PRIVACY POLICY- PERSONAL DATA PROTECTION

We, KADRA TECH S.R.L., have taken action, technical and organisationally, as to respect personal data, against loss, modification of such data, and as to eliminate risks of unauthorized access.

Thus, the personal data processed by us are in accordance with the legal provisions regarding the protection of personal data and the EU Regulation 2016/679 (hereinafter GDPR)

Type of personal data – the personal data that will be processed by KADRA TECH S.R.L. are data such as: name, e-mail, phone number, address.

Methods of data collection are done through: filling out a form regarding the request for information/offers or subscribing to the newsletter of KADRA TECH S.R.L.

Furthermore, we specify that our site is addressed to individuals over 18 years of age.

I. DEFINITIONS:

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 one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
2. Data controller – means the person who transfers personal data
3. Technical and organizational security measures – means measures designed to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, especially when processing involves the transmission of data over a network, as well as against any other form of
4. Categories of processed data – personal data (first name, last name, address, phone number, email address, etc.) are processed by us only when these data are entered by the interested person in the fields created on our site (e.g., field regarding the request for information/offers or subscribing to the newsletter)
5. Processing of personal data: means any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

II. PERSONAL DATA WE PROCESS

We use your personal data to benefit from our services as follows:

A. Data for the Newsletter Service:

We process your data consisting of name and email address for subscribing to our newsletter.

Upon accessing the website, the option to subscribe to our newsletter is visible, in which case, to subscribe, you need to press the “Subscribe to Newsletter” button.

Following this subscription agreement step, you are asked to enter a series of data about yourself that will allow us to send you relevant offers and information, as well as to express your agreement on how you wish to communicate.

By subscribing, you will benefit from direct marketing actions specific to our activity segment, through which we will keep you updated with our products, services, and campaigns, respecting the legal provisions in force.

The use of data ceases as soon as you unsubscribe from the newsletter service. You can unsubscribe at any time and free of charge from the newsletter service by: checking the “Unsubscribe” option within the newsletter or sending an email to marketing@kadra.ro expressly requesting unsubscription or by accessing the following link: https://kadra.us5.list- manage.com/unsubscribe?u=2c770b0c5d4a80323075e9b5c&id=e3dbdc86e2

B. Data for Requesting Information/Offers

By filling out the contact forms intended for potential clients or partners, you provide us access to your contact data, which we will use to respond to the requests and questions addressed.

C. Social Network Plugins and the Use of Cookies

Our website uses “plugins” from social network operators (e.g., www.facebook.com). All social network plugins on our website are clearly and distinctly marked.

Through these plugins, KADRA TECH S.R.L. does not collect/store personal data of clients. In addition to our clients, according to the way social networks operate, there is a possibility that the virtual friends of our clients may view our page as a result of liking our web page.

Regarding the use of cookies (the terminology includes “Internet Cookie”, “browser cookie”, “HTTP cookie” or simply “cookie”), we specify that these are files or information that can be stored on your computer or mobile devices with Internet access (smartphone or tablet) when you access the Internet. The cookie is installed by a request issued by a web server to a browser (e.g., Internet Explorer, Chrome) and cannot access information from the user’s computer/mobile device. We mention that this technology does not contain software programs, viruses, or spyware.

We use cookies to make the site easier to use and to better adapt it, through our offers, to your interests and needs. Cookies are also used to increase the speed of your future activities and experiences on our site.

III. PURPOSE OF DATA PROCESSING

In general, all collected information is used for the intended purpose for which you sent it to us, mentioned at the time of collection or in the privacy policy. We may use your personal data for one of the following purposes:

• We use your contact data to respond to your requests communicated either through the contact form or directly using our email or postal address.

• We use the email address you provided to receive commercial information such as newsletters, promotions, offers, etc., if you have given your consent for this.

• We use the information collected through cookies, pixels, or plug-ins to provide you with an optimized experience when using our site.

• We may use your data for statistical purposes, to assess customer satisfaction with our services. Your responses are strictly confidential and will be used exclusively to improve our services; the data is collected and processed through an external application so there will be no connection between your personal data and the responses you provide through these surveys.

If you choose not to provide any personal information when requested, you may not be able to participate in certain activities and personalized features on our sites and have limited access to services and special offers. For example, if you refuse to share your email address, you will not be able to receive any newsletters and will not be able to contact us through the form on the site.

However, to simply browse our sites and learn more about our products, you do not need to provide us with any personal information.

IV. DATA TRANSFER

We guarantee that your data will not be sold or rented to other individuals or legal entities so that they can be used by other companies without your consent. However, we may communicate your data to third parties to ensure you benefit from our services, such as service providers who ensure the operation of the site, marketing agencies that ensure the communication of the newsletter, authorities, or public institutions to fulfill legal obligations, etc.

V. RIGHTS REGARDING THE PROCESSING OF PROVIDED PERSONAL DATA:

According to GDPR, as a data subject, you benefit from a set of rights, namely:

1. Right to information and access to personal data: the right to obtain confirmation of whether or not personal data concerning you is being processed and, if so, access to the data.
2. Right to rectification: the right to request the Operator and obtain, without undue delay, the rectification of inaccurate personal data concerning you and/or to obtain the completion of incomplete personal data, with the mention that in the case of an online account, you can make these changes yourself from the account data editing section.
3. Right to data erasure (“right to be forgotten”): the right to obtain the erasure of personal data concerning you, without undue delay, where certain reasons mentioned in apply.
4. Right to restriction of processing: the right to obtain restriction of processing in certain cases.
5. Right to data portability: the right to receive the personal data concerning you and to transmit it to another
6. Right to object: the right to object at any time to the processing of personal data concerning you, under the conditions
7. Right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you to a significant extent
8. Right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP) if you consider that your data has not been processed in accordance with the provisions

National Supervisory Authority for Personal Data Processing

Bld. General Gheorghe Magheru 28-30, 010336, Bucharest,

Romania

Tel: 031 805 9211

www.dataprotection.ro

To exercise these rights, please send us a written and signed request using the following contact details:

email address: marketing@kadra.ro

postal address: Sos. Dudesti-Pantelimon, nr 42, RAMS premises, Kadra Tech company

VI. UPDATING THE PRIVACY POLICY

We reserve the right, at our discretion, to add, modify, or remove elements from this Privacy Policy in the future to ensure that the information provided offers relevant and adequate information regarding our collection and processing of your personal data.

To optimize your experience in the digital communication environments used by KADRA, we implemented the CRM system offered by HUBSPOT on August 27, 2019. This system involves a series of activities, which we explain below:

1. Information we collect

By completing the forms on the KADRA site, you send us personal information. We request this information to learn more about you and to provide you with the information you need more quickly and easily. The information is stored in the HubSpot system (the information goes into the HubSpot cloud and is stored on HubSpot servers in the USA). The information we collect and manage using the HubSpot service belongs to us and is used, disclosed, and protected in accordance with this Privacy Policy.

When you visit our websites

You are free to explore the websites without providing personal information about yourself. When you visit the websites or register for the subscription service, we ask you to provide personal information about yourself and collect navigation information.

“Personal Information”

This refers to any information you voluntarily send us that personally identifies you, including contact information such as your name, email address, company name, address, phone number, and other information about you or your business. Personal information may also include information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter, and Google.

Personal information includes navigation information. Navigation information refers to information about your computer and your visits to sites, such as your IP address, geographical location, browser type, referral source, visit duration, and pages viewed. See the “Use of Navigation Information” section below.

Log files

When you view the content provided by us, we automatically collect information about your computer’s hardware and software. This information may include your IP address, browser type, domain name, Internet service provider (ISP), files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times, and referring website addresses. This information is used by HubSpot to provide general statistics regarding the use of the sites. For these purposes, we link this automatically collected data to Personal Information such as name, email address, address, and phone number.

Information we collect from third parties

From time to time, we may receive personal information about you from third-party sources, including partners with whom we offer co-branded services or engage in joint marketing activities and publicly available sources such as social media websites.

2. How we use the information we collect

Compliance with our Privacy Policy

We use the information we collect only in accordance with this Privacy Policy. Customers who complete our forms are obligated by our agreements with them to comply with this Privacy Policy.

We never sell personal information

We will never sell your Personal Information to third parties.

Use of personal information

In addition to the uses identified in the previous chapters of this Privacy Policy, we may use your personal information to:

• improve your browsing experience by personalizing the websites and enhancing the communication service;
• send you information or KADRA content that we think may interest you by mail, email, or other means and send you marketing communications related to our business, in accordance with your communication preferences;
• promote our services, products, and share promotional and informational content in accordance with your communication preferences;
• provide other companies with statistical information about our users – but this information will not be used to identify any user;
• send you information regarding changes to the Terms and customer services, Privacy Policy (including the Cookie Policy), or other legal agreements.

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will clarify this at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information relying on our legitimate interests (or those of any third party), we will clarify at the relevant time what those legitimate interests are.

Use of navigation information

We use Navigation Information to deliver the best content to you and to continuously improve the sites. We may also use Navigation Information alone or in combination with Personal Information to provide you with personalized information about KADRA.

Customer testimonials and comments

We post customer testimonials and comments, which may contain personal information, on our websites. We obtain each customer’s consent via email before posting their name and testimonial.

Security of your personal information

We use a variety of technologies and security procedures to protect your personal information against unauthorized access, use, or disclosure. We secure the personal information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. All personal information is protected using appropriate physical, technical, and organizational measures. All these solutions are offered by HubSpot. For more information about HubSpot security, please visit https://www.hubspot.com/security.

Social media features

Our sites include social media features, such as the Facebook Like button and widgets. These elements may collect your IP address, the page you are visiting on our sites, and may set a cookie to allow the feature to function properly.

External sites

Our websites provide links to other websites. We do not control and are not responsible for the content or practices of these other websites. Providing such links does not constitute our endorsement of these other websites, their content, owners, or practices. This privacy policy does not apply to these other websites, which are subject to any privacy policy and other policies they may have.

Public forums

We offer areas on the site where you can leave messages accessible to the public. Please note that if you disclose information directly through these public areas, the information may be collected and used by other users. We will correct or delete any information you have posted on the sites if you request it, as described in “Unsubscribe and Opt-Out” below.

Retention of personal information

It depends on the type of information how long we retain the information we collect about you, as detailed below. After such time, we will delete or anonymize your information, or if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.

When there is no need to process your personal information, we securely delete the information or anonymize it, or if this is not possible, we securely store your personal information and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you request it, as described in “How to Access and Control Your Personal Data” below.

If you have chosen to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you expressed interest in our content, products, or services, such as when you last opened an email from us or stopped using your HubSpot account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date these information were created.

3. How we share the information we collect

Service providers

We engage other companies and individuals to provide services to visitors of our websites, and we may need to share your information with them to provide you with information, products, or services. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis, providing marketing assistance, supplementing the information you provide to us to offer you a better service, and providing customer service or support. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data management policies. These processes do not involve transferring information to these entities, but only facilitating access to these data in the safest way.

4. International transfer of information

International transfers within HubSpot entities

Information collected by HubSpot is stored and processed in Ireland and the USA.

This privacy policy will apply even if we transfer personal information to other countries. HubSpot has taken appropriate safeguards to ensure that your personal information remains protected. HubSpot holds standard contractual data protection clauses, which have been approved by the European Commission and are based on bilateral agreements regarding personal data protection – EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.

Privacy Shield Notice

HubSpot participates in and is certified under the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. The following affiliated entities adhere to the Privacy Shield principles: HubSpot Ireland Limited, HubSpot Germany GmbH, HubSpot France S.A.S, HubSpot Australia Pty Ltd, HubSpot Asia Pte. Ltd., HubSpot Latin America S.A.S, and HubSpot Japan KK. HubSpot publicly commits to subject all personal data received from European Union (EU) member countries and Switzerland, in accordance with the Privacy Shield Framework, to the applicable Framework Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov.

VII. COOKIE POLICY

KADRA, through HubSpot technologies, uses cookies or similar technologies (such as web beacons) to analyze trends, administer the site, track users’ movements on the website, and collect demographic information about our user base as a whole. To learn more about how we use cookies on our websites and how we manage your cookie preferences, please refer to our Cookie Policy.

What types of cookies do we use and how do we use them?

The specific types of first-party and third-party cookies served through our websites and the purposes they fulfill.

Essential web cookies: These cookies are strictly necessary to provide you with services available through our websites.

Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our websites but are not essential for their use. However, without these cookies, certain functionalities may become unavailable.

Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our websites are being used, how effective our marketing campaigns are, or to help us customize our websites for you.

Advertising cookies: These cookies are used to make advertising messages more relevant to you. They perform functions such as preventing the continuous reappearance of the same ad, ensuring the proper display of ads for advertisers, and, in some cases, selecting advertisements based on your interests.

Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our websites through third-party social networks and other websites. These cookies may also be used for advertising purposes.

What about other tracking technologies, like web beacons?

Cookies are not the only way to recognize or track visitors to a website. We use a software technology called clear gifs (e.g., Web Beacons/Web Bugs), which helps us better manage the website by informing us about what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. Unlike cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages or in emails and are about the size of the period at the end of this sentence. We use clear gifs or pixel tags in our HTML-based emails to inform us which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. We link the information collected by clear gifs in emails to our customers’ personal information.

Read more about the cookies we use and the Cookie Policy on the dedicated page here.