This Policy is applicable from December 21, 2023.
The data operator is GLODEANU ȘI ASOCIAȚII SPARL, with headquarters in Bucharest, District 1, 194 Calea Floreasca, Floreasca Lake Offices, 2nd floor, authorized by decision no. 570 issued by the Bucharest Bar on 12 March 2019, registered at the Bucharest Bar under no. 82/2019 (“Glodeanu Partners” or the “Company”).
General contact details include the email address firstname.lastname@example.org.
1.2 Basis for personal data processing
The Company acts with the greatest diligence when processing personal data, in accordance with the principles provided by the data protection legislation applicable in Romania, including the provisions of the General Data Protection Regulation 2016/679/EU regarding the protection of natural persons concerning the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC.
Personal data means any information related to an identified or identifiable natural person. An identifiable person is that person who can be identified directly or indirectly, in particular, by reference to an identifier or to one or more specific factors for its physical, physiological, mental, economic, cultural or social identity.
Also, the processing of personal data is carried out on a legal basis, such as: concluding or executing an agreement to which you are a party, complying with a legal obligation of the Company, your consent, protecting your vital interests, of another natural person, of the Company or of a third party (except in situations where your interests or fundamental rights and freedoms prevail over other interests), establishing, exercising or defending a right in court.
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1.4 Categories of personal data that can be processed
The Company may process personal data obtained both from you and from public or other third-party sources.
Therefore, among the personal data that the Company can process are:
- contact and identity information about you (such as postal address, email address, telephone number, full name, date of birth, gender, photograph, company you work for, position and other data from identity documents or related to the form of exercising your profession);
- technical information (such as information generated as a result of the Company’s IT security policy, your access to the Internet from the Company’s premises or materials and communications that the Company sends electronically);
- financial information (related to payments, bank account);
- information relevant to the procedures for accepting projects, collaborations or new partners, including financial soundness and reputational aspects;
- professional information;
- information generated by the Company as part of the legal assistance provided to a client or other company activities;
- other personal information provided to the Company by or on behalf of contractual partners or obtained by the Company from public sources;
- any other information about you that you may provide to the Company.
1.5 Provision of personal data
If personal data is to be communicated by you directly, it is necessary to provide all categories of personal data requested. Otherwise, we will not be able to operate (including, but not limited to, providing you with our services).
1.6 Personal data storage period
The duration for which the Company will keep personal data differs according to several criteria:
(a) the duration provided by specific legislation,
(b) the duration of your consent (if, after the withdrawal of consent, there are no legitimate and compelling reasons justifying the continuation of data processing),
(c) the duration in which aspects of legal liability could be attracted towards the Company or by the Company,
(d) the duration of the collaboration,
(e) the duration necessary to fulfill the purpose of processing personal data,
(f) the duration of the legal assistance contract, as well as after its termination, in accordance with the Company’s internal policies and legal obligations.
1.7 Your rights regarding the processing of personal data
1.7.1 Right of access
You can obtain a confirmation of whether or not your personal data is processed by the Company and, if so, relevant information regarding the processing activity. You may also obtain a copy of the personal data provided by you.
1.7.2 Right of rectification
You can correct your personal data if it is inaccurate.
1.7.3 Right to erasure
You can obtain the deletion of your personal data only in certain situations. For example, we will not be able to comply with your request in the following cases:
- there is another legal basis for the processing of personal data apart from consent,
- there are some legitimate reasons of the Company that prevail with regard to the processing of personal data,
- if the processing of personal data involves the exercise of the right to free expression and information,
- if the processing of personal data involves compliance with a legal obligation or the fulfillment of a task performed in the public interest or in the exercise of an official authority,
- if the processing of personal data involves establishing, exercising or defending a right in court.
1.7.4 Right to restriction
You can request that we not use your personal data, but only store it until another request you have is resolved, such as:
- requesting data rectification,
- opposition to data deletion in the event of illegal processing,
- requesting the provision of certain data for the defence of a right,
- opposition to data processing.
1.7.5 Right to portability
You may receive your personal data that you have provided to the Company in electronic form and transmit it to another data controller.
1.7.6 Right to object
You can object to the processing of your personal data, within the limits and conditions provided by law. Therefore, the right to object does not apply if the processing is based on legitimate interest, or on the basis represented by the need to process the data for the performance of a task that serves a public interest, nor if the Company demonstrates that it has legitimate and compelling reasons which justifies the processing and which prevails over the interests, rights and freedoms of the person concerned or that the purpose of the processing concerns the establishment, exercise or defence of a right in court.
1.7.7 Right to file a complaint with a supervisory authority
You can file a complaint with the National Supervisory Authority for the Processing of Personal Data.
1.7.8 Right to withdraw consent
You can withdraw your consent to the processing of your personal data, provided that this withdrawal does not affect the lawfulness of the data processing carried out on the basis of the consent given before the time of withdrawal (or on another basis).
1.8 Automated decision-making process. Creating profiles
1.9 Purpose of personal data processing
We will use the personal data provided by you for the following purposes:
- the preparation and provision of the requested services,
- to communicate with you regarding your requests and any other matter considered relevant,
- to send, in electronic format, our informative notes regarding the changes made in the legislation, jurisprudence and practice of the authorities, but only if you have expressly agreed to this processing,
- in view of potential collaborations with clients or potential clients,
- logistics management and the development of legal assistance support activities,
- administrative management of contracts, including financial and accounting aspects, invoicing and debt recovery,
- management of public relations and the representation of the Company’s interests, including in the relationship with statutory bodies, chambers of commerce, other law firms, NGOs, media platforms, various public authorities, other entities,
- recruitment, as well as the provision of professional practice and other internships,
- development or reorganization operations.
1.10 Interests of the Company
The processing of personal data carried out by the Company is based on legitimate interests, such as:
- legitimate interest in minimizing the relationship with natural or legal persons who may present increased legal, financial or reputational risks,
- legitimate interest in the proper execution of contracts with the Company’s clients or other contractual partners,
- legitimate interest of promoting the Company’s brand, expertise and reputation, within the limits allowed by legislation and the rules of the profession, including in the context of organizing or participating in various conferences, seminars or other events or scientific or informative contributions to clients, potential clients or other persons or entities,
- legitimate interest to develop and implement effective relationships with suppliers,
- legitimate interest in developing and maintaining an adequate infrastructure, including at IT and communication level, correlated with the evolution of activities,
- legitimate interest in the smooth running, development, protection and promotion of the Company’s activities according to the business activity.
1.11 Potential recipients of personal data
Your personal data may be transmitted, as appropriate, to:
- judicial or arbitration courts, as well as other public authorities and institutions (such as the Commercial Registry, the Land Registry, the Electronic Archive, the National Authority for the Protection of Personal Data, the National Agency for Fiscal Administration, criminal prosecution bodies, public order and national security bodies, the Competition Council), as well as entities indicated by you, if this is in your interest and necessary,
- customers who have provided us with your personal data or to parties involved in your case, in the context of providing the requested services, if this is necessary to fulfil these purposes,
- other contractual partners and their contractors, our affiliates within the Company, as well as the Company’s service providers, including proxies,
- external providers in the field of IT, accounting, fiscal, technical, insurance, cloud services, telephony, e-mail, archiving,
- other people within the entity you represent/within which you work/are registered,
- other lawyers (including other forms of practicing the profession with whom we collaborate in the provision of services),
- specialists (including mediators, industrial property advisers), consultants or experts involved in the services we provide or in other projects in which we are involved,
- persons relevant to the correspondence received by the Company or to other persons involved in the projects in connection with which the correspondence took place or to their consultants,
- if the Company organizes events or is involved in the organization (such as conferences, webinars), photo/video images may be transmitted by publishing them on our website or on social platforms. We can also transmit the photo/video images to the event participants, panelists or presenters, people who registered for the events but could no longer participate, professional organizations, contractual partners or representatives of the Company with whom we collaborate in the context of these events.
1.12 Transfer of personal data abroad
We may transfer your personal data to countries that are part of the European Economic Area or to countries that have been recognized by the European Commission as providing an adequate level of personal data protection if such transfer is deemed necessary.
In exceptional circumstances, if necessary, we may transfer your personal data to third countries that have not been recognized by the European Commission as providing an adequate level of protection.