Links respects your privacy and will protect your personal data that you provided us. We undertake to collect and use your personal data according to General Data Protection Regulation (GDPR).
This policy will inform you about the way we manage your personal data and it explains your personal data rights and the way that the law (including GDPR) protects you.
- Important information and details about Links
- The data that we collect
- How your personal data is collected
- How your personal data is used
- Sharing your personal data
- Disclosure of your personal data
- Data Retention
- Your legal rights
1. Important information and details about Links
This website is not intended for children and we don’t collect personal data from children.
This version was last updated on [18.07.2018].
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data that we collect
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
In order to provide our services, we collect or receive your personal information in different ways. Usually you choose what information to provide, but sometimes we need certain information from you to use, in order to be able to provide these services.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: (all or any of them):
- Identity data include surname, name, [username] or [similar indicator], job, [birth date] and sex.
- Contact data include billing address, delivery address, e-mail address and telephone numbers.
- Financial data include bank account and credit card details. [if necessary]
- Transaction data include details about payments to and from you and other details about the products and services that you contracted from us. [if necessary]
- Technical data include address [IP protocol], your connecting data, browser type and version, time-zone setting and localization, browser’s plug-ins types and versions, operating system and platform and other technologies that you use on your devices.
- Usage data include information about the way that you use the website, products and our services.
- Marketing and communication data include your preferences about receiving our communications and your preferences of communication.
[We also, collect, use and share Aggregated Date type of data, like statistics or demographic data. Aggregate data can be obtained from your personal data, but they are not considered personal data in legislation, because this data doesn’t show your identity, directly or indirectly. For example, we can mix up your using data in order to calculate the percentage of users that access a service or product of Links].
We don’t collect any special category of your personal data (this includes details about race, ethnicity, religious or philosophical beliefs, sexual life, sexual orientation, political opinions, function of syndicate member, information about your health and biometrical and genetic data). We also, don’t collect information about criminal convictions and offences.
If you fail to provide us your personal data
In case we have to collect personal data by law in order to execute a contract concluded with you or with the organizations that you are affiliated to and you fail in providing us this data when you are asked to, it is possible that we cannot execute the contract that we have (for example, to provide goods and services). In this case, it is possible to be necessary to cancel a product or a service that you have with us, but we will let you know if it is necessary in that moment.
3. How your personal data is collected
We use different methods to collect personal data also through:
- Different interactions. We collect your data when you voluntarily provide contact data through your correspondence with us (including mail, phone, e-mail, or other method of communication). These includes personal data that you provide when, for example:
- you take part to an event or campaign hosted by Links;
- you ask Links for offers or promotional materials;
- you give feedback to our services and products;
- you do or you offer to do services for us;
- Third parties or public sources It is possible to receive personal data about you from different third parties or public sources (public registers). These sources includes:
- Organizations and professional associations that you are affiliated to;
- Authorities or public institutes of any kind;
- Human resources companies;
- Credit institutes (for example when pay us through a payment order)
4. How your personal data is used
We only use your personal data when the law allows us. The most frequent, we will use your personal data in the following situations:
- In case we have to execute a contract concluded with you (or to be concluded with you);
- In case we have to execute a contract concluded with an organization, association or company that we are affiliated to;
- In case it is necessary for our legitimate interests (or for one of a third party’s) and your fundamentals interests and rights don’t exceed these interests;
- In case we have to comply with a legal obligation;
- In case you give us your prior express consent or on the basis of the correct proof of your consent provided by a third person who communicates these data to us.
The scope of using your personal data
We have presented below, in a table format, a description of every way we intend to use your personal data and which are the legal grounds for its processing. We also have identified which are our legitimate interests, where necessary.
Keep in mind that we can process your personal data based on many legal grounds, depending on the specific scope of using it. Contact us if you need details about the specific legal grounds for processing your personal data if in the table below are many of them.
|Scope/Activity||Category of personal data||Legal grounds of processing, including legitimate interest, where it’s necessary|
|Host event/campaign||(a) Identity data
(b) Contact data
In exceptional situations, we can process your data from your ID card (CNP, photo, series and number ID card)
|(a) the performance of a contract;
(b) legitimate interest;
(c) legal obligation;
|Processing and execution of a contract, including:
(a) Cost administration, fees, taxes;
|(a) Identity data;
(b) Contact data;
(c) Financial data;
(d) Transaction data;
(e) Marketing and communication data.
|(a) execution of a contract;
(b) legitimate interest;
(c) legal obligation.
|For administrating the relationship with you, including:
b) to demand feedback or participate to poll;
c) to communicate requests or any other aspects about our partnership.
|(a) Identify data;
(b) Contact data;
(c) Marketing and communication data.
|(a) performance of a contract;
(b) legal obligation;
(c) legitimate interest (in order to keep the registers updated and to analyze how clients use our products and services).
|For administrating the business and the website (including troubleshooting, data analysis, testing, system maintenance, support)||(a) Identity data;
(b) Contact data;
(c) Technical data.
|(a) Necessary for legitimate interest (business administration, IT administration);
(b) Necessary for a legal obligation;
|Suggestions communication and reviews regarding Links’ products and services which are of interest||(a) Identify data;
(b) Contact data;
|(a) Necessary for legitimate interest (business administration);
(b) On agreement basis
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your identify, contact, technical, using and profile data, in order to create an image of what we think that you need or may be of interest to you. This is the way we decide what products, services and offers could be relevant for you.
You will receive marketing communications from us if you requested information from us or if you gave us your consent to receive these communications and, in each case, if you don’t withdraw your consent.
You can ask us to stop sending you marketing messages in every moment, by sending an e-mail at the email@example.com address or using the UNSUBSCRIBE link from newsletter.
In case you opt out of receiving these marketing messages, it is possible that we will continue to process your personal data, on other legal ground.
Changing the scope
We will only use your personal data for the scopes that we collected for, except the case we consider reasonable that we must use them for another reason and that reason matches with the initial scope. If you want to receive an explanation of the way you’re the processing for the new scope matches with the original scope, please contact us.
If we have to use your personal data for unrelated scopes, we will let you know and we will explain you the legal base that allow us to do this.
Please, remember that we can process your personal data without your consent, according to the presented rules, where this is required or permitted by law.
5. Disclosure of your personal data
It is possible to share your personal data with the parties presented below, for the scopes established in the table at point 4.
- Intern third parties, as they are defined in the Glossary.
- Extern third parties, as they are defined in the Glossary.
- Third parties that we choose to transfer or merge parts from our business or our assets. Alternatively, we can search to buy other businesses or to merge with them. If a change come up to our business, then the new owners can use your personal date in the same way as in the one described in this privacy notice.
We request all third parties and partners to respect the security of your personal data and treat them according to the law. We don’t allow third parties to use your personal data for their personal scopes. They can use your personal data if only we allow them to process it and just for the scopes we mentioned.
6. The privacy of your personal data
We implemented security measures to prevent the accidental loss of your personal data, use or unauthorized access, editing or sharing your personal data. In addition, we limit the access to your personal data for those employers, agents, contractors and other third parties who have a business need to know this data. They will only process your personal data according to our instructions and will make the object of a privacy obligation.
We established procedures to manage any suspected personal data breach and we will inform you and any authority about a breach in case we are forced by the law to do this way.
7. Data retention
How long do we keep your personal data?
We will keep your personal data as long as it is necessary to fulfil the scopes for which they were collected for, including the scope of reaching every legal, financial or report request.
In order to correctly determinate the period for keeping your personal data, we took in consideration the value, origin and the sensitivity of your personal data, potential risk of injury caused by unauthorized use or sharing of your personal data, scopes for which we process your personal data and if we can fulfil these scopes trough any other meanings.
8. Your rights
[Request correction of your personal data]
[Request erasure of your personal data]
[Object to processing of your personal data]
[Request restriction of processing your personal data]
[Request transfer of your personal data]
[Right to withdraw consent]
[The right to not be subject to a decision based only on automated processing, including profiling]
If you want to exercise any of the rights enlisted above, please fill the related form and send it to us. You can find here the complete list of forms.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Intern third parties
Other companies in the Links group acting as as controller or processors and which have their headquarters in Romania, Links’ associates, employers or contractors.
Extern third parties
- Services providers who supply administration and managing services of IT systems.
- Professional consultants including lawyers, accountants, bankers, audits and insurance workers who perform services such as consultancy, banking, juridical, insurance and accounting.
- The authorities and public institutes of regulation and other public authorities from Romania or European Union.
- Contractors or business partners that Links works with in order to perform their services.
You have the following rights:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
The right to rectification your personal data allows you to request the correction of your personal data which we keep. This right allows demanding the correction of each incomplete or inexact data that we have. Please, take in consideration that it is possible to be necessary to verify the validation of the data that you provide us.
The right to erase your personal data. That allows you to request to erase or to eliminate your personal data if there are no more reasons to continue the processing. Keep in mind though, that is possible not be always able to fulfil your request of erasing, based on specific juridical reasons, that will be notified, if it is necessary, at the moment of the request.
The right to object against processing your personal data when we process data having as basis, the legitimate interest (ours or one of a third party) when in your particular situation you consider that your fundamental rights and liberties are violated. As well, you can object to processing your personal data in a marketing scope. In certain situations we can prove legitimate and imperious reasons that justify the processing and stands on personal interests, rights and liberties.
The right to request the restriction of processing your personal data. This right allows you to request to suspend the processing of your personal data in the following situations: (a) if you want to establish data accuracy or validation or; (b) in the case that our processing of your personal data is illegal, but are against erasing it; (c) in case you need us to keep your data, even if we don’t process it anymore, because you need it for finding, exercising or defending rights in the court of law; or (d) you are against processing your personal data, but we have to verify if we have imperative legal grounds to process it.
The right to data portability. We will provide you or a third party that you have chosen, your personal data in a structured format, commonly used, that can be read automatically. Keep in mind that this right is applied to automatic processing of your data for which you gave us your agreement or, in the situation that we used your data, to exercise a contract with you.
The right to withdraw your consent when we are processing the data based on your agreement. Although, this right won’t affect the legality of your processing that were done before consent withdrawn.
The right to not be subject to a decision based only on automated processing, including profiling, that will cause juridical effects which will harm you in a similar manner.