1. ABOUT US
This policy describes why and how we process your personal data and provides information regarding your rights when Atlas acts as a personal data controller.
This policy does not include the processing carried out by the commercial partners of Atlas. The way your personal data are processed by our partners, acting as controllers, please refer to their policies regarding the processing of personal data.
3. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
We collect your personal data in order to achieve the purposes of Atlas, in accordance with section 4 below. We do not collect or intend to get in possession personal data related to racial or ethnic origin, political, religious, philosophical or similar beliefs, trade union membership or personal data regarding health or sex life.
3.2. If you are a visitor of our pages on social media, we may process personal data included in your reaction with our posts, including in messages received from you, such as first and last name, username or other data you provide to us.
3.3. If you are interested in our services, to contact us or participate to our training sessions, we will process the data you provide us to the extent that you fill out the form, such as first and last name, contact details (email address, phone number) and any other data included in your message.
3.4. If you are the contact person or the legal or conventional representative of one of our corporate clients, we will process your data, such as first and last name, e-mail address and telephone numbers, role/function, workplace address, information you provide in the context of starting or during the contractual relationship. At the same time, we can obtain your contact details within our referral programs, from the visitors of our Site, while making sure that the person supplying the contact details has previously obtained your approval for such an action.
3.5. If you contact us by phone, we will process your data, such as first and last name, phone number and any other data that you will provide voluntarily.
4. WHAT ARE PERSONAL DATA USED FOR AND WHAT ARE THE GROUNDS FOR PROCESSING?
In general, we collect personal data directly from you.
We may use personal data for one or more of the purposes described in this policy. If we subsequently process your personal data for a purpose other than those on which you have already been informed and which are not compatible with the purposes for which your data was originally collected and which was brought to your attention, Atlas shall provide information on that secondary purpose and any relevant additional information.
We will process your personal data in the following manner:
4.1. For statistics and improving our Site performance. We will collect and use data through cookies only if we have your consent. Providing your data for this purpose is voluntary. Your refusal to provide the data for this purpose will have no consequences for you.
4.2. For taking security and fraud prevention measures to protect your personal data and the Site, measures that involve detecting, investigating and solving security and fraud threats. The processing of your data for this purpose is based on the Atlas’ legitimate interest in ensuring the proper functioning of the Site, in defending our rights and interests.
4.3. For processing your requests related to accessing/using our services. The processing of your data for this purpose is based on the contract concluded between you and Atlas, or to take steps at your request prior to entering into a contract with Atlas, as well as Atlas’ legitimate interest to initiate and have contractual relationships with your employer for offering the services provided by us. Your refusal to supply the data for this purpose may have as consequences our impossibility to provide and carry out our services.
4.4. For settling complaints and answer to requests. Processing your data for this purpose is based on Atlas’ legitimate interest to answer various questions or complaints received by email, phone or through the contact form.
4.5. For direct marketing and other commercial communications with clients. Processing your data for this purpose is based on our legitimate interest to send communications meant to ensure the promotion and development of the Atlas business and, at the same time, to facilitate the access of its clients/ to services offered by Atlas that could be useful or of interest for their businesses.
4.6. For direct marketing and other commercial communications with potential clients. We will only send you such communications if we have obtained your consent. We want to keep you up to date with our offers. We may send you promotional materials to inform you about our or our partners’ services. Providing your data for this purpose is voluntary. Your refusal to provide the data for this purpose will have no consequences for you.
4.7. To fulfil certain legal obligations. We have the legal obligation to keep accounting records and archiving data in accordance with the existing legislation that involve the processing of personal data.
4.8. For ascertaining, exercising or defending a legal right during a procedure before a court of law, of an administrative procedure or any other formal proceedings involving Atlas. The processing of your data for this purpose is based on our legitimate interest to defend our rights and interests.
5. TO WHOM DO WE DISCLOSE YOUR DATA?
Atlas may transfer/grant access/disclose personal data to the extent necessary, mainly to the following categories of persons/entities:
a) service providers and subcontractors (such as, various service providers with whom we collaborate, companies providing courier services, companies providing archiving services, companies providing IT services, software or hardware providers, marketing companies, market research companies, etc.);
b) authorities and public entities, if disclosure is necessary to comply with an obligation under the applicable law;
c) courts or arbitral courts, as well as authorities competent to investigate criminal acts perpetration.
As a rule, the transmission of your personal data to the abovementioned recipients will be done only based on a commitment of confidentiality and a commitment of ensuring the adequate level of security by such recipients, guaranteeing that personal data are kept safe and that their transmission is carried out in accordance with the legislation in force.
6. TRANSFER OF PERSONAL DATA
Datele cu caracter personal furnizate de tine pot fi transferate în afara României, dar doar către state din Uniunea Europeană.
Personal data provided to Us may be transferred outside Romania, but only to European Union states.
In exceptional cases, if Atlas transmits your personal data to a third country or an international organization, we shall ensure that they are adequately protected, respectively that we transmit data to a country that provides an adequate level of protection as assessed by the European Commission, or if the respective country is considered not to have laws equivalent to EU data protection standards, we shall ask the third party to conclude a legally binding contract/agreement/instrument that reflects such standards or to provide other appropriate safeguards in this regard (such as standard contractual clauses issued by the European Commission).
You may request a list of recipients from third countries, as well as a copy of the agreed provisions that ensure an adequate level of protection of personal data, at e-mail address firstname.lastname@example.org.
7. DURATION OF THE PROCESSING
In general, we will process your personal data as much as it is necessary for the processing purposes mentioned above (including in accordance with the applicable law or regulations). Therefore, personal data will be stored:
a) during the contract/legal relationship with Us, for the personal data necessary for its execution; in certain specific cases, we may keep your data for an additional period that is reasonably necessary to exercise or protect our rights in connection with the products/services offered and the personal data processed;
b) for the duration provided for by law in situations where there are applicable legal provisions in this respect (e.g. in case of mandatory accounting books and supporting documents underlying financial accounting records, such as invoices issued by Atlas);
c) with respect to statistics and improving the Site’s performance, we will keep in our database data from cookies as long as we have your consent;
d) up to 3 years for performing analysis regarding the security and preventing fraud on our Site ad your interactions with the Site;
e) with respect to commercial communications sent by Atlas or its partners, we will keep your email address or phone number in the database as long as your subscription is active; once we receive your unsubscribe request, we shall stop sending such communications to your email address or phone number;
f) with respect to the contact form, we will keep your personal data for the period necessary to provide answers to your messages and requests and to prove the correspondence with you;
g) for the period needed to ascertain, exercise or defend a legal right during a procedure before a court of law, of an administrative procedure or any other formal proceedings involving Atlas.
Any data may be retained by us, by way of exception to the previous provisions, where appropriate, until the expiry of the legal prescription period, in respect of situations in which Atlas would have a legitimate interest in retaining certain personal data in connection with a potential dispute which might arise between the parties, for example in the context of the possible liability of Atlas or the data subject for processing.
Atlas may delete or anonymize your personal data when it considers that they are no longer necessary for the purposes for which they were collected.
However, if you withdraw your consent and there are no legal grounds for processing or you object to processing and there are no compelling and legitimate grounds for processing that prevail, we shall cease processing the data.
8. WHAT ARE YOUR RIGHTS?
Under the applicable law, you have the following rights:
Right of access: You have the right to obtain confirmation from us that your Personal Data are processed by us, as well as information on the specifics of processing, such as: purpose of processing, categories of data processed, recipients of personal data, period for which the data is kept, if it is transferred abroad and how we protect it, the source of your Personal Data.
b) Right to rectification: At any time, you have the right to request the rectification of your Personal Data. In the event of errors, after notification, we will immediately rectify your Personal Data.
c) Right to erasure: You have the right to request the deletion of Personal Data, provided that your request comply with applicable legal requirements. Personal Data will be erased when the legal requirements are met.
d) Right to restriction of processing: If the applicable legal provisions are met, you can request that we restrict the processing of Personal Data.
e) Right to data portability: If the applicable legal provisions are met, you have the right to provide Personal Data in a structured, commonly used and automatically readable format and the right to transmit it to another data controller.
f) Right to object: In certain situations, such as when we process Personal Data based on legitimate interest, you have the right to object to the processing of your Personal Data by us. In the event of unjustified opposition, Atlas is entitled to further process Personal Data.
g) Right not to be subject to decisions based solely on automated processing: If the applicable legal provisions are met, you have the right not to be subject to a decision based solely on automatic processing, including profiling, which has legal effects on you or affects you similar to a significant extent.
h) Right to address to the Supervisory Authority: You have the right to file a complaint with the National Authority for the Supervision of Personal Data Processing, in connection with any violation of your rights regarding the processing of your Personal Data. Contact details for the National Authority for the Supervision of Personal Data Processing: 28-30 G-ral. Gheorghe Magheru Blvd., 1st District, 010336 Bucharest, Romania; e-mail: email@example.com.
i) Consent withdrawal: To the extent that we process your Personal Data based on your given consent, you can withdraw your consent at any time, without affecting the legality of the processing based on the consent before its withdrawal.
j) Right to object to receiving commercial messages: You may also object to the processing of your Personal Data for the purpose of sending commercial messages.
When we receive a request from you to exercise any of your rights, we may ask for additional information to verify your identity before acting on the request.