CONFIDENTIALITY POLICY OF THE SITE “www.rubeco.ro”

• Information regarding the Personal Data Operator

For RUBECO DITRIBUTION S.R.L (“Rubeco”), the confidentiality of your personal data is of particular importance. For this purpose, we have developed this commitment to respect the confidentiality of your data, through which we explain which categories of personal data Rubeco collects, as well as the way in which said data are used and the purpose for which they are subjected to processing operations.

This Policy refers only to your personal data that Rubeco processes through the website www.rubeco.ro. We want to assure you that all the necessary measures have been taken at the company level to ensure the confidentiality of your data, they being processed only by Rubeco personnel trained in the processing of personal data and authorized in this regard.

The operator that processes your personal data when you browse the online platform www.rubeco.ro is RUBECO DITRIBUTION S.R.L (hereinafter “Rubeco”) registered at the Trade Register under no. J40/6401/2019, CUI RO41114592, with registered office in Sos. Oltenitei, no. 2, ground floor, sector 4, Bucharest.

For any questions/concerns regarding the protection of personal data, you are invited to send a request to the postal address: Sos. Oltenitei, no. 2, ground floor, sector 4, Bucharest, or to the electronic correspondence address: office@rubeco. ro with the title “Personal data protection” or “GDPR”.

• Definitions

• “Personal data” means, in the sense of the national and international legislation in force, any information relating to an identified or identifiable natural person. An identifiable person is that person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, psychological, economic, cultural or social identity.

• For the purposes of this policy, the personal data that will be processed may refer to: name, surname, telephone number, e-mail address, residence/domicile.
• “Personal data processing” means any operation or set of operations performed on personal data, by automatic or non-automatic means, such as collection, registration, organization, storage, adaptation or modification, extraction, consultation, use, disclosure to third parties by transmission, dissemination or in any other way, joining or combining, blocking, deleting or destroying.
• In the sense of this policy, data processing refers to those processing carried out when you browse the website www.rubeco.ro or fill out the form available on the site.
• “Operator” means the person who, alone or together with others, establishes the purposes and means of personal data processing. For clarity, in the sense of this Privacy Policy, the Operator is the company RUBECO DISTRIBUTION.
• “Data subject” means the person whose personal data are the subject of processing. In terms of this Policy, the person concerned by the data processing is the user of the website rubeco.ro.
• “Consent” of the data subject means any free, specific, informed and unambiguous manifestation of the data subject’s free will by which he/she accepts, through a statement or an unequivocal action, that the personal data that they look to be processed.
• “Third party” means a natural or legal person, public authority, agency or body, other than the data subject, the operator, the person authorized by the operator and the persons who, under the direct authority of the operator or the person authorized by the operator, are authorized to process data personal.
• “Person authorized by the operator” means the person who processes personal data on behalf of the operator.

3. Categories of personal data processed

Browsing the www.rubeco.ro website involves the processing of two categories of personal data, namely:

1. a) personal data that you disclose to the Operator voluntarily (e.g. through the contact form/email), these being collected individually;
2. b) data that you provide involuntarily, by simply browsing our website.

Rubeco collects, based on the voluntary provision of the data subject, the following personal data: name (for identification), telephone number, e-mail address (for communication) and any other categories of personal data that the user can make Rubeco available through the contact form/email.

Distinct from the data collected through the form/email available on the site, the Operator can also process other data of the persons concerned, based on consent or in legitimate interest, including, but not limited to: domicile/residence, signature, contact person data or of the representative of the legal entity, etc. In general, such processing is carried out outside the platform, which is why specific processing rules will be applied to them.

Regarding the site, the categories of data processed through it are limited to those listed above.

The operator may involuntarily collect other personal data belonging to you, namely your IP address or data related to the searches performed on our site. This information will not be used to identify individuals and will not be made public other than under the conditions inserted in the Privacy Policy.

In certain situations strictly regulated by law, the Operator reserves the right to request additional information from you, accompanied by supporting documents, by email, in print or in any other way deemed appropriate by the Operator.

Note: Rubeco has concluded data processing agreements with affiliated companies, but is not responsible for the processing carried out by these entities, in its own name, the data subject being properly informed about the processing that involves a transfer of data between Rubeco and any company affiliated.

Your personal data can be communicated by Rubeco, under the conditions of the law, for the purpose of processing, to persons empowered with data processing, including banks, authorities and financial institutions, courts or competent bodies, at their request and for the purpose of providing Rubeco services.

4. The purpose and legal basis of the processing of personal data

Rubeco processes your personal data for the following purposes and with the following legal grounds:

1. a) the processing is necessary for the execution of a contract to which the data subject is a party or to take steps at the request of the data subject before concluding a contract (art. 6 para. (1) letter b) of Regulation (EU) no. 679/2016 of the European Parliament and of the Council of April 27, 2016), specifically, in order to ensure the access of the concerned person to the Rubeco services, found in the “CONTACT” section, by sending a message;
2. b) the processing is carried out based on the consent of the persons concerned (art. 6, paragraph (1), letter a) of Regulation (EU) no. 679/2016 of the European Parliament and of the Council of April 27, 2016), in the case of sending marketing communications;
3. c) the processing is necessary for the purpose of the legitimate interests pursued by the operator (art. 6 para. (1) letter f) of Regulation (EU) no. 679/2016 of the European Parliament and of the Council of April 27, 2016), for solving problems of any nature related to the content of the www.rubeco.ro website and for actions involving interaction with the online platform.

Your personal data will be processed for Rubeco to:

1. improve the website and the services provided through it;
2. determine the usefulness/popularity of the web content presented on the site;
3. send technical, assistance or administrative notifications;
4. honor requests and resolve complaints received from users;
5. facilitate the user’s access to Rubeco’s services and offers;
6. communicate information of interest to site users;
7. protect Rubeco’s rights.

The company will be able to perform anonymous registrations based on the information you provide, by excluding the data that leads to your identification. The purpose of anonymous registrations is to analyze requests, which will generate an improvement of our services and navigation on the site.

5. Duration of personal data processing

The personal data processed at the Rubeco level through the website www.rubeco.ro are retained for a reasonable period of time in relation to the purpose of the data processing, so as not to exceed the period necessary for their processing and in no case, more than 3 years from the moment of their collection.

6. Transfer of personal data

Your data are processed on the territory of the European Union, through secure internal servers.

Rubeco undertakes that the collected data will be processed only in accordance with the stated purposes and not to publish, sell, rent, license, transfer, etc., without authorization, the database containing information about the data of the persons concerned to any third party not involved in the fulfillment of the stated purposes , except for the situation in which the transfer/access/viewing/etc. is required by the competent authorities, in the cases provided by the legal regulations in force.

It is possible that your data will be disclosed to other companies that provide us with services and act as authorized persons, such as providers that provide website maintenance services, etc.

These entities are selected with particular care to ensure that they meet the specific requirements in terms of personal data protection. They have a limited capacity to use your information for purposes other than providing us with services.

In addition to the disclosures described in this Privacy Policy, we may transmit information to third parties to whom you consent or request such disclosure.

7. Links, hyperlinks, third party sites

The www.rubeco.ro site may contain links to third-party sites that may, in turn, collect your personal data, including through other technologies. In the case of connecting to a third-party website, Rubeco’s privacy policy will not be applicable in the case of your browsing on that website.

8. The rights of data subjects

Any natural person who browses our website, as a data subject, has the following rights in relation to Rubeco, as a Personal Data Operator:

• The right to information means the right of the data subject to receive any information related to the processing, in a concise, transparent and easily accessible form;
• The right of access means the right of the data subject to obtain a confirmation from the Operator that it processes or not the personal data concerning him and, if so, access to the respective data and to information regarding the manner in which the data are processed;
• The right to rectification refers to the right of the data subject to obtain from the operator the correction, without undue delay, of inaccurate personal data concerning him or to their completion, if they are incomplete. They can be modified by sending an e-mail to the address: office@rubeco.ro;
• The right to data deletion means the right of the data subject to obtain, from the operator, the deletion of the personal data concerning him, without undue delay, if one of the following reasons applies: they are no longer necessary to fulfill the purposes for which were collected or processed; withdraws consent and there is no other legal basis for processing; opposes the processing and there are no legitimate reasons to prevail; personal data were processed illegally; personal data must be deleted to comply with a legal obligation; personal data were collected in connection with the provision of information society services;
• The right to restrict processing. The data subject has the right to obtain from the operator the restriction of processing in the situation where one of the following cases applies:

1. a) the data subject contests the accuracy of the data, for a period that allows the operator to verify the accuracy of the data;
2. b) the processing is illegal, and the data subject opposes the deletion of personal data, requesting instead the restriction of their use;
3. c) the operator no longer needs the personal data for the purpose of processing, but the data subject requests them for establishing, exercising or defending a right in court; or
4. d) the data subject objected to the processing in accordance with Article 21 paragraph (1) of the GDPR, for the period of time in which it is checked whether the legitimate rights of the operator prevail over those of the data subject.

• The right to portability refers to the right to receive personal data in a structured format, currently used and that can be read automatically and to the right for these data to be transmitted directly to another operator, when the processing is based on consent or the execution of a contract and is carried out by automated means, if this is technically feasible;
• The right to opposition refers to the right of the data subject to oppose the processing of personal data concerning him/her when the processing is carried out for the performance of a task that serves a public interest or when it is necessary for the purpose of the legitimate interests pursued by the Rubeco operator;
• The right to object to data processing based on automatic individual decisions refers to the fact that the data subject has the right not to be the subject of a decision based exclusively on automatic processing, including the creation of profiles, which produces legal effects concerning the data subject or similarly affects it to a significant extent. However, it will not be possible to exercise this right if the decision is necessary for the conclusion or execution of a contract between the person concerned and Rubeco, is authorized by Union law or internal law applicable to Rubeco, provided that adequate protection of rights is ensured , liberties and legitimate interests of the concerned persons; or it is based on the consent of the person concerned obtained in compliance with the legislation in force.

To exercise the rights provided above, as well as for additional information, the data subject can contact the Data Protection Officer within Rubeco, by sending a request by e-mail to office@rubeco.ro or by sending a request to the address of the company in Soseaua Oltenitei no. . 2, ground floor, sector 4, Bucharest.

Also, the data subject has the right to file a complaint with the National Authority for the Supervision of Personal Data Processing (Bucharest, Bd. G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336; Phone: +40.318.059.211 /+40.318.059.212; Fax: +40.318.059.602; E-mail: anspdcp@dataprotection.ro) and the right to go to court.

9. Final provisions

If Rubeco deems that a change to the confidentiality rules is necessary, we will publish those changes to inform the persons concerned about the information we collect and how we use it.