General Data Protection Regulation (GDPR)

The General Data Protection Regulation (EU) 2016/679 (GDPR) has become applicable since May 25, 2018. The GDPR is a single regulation, directly applicable in all Member States of the Union and replaces Directive 95/46/EC and, implicitly, the provisions of Law no. 677/2001 on the protection of individuals with regard to the processing of personal data and the free movement of such data.

Our company Planning Ahead SRL, a company headquartered in Constanţa Municipality, B-dul TOMIS, No. 287, Block T12, Stair B, Floor 5, Apartment 67, Constanţa County, identified by J13/3650/2021, CUI 45170617, represented by administrator Adrian Sorin Cristea, applies a privacy and security policy for personal data in strict accordance with the provisions of the GDPR, and as part of our commitment to respecting the rights of the persons whose personal data we process, we provide you with relevant information below regarding the manner, purpose, legal basis and duration for which we process your personal data, as well as regarding the rights you benefit from and the way in which you can exercise these rights.

Starting with May 25, 2018, in order to be able to provide you with our services, it is necessary for us to obtain your express consent, or to process your personal data based on one of the legal grounds listed by the Regulation.

For subsequent unsubscription, you can exercise the right to withdraw this consent by submitting a request in this regard, according to the procedure below.

1. PROCESSING OF PERSONAL DATA

Personal data means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.

The processing of personal data is any operation or set of operations which is performed on personal data, by automatic or non-automatic means, such as collection, recording, organization, storage, adaptation or modification, retrieval, consultation, use, disclosure to third parties by transmission, dissemination or otherwise, alignment or combination, blocking, erasure or destruction.

Our company only records personal information voluntarily provided by the visitor/user/client, for which they have expressly expressed their consent.

2. THE LEGAL GROUNDS FOR PROCESSING PERSONAL DATA ARE:

• Consent of the data subject;

• Conclusion or execution of contracts concluded with us;

• Fulfillment of a legal obligation;

• Vital interests;

• Public interest;

• Legitimate interest;

The Company may process personal data based on one or more of the aforementioned grounds, as appropriate. Express consent for processing is required only when another of the aforementioned grounds is not applicable;

In accordance with the requirements of Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, our Company is obliged to manage in a secure manner and only for the specified purposes, the personal data provided by users/clients.

Our Company respects the right to confidentiality of the data of each person accessing the site, as provided in the Privacy Policy displayed on the site.

3. WHAT PERSONAL DATA DO WE USE?

When you browse our website, when you register as a user, when you send us a request by e-mail or contact us for any other purpose and on any other communication channel, you can communicate to us on your own initiative one or more of the following personal data, as applicable, which we collect directly from you, such as: name and surname, e-mail address; telephone number; occupation; specific personal data, necessary to ensure the possibility of providing our services to customers; other personal data, which you can transmit to us voluntarily, without us having requested them in advance, as applicable.

4. WHAT PERSONAL DATA DO WE USE?

Also, when you visit our website, we may process information about the devices used to access the website and about your interaction with the website.

Also, with regard to the chat integrated within the website, (if applicable) your consent will be requested prior to the transmission of any type of personal data to us, by requesting the agreement to use the chat according to the privacy and personal data processing policies of our website. Access to the chat will be allowed only after express acceptance of the terms of use, so it is impossible to transmit personal data through the chat without previously obtaining consent for its use according to the specific terms of use.

Regarding the possible transmission of personal information through the contact form available on our website, by voluntarily transmitting such information to us through the form, you expressly consent to our processing of such personal data for the purpose of processing your request. Withdrawal of consent is, of course, possible at any time, based on your express request, and our company will delete/anonymize any personal information from the database, in accordance with the provisions of the GDPR Regulation.

Your personal data may be processed for one or more of the following purposes:

• for the provision of services and the performance of activities carried out by us, with all subsequent activities;

• in order to conclude or execute a contract or a collaboration between you and us;

• sending you information / commercial / marketing messages, regarding the activity of our company and / or third parties / collaborators with whom our company has commercial or any other nature, to your contact addresses provided to us (e-mail, telephone, sms, etc.);

• to keep you informed in the future regarding our activity and that of our collaborators;

• sending non-commercial or administrative messages;

• to access special sections of the site, based on the user account (if applicable);

We may disclose this information to our collaborators, for the performance of the activities mentioned above, of course, based on bilateral protocols regarding the adequate protection of the processing of personal data, concluded between us and them.

Also, if you have requested an offer from us or have benefited from a service or if you have been our collaborator, we process your data in order to be able to respond to your requests and to provide you with the respective service or product, or to keep in touch for future collaboration opportunities.

We may contact you or transmit your personal data for the purpose of carrying out our object of activity. We may also contact you when we consider that a possible collaboration or a specific product / service suits your interests.

Your data will be stored securely within the company, in accordance with the policies regarding data processing and security, and used for the purposes mentioned above.

Also, in order to achieve the purposes described above, we may disclose your personal data to our employees, our suppliers of products and services or to other collaborators of ours, such as:

• specialized companies that carry out marketing campaigns on behalf of the company;

• collaborators / IT service providers, in order to administer databases and adjacent activities;

• specialized collaborators of our company, in various areas of practice, in order to ensure the possibility of providing complete services to you;

• other collaborators of our company, for other categories of services, such as: courier, etc.;

• to other companies that belong to the same group as the Company;

If applicable, to the extent that it will be necessary to transfer data to countries outside the EEA (European Economic Area), we will inform you of this and will ensure, in all cases, that the transfers are legitimate and carried out in complete security, by adopting appropriate technical and organizational measures to ensure an optimal level of protection. In this case, you give your consent to carry out these data transfers, under the security conditions imposed by the GDPR Regulation.

In all cases, the disclosure of your personal data is carried out based on a contract concluded with the recipients of the data, through which they undertake to use the data exclusively for the purpose for which they were entrusted, to comply with the obligation of confidentiality and data security, as well as to comply with all provisions of the legislation in force regarding the protection of personal data.

Our company does not sell, transfer, disclose or allow access to your personal data to third parties that are not related to our activity.

Our website may contain, at some point, links to other websites whose data processing policies may differ from those of our company. Please be aware of and consult the privacy policies of other websites, as our company is not responsible for the information sent or collected by these third parties.

Also, based on and within the limits of legal provisions and following express requests from them, we may disclose your personal data to public authorities, if they are requested on a legal basis (courts and other competent state bodies, police, etc.).

5. HOW LONG DO WE PROCESS YOUR DATA?

To ensure you have a more personalized experience when interacting with us, we retain your personal data for a maximum period of five years from your last interaction with us, unless applicable legal regulations require a different storage period. However, we do not commit to retaining this data for the entire period mentioned above and may delete or anonymize your data earlier.

6. WHAT RIGHTS DO YOU HAVE AND HOW CAN YOU EXERCISE THEM?

According to Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data:

USERS/CLIENTS benefit from the following rights, according to the GDPR Regulation:

• Right to withdraw consent;

• Right to be informed about the processing of your data;

• Right to access data;

• Right to rectify inaccurate or incomplete data;

• Right to erasure (“right to be forgotten”);

• Right to restrict processing;

• Right to transmit the data we have about you to another operator;

• Right to object to data processing;

• Right not to be subject to a decision based solely on automated processing, including profiling;

• Right to seek justice;

• Right to lodge a complaint with a Supervisory Authority (http://www.dataprotection.ro/; tel: +40.318.059.211; +40.318.059.212; e-mail: anspdcp@dataprotection.ro );

To exercise these rights, any person may submit a written, dated and signed request to our headquarters, or may contact us at the e-mail address and/or telephone number displayed in the contact section on our website.

To protect your personal data and your interests, we may request additional information for the purpose of identifying you.

7. CONFIDENTIALITY OF YOUR DATA

When we process your data, we use technical and organizational measures to ensure the confidentiality, availability and accuracy of your data.

Personal data that benefit from a special protection regime are processed under restrictive conditions, with access to this information only to certain persons within the company, and in accordance with the legal provisions applicable to this type of data, with the provision of adequate technical measures to protect them (password protection and/or back-up, etc.).

For any additional details, our Data Protection Officer is ready to respond to your request, at the contact address office@ahead-group.com