PRIVACY POLICY

ON THE PROCESSING OF PERSONAL DATA

Updated: July 2024

 

Who are we?

PartnerVet is operated by Vet Opco S.R.L. with CUI 49826960, with headquarters in Bucharest, 1st Sector, Haga street, no. 12, a company registered in Romania offering business management consulting services.

We value your privacy. This information is addressed to you as a user of our website https://partnervet.ro(the Website), regardless of your other capacity (potential partner, employee/collaborator/representative of a potential partner/partner). It explains how we use and protect the personal data you provide to us while using the Website or communicating with us in order to enter into a relationship with us or to send us certain requests.

We process your personal data in line with the relevant legal provisions, in particular by aligning with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (“GDPR“), as detailed below.

This policy does not cover the partnership relationships themselves which are described in the policy made available to you. if we get to the point of collaboration.

What data do we process?

We process the following categories of personal data:

• Identifying data: name and surname, position, type of control in the firm, beneficial ownership, company, object of activity, length of time in the market;
• Contact details: e-mail address, telephone number; company address;
• Company data: age, specialization, facilities, profit, number of employees, etc.
• Data on professional training: certifications, seniority, specialization, diplomas;
• Data relating to our relationship with you: any information contained in your requests/complaints, such as: dissatisfaction with the way our staff handled your request, etc.;
• Website navigation data: IP, preferences, pages visited.

• Any other information you request/supply us. or the person acting on your behalf.
• Inferred data: data we generate based on data you provide. or data in our systems.

Where do we get your data?

• we get your data directly from you. when you submit them to us through the Website or by contacting us at any of our contact details.
• we can obtain data about you. from your employer/employee who wants to be our partner, from representatives of the company/employees/collaborators of our potential partners.
• We may collect contact data from public sources (Linkedin profile of the company/person, Facebook, Instagram and other similar sources/platforms, company databases) in order to respond to you, to the extent that we are unable to contact you at the contact details you have provided or in the process of establishing partnerships.
• we can generate data about you. from our own systems and records. For example, if you tell us about certain problems you encounter in communicating with us, we can generate information about previous requests and how they were resolved.
• from public authorities or institutions, for example in the context of court requests, requests related to complaints lodged by you. (in which case we may learn certain information about you).

What do we use your data for?

1. Contract conclusion and performance

In order to facilitate the conclusion of partnerships, communicating with the user and sending information messages on the stages of negotiation, providing clarifications on the conditions for concluding a partnership, in general, information on the status of negotiations, checking potential partners). For this purpose we may collect the following data, to the extent necessary: Identification data: first and last name, position, type of control in the firm, beneficial ownership, company, subject matter, length of service; Contact data: e-mail address, telephone number; firm address; Data on the firm: age, specialization, facilities, profit, number of employees, etc. Data on professional training: certifications, seniority, specialization, diplomas; Data on our relationship with you: any information contained in the requests.

Grounds: to take steps to conclude the partnership contract with you and our legitimate interests: to verify the fulfillment of the contracting conditions by potential partners and to confirm the information provided from public sources, to ensure the quality of our services and proper relationship management with potential partners; to keep proper records of partnership applications and related contractual relationships; to communicate properly with you. during negotiations; that is, to comply with certain legal obligations imposed in the context of negotiations.

How long we keep your data (depending on the specific situation):

• data closely linked to the negotiations will be kept for the duration of the negotiations plus at least 3 years after termination;
• in the event of litigation/investigations/proceedings, data and documents will be kept for the duration of the litigation/investigation/proceedings, and for 3 years after the final settlement.

What happens if you do not provide us with the data in the standard forms and/or requested by our colleagues: the data we request from you are mandatory for the proper conclusion/modification and execution of the orders placed. Refusal to provide those data that we have indicated as mandatory may prevent the conclusion of the partnership, affect its proper execution, lead to the cancellation of the order or block the delivery of the product to you.

 

2. To monitor traffic and improve your website experience

When you visit our Website, we may use cookies and/or similar technologies to collect technical information that may identify the user, such as your IP address, the type of internet browser used to browse the Website, your operating system, the domain name or host of the domain through which the user browses the Website.

The main purpose of using cookies is to help you have a better browsing experience and also for advertising purposes, so that we can provide you with individualized content tailored to your interests and preferences. As a result, to the extent that you have consented to the use of different categories of cookies or other similar technologies, we will use them to provide you with a personalized and relevant browsing experience and to understand how you interact with our advertising content.

For more information on the use of cookies on the Website and the purposes for which they are used, as well as on the possibilities to control and/or disable cookies, please consult our Cookie Policy for the Website, accessible at the following address: https://partnervet.ro/politica-cookies/.

Basis: The processing of your data for this purpose is based on the legitimate interest of PartnerVet to ensure the proper functioning of the Website as well as to continuously improve the visitor experience including by resolving various questions or complaints for the necessary functionalities (necessary cookies) respectively your consent for other cookies and technologies that ensure performance, functionality or marketing cookies.

Data collected through the Website may be used for any of the purposes indicated below, depending on their relevance (e.g., data provided for a possible partnership to establish a partnership relationship with you, data provided through other requests/complaints in order to handle your requests and inform you according to the law, data collected through cookies for functionality and improvement of our website and your experience, etc.)

 

3. Establishing a partnership relationship

What data we use: identification data, contact data, company data, training data, cookie permission and the date and time of its collection, and any other data in these categories that you provide to us in order to enter into a partnership with us.

On what grounds we process your data:

• taking steps to conclude and execute the partnership contract;
• our legitimate interests to respond to requests to establish partnerships and to request information for their establishment.

How long we keep your data (depending on the specific situation):

• as long as we are in a partnership relationship, and for a period of 3 years after the end of the partnership; if we do not collaborate, for a period of 3 years after communicating with you.
• for the duration required by law, if the legal time limits become applicable in the context: e.g., a public authority asks us to keep your data for a certain period.

 

4. Communicating with you and dealing with your requests

What data we use: Identification Data; Contact Data; Company Data; Professional Training Data, Data relating to our relationship with you, and any other information you or the person acting for you request/supply to us.

On what grounds do we process your data: our legitimate interests: to ensure optimal and easy communication with partners/users, to provide partners with an easy communication channel; to ensure efficient management of partners/potential partners and to improve PartnerVet’s performance indicators, i.e. to fully resolve your requests.; to defend our rights and interests and to investigate internally or with our partners any issues raised; your consent by submitting documents/information to us; specific legal obligations: where there are legal provisions requiring certain processing – e.g. a request from the authorities in the context of a control, complaints.

How long we keep your data (depending on the specific situation):

• 3 years from the settlement of your request;
• for the duration of official proceedings in relation with you, your authorities, your representatives and for a period of 3 years after their completion, respectively for the duration of any related litigation and 3 years after their completion;
• for the duration required by law.

What happens if you do not provide us with the data in the standard forms and/or requested by our colleagues: The data we request from you is mandatory for the proper handling of your requests. Your refusal to provide that data may prevent or affect the full handling of your request (e.g. refusal due to lack of sufficient information, delays, partial settlement, etc.).

If you choose to contact us through another communication channel operated by a third party (e.g. WhatsApp, Facebook) we will share your data. personal with the owner of this channel to confirm that you are a user of this service. We recommend that you check the privacy settings and read the privacy policy of the respective operators to get more detailed information on how they use the personal data of the users of the services they provide.

 

5. Improving relationship with you. and our services

In order to perform various analyses, internal reporting on the functioning of the Website, basic profiling of your data. demographics and browsing preferences, for marketing purposes, mainly in order to improve the experience offered by the Website. This analytical data is aggregated data that cannot directly identify you.

Basis: The processing of your data for this purpose is based on PartnerVet’s legitimate interest to continuously improve the experience of Website users and potential partners and to help us understand their needs and expectations regarding the services offered on the Website. Providing your data for this purpose is voluntary.

How long we keep the data: the data underlying the analyses extracted from the main databases will be kept for a very short period of time until the aggregated analyses are generated.

Refusal to provide data for this purpose will not have negative consequences for you.

 

6. Analysis on the performance of the Website and our team

To carry out various internal analyses regarding our Website and the performance of our team, respectively the image of our company in the market, to improve the quality of our services, to develop our services, to adapt our services/Website to your requirements.

We use the following data: identification data; contact data; data concerning our relationship with you.

Grounds: our legitimate interests to know the opinion and preferences of users regarding our services or those of other similar providers, as well as to optimize our work and identify new opportunities to develop and promote our services and business in general; your consent. expressed in the context of the surveys/market studies we conduct. Your participation in such surveys or market research is voluntary. Accordingly, it is your choice whether or not you provide us with your data by filling in the participation forms on our website or other similar forms provided in those surveys or studies.

We will ensure that we use personal data only if such use is necessary for the fulfillment of the intended purpose. As a rule, the results of internal analyses and studies are anonymized.

Where we may obtain the above data: in general, we use data that we either: receive from you. (directly or through our partners – such as marketing, promotion and market research agencies), or we generate or infer them on the basis of information we hold about you.

How long we keep your data (depending on the specific situation): in the case of data underlying studies, surveys, analyses with anonymized results – for the time necessary to transform them into anonymized statistics, but not more than 6 months after the survey/market research or internal analysis/study. If not anonymized, the results of the studies, surveys, analyses will be kept for 1 year from the date of their generation and will not be made public.

What happens if you do not provide us with your data: if you do not wish to participate in our surveys or studies or, where applicable, provide us with certain information for this purpose, we may not implement or take into account certain of your suggestions. or other issues of interest to you. In any case, your participation refusal will in no way affect your relationship with PartnerVet.

Certain surveys may be conducted through our Website. For data processed via cookies and new technologies in this case see our Cookies Policy here: https://partnervet.ro/politica-cookies/.

 

7. Defense the rights and interests of PartnerVet and our users

We use any of the categories of data from the PartnerVet systems mentioned above, appropriate to the type of official procedure/investigation/litigation/audit.

Foundations: our legitimate interests to defend our rights and interests in the context of situations where PartnerVet’s image and interests would be exposed or affected, i.e. to keep evidence of our rights and interests as well as our compliance with specific legal obligations (e.g. resolution of complaints within the legally required timeframe or data protection, manner of resolution, identification and proof of identification of users/their representatives before providing data subjects’ data, etc.); our legal obligations, such as complying with requests from public authorities/bodies/other public institutions that have the power to impose certain processing operations on us; obligation to archive certain documents/information according to PartnerVet’s archiving rules or other applicable PartnerVet regulations; obligation to notify confidentiality/security incidents to the competent authorities, etc.

Where we can obtain the above data: from any of the sources mentioned for the above purposes, as well as from the authorities, institutions or courts involved.

How long do we keep your data (depending on the concrete situation): for the duration required by specific legal provisions; where there are no rules, for the duration of the procedure/audit/investigation/litigation, and for a period of 3 years from its conclusion respectively, taking into account the limitation period applicable to the concrete situation; for the duration required by the competent authority/institution/body, as required by law; for the duration requested by you. to defend your rights and interests. or of a third person who has a legitimate interest therein.

What happens if you don’t provide us with your data: in certain situations, refusing to provide us with your data may make you liable. contractual or civil in relation to PartnerVet, other persons whose rights/interests would be affected.

 

8. Compliance legal obligations

For the fulfillment of PartnerVet’s legal obligations in the context of the services provided through the Website, including the manner of handling any requests/complaints.

Any of your above data may be processed. For specific data protection obligations we will generally use: Identification Data, Contact Data, Data relating to the relationship with you.

Grounds: The processing of your data for this purpose is necessary on the basis of legal obligations where the law expressly provides for the processing of certain data – e.g. the obligation to archive certain documents/information in accordance with archiving rules or other applicable regulations; the obligation to notify privacy/security incidents to the competent authorities, or our legitimate interest to comply with legal obligations involving certain processing operations where the law does not specify exactly what data will be processed, such as to comply with requests from public authorities/bodies/other public institutions that have the power to impose certain processing operations on us.

What happens if you don’t provide us with your data: in certain situations, refusing to provide us with your data may give rise to contractual or civil liability in your relationship with us, or even lead to the termination/non-termination of our partnership with you, if we are talking about data that is binding for our relationship.

If you are a representative/employee of a legal entity Business Client (e.g. S.R.L., S.A. other legal entities other than self-employed natural persons), all the above-mentioned purposes will apply to you accordingly, strictly to enable their realization for the partner you represent/for whom you are the contact person. For these purposes we will process the following data about you: Identifying Data, Contact Data, Professional Background Data, Inferred Data (e.g., date and time of interactions with you, gender).

Grounds: our legitimate interests as described under the purposes above and our specific legal obligations, where applicable (e.g. the obligation to archive certain documents that may include your data). The other details from the above purposes will apply accordingly.

 

Who do we disclose data to?

We will mainly communicate your data. personal data to third parties, solely for the purpose of ensuring the optimal performance of our relations with you. and their performance of the contracted services, but also in order to fulfill specific legal obligations. In each case, data that is strictly necessary for the provision of the services or that we are obliged to provide will be disclosed.

Potential recipients:

• audit firms;
• public and regulatory authorities, governmental bodies, the courts – if necessary (including if we are required to do so by law) or, where applicable, a third party entity or organization – if such disclosure is necessary to comply with any applicable legal provisions, or other legal or regulatory requirements (e.g, in the event we receive such a notification and/or address from central or local public authorities or in connection with pending litigation pending before the Romanian courts, i.e. for the fulfillment of our tax reporting obligations, disclosure to the ANSPDCP in the context of a complaint);
• third party consultants (e.g. external lawyers, auditors, experts), where we involve them in litigation or disputes relevant to us or other activities requiring their professional expertise;
• software/hardware and IT support service providers; equipment/network installation and maintenance service providers; server maintenance service providers – e.g. for storage, IT incident remediation;
• call center service providers – to answer your questions, requests or complaints;
• archiving service providers;
• Individuals complaining about certain situations, incidents concerning you if there is a justification for receiving access to the data and granting access would not affect your rights.
• print service providers;
• Business users individuals, for their personal data;
• Our electronic communication service providers – chat platforms, customer interaction applications, e-mail or automated message platforms;
• Providers of surveys or market research/user surveys – to conduct surveys or market research, satisfaction surveys or to obtain feedback from our users about our services.

 

Where do we transfer data and automated decision-making processes?

Data is processed and stored in the European Union or in countries recognized as providing an adequate level of protection.

For the purposes described here, we do not use automated decision-making processes.

 

What are your rights?

One of the main objectives of the GDPR is to protect and clarify the rights of individuals with regard to the protection of personal data. This provides you with a number of specific rights that you have in relation to the processing operations we carry out:

Right of access
means that you have the right to obtain a confirmation from us as to whether or not we are processing your personal data and, if so, access to that data and information on how the data is processed. You also have the right to obtain a copy of the personal data provided to us and subject to processing (we would like to inform you that for any other copies requested by you, a reasonable fee based on administrative costs may be charged).

Right to data portability
refers to the right to receive personal data in a structured, commonly used and machine-readable format and the right to have these data transmitted directly to another controller, if technically feasible.

Right to object
concerns the right to object to the processing of personal data when the processing is necessary for the performance of a task carried out in the public interest or when it serves a legitimate interest of PartnerVet. Where the processing of personal data is for direct marketing purposes, you have the right to object to the processing at any time.

Right to withdraw consent
refers to cases where we have obtained your consent to process your data. personal data for certain activities (e.g. for direct marketing purposes), you may withdraw that consent at any time and we will cease to carry out that particular activity unless we consider that there is an alternative lawful basis to justify continuing to process your data. personal data for this purpose, in which case we will inform you about this condition.

Right to rectification
refers to the correction, without undue delay, of inaccurate personal data. The rectification will be communicated to each recipient to whom the data have been transmitted, unless this proves impossible or involves a disproportionate effort. The right to rectification of personal data and we will inform you of these recipients if you so request.

Right to erasure
(“the right to be forgotten”) means that you have the right to request that we delete your personal data, without undue delay, if one of the following grounds applies:

• they are no longer necessary for the purposes for which they were collected or processed;
• you withdraw your consent and there is no other legal basis for the processing;
• you object to the processing and there are no overriding legitimate grounds;
• personal data has been processed unlawfully;
• personal data must be deleted to comply with a legal obligation;
• personal data were collected in connection with the provision of information society services.

In doing so, we will notify each recipient to whom personal data has been disclosed of any deletion of personal data, unless this proves impossible or involves disproportionate effort, and we will inform you of these recipients if you so request.

In close connection with the right of access and rectification/completion/deletion of personal data, PartnerVet offers registered users on the Website the possibility to view, rectify/complete/delete personal data through their personal account in the “My Account” section.

Right to restriction of processing
may be exercised in one of the following cases:

• when you contest the accuracy of the data, for a period that allows us to verify the accuracy of the data;
• processing is unlawful and you object to the deletion of your personal data, requesting restriction instead;
• if Sport Vision no longer needs your personal data for processing purposes, but you ask us to collect, exercise or defend a right in court;
• if you have objected to the processing for the period of time during which our legitimate rights are checked to see whether our legitimate rights prevail, in which case we will explain our reasons to you in full.

In doing so, we will notify each recipient to whom personal data has been disclosed of any restriction on processing, unless this proves impossible or involves disproportionate effort we will inform them of these recipients if you so request.

All these rights can be exercised by a written request, signed and dated, sent to our office or by email, the necessary contact details can be found below.

Upon request, you will receive from us a copy of the personal data processed; you may request and receive a response from us in any way you wish. (including email). Please note that your right to request a copy, as set out above, must not prejudice the rights and freedoms of others.

 

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

Right to complain to the supervisory authority
– if you consider that your rights regarding your personal data have been breached, you can also contact and lodge a complaint with the local data protection authority either by email at anspdcp@dataprotection.ro or by post at B-dul G-ral. Gheorghe Magheru nr. 28-30 Sector 1, Bucharest.

 

CHANGES TO THIS POLICY

This Privacy Policy is subject to change from time to time and may be updated by PartnerVet at any time and as necessary. But in all cases, we will inform you accordingly.

 

CONTACT

For questions related to the protection of personal data, to exercise your rights or to register a complaint, please contact PartnerVet by sending an e-mail to: dpo@partnervet.ro