Flashnet takes your privacy extremely seriously and respects your rights to personal data protection and privacy. This privacy policy concerns the personal data we collect through our website or other electronic environments (social media, email), as well as those we collect in live interactions (meetings, trade fairs, telephone or other interactions), including personal data we might receive through our partners (recruitment agencies).

Please read this Privacy Notice carefully to understand how we handle your personal information. If you don’t agree with our privacy policy please don’t use our website or don’t send us any of your personal data.

For any questions or requests concerning your personal data that we process, please contact us at dataprotection@flashnet.ro

1. Who we are

Flashnet SA is a Romanian limited liability company (hereinafter “Flashnet”, “we, “us” or similar) whose principal office is in Brasov, ROMANIA.

Due to the fact that we process your personal data through our website https://www.flashnet.ro/ (hereinafter “website”, “our website” or similar), other electronic means of communication (social media, email etc.) and also outside the electronic environment, we are a controller in accordance with (EU) Regulation 679/2016 (“GDPR”).

2. Definitions

According to the EU Regulation 679/2016 (GDPR), the next terms mean:

  1. Personal data: any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
  2. Data subject: A natural person whose personal data are processed
  3. Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
  4. Controller: any natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law
  5. Processor: any natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
  6. Consent: of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;.

 3. Personal data categories and their processing

Brief description

How we collect your personal data:

We collect your personal data:

  • Provided by you – personal data that you provide to us through the use of our contact form, on our social media pages, via email, on the telephone or in physical form (name, email address, phone number, other details that you communicate to us)
  • Observed by us – cookies, IP, geographic location, and information you made public on your social media profile which you use to engage with us
Cookie names Type of cookie First or Third party Can be blocked Session or Persistent Expiry Time Purpose
time Analytics Third party Session
__cfduid Analytics Third party Persistent 21 Jun 2019 12:49:40
NID Analytics Third party Persistent 21 Dec 2018 12:45:12
devicePixelRatio Analytics Third party Persistent 28 Jun 2018 12:35:46
__utma, __utmb, __utmc, __utmt, __utmz, _ga, _gat, _gid Analytics Third party Persistent
act, wd, xs, datr, sb, presence, c_user, fr, pl, reg_ext_ref, reg_fb_gate, reg_fb_ref Advertising Third party Persistent

Personal data categories that we process and the purposes of this processing:

The categories of personal data we process are:

  • Data obtained through your interaction with our website: IP, functional cookies, tracking cookies for Google and Facebook, data regarding the device you use to access our website. We use these data to assure our website’s functionality and to determine its efficiency, to analyse our audience and to promote our services in the online environment.
  • Contact information: Name, email address, phone number, company. We process these data if you provide it to us in order to communicate with you and to establish commercial relations if you want to become a client.
  • The content of the messages you send us: we process these data in order to be able to answer to your enquiries and also be able to provide you with accurate information.
  • Data from your CV: in the case you send us your CV or apply for one of our positions we will process the data in your CV to evaluate the compatibility with the position you apply for.

Lawfulness of processing

All situations în which we process personal data have a legal ground described în the EU Regulation 679/2016 (GDPR) 

Based on your consent – We process certain personal data such as profiling data and cookies for online advertising and email addresses for direct marketing purposes, based on the consent you have given us for these specific purposes.

Legitimate interests – We process certain personal data such as (functional cookies, contact information you provide to us, the content of the messages you send us, data from CV’s we receive) based on our legitimate interests to continuously develop the quality of the services we provide, respond to inquiries we receive and communicate with people interested in our services, sell our products/services and recruit new employees.

 

Personal data retention period

In order to respect the principle of “storage limitation” of GDPR, we only store personal data for the periods of time necessary for us to fulfill the purposes for which we process the data and to respect and legal obligations we have.

 

Transfer of personal data to third parties

We can send certain personal data to certain categories of third parties such as:

  • Web hosting provider
  • Marketing services provider
  • HR services provider

Below, we describe in detail what categories of data we process and how we do it, based on the three scenarios în which we will collect personal data from data subjects:

For HR and recruitment purposes

When you choose to send us a resume or you show interest in working with us, you send us personal data about you, your skills, your educational and professional path. We need this information to contact you and to evaluate your skills and knowledge in order to perform our recruitment process.

Categories of personal data, legal grounds for processing and the purpose of processing

  • Contact data (name, first name, email address, phone number).
  • History of studies and work experience
  • Skills and qualifications 

We process these data based on the basis of our legitimate interest in recruiting new employees and the basis of your consent for keeping them for another year if you are not employed by us but you wish to be contacted by us at a later date.

The purpose of these processing operations is the recruitment of new employees.

 

Source of personal data

We receive these data directly from you through one of the following methods:

  • CV is sent to us through our website, through recruitment platforms, via email or directly at our headquarters
  • Data you give us during the recruitment interview

The need for their disclosure and likely consequences if you do not provide them

We consider that we need this data to make an informed decision to select the right candidates for the position we want to hire someone for. If you do not provide this data, we will not be able to consider you for the recruitment process

Transfer towards third parties or countries and security measures

We reserve the right to share information with our HR consultants or HR outsourcing companies. Also, the online platforms we use in the recruitment and communication process might have access to the data you provide (social media networks through which you contact us, Google, Bestjobs, Ejobs, etc.). We do not transmit this data to other third parties or other countries without your consent.

Security measures. To reduce the risk of security incidents, we have implemented security measures such as:

  • Access control over the physical space of our headquarters
  • Securing electronic access through: secure servers, implementing strong password policies, IT security software, firewall, data protection training for employees, privacy obligations imposed on employees, limiting access to personal data
  • Security measures implemented by third parties we use, under contractual obligations

 

Retention period

  • In the case of accepted candidates we will keep these data for the duration of the employment contract and for the period necessary to comply with the legal provisions. 
  • In the case of rejected candidates, we will keep these data until after the recruitment interview, or, if they have given their consent, we will retain the data for another year after the interview for further contact.

 

Automatic decisions and profiling

These data are not used to make decisions following an automatic profiling process.

As a visitor on our website

By accessing our website you allow the technologies which contribute to the normal functioning of our website to collect certain personal data from you.

 

Categories of personal data, legal grounds for processing and the purpose of processing

Data from your interaction with the website (IP, geographic location data , cookies, data about the type of device used to access the website).

We process these data on the grounds of our legitimate interest in analyzing the audience and improving our website’s structure and content, to improve the relevance of the information we provide and to protect ourselves from cyber attacks and fraud.

We also process analytics and advertising cookies based on consent you give for these purposes.

The purposes of these processing operations:

  • continuous improvement of our services,
  • ensuring the website’s functionality and optimization
  • investigation and resolution of potential fraud or security incidents
  • market analysis and promoting our services online

 

Source of personal data

These data are personal data observed by us from your interaction with our website

The need for their disclosure and likely consequences if you do not provide them

  • Data which enables the proper functioning of our website

Providing this data is mandatory because it allows access to and use of our website. If you did not provide this data, you could not properly access or use the website.

  • Data for website optimization, analytics and advertising

Providing these data is not mandatory, you can choose if you want to give your consent for us to use. În the case you choose not to give us this data, you will not be able to receive advertising messages from us and we will not be able to analyse the way in which you interact with our website.

To give or retract consent for the use of these cookies please click here __link catre cookie management tool__

 

Transfer towards third parties or countries and security measures

The following third parties will be able to access these data: our web hosting provider, Google, Facebook.

The servers on which this data is stored are located within the European Union or are part of Privacy Shield, guaranteeing the handling of personal data according to GDPR standards.

 

Security measures.

To reduce the risk of security incidents, we have implemented security measures such as:

  • Access control over the physical space of our headquarters
  • Securing electronic access through: secure servers, implementing strong password policies, IT security software, firewall, data protection training for employees, privacy obligations imposed on employees, limiting access to personal data
  • security measures implemented by third parties we use, under contractual obligations

 

Retention period

We do not store cookies. Cookies are stored on your own browser and you can delete them at any time.

The only data we have access for a longer period of time (38 months) is the data Google Analytics provides us about how the visitors which have given consent for analytics cookies have interacted with our website.

 

Automatic decisions and profiling

We do not conduct any automatic profiling and we do not make decisions as a result of the automatic profiling of the processed data. However, external analysis and reporting services (Google Analytics) can use your data for complex profiling processes. To avoid this, we recommend one of the options below

  • Cancel the acceptance for analysis and marketing cookies from our cookie management application
  • Unsubscribe from cookies directly from your browser or navigate the Internet in ‘incognito’ mode provided by your browser

As a potential client / person who contacts us

When you choose to write us a message through the contact form on our website or interact with us on a social media platform, you offer us personal data about you. We need this information to be able to contact you and to provide you with a specific and comprehensive response.

Categories of personal data, legal grounds for processing and the purpose of processing

  • Contact data (name, surname, email address, phone number)
    We process these data on the basis of our legitimate interest in selling our services and answering your queries.
    The purpose of processing these data is public communication, answering to your requests in the most effective way and developing new business relationships.
  • Additional data (company, the content of your messages)
    These data can be processed if you show an interest in working with us.
    We process these data based on our legitimate interest in selling our services and answering your queries .The purpose of their processing is to respond as efficiently as possible to your requests and to prepare for the commencement of business relationships.

 

Source of personal data

We can receive these data directly from you or we can observe them from sources which are publicly available (social media platforms on which you contact us on)

 

The need for their disclosure and likely consequences if you do not provide them

We need this data to answer your questions or requests

In the event that you refuse to provide us with this data, we will not be able to contact you, respond to your questions or requests or develop new business relationships with you.

 

Transfer towards third parties or countries and security measures

We do not transmit this data to third parties or other countries without your consent.

Security measures. To reduce the risk of security incidents, we have implemented security measures such as:

  • Access control over the physical space of our headquarters
  • Securing electronic access through: secure servers, implementing strong password policies, IT security software, firewall, data protection training for employees, privacy obligations imposed on employees, limiting access to personal data
  • security measures implemented by third parties we use, under contractual obligations

 

Retention period

We will keep your personal information for as long as needed to be able to answer your questions and interact with you. If you are a customer or potential customer, we will process and keep your business information in our CRM/database, in order to develop and maintain a business relationship.

 

Automatic decisions and profiling

These data are not used to make decisions following an automatic profiling process.

4. Your Rights

According to the GDPR, all data subjects benefit from the following rights

  1. Right of access to data. You have the right to access your personal data to check the lawfulness of the processing or to find out what personal data related to you we are processing and why. If we process personal data related to you, you can request to receive this data
  2. Right to rectification. If we process your personal data and these are inaccurate, you can request for it to be rectified
  3. Right to erasure or “the right to be forgotten”. You may request the deletion of your personal data and we have an obligation to comply with this request in cases where this data is no longer necessary for the purposes for which we process it, if you withdraw the consent on which it our processing relies, if we are processing it based on our legitimate interests and we have no overriding legitimate interest to continue processing, the processing is unlawful or where there is no other legal basis for their processing
  4. Right to restrict processing. You may request the restriction of the processing of your personal data. In this case, we will not delete your personal data, but we will stop processing it.
  5. Right to data portability. You have the possibility to transfer your personal data from one operator to another or to ask us to transfer your personal data to you to use for your own purposes
  6. Right to object. You may oppose to the processing of your personal data for purposes such as direct marketing or other purposes based on our legitimate interests, such as profiling. 
  7. Right to not be subject to automated decision making and profiling which can bring harm . You have the right not to be the subject of a decision based solely on automatic processing that could have significant legal effects or which could affect you in a meaningful way

In addition to these rights, you have the right to withdraw your consent at any time where it is applicable.

If you wish to exercise any of the rights in the list above, please contact us at

You also have the right to file a complaint with the supervisory authority (ANSPDCP – http://www.dataprotection.ro/) about how your personal data is processed by Flashnet

5. Contact

For any questions or requests relating to personal data that we process from you, please contact us by email at info (at) flashnet.ro

Below, you can request for your personal data that's collected by this website sent to you in an e-mail.




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