SPARTAN DETECTOR

PRIVACY POLICY REGARDING THE PROCESSING OF PERSONAL DATA

Personal data privacy policy


Omega Trust SRL (hereinafter referred to as “Omega Trust”), a Romanian legal entity, based in Bucharest, Street Puțul lui Zamfir, No. 37, floor 4, sector 1, we provide you with this Privacy Policy, in order to explain how we process and protect personal data.

1. To whom does this policy apply?

This Policy applies to the processing of personal data of:

• visitors and users of our site www.spartandetector.ro (hereinafter referred to as "Users");

What data do we collect about you?

We collect and process your personal data as follows:

• from the information you provide us by filling in the forms on our website: the form on the subscription purchase page, the form for creating a new user account, the form on the contact page

• by correspondence with us by phone, e-mail or in any other way.

The information you provide to us may include your name, email address and telephone number, as well as other information as appropriate.

Through our activity on the site, we will not collect or process sensitive personal data about you (i.e. information about racial or ethnic origin, political opinions, religion or philosophical beliefs, health, sex life or sexual orientation).

If you voluntarily provide us with personal data (including sensitive personal data) through your interaction with the site www.spartandetector.ro or through correspondence with us by telephone, e-mail or in any other way, voluntarily and not at our request, we will delete such personal data from our systems if we do not consider that their processing is necessary for a legitimate purpose of the Omega Trust, unless you have made this data public (e.g. in a message board that is visible to the public), in which case we will delete this data from the site www.spartandetector.ro only if the law requires it or if we do not want to keep it.

Every time you visit the site www.spartandetector.ro, we automatically collect the following data:

• technical data, for example this may include the Internet Protocol (IP) address used to connect your computer to the internet, connection information, browser type and version, time zone setting, types and versions of browser extensions (plug-ins), operating system and platform, device type and mobile device brand; this data is collected and processed on our behalf through third-party cookies and you can find more information about this on the page dedicated to the Cookie Policy.

• data about your visit, for example this may include data about the URL, sequence of clicks to, through and from the site www.spartandetector.ro, the information you have viewed or searched on the site.

3. What are the purposes of processing personal data and what is the legal basis for processing?

We may process your personal data in the following cases:

• when we need to take the necessary steps to conclude a contract with you;

• when we have to execute a contract, we have concluded with you;

• when we have to comply with a legal obligation (i.e. the applicable legislation in the field of taxation, finance, accounting, auditing, the legislation applicable in labor relations);

• when necessary for our legitimate interests (or those of a third party) and your interests (i.e. to detect and prevent fraud or to ensure the security of IT and the computer network), unless your fundamental rights prevail over of these interests;

• if necessary, for the public interest or for official purposes.

We process your personal data for various technical, administrative and operational reasons, such as:

• to ensure that the content is presented in the most efficient way for you;

• to improve the site www.spartandetector.ro, including its functionality;

• for the administration of the site www.spartandetector.ro;

• for internal operations, including for troubleshooting, data analysis, testing, statistics and research purposes;

• to keep the www.spartandetector.ro website safe;

• for advertising and marketing, including for specific marketing purposes, so that we provide content, including personalized content, that may be of greater interest to you.

In some cases, we will process your personal data only with your consent (i.e. in advertising and marketing cases). In these cases, we will ask for your consent separately, in a transparent manner, when you provide your personal data. Subsequently, you can withdraw your consent, at any time, by sending a request to the e-mail address dpo@omega-trust.ro. Withdrawal of consent will not affect the lawfulness of the processing that took place before its withdrawal.

When we request personal data in order to comply with legal or contractual obligations, the provision of such personal data by you is mandatory. This means that if such personal data is not provided, we will not be able to manage the contractual relations or comply with the legal obligations imposed on us. In all other cases, the provision of personal data is optional and you are not obliged to provide it.




PARTICULARLY, WE WILL USE YOUR PERSONAL INFORMATION AS FOLLOWS:


Users:

In order to provide the services, based on the relevant subscription chosen by you, we may process your personal data, such as identification data, contact details, bank details.

This processing is based on

• The legal obligations that are imposed on us, according to Law no. 365/2002 on electronic commerce, republished with subsequent amendments and completions, according to Law no. 227/2015 on the Fiscal Code, updated, with subsequent amendments and completions.

4. To whom we send the personal data to?

Omega Trust does not send (by sale or rental) to third parties your personal information.

At Omega Trust, only a limited number of staff members, such as those in the Sales and IT departments, have access to your personal data on a need-to-know basis. These staff members are subject to confidentiality obligations regarding the processing of personal data. Omega Trust staff members have the right to manage personal data only on the basis of the instructions communicated by Omega Trust, in connection with their responsibilities.

Appropriate technical and organizational measures are taken for the protection of personal data. This site uses security measures against the loss, alteration or misuse of information under our control.

However, Omega Trust does not assume responsibility for information loss caused by errors in the software with which the site is designed and hosted. We are also not responsible for errors in the security of the server hosting the site.

Personal data may be disclosed to governmental authorities, tax authorities and / or law enforcement agencies, if required by applicable law or if necessary, for the exercise of our rights, including conditions of use, or to protect our legitimate interests. (including the legitimate interests of third parties) in accordance with applicable laws.

Your personal data may also be disclosed to third parties, as follows:

• To service providers who provide administrative, professional and technical support to the Company for IT support;

• To external consultants (i.e. lawyers, accountants, auditors), for specific purposes, when necessary


Omega Trust performs an appropriate prior assessment in the selection of third-party service providers and requires such service providers to maintain adequate technical and organizational security measures to protect personal data and to process personal data only in accordance with the instructions specified by Omega. Trust. Service providers will have the right to use subcontractors in the provision of services to Omega Trust, provided that each subcontractor complies with the same data protection obligations as the service providers.

5. What is the retention period of the personal data?

We will retain your personal data for the period necessary to fulfill the purposes listed in this Policy or for the period required by applicable national law, in accordance with the applicable minimum legal retention periods and / or as long as is necessary to exercise our legitimate rights (and the legitimate rights of others).

If we have a continuous business relationship with you, we will continue to keep this personal data until the end of our business relationship, as well as for an additional period of 10 years, from the end of the financial year, according to Law no. 82/1991 of the Accounting, republished, with the subsequent modifications and completions.

If you are a user of the site www.spartandetector.ro (i.e. you have created a user account on the site), we will keep your personal data for the period in which the user account is active.

If we process your personal data on the basis of your consent, this personal data will only be processed for the period provided by your consent, unless you withdraw or limit your consent before the expiry of this period. In such cases, we will cease the processing of such personal data for the relevant purposes, subject to any legal obligation to process such personal data and / or our need to process such personal data for the purpose of exercising our legitimate rights (including the legitimate rights of others).

6. Transfer of persona data abroad

The website www.spartandetector.ro is managed and maintained by SC Omega Trust SRL and hosted by the servers of the company Omega Trust SRL, located in Romania.

We do not intend to transfer your personal data outside the EEA unless there are adequate protections, including:

• a decision on the appropriateness of the European Commission regarding the country or countries of destination;

• appropriate mandatory corporate rules;

• an approved code of conduct, together with the binding and enforceable commitments of the data controller or the person authorized by the data controller in the non-EU and EEA country;

• an approved certification mechanism, together with the mandatory and enforceable commitment of the data controller or the person authorized by the data controller in a non-EU and EEA country to apply the appropriate safeguards; or

• EU standard contractual clauses approved by the European Commission.

7. What are your rights?

You have the following rights over your personal data, according to the provisions of EU Regulation no. 679/2016:

• The right to confirm whether or not your personal data are processed by us, and to provide you with a copy of your personal data;

• The right to request the rectification of personal data;

• The right to request the deletion of personal data;

• The right to request the restriction of the processing of personal data;

• The right to object to the processing of personal data by the site www.spartandetector.ro (for example the use of processing for direct marketing purposes);

• The right to request the portability of personal data;

• The right to withdraw your consent, at any time, without affecting the legality of the processing carried out on the basis of the consent before its withdrawal;

• The right to submit a complaint to the National Authority for the Supervision of Personal Data Processing.

Please note that your rights described above may be limited in certain situations and are subject to applicable laws and regulations regarding the protection of personal data. For example, your right to object to the processing of your personal data may be limited if we can demonstrate that we have compelling legitimate reasons to process your personal data that prevails over your interests.

When requesting one or more rights, you will need to prove your identity and provide us with other details to help us respond to your request.

We will not charge a fee to respond to your request, unless permitted by law, and if such a fee is charged, it will be reasonable and proportionate to your request.To exercise one or more of these rights, please contact us at dpo@omega-trust.ro

8. Security of personal data

We keep your personal data on the servers of Omega Trust SRL, located in Romania.

We use appropriate technical and organizational measures in order to protect personal data and to prevent unauthorized access to it.

All payment transactions will be encrypted (for example, using the TLS / SSL protocol).

You are responsible for maintaining the confidentiality of all means of authentication (for example, username, passwords, etc.) used by you to access parts of the site www.spartandetector.ro. Data transmission over the Internet is not completely secure. Although we do our best to protect your data, we cannot guarantee the security of your data transmitted on our site 100%; any transmission of personal data is at your own risk.

Once we receive your data, we will use strict security procedures to try to prevent unauthorized access.

9. Confidentiality of children's data

The website www.spartandetector.ro does not knowingly collect personally identifiable data from persons under the age of 16. If the parent or legal guardian is aware that the minor in his / her custody has provided his / her personal data to the site www.spartandetector.ro, he / she must immediately inform Omega Trust, at the e-mail address dpo@omega-trust .com. If we discover that a person under the age of 16 has provided personal data through the site www.spartandetector.ro, then we will destroy this information on our servers immediately, unless the parent or guardian gives his / her explicit consent for the processing by the site of the child's personal data for the specified purposes.

10. Cookies

The site www.spartandetector.ro uses cookies to give you a better experience when browsing our site. This processing is based on your consent expressed on the site or through the settings in your browser. You can find more information about cookies on the Cookie Policy page.

11. Contact

If you have questions or ambiguities regarding the processing of your personal data by the site www.spartandetector.ro or if you want to exercise one or more of your rights, you can contact us at the e-mail address dpo@omega-trust.ro Please do not disclose sensitive personal data (for example, information related to racial or ethnic origin, political opinions, religious or other beliefs, health or trade union membership), social security numbers when contact us.

Last updated: September 17, 2020.

Note: We may periodically update this Policy and we will notify you of any changes by posting the new version on the website www.spartandetector.ro.

Please check the Privacy Policy periodically for updates on new changes.