1. Who is accountable for processing my personal data?
MSE – Majorel Strategy & Expertise SRL
1, Ionescu Crum street, Tour 1, 6 floor, Brasov
is responsible for processing your personal data on this website (hereinafter referred to as “we”).
We process personally identifiable information (“personal data”) in accordance with GDPR provisions and Law no. 190/2018 for the implementation of the GDPR.
You can contact our designated Data Protection Officer at the address indicated above by using the reference ‘For the attention of the Data Protection Officer’ or by writing to: email@example.com
2. What data is collected?
When you visit our website, the data of the computer you use to access our website is automatically logged (“access data”). This access data includes server log files that generally consist of information pertaining to your web browser type and version, your operating system, your internet service provider (ISP), the date and time you used the website, the websites previously visited by you and the websites you accessed from our website, in addition to the IP address of your computer. With the exception of your IP address, the information contained in the server log files is not personally identifiable. An IP address is personally identifiable when it is static (permanently allocated when using internet access) and the ISP is able to attribute it to a specific person.
Some features of our website require that you divulge personal information to us. In this case, the information provided by you is used to provide the service requested by you or process a matter submitted by you (e.g. search queries, entries made in forms or contracts, click data).
3. What cookies are used?
As a general principle, cookies enable online recognition without reference to a specific person. Cookies may become personally identifiable when the information they contain is merged with other information apart from the information generated by the cookies themselves. Here a distinction is made between cookies that are necessary for the provision of website features, and cookies that are required for other purposes, e.g. analysis of user behaviour or displaying advertising-related content.
The cookies that are required for the provision of website features include the following in particular:
- Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
- Quriobot: Used to set start and end of a conversation with Quriobot
- Google Tag Manager: Used to manage third party tools
- Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
- Polylang: Used to remember user’s choice of prefered language
- Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
- Google Analytics: Used for tracking customers behaviour
- Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.
4. What personal data is collected and for what purpose?
The purpose of data processing may be based on technical, contractual or statutory requirements or result from consent having been given by the user.
We use the data described in section 2 for the following purposes:
- To provide website features and content and ensure technical security in trouble-shooting technical issues and also to ensure that unauthorized persons do not gain access to our website systems;
- To conduct marketing reach measurements and web analyses in order to make our website more efficient and interesting for you, and for market research purposes;
- For communication, completion of precontractual procedures, and customer care purposes;
- To send out newsletters via email;
- For event registration and participation; and
- Founding an employment relationship.
4.1 Provision of the website
4.1.1 Description and scope of data processing
In order to enable the proper functioning of our website, security analyses to be conducted, and denial-of-service attacks to be prevented and stopped, server log files are automatically collected and saved on a short-term basis as an integral part of access data that is created by the system of the visiting computer upon accessing our website and while using it (see section 2). The content of the server log files is not merged with other data. We use the server log files for statistical analyses to troubleshoot and remedy technical issues, prevent and defend against denial-of-service attacks and attempted fraud, and to optimize the proper functioning of our website.
4.1.2 Purpose and legal basis of data processing
The legal basis for the creation of server log files follows from Art. 6(1)(f) GDPR. Our legitimate interests lie in the proper functioning of our website, conducting security analyses and defending against threats.
4.1.3 Duration of storage or criteria applied in defining this period
When the pages of our website are accessed, information is logged to server log files that are stored on our web server; the IP address contained in them is deleted after 7 days at the latest. No analysis is conducted during this time unless there is a denial of service or other attack.
4.1.4 Options for lodging an objection and having your data removed
You have the right to lodge an objection to the processing of your data contained in the server log files provided that there are cogent reasons that arise from your specific situation. If you would like to exercise your right to lodge an objection, please write to the contact address in section 1.
4.2 Contact form, email, chatbot and telephone contact information
4.2.1 Description and scope of data processing
On our website you have the option of contacting us by way of a contact form, by email, by telephone or by chatbot using the designated email address and phone number. If you take advantage of this option, the information you enter in the contact form, your email address and/or your phone number are disclosed to us. Depending on the reason you are contacting us (questions about our products and services, pursuing your rights as a data subject, e.g. submitting a request for information) your contact details are processed (with the assistance of service providers). If necessary for processing your request, this information may be shared with third parties (e.g. partner companies).
4.2.2 Purpose and legal basis of data processing
The legal basis for processing your contact details follows from Art. 6(1)(f) GDPR. We have legitimate interests in processing your request and in continued communication. If the purpose for your establishing contact with us is to enter into a contract with our company, the legal basis for processing your contact details follows from Art. 6(1)(b) GDPR.
4.2.3 Duration of storage or criteria applied in defining this period
Your contact details are deleted once your request has been processed and further communication has been discontinued. This does apply if the purpose of your establishing contact with us is to conclude a contract or you wish to exercise your right as a data subject (e.g. request information). In this case your details are stored until all contractual and/or statutory obligations have been fulfilled and statutory retention periods (currently 6 to 10 years) do not prevent this information from being deleted.
4.2.4 Options for lodging an objection and having your data removed
You have the right to lodge an objection to the processing of your contact information provided that there are cogent reasons that arise from your specific situation. If you would like to exercise your right to lodge an objection, please write to the contact address in section 1. If you lodge an objection, communication with you cannot be continued. This does not apply if the storage of your contact details is necessary for completing precontractual procedures, fulfilling a contract or exercising your rights as a data subject.
4.3 Asserting your rights as a data subject
4.3.1 Description and scope of data processing
On the website you have the possibility of asserting your rights as a data subject, e.g. request information on your personal information that is currently stored by us. In order to assert your rights as a data subject, it may be necessary that you provide us information pertaining to your person and the specific information that has been processed. Without providing this information, we are not able to cater to your rights as a data subject.
4.3.2 Purpose and legal basis of data processing
The legal basis for processing your personal information in asserting your rights as a data subject follows from Art. 6 (1) point c GDPR, “Complying with a legal obligation”.
4.3.3 Duration of storage or criteria applied in defining this period
We store the correspondence exchanged with you in relation to your asserting your rights as a data subject for a period of three years. This does not apply to information obtained to clarify your identity, e.g. by way of a labeled photocopy of your personal identity card, where we have been provided one. It will be deleted within one week at the latest of establishing your identity.
4.3.4 Options for lodging an objection and having your information removed
The processing of your information is required for complying with your rights as a data subject, and to that extent you have no right to revoke your consent to its processing.
4.4 Studies, reports and whitepapers
4.4.1 Description and scope of data processing
4.4.2 Purpose and legal basis of data processing
Processing the information entered by you in the registration form is necessary for advertising pertaining to products and/or services provided by us. The legal basis for this is your consent pursuant to Art. 6(1)(a) GDPR.
4.4.3 Duration of storage or criteria applied in defining this period
Your information is stored to show proof that we obtained your consent for sending you Majorel’s free studies, reports and whitepapers. The same applies if you have revoked your consent.
4.4.4 Options for lodging an objection and having your data removed
You can revoke your consent to receiving press releases at any time by writing to MSE – Majorel Strategy & Expertise SRL, 1, Ionescu Crum street, Tour 1, 6 floor, Brasov, Email: firstname.lastname@example.org.
4.5 Business customer survey
4.5.1 Description and scope of data processing
As part of our business customer relationships, we occasionally conduct customer surveys to measure satisfaction and improve our services. The customer survey is aimed at our business customers, but we regularly store your contact data in our customer database. We use your contact details to invite you to participate in the customer survey. Participation is voluntary and you have the possibility to communicate to us at any time that you no longer wish to receive an invitation to participate in customer surveys. Your contact data is no longer regularly required for the evaluation, so that the survey results consist of purely statistical information. It is then no longer possible to draw any conclusions about your person.
4.5.2 Purpose and legal basis of data processing
The legal basis for processing your contact data is art. 6 sec. 1 lit. f GDPR. The legitimate interests lie in customer care and customer loyalty as well as the improvement of our services.
4.5.3 Duration of storage or criteria applied in defining this period
In principle, the survey results are stored for the duration of the business relationship. This does not apply if the survey results consist of purely statistical data.
4.5.4 Options for lodging an objection and having your data removed
You have the right to object to the processing of your contact data if there are reasons for this arising from your particular situation. If you would like to exercise your right of objection, please contact us at the address given under point 1.
4.6 Application for employment
4.6.1 Description and scope of data processing
Job advertisements are published on the website. Via the job advertisement you will be forwarded to our applicant portal, which collects and processes your data for recruitment purposes. Further information about data processing for recruitment purposes can be obtained by registering in the applicant portal.
In addition to applying via the applicant portal, you can also submit a short application on the website to Majorel Group Luxembourg S.A., based in Luxembourg, as well as to other affiliated companies of the Majorel Group Luxembourg S.A.. With the short application you can draw attention to yourself as a suitable talent without referring to a specific job posting. To assess your talent and contact you for suitable vacancies, you must provide your first and last name, e-mail address and telephone number as well as a small cover letter in the online application form provided for the short application. The short application is voluntary and can be revoked at any time with effect for the future.
4.6.2 Purpose and legal basis of data processing
Your application data will be processed in order to assess your talent and to be able to contact you in suitable vacant positions. The legal basis is Art. 6 sec. 1 lit. a GDPR, by submitting your short application you give your consent to the data processing.
4.6.3 Duration of storage or criteria applied in defining this period
After your consent has been given, your short application will be stored for 1 year, unless you withdraw your consent prematurely. This shall not apply if statutory retention obligations oblige us to a longer storage period. Your consent, on the other hand, will be stored 3 years after deletion and/or revocation in order to be able to prove that we have complied with our legal obligations – to let you consent to data processing.
4.6.4 Options for lodging an objection and having your data removed
You can obtain your consent any time without any formality by contacting MSE – Majorel Strategy & Expertise SRL, 1 Ionescu Crum street, Tour 1, 6 floor, Brasov, Email: email@example.com.
The same applies to the individual companies in the group. The corresponding address can be found in Section 4.6.1 or in the consent.
4.7.1 Google Tag Manager
This website uses Google Tag Manager. Google Tag Manager managers „tags“ (placeholder for website code). Google Tag Manager does not collect data and data collected by the tags cannot be accessed by the Google Tool Manager.
4.7.2 Google Analytics
This website uses Google Analytics. Google Analytics is a service provided by Google Inc. Google Analytics causes a usage profile to be created in order to optimize the user-friendliness of our website. A pseudonym is assigned to this profile. In so doing, your access data is collected as described in section 2 and your usage behaviour analyzed using analytics cookies as described in section 3. Personal identification is not necessary for web tracking: when collecting your access data your IP address is shortened before being transmitted to Google Inc., meaning no information can be attributed to you. These usage profiles to which pseudonyms are assigned are analyzed for the purpose of optimizing user-friendliness. This data is not merged with other data by Google Inc. We ensure that Google Inc. only uses this data as instructed by us under a contract data processing contract we have concluded with Google Inc.
4.7.3 Google Ads
4.7.4 Purpose and legal basis of data processing
The legal basis for collecting and analyzing pseudonym usage profiles follows from Art. 6(1)(f) GDPR. We have a legitimate interest in optimizing the user-friendliness of our website and performing marketing reach measurements.
4.7.5 Duration of storage or criteria applied in defining this period
As a general rule, the data that is collected and analyzed in association with Google and Adobe Analytics remains stored until you raise an objection to it being used in this manner. Analytics cookies are stored for a maximum of 24 months.
4.7.6 Options for lodging an objection and having your data removed
You can raise an objection to the use of Google Analytics by changing your browser settings and/or clicking on the following links to download and install the browser plug-ins and/or opt-out:
● Google Analytics: https://tools.google.com/dlpage/gaoptout
4.8 External services and content on our website
We integrate external services and content on our website. If you use one of these services or you are shown the content of third parties, communication data is exchanged between you and the provider of that service or content for technical purposes.
That provider may use your data for their own purpose. To the best of our knowledge and belief, we have configured the services or content of third-party providers who are known to use data for their own purposes so that communication for purposes other than rendering their content or services on our website is prevented or communication does not come about unless you actively decide to use the service. However, since we have no control over the data collected by third parties and its processing by them we are unable to make any binding statements pertaining to the purpose and scope of the processing of your data.
- YouTube: https://support.google.com/youtube/answer/7671399
- Google Maps: https://maps.google.com/help/terms_maps.html
4.9.1 Description and scope of data processing
You have the option of registering for webinars. Registering requires that you provide your first and last name and your email address. If you would like to be addressed as a company you can also optionally provide details on your company and your position there. After you have entered your details and given your consent to data processing, we use this information to send you confirmation of registration including a link enabling you to take part in the webinar. No other data processing takes place.
4.9.2 Purpose and legal basis of data processing
Your participation in our webinars on current topics relating to our business segment enables us to inform you of current developments in our company or provide the results of scientific research. All webinars are free of charge. The legal basis for data processing follows from your consent pursuant to Art. 6 (1) point a General Data Protection Regulation (GDPR).
4.9.3 Duration of storage or criteria applied in defining this period
As a general principle, the information provided by you is stored for two years. If, however, you revoke your consent before this two-year period lapses, your information will be deleted. After the information provided by you is deleted, your consent is stored for another three years so that we are able to comply with our statutory obligation of documenting proof that you gave your consent to the processing of your data. If you should revoke your consent, this is treated like your initial provision of consent in that it is stored for a period of three years upon the deletion of your information.
4.9.4 Options for lodging an objection and having your information removed
You can revoke your consent at any time. This can be done by way of a simple notice to this effect, without having to state any reasons. Any revocation only has effect for the future, meaning it does not affect the admissibility of data processing during the time prior to you revoking your consent. In the event you would like to revoke your consent, please write to MSE – Majorel Strategy & Expertise SRL, 1, Ionescu Crum street, Tour 1, 6 floor, Brasov, Email: firstname.lastname@example.org.
4.10.1 Description and scope of data processing
Our website offers the possibility to subscribe to a free email newsletter. The data entered in the contact form will be collected by us processed with involvement of data processors and used to provide you with the requested information. By subscription we will collect a consent and refer to our Data Protection Notice, where we provide further information how we process personal data. There is no transmission of your data to third parties. The only mandatory information for a subscription to our newsletter are a name (so we can address it accordingly) and a valid Email-address. The so provided information will firstly be processed in order to verify the validity of the consented Email-address by means of an Opt-In. Additionally provided data are not mandatory.
4.10.2 Purpose and legal basis of data processing
For the provision of the requested newsletter we will process your entered data accordingly. The legal basis for this is to be found in Art. 6 sec. 1 lit. a GDPR.
4.10.3 Duration of storage or criteria applied in defining this period
For the time of your subscription we will store the data needed for the provision of the newsletter. The data will be processed only for this purpose and in order to demonstrate to authorities that we have obtained a valid consent for this processing. Where you withdraw your consent, we will delete all data about you, unless they are needed to demonstrate that we have complied with your withdrawal.
4.10.4 Right to object
You can unsubscribe from our newsletter at any time by using the unsubscribe button at the end of any newsletter or by sending an email with the subject “[Your email address] Unsubscribe [Name of the newsletter]” to email@example.com. You will get a confirmation mail for your revoked subscription.
5. Who comes into possession of my personal data?
Within our company those who need access to your information for the purposes described in section 4 will be given access to it. Service providers contracted by us may also be given access to your information (“contract data processors”, e.g. data centers, mailing services for newsletters, web tracking). They are bound by our directives and must provide for data security and the confidential treatment of your information under the contract data processing agreements we have concluded with them.
No sharing of information with other recipients such as advertising partners, providers of social media services or credit institutions (“third parties”) takes place.
6. Is my personal data processed outside of the EU or EEA (‘transfer to a third country’)?
The use of Google Analytics as described in section 4.4 above causes personal data to be transferred to a third country since the data centers of Google Inc. are located outside of the European Union and the European Economic Area (“EU or EEA”). Such transfers of personal data to third countries may result in your personal information being transmitted to a country which does not provide for the same standard of data protection as the EU or EEA. You can request a copy of these safeguards by contacting the addresses indicated in section 1 above.
7. What data privacy rights do I have?
You have the right to request access to your personal data that is currently stored by us. If this data is incorrect or not up to date, you have the right to request rectification. You also have the right to have your personal data erased and/or its processing restricted as provided for in Art. 17 and Art. 18 GDPR. You also have the right to request a copy of the personal data provided by you in a structured, commonly-used, machine-readable format (right to data portability).
If you have given your consent to the processing of your personal information for specific purposes, you can revoke that consent at any time for the future. Your notice of revocation is to be addressed to us by writing to the contact address indicated in section 1.
Pursuant to Art. 21 GDPR, you also have the right for reasons relating to your specific situation to raise an objection to the processing of your data that is done on the basis of Art. 6 (1) (f) GDPR. You also have the right to lodge an objection to the processing of your personal information for direct marketing purposes. The same applies to automated processes involving the use of individual cookies, unless they are required for providing the functionality of our website.
You also have the right to lodge a complaint with the competent data protection authority. The authority responsible for us is:
Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal, B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, cod postal 010336, Bucuresti, Romania Telefon: +40.318.059.211
You also have the right to contact the data protection authority at your place of residence and request support in pursuing your matter.
8. To what extent does automated decision-making take place?
We do not use any fully automated decision-making processes for any of the purposes set out in section 4.
9. Is profiling done?
No profiling takes place for any of the purposes set out in section 4.
I. Data controller
MSE – Majorel Strategy & Expertise SRL, 1, Ionescu Crum street, Tour 1, 6 floor, Brasov, Email: firstname.lastname@example.org.
MSE – Majorel Strategy & Expertise SRL is accountable for the processing of the personal information described below (referred to hereinafter as “we”, “us”, “our”).
You can contact our data protection officer by writing to email@example.com or writing to us at the postal address indicated above by using the reference ‘For the attention of the Data Protection Department ’.
Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland (“Facebook”) is also responsible for processing information. For more information, please consult: https://www.facebook.com/policy.php.
You can contact Facebook’s data protection officer here: https://www.facebook.com/help/contact/540977946302970
You can find information on the processing of personal information by Facebook in your Facebook profile under the Settings menu – Privacy, or here: https://www.facebook.com/help/568137493302217.
II. Processing of personal information
1. General remarks
According to the GDPR, “personal data” (referred to below as “personal information”) means any information relating to an identified or identifiable natural person (“data subject”). Also pseudonymized information that cannot be directly linked to you, e.g. by way of a name or email address, is also personal information.
2. Your rights
You have the right at any time to request access to your personal information that is currently on file with us. If this information is incorrect or not up to date, you have the right to request that it be corrected. You also have the right to have your personal information deleted and/or its processing restricted as provided for in Art. 17 and Art. 18 GDPR. Where our processing by automated means of information provided by you is based on your consent or is the subject of a contract with you, you have the right to request a copy of this data in a structured, commonly-used, machine-readable format (right to data portability). If you want to exercise any of your rights, you can address these issues to the contact indicated in section 1 above.
You also have the right to lodge a complaint with the competent data protection authority. You can assert these rights by contacting the data controller.
3. Obligation to provide personal information
As a general rule, you are not obligated to provide personal information to us. You must provide specific information only when concluding a contract (e.g. your email address or your name). Without this information we cannot enter into a contract with you or perform the contract. Facebook may impose other requirements on you. For more information, please consult: https://www.facebook.com/policy.php.
4. Disclosure of personal information to third parties
Your personal information is not disclosed to third parties unless this is necessary for fulfilling obligations under a contract, we or the third party have/has an legitimate interest in disclosure, or your consent has been obtained. In addition, personal information may be shared with third parties in the event that we are obligated by virtue of operation of the law or by virtue of an enforceable directive of a governmental or other regulatory authority, or by order of a court or other authority of competent jurisdiction.
5. Service providers
We contract service providers in part for processing data. Access by service providers to your personal information is restricted to the extent necessary. As a general rule, service providers are engaged as contract data processors who are bound by our directives when processing data.
6. Transfer of data to non-EEA countries
Personal information may be transferred to third parties and contract data processors who are headquartered in non-EEA countries. In these cases, we ensure that the recipient provides for an appropriate level of data protection prior to transferring data. We have also concluded EU standard contractual clauses with various companies. Details can be obtained from our data protection officer on request.
7. Duration of storage
We store your personal information for as long as it is necessary to provide our offerings and the associated services, or we have a legitimate interest in continued retention. In all other cases we delete your personal information with the exception of information (e.g. invoices) that we must retain for compliance with statutory retention periods (e.g. imposed by the tax code or commercial code).
8. Pseudonymized data processing
The processing of information described below primarily takes place on a pseudonymized basis. This means that we do not provide information to third parties that can be directly linked to you, e.g. by way of a name or email address, but rather a profile is created on the basis of an ID or cookie.
III. Processing of information by us of users using our Facebook pages
The processing of information described below is for the purpose of operating our Facebook pages.
We receive statistical data from Facebook about the visitors to our Facebook pages by way of Facebook’s Audience Insights service. We are unable to link this information to any specific person. This feature enables us to better analyze our pages and adapt them to the needs and interests of our visitors. Facebook processes personally identifiable information in relation to this service on its own responsibility. For more information, please visit: https://www.facebook.com/iq/tools-resources/audience-insights. We need no legal basis for processing statistical or anonymized data.
2. Interaction on our pages
We are also able to see when a specific Facebook user likes or subscribes to one of our Facebook pages. We are also able to link comments to individual users on our Facebook pages. The legal basis for this processing of information follows from Art. 6 (1) sentence 1 point b) and f) GDPR. We have a legitimate interest in interacting and continued communication with you. To the extent that the processing of information follows from Art. 6 (1) sentence 1 point f) GDPR, pursuant to Art. 21 (1) GDPR you have the right, for reasons relating to your particular situation, to lodge an objection at any time to the processing of your personal information with effect for the future by writing to firstname.lastname@example.org and setting out your objection.
We review the comments on our Facebook pages for any inappropriate content. In so doing, it is readily clear under which Facebook profile a specific comment was posted. A link is made between the content of the comment, the timestamp created when the comment was posted, the user ID, the Facebook user name, and a reference to the preceding posts and comments. The result of a review may lead to the comment being hidden or the user being blocked. The legal basis for this follows from Art. 6 (1) sentence 1 point c) GDPR.
IV. Processing of information provided by you by way of a contact form or email
On our Facebook pages you have various options for contacting us for various purposes. We use the information provided by you in this manner solely to respond to the matter for which you have contacted us. Messages are deleted at the latest upon attending to your query, provided that we are not required to retain them for other reasons.
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