Last updated: June 2024

General information

The confidentiality of your personal data is one of the main concerns of ITOTB Tech Solutions SRL, based in Bucharest, Sector 4, Str. Luica, nr. 45, Bl III\7, sc 2, et.4, ap 72, as data controller.

This document is intended to inform you about the processing of your personal data in the context of your use of the www.itotb.ro website. (the "Site")

Categories of personal data processed

If you are a visitor to the Website, ITOTB Tech Solutions SRL will process your personal data that you provide directly in the context of your use of the Website, such as the data you provide in the contact/questions/complaints section, to the extent that you contact us in this way.

Purposes and grounds for processing

If you are a visitor to the Site, ITOTB Tech Solutions SRL processes your personal data as follows:

• for marketing activities, respectively for the transmission, through remote communication means (e-mail, sms), of commercial communications regarding the products and services offered by ITOTB Tech Solutions SRL, through the Site.

Basis: The processing of your data for this purpose is based on your consent if you choose to provide it.

You can express your consent to the processing of data for this purpose by filling in and ticking the appropriate box in the newsletter subscription form available on the Site. To unsubscribe from receiving such commercial communications, you can use the option at the end of each e-mail/sms containing commercial communications.

The provision of your data for this purpose is voluntary. Refusal to provide consent to the processing of your data for this purpose will not have negative consequences for you.

• to resolve complaints, claims and to monitor traffic and improve your experience on the Site.

Basis: The processing of your data for this purpose is based on the legitimate interest of ITOTB Tech Solutions SRL to ensure the proper functioning of the Site, as well as to permanently improve the experience of visitors to the Site, including by resolving various comments, questions, or complaints.

The provision of your data for this purpose is voluntary. Refusal to provide data for this purpose will not have negative consequences for you.

Duration for which we process your data

As a principle, ITOTB Tech Solutions SRL will process your personal data as long as necessary to achieve the processing purposes mentioned above.

If you are a customer, we will process your data for the entire duration of the contractual relationship and subsequently in accordance with the legal obligations incumbent on ITOTB Tech Solutions SRL (e.g., in the case of financial-accounting supporting documents for which the retention period provided by law is 10 years from the date of the end of the financial year during which they were prepared).

If you withdraw your consent to the processing of data for marketing purposes, ITOTB Tech Solutions SRL will cease to process your personal data for this purpose, without affecting the processing carried out by ITOTB Tech Solutions SRL based on the consent expressed by you before its withdrawal.

Disclosure of personal data

To fulfill the processing purposes, ITOTB Tech Solutions SRL may disclose your data to partners, to third parties or entities that support ITOTB Tech Solutions SRL in carrying out its activity through the Site (e.g., courier companies, IT service providers), or to central/local public authorities, in the following cases listed by example:

• for the administration of the Website;

• in situations where this communication would be necessary for the attribution of prizes or other facilities to the data subjects, obtained as a result of their participation in various promotional campaigns organized by ITOTB Tech Solutions SRL through the Site;

• to maintain, personalize and improve the Site and the services carried out through it;

• to perform data analysis, testing and research, monitor usage and activity trends, develop security features, and authenticate users;

• for the transmission of commercial marketing communications, under the conditions and limits provided by law;

• when the disclosure of personal data is required by law, etc.

Transfer of personal data

The personal data provided to ITOTB Tech Solutions SRL may be transferred outside Romania, but only to states in the European Union.

Your rights

Under the conditions provided by the legislation on personal data processing, as data subjects, you benefit from the following rights:

• the right to information, respectively the right to receive details regarding the processing activities carried out by ITOTB Tech Solutions SRL, as described in this document;

• the right of access to data, respectively the right to obtain confirmation from ITOTB Tech Solutions SRL regarding the processing of personal data, as well as details regarding the processing activities such as the way in which the data are processed, the purpose for which the processing is carried out, • the recipients or categories of recipients of the data, etc.;

• the right to rectification, respectively the right to obtain the correction, without justified delay, by ITOTB Tech Solutions SRL of inaccurate/unjustified personal data, as well as the completion of incomplete data; The rectification/completion will be communicated to each recipient to whom the data have been transmitted, unless this proves impossible or involves disproportionate efforts.

• the right to erasure of data, without undue delay, ("right to be forgotten"), if one of the following grounds applies:

o they are no longer necessary for the fulfilment of the purposes for which they were collected or processed;

o where consent is withdrawn and there is no other legal basis for the processing;

o where the data subject objects to the processing and there are no overriding legitimate grounds;

o where personal data have been unlawfully processed;

o where personal data must be erased to comply with a legal obligation;

o the personal data have been collected in connection with the provision of information society services under Union or national law to which the controller is subject.

It is possible that, following the request for deletion of the data, ITOTB Tech Solutions SRL will anonymize these data (thus depriving them of their personal character) and continue under these conditions the processing for statistical purposes;

• the right to restriction of processing to the extent that:

an individual disputes the accuracy of the data, for a period that allows us to verify the accuracy of the data;

o the processing is unlawful and the data subject objects to the erasure of the personal data, requesting instead the restriction of their use;

o the controller no longer needs the personal data for the purpose of processing, but the data subject requests them to establish, exercise or defend a right in court;

A data subject has objected to the processing (other than direct marketing), for the period of time in which it is verified whether the legitimate rights of the controller prevail over those of the data subject.

o the right to data portability, namely (i) the right to receive personal data in a structured, commonly used and easy-to-read format, as well as (ii) the right for such data to be transmitted by ITOTB Tech Solutions SRL to another data controller, to the extent that the conditions provided by law are met;

o the right to object – regarding processing activities, it can be exercised by submitting a request as indicated below;

o at any time, for reasons related to the particular situation in which the data subject finds himself, that the data concerning him or her may be processed on the basis of the legitimate interest of ITOTB Tech Solutions SRL or on the basis of the public interest, except in cases where ITOTB Tech Solutions SRL can demonstrate that it has legitimate and compelling reasons justifying the processing and which prevail over the interests,  the rights and freedoms of data subjects or that the purpose is to establish, exercise or defend a right in court;

o at any time, free of charge and without any justification, that the data concerning him or her may be processed for direct marketing purposes.

o the right not to be subject to an automated individual decision, i.e. the right not to be subject to a decision taken solely based on automated processing activities, including profiling, which produces legal effects concerning the data subject or similarly affects him or her to a significant extent;

o the right to address the National Supervisory Authority for Personal Data Processing or the competent courts, to the extent you deem necessary.

For any further questions regarding how personal data is processed and to exercise the rights mentioned above, please contact the email address: contact[@]itotb.ro

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