents were drawn up, in accordance with the provisions of the Accounting Law. Last but not least, in the context of the defense and exercise of TDP Partners' legal rights and interests, your personal data necessary for this purpose will be kept in accordance with the general limitation periods. If you are a potential candidate for a position within our team, we will keep your personal data for as long as necessary to complete the position you applied for within our organization, but no more than 6 months from the date of data collection, after which your personal data (including CV data) will be deleted/destroyed from our records. If you are a visitor to our registered office, your personal data processed through the use of video surveillance will be kept for a period of 30 days.

If you are a visitor to our website and you register your personal data in the relevant sections, our website will capture your data for a period of 3 months from the date of data registration.

After the expiry of the above deadlines, your personal data is deleted or anonymized and/or destroyed from TDP Partners' records/databases. 5. TO WHOM DO WE TRANSMIT YOUR PERSONAL DATA AND THE RESULTS OF OUR PROCESSING ACTIVITIES (REPORTS, LISTS, ETC.)

We disclose/transmit your personal data to our suppliers for archiving, data security, software application development, as well as for audit purposes.

We transfer your personal data for the purposes described in this Policy only to providers who guarantee the protection of your personal data, the fundamental rights and freedoms you have. For any additional information regarding the transfer of your personal data to our providers, please contact TDP Partners at office@tdppartners.ro.

6. YOUR RIGHTS

As a data subject, according to the applicable legislation regarding the processing of personal data, you have the following rights:

• Right to information: the right to receive information regarding the processing operations of your data carried out by TDP Partners (i.e., about the purposes of processing your personal data, categories and sources, recipients, storage periods of your personal data and the rights you have).

• Right of access: the right to obtain from TDP Partners confirmation as to whether or not it processes personal data concerning you and, if so, access to that data and provision of information regarding data processing;

• Right to rectification: the right to obtain from TDP Partners, without undue delay, the rectification of inaccurate data concerning you or the completion of incomplete personal data. Thus, we update your personal data, asking you to review them periodically whenever the need for updating is provided for by law.• Right to erasure: the right to obtain from TDP PARTNERS, without undue delay, the erasure of personal data concerning you, if: (i) the personal data are no longer necessary for the purposes for which they were collected or processed by TDP PARTNERS; (ii) you withdraw your consent for data processing based on consent; (iii) you object to the processing of personal data carried out by TDP PARTNERS; (iv) your personal data have been unlawfully processed by TDP PARTNERS; (v) your personal data must be erased for compliance with a legal obligation of TDP PARTNERS;

• Right to restriction of processing: the right to obtain from TDP PARTNERS restriction of the processing of your personal data, if: (i) you contest the accuracy of the data that TDP PARTNERS processes. The processing will be restricted for a period that allows TDP PARTNERS to verify the accuracy of the data; (ii) the processing of personal data by TDP PARTNERS is unlawful and you do not want the data to be deleted, but request the restriction of their use by TDP PARTNERS; (iii) TDP PARTNERS no longer needs your personal data, but you request them for the establishment, exercise or defense of a right in court; (iv) you object to the processing.

The processing will be restricted for the period of time during which it is verified whether the legitimate rights of TDP PARTNERS prevail over your rights. If you have obtained the restriction of processing, you will be informed before the restriction of data processing is lifted.

• Right to object: your right to object, on grounds relating to your particular situation, to processing carried out by TDP PARTNERS based on our legitimate interest. When you object to such processing, TDP PARTNERS will no longer process your personal data, unless TDP PARTNERS demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims by TDP PARTNERS.

To exercise the above rights, you can send a written request (i) by e-mail to the following address: office@tdppartners.ro. Your requests will be processed as soon as possible. We strive to resolve any request related to the processing activities of your personal data, within a maximum of 30 days from receipt of the request. This term may be extended by a maximum of 2 months when necessary, taking into account the complexity and number of requests. In order to respond to requests to exercise the above rights, TDP PARTNERS may request additional information necessary to identify you, to protect your personal data against any fraudulent attempts.

If you believe that your rights regarding the processing of personal data have been violated, you have the right to address the courts or to file a complaint with the National Supervisory Authority for Personal Data Processing, at Bld. G-ral Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania, telephone: +40318059211, e-mail: anspdcp@dataprotection.ro.

7. HOW DO WE PROTECT YOUR DATA?

In order to ensure that your rights and freedoms are not jeopardized and that compliance with relevant data protection laws and regulations is maintained, we have implemented appropriate technical and organizational measures to ensure an adequate level of security. These measures consist, without being limited to, regular training and testing of our employees and partners, the introduction of relevant policies and processes, which are regularly reviewed and updated. We also ensure that we carefully evaluate our service providers to meet an appropriate level of protection of your personal data and conclude personal data processing agreements with them to ensure that each contractual partner who comes into contact with your personal data carries out the contracted processing activities in complete security and complies with the provisions of the Applicable Legislation regarding the processing of personal data.

8. UPDATES

This Personal Data Protection Policy is applicable as of February 9, 2022.

This Policy is reviewed annually. Updated versions will be published on our website: www.tdppartners.ro.