Privacy Policy

Privacy Policy 2019-03-15T04:39:34+00:00

APT Data Privacy Policy – DPP

The new EU Data Protection Act (GDPR – General Data Protection Regulation) was aproved on the 27th of April 2016 and got implemented across all businesses on May 25th 2018. This law is the most major change in personal data protection over the last 20 years, and has objectives that go far beyond the mere protection of the private space.

The protection of your personal data is important to us, therefore we pay special attention to protecting the privacy of those who visit APT Resources & Services website, as well as those whose personal data has been provided to us by a third party or we accessed from another source in accordance with Regulation (EU) 2016/679 of the European Parliament and the Council from 27th of April 2016 on the protection of individuals with regard to the processing of personal data and its free movement (hereinafter referred to as “GDPR”).

Please read carefully  the following Policy (hereinafter referred to as “DPP”) to understand how your information will be managed (hereinafter referred to as “personal data”).

The DPP explains the APT Resources & Services’s practices regarding the application of the GDPR regulations and the rights that you have regarding to how your information is processed by APT Resources & Services.

The APT Resources & Services will always proccess your personal data in accordance with the GDPR regulations and as well as with the specific data protection laws of each country in which APT Resources & Services operates.

Through DPP, APT Resources & Services wants to inform the natural persons about the nature of the personal data we collect and process, as well as about the purposes of the  processing. In addition, natural people are informed through the DPP and about their rights.

 

WHO ARE WE?

We are APT Resources & Services S.R.L., a company based in Bucharest, Clucerului Street, no. 82 B2, with the serial number in the Trade Register J40 / 26889/1994 and unique registration code 6646907. We have as main activity HR services, CAEN 7820- Contracting activities for on the basis of temporary staffing. Our legal representatives are the administrators Donisa Sorina, Mirela Nicoleta Marin and Jacek Lorek.

WHAT IS PERSONAL DATA?

“Personal data” means any information that can directly identify you (eg your name) or indirectly (for example, by pseudonymis data such as a unique identifier as is National Security Number). This means that personal data includes various information such as email address, home address, mobile phone, username,  personal preferences, user-generated content, financial information, and financial status information. This could include unique numeric identifiers, such as your computer’s IP address or the MAC address of your mobile device, as well as cookies for strictly browser operability.

WHAT DOES THE PROCESSING OF PERSONAL DATA MEAN?

“Processing” means any operation or set of operations performed on personal data or on personal data sets with or without the use of automated technologies such as collecting, recording, organizing, structuring, storing, adapting or modifying, extraction, consultation, use, disclosure by transmission, dissemination or making it available in any way, alignment or combination, restriction, erasure or destruction.

PERSONAL DATA CONTROLLER

The Personal Data Controller (hereinafter referred to as the “Controller”) is APT Resources & Services.

DATA PROTECTION RESPONSIBLE (DPO)

APT Resources & Services, as an operator, named  Mr. Aurel Spornic as Data Protection Officer (DPO), having the obligation to verify compliance with the GDPR regulations in the data processing operations performed by the operator and to represent the operator in relation with the natural persons and the Supervisory Authority.

Natural persons have the posibility to address the DPO directly at any time in any matter related to this DPP using the contact details below:

DPO name: Aurel Spornic

DPO Email: dataprotection@apt.ro

Phone DPO: 0212221303 ext 118; 0728979688

DPO mailing address: Bucharest, sector 1, Clucerului street no. 82 B2

DATA PROCESSING

We process the data given directly by You, after accepting the DPP policy by consent: first name, second name, phone number, email adress and all data included into your CV (age, contact data, address, education, employment history).

PRINCIPLES ON DATA PROCESSING

APT Resources & Services undertakes to comply with the principles of personal data protection (hereinafter referred to as the “Principles”) provided by GDPR to ensure that all data are:

  1. Processed fairly, legally and transparently;
  2. Collected for specified, explicit and legitimate purposes;
  3. Adequate, relevant and limited to the purposes for which they are processed;
  4. Correct and up-to-date;
  5. Stored in a form that does not allow the identification of the individuals longer than necessary in relation to the purpose of the processing;
  6. Processed in accordance with the rights of the natural persons, in a way that ensures adequate processing security so that the data is complete, confidential and available.

THE BASIS AND PURPOSES OF PERSONAL DATA PROCESSING

  1. For the purpose of concluding and executing contracts – According to section 6 paragraph. 1 allign b) from GDPR, personal data may be processed for the purpose of concluding or executing the contract. In order to be able to offer you our products and services, we need to process personal data that you own.
  2. For the purpose of meeting legal obligations – In agreement with section 6 paragraph. 1 allign c) from GDPR personal data may be processed for the purpose of meeting legal obligations. We request a series of personal data, including, in some cases, the personal numeric code, in order to meet our tax authorities’ obligations regarding billing and reporting to fiscal authorities
  3. For marketing purposes – According to section. 6 paragraph. 1 section. Allign a) from GDPR personal data may accessed if the person has given his / her consent to the processing of his / her personal data for one or more specific purposes. Thus, in some situations, your personal data will be used to send you marketing messages, offers, news, future campaigns or invitations to various events.
  4. In order to accomplish our object of activity – In agreement with section. 6 paragraph. 1 allingn. a) from GDPR personal data may be accessed if the person has given his / her consent to the processing of his / her personal data for one or more specific purposes. Thus, we may contact you or we may transmit your personal data in order to achieve our object of activity:
    • We will contact you whenever we consider that a job offered by a third party employer matches your professional skills and we will transmit your personal data that is contained in your third-party CV / Letter of Intent . If you represent an employer, we will contact you whenever we consider that we have a suitable candidate to occupy a position within the employing company. There will be situations in which we will send your personal data to people who might opt ​​for a job within the employing company.
    • We should contact or process your personal data, as necesary for our temporary employment work activity, to the intention to sign a working contract for a third party APT Client.
    • Or for training sesions

PROCESSING THE CONTACT FORM

APT Resources & Services will use the information you provide in the corresponding contact section existing on the site exclusivly for the purpose of processing your request for a position published by APT Resources & Services.

By providing any personal data through the APT Resources & Services website, you understand and agree that your data will be processed in accordance with the APT Resources & Services DPP ‘s provisions .

Please be aware that in order to be able to process your requests submitted to the site’s contact section, it is possible under certain circumstances to be required to disclose your data to partners with which APT Resources & Services collaborates and/or other third-party service providers of APT Resources & Services, but only for the purpose You consent.

APT Resources & Services has adopted adequate technical and organizational measures to ensure the security of data transfer as well as processing your data in agreement with the GDPR requirements by the above mentioned entities.

APT Resources & Services undertakes to not process your provided data for other purpose rather than the established ones, excepting the situations in which you express consent for use in other purposes.

DISCLOUSURE OF PERSONAL DATA TO THIRD PARTIES

Personal data processed by APT Resources & Services may be disclosed and / or transferred to third parties only if your express consent unless there is a legal / contractual obligation for APT Resources & Services to do so.

APT Resources & Services will send your personal data to third-party employers for the employment purpose on published positions .

Please be aware that under certain circumstances we may be required to disclose your data to partners with whom APT Resources & Services collaborates and / or other third-party service providers of APT Resources & Services.

DATA PROCESSING BY THIRD PARTY, OTHER SITES AND SPONSORS

The APT Resources & Services site may some time contain access links to other sites whose data processing policies may be different from those of APT Resources & Services.

Please consider and consult the personal data protection policies of other sites, APT Resources & Services does not responsibility for the information sent or collected by these third parties.

AUTOMATIC DATA PROCESSING-COOKIES

The APT Resources & Services site uses cookies. In this regard, you can review our Cookie Policy, available on the site, and exercise your right to disable Cookies except the cookies strict necesary for browser functionality, as outlined below.

DATA STORAGE PERIOD

APT Resources & Services may store processed data for different periods of time percived as reasonable for the purposes specified above. We keep your data only for the necessary period of time to reach the objectives for which we hold the data, to meet your needs and our legal obligations.

To know how long your data can be stored, we use the following criteria:

  1. When you purchase products and services, we retain your personal data during our contractual relationship;
  2. If you participate in a promotional offer, we retain your personal data during the promotional offer;
  3. If you contact us for a question, we keep your personal data for as long as your questions are processed, but no more than 3 years after the last mail sent;
  4. If you create an account, we retain your personal data until you ask us to delete it or after a period of inactivity (without an active interaction with us). In this regard, please note that data processed for this purpose will be deleted 3 years after the last user account interaction (such as login to your account);
  5. If you have given your consent to marketing, we retain your personal data until you unsubscribe or ask us to delete it or after a period of inactivity (without active interaction with our marks) defined in accordance with local regulations and guidelines. In this regard, we mention that the data stored in our databases for the purpose of direct marketing communications are deleted from the records of these databases at 3 years from the last interaction with you;
  6. If the cookies are stored on the computer, we keep them for as long as it is necessary for them to achieve their goals (for example, during a shopping cart cookie session or cookie ID session) and for a period defined in accordance with local regulations and guidelines. In this regard, we mention that the data processed through the cookies used to provide online behavioral advertising, to customize our services for you, and to allow our content to be distributed on social sites (distribution buttons to display the site) will be retained for a maximum of 3 years from collection, based on your consent.

THE RIGHTS OF NATURAL PERSONS

According to GDPR, you have a series of rights with respect to the personal data that APT Resources & Services processes:

  1. Right to access processing data– You have the right to access our personal data. The first information will be provided without any charge. If you will need copies of the information already provided, we may charge a reasonable fee considering the administrative costs of providing the information. The manifestly unreasonable, excessive or repeated requests may not be answered.
  2. Right to Data Rectification– You may request that your Data be rectified if inaccurate or out-of-date and / or filled in if they are incomplete. If you have an account, it can be easier to correct your own data through the “My Account” feature.
  3. Right to delete data(“the right to be forgotten”) – In some cases, you have the right to obtain the deletion or destruction of your Data. This is not an absolute right, because sometimes we may be forced to keep your Data for legal or forensic reasons.
  4. Right to Restrict Processing– You have the right to request restriction of the processing of your data. This means that your data processing is limited so we can keep the data, but not use or process it. This right applies in specific circumstances provided by the General Data Protection Regulation, namely:
    1. the accuracy of the data is contested by the person in question (you) for a period that allows the operator (APT Resources & Services) to verify the accuracy of the Data;
    2. the processing is illigal and the person in question (you) opposes data deletion and calls restriction of use;
  • the operator (for example, APT Resources & Services) no longer needs data processing, but they are required by the person in question (you) to establish, exercise or defend legal claims;
  1. the person concerned (you) raised objections to processing based legitimate done by the operator (in this case APT Resources & Services) on the basis of verifying if the legitimate reasons of the operator (APT Resources & Services) exceed those of the person in question
  1. Right to data portability– You may move, copy or transfer the data you are interested in from our database to another. This applies only to the data you have provided for processingbased on your consent or contract and is implemented by automated resources.
  2. Opposition Right– You may oppose at any time to the processing of your data when such processing is based on a legitimate interest.
  3. Right to withdraw consent at any time– You may withdraw your consent in what concerns the processing of your data when such processing is based on your agreement. Withdrawal of consent does not affect the legallity of processing on the basis of agreement prior to its retraction.
  4. Right to complaint to the competent supervisory authority– You have the right to complain to the data protection authority of your country of residence or home country to object to the data protection practices offered by APT Resources & Services.
  5. Right to oppose to the processing of your data for direct marketing purposes– You can unsubscribe or quit our direct marketing communications at any time. It’s easier to do this by clicking the “unsubscribe” link in any email or communication we send you.
  6. The right to oppose to the processing of your data by us when conduct actions in the public interest or in our legitimate interests or those of a third party– You may oppose at any time to the processing of your data when such processing is based on a legitimate interest.
  7. Right to Disable Cookies– You have the right to disable cookies. Internet browser settings are usually programmed to accept cookies by default  but you can easily adjust them by changing your browser settings. Many cookies are used to increase the usability or functionality of web sites / applications; therefore, disabling cookies may prevent you from using certain parts of our sites or apps, as detailed in the relevant Cookie table. If you want to restrict or block all cookies set up by our websites / apps (which may prevent you from using certain parts of the site) or any other sites / apps, you can do so through your browser settings. The Help feature in your browser will tell you how. For more information, see the following links: http://www.aboutcookies.org/;

You may exercise any of these rights with respect to personal data that APT Resources & Services processes by addressing a simple request to APT Resources & Services DPO. In such a situation, it is very possible that we ask for proof of your identity.

LEGAL REQUESTS

We access, preserve and provide your information to regulatory authorities, law enforcement or other legaly authority entities:

  1. In response to a legal request, when we consider with good intentions that the law requires us to do so. It is also possible to respond to legal claims when we consider with good intentions that the response required by the laws of jurisdiction affects the users of that jurisdiction and complies with internationally recognized standards.
  2. When we believe with good intentions that it is necessary to: detect, prevent and respond to acts of fraud, unauthorized use of any material belonging to us, violations of our terms or policies, or other harmful or illegal activities, to protect ourselves (including our rights, property or materials), yourself and others, including during investigations or inspections of authorities for regulatory purposes or to prevent imminent death or injury. For example, if it’s relevant, we provide and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activities inside and outside of our materials.

The information we receive about you may be accessed and stored for a longer period of time when they are a subject of a legal request, legal obligation, governmental investigation or other investigation about possible violations of our terms or policies or in other cases to prevent damage.

RELATIONS WITH OTHER OPERATORS

Depending on the context, we may find ourselves in the situation of the absolute necessity to provide information at a higher level, both globally and internally or externally, to our partners and to those with whom we transfer GDPR data in the virtue of providing the most professional services possible.

The information controlled by APT Resources & Services may be transferred, transmitted or stored and processed in the EU or in other countries rather than the country you live in for the purposes described in this policy. These data transfers are necessary to deliver the highest level of service and to continue to provide you with our best professional content. We use standard contractual clauses approved by the European Commission, and we rely on the fidelity of the European Commission’s decisions on certain countries, as the case may be, for transfers of EEA data to the United States and other countries.

PROCESSING SECURITY

APT Resources & Services has adopted updated technical and organizational data processing measures in accordance with GDPR requirements to protect your personal data against any unauthorized access, misuse or disclosure, unauthorized modification , destruction or accidental loss. All employees and partners of APT Resources & Services, as well as any third parties acting in the name and on behalf of APT Resources & Services, are bound to respect the confidentiality of your information and the GDPR requirements, in agreement with DPP’s provisions.

LIABILITY DISCHARGE

APT Resources & Services may contain links to other sites and / or other webpages that are not owned by APT Resources & Services. APT Resources & Services does not assume any responsibility for the content of these sites and therefore it can not be held responsible for the content, advertising, goods, services, software, information or other materials available on or through these sites. APT Resources & Services will not be responsible for the loss of personal data, any adverse effects on visitors’ personal data or other moral and / or patrimonial damage caused by access to those sites.

UPDATING OF THE PERSONAL DATA PROTECTION AND PROCESSING POLICY

Please note that this Policy may be subject to periodic content changes by updating the APT Resources & Services site.

How will we let you know about the changes made to this Policy?

We will send you a notification before making any changes to this Policy and will give you the opportunity to review the revised DPP before choosing to continue using our materials.

Please do not continue to use APT Resources & Services if you do not agree to such changes. We also recommend that you check this page for any updates.

All DPP terms are interpreted in agreement with applicable law.

CONTACT

If you have any questions or concerns about the way we manage and use your personal data or you want to exercise any of your rights, please contact us by accessing our DPO contact details.