www.smartcampaign.ro undertakes to respect your confidentiality, complying with all laws and regulations applicable to data protection, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
This policy (along with the Terms and Conditions of this website and any other documents referred to in the content of this policy) is intended to provide you with information about the personal data we collect from website users and the method of processing by us.
Identification data of the company that manages the www.smartcampaign.ro website
The data operator is SMART CAMPAIGN ADVERTISING S.R.L., a limited liability company of Romanian nationality, with registered office in: Constanta, str. Str. Poporului, No. 36, Room 4, Floor 1, commercial register J13/3297/2019.
WHAT TYPE OF PERSONAL DATA DO WE PROCESS, FOR WHAT PURPOSES AND ON WHICH GROUNDS?
In the process of administering this website, the Company will collect certain information (“personal data”) in relation to identified natural persons or that may lead to the identification of natural persons, which are provided by the users of this website directly (for example , first name, last name, e-mail address, phone number) or indirectly (for example, IP address).
Mainly, the Company has in its portfolio or clients legal entities, and the possible personal data processed in order to carry out the activity, are represented, as the case may be, by the data of the representative of the company, of his proxy, as well as of the staff within these entities, in charge of improving the strategies and promotion processes of these clients. The processing of this data has a contractual basis, not being necessary, according to the Regulation, to express an express consent in this regard. There may also be situations when the persons concerned are natural persons, not related to any legal entity, recipient of our services.
The processing of personal data will be done for the following purposes, based on the legal grounds indicated for each of them, as follows:
Browsing the website www.smartcampaign.ro.
Use of cookies
When visiting our website, cookies are used to automatically collect technical information that can identify the user, such as the operating system, IP address, type of internet browser used to browse our website web, the name of the domain or the host of the domain through which the user navigates the website.
The main purpose of using cookies is to help you have an improved browsing experience and also for advertising purposes, to be able to offer you individualized content adapted to your interests and preferences. Thus, to the extent that you have expressed your agreement regarding the use of cookies, we will use them to offer you a personalized and relevant browsing experience on our website and to understand how you interact with our content advertiser.
For more information on the use of cookies on this website and the purposes for which they are used, as well as on the possibilities to control and/or disable cookies, please consult our Cookie Policy.
The answer to the contact form or your questions, requests or complaints
We will process your personal data, such as name, surname, e-mail address, telephone number and any other information or details that you can provide us in correspondence, in order to solve and answer your questions, complaints or your requests, depending on the communication channel through which you contact us.
Purpose: The possibility to provide answers to: requests for offers, complaints, questions or correspondence requests
Legal basis: The processing is based on a legitimate interest, allowing us to provide answers to your questions, complaints or requests.
Direct marketing communications/email marketing
We have the possibility to process personal data to inform you about our products and services, promotional offers and to subscribe to newsletters. These personal data will be processed for direct marketing purposes only with your prior consent and by using the communication channels (e.g. e-mail, SMS, etc.) with which you have agreed.
We will process personal data in order to establish contractual relations following your voluntary expression of the desire to receive an offer or details about Smart Campaign Advertising products.
The contractual services are represented by the provision by the Company of the administration and management of accounts and campaigns your internet marketing efforts. For this purpose, we will use the data that you will fill in on the page mentioned above, according to the existing form at this address, respectively, Name, Surname, E-mail, Telephone.
TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?
To achieve the goals described above, the Company uses the services of external partners. Some of them have the quality of authorized persons, such as, IT Services and WEB Hosting, Companies contracted for the outsourcing of legal services, accounting, programming and repair of our PCs, invoicing and accounting, legal consulting services, assistance and representation and are active in the IT, Accounting, legal industry/sector and carry out their commercial activity in Romania, and your personal data can be provided to them to be used within the limits of the obligations they have assumed towards the Company. The personal data that we disclose to the persons authorized by us, are limited to the minimum personal information that is necessary for the provision of the respective services and we ask them not to use the personal data for any other purpose.
Some of them are third parties who do not intend to process the data, but may have access to them in the performance of their tasks or in their interactions with the Company, such as companies that provide technical maintenance, financial or legal auditors.
The personal data indicated above can be made available or transmitted to third parties in the following situations: (i) public authorities, auditors or institutions with competence in carrying out inspections and controls on the Company’s activity and assets, which request the Company to provide information , by virtue of the latter’s legal obligations. These public authorities or institutions can be the National Fiscal Administration Agency; (ii) to comply with a legal requirement or to protect the rights and assets of our Company or other entities or persons, such as courts, law firms; (iii) third parties, to the extent that the Company’s activity would be transferred (in whole or in part), and the data of the persons concerned would be part of the assets that are the subject of such a transaction.
The persons and entities to whom we can distribute personal data are the following:
For the purpose of browsing the website and for purposes related to the use of cookies, we may transmit personal data to providers of analysis services and search engines for them to provide maintenance services for our website;
In order to answer your questions, requests or complaints, we may distribute your personal data to our call center service providers;
For the organization and management of promotional campaigns, as well as for analyzing their effectiveness, we can distribute your personal data to advertising and marketing agencies or digital media agencies or social media agencies;
For direct marketing communications, we can transmit personal data to the advertising and marketing agencies that carry out the communication on our behalf;
In order to conduct surveys or market studies, customer satisfaction surveys or to obtain feedback from our customers regarding our products and services, we may distribute personal data to survey or market study service providers/ customer inquiries.
TRANSFER OF PERSONAL DATA ABROAD
In the context of the operations described above, your personal data may be transferred abroad to countries in the European Union (“EU”) or the European Economic Area (“EEA”).
We hereby inform you that any transfer carried out by the Company in an EU or EEA member state will comply with the legal requirements stipulated in the GDPR.
Some of the personal data listed in this privacy policy are transferred to countries that do not provide adequate protection for the processing of personal data, namely, the United States of America. These data are those over which Google has control, within its Google Analytics services.
HOW LONG DO WE STORE YOUR PERSONAL DATA
We will store your personal data only for the period of time necessary to achieve the processing purposes set out above, while respecting the legal requirements in force. If the Company establishes that it has a legitimate interest or a legal obligation to further process your personal data for other purposes, you will be informed accordingly or in this sense.
We estimate that the processing activities detailed above will require the storage of personal data for the following periods:
Purpose Duration Storage
1 Browsing the website and using cookies The one set by Google
2 The answer to your questions, requests or complaints During the duration of the contractual relations, to which is added a period of another 3 years
3 Organization and management of promotional campaigns, of personal data During the duration of the contractual relations, to which is added a period of another 3 years
4 Direct marketing communications During the duration of the contractual relations, to which a period of another 3 years is added
5 Carrying out surveys, market studies, surveys regarding the degree of customer satisfaction or to obtain feedback from our customers regarding our products and services During the duration of the contractual relations, to which is added a period of another 3 years
6 Presentation of own service offers; Initiation of contractual relations During the duration of the contractual relations, to which a period of another 4 years is added
Once the processing period indicated above expires, and the Company no longer has legal or legitimate reasons to process your personal data, the data will be deleted in accordance with its procedures, which may involve archiving, anonymizing or destroying them.
DATA PROCESSING OF CHILDREN UNDER 16 YEARS OF AGE
All personal data processing activities presented in this Policy refer exclusively to persons who are at least 16 years old. The use of the systems, as well as the processing results, is prohibited for children who have not reached this age without the consent of their parents/legal representatives. If, despite our reasonable prevention efforts, such processing still takes place, we will stop it once we notice that the users have not reached the legal age to be able to initiate commercial relations.
REFUSAL OF PROCESSING AND ITS CONSEQUENCES
Being a private entity, there is no legal obligation on the basis of which we could claim that you provide us with your personal data. Your refusal to communicate your data to us has, in principle, no consequence regarding you or your experience on our website. However, to the extent that you decide that you want to benefit from the services of our company, the communication of the requested data, as described above, is inevitably necessary. Since contractual relations have been established between the Company and you, our legitimate interest in the mutual execution of contractual obligations will prevail over your refusal to process, until the obligations have been fully executed and there is no prospect of concluding new ones contractual relations.
THE RIGHTS OF THE PERSONS CONCERNED
In the context of the processing of your personal data, you have the following rights:
The right of access to processed personal data: you have the right to obtain confirmation of whether or not your personal data is processed and, if so, to have access to the type of personal data and the conditions under which it is processed , by addressing a request in this regard to the data operator;
The right to request the rectification or deletion of personal data: you have the possibility to request, by addressing a request in this regard to the data operator, the rectification of inaccurate personal data, the completion of incomplete data or the deletion of your personal data if in the event that (i) the above data are not necessary for the initial purpose (and there is no new legal purpose), (ii) the legal basis of the processing is the consent of the data subject, the data subject withdraws his consent and there is no other legal basis, (iii) ) the data subject exercises his right to object, and the operator does not have legitimate reasons to continue the processing, (iv) the data were processed illegally, (v) the deletion is necessary to comply with EU or Romanian legislation or ( vi) the data were collected in connection with information society services offered to children (if applicable), when specific requirements regarding consent are applied;
The right to request the restriction of processing: you have the right to obtain the restriction of processing in cases where: (i) you consider that the processed personal data are inaccurate, for a period that allows the operator to verify the accuracy of the personal data; (ii) the processing is illegal, but you do not want us to delete your personal data, but to restrict the use of these data; (iii) if op the data controller no longer needs your personal data for the purposes mentioned above, but you need the data to establish, exercise or defend a right in court or (iv) you objected to the processing, for the time period in which to verify whether the legitimate grounds of the data operator prevail over the rights of the data subject;
The right to withdraw your consent regarding the processing, when the processing is based on consent, but without affecting the legality of the processing activities carried out until that moment;
The right to object to data processing for reasons related to your particular situation, when the processing is based on legitimate interest, as well as to object, at any time, to data processing for direct marketing purposes, including creating profiles;
The right not to be subject to a decision based exclusively on automated processing, including the creation of profiles, which produces legal effects concerning the data subject or similarly affects him in a significant way;
The right to data portability, meaning the right to receive the personal data you have provided to the data operator in a structured, commonly used and automatically readable form, as well as the right to transfer said data to another operator, if the processing is based on your consent or the execution of a contract and is carried out by automatic means;
The right to file a complaint with the Data Protection Authority (ANSPDCP) and the right to address the competent courts.
The above rights can be exercised at any time. To exercise these rights, we encourage you to use the forms available at
http://www.dataprotection.ro/?page=Modele_de_plangere on the ANSPDCP website or send a written, dated and signed request or in electronic format to the following address: B-dul G-ral. Gheorghe Magheru 28-30 Sector 1, postal code 010336 Bucharest, Romania or by e-mail at anspdcp@dataprotection.ro. Also, if you wish to withdraw your consent regarding direct marketing purposes, you have the possibility to use the “unsubscribe” option that is included in every marketing communication.
CHANGES TO THIS POLICY
This Privacy Policy may undergo changes from time to time and may be updated by the Company, as necessary, respecting the legislation in force. The company will notify you of any material or substantial changes to this Privacy Policy and will ensure that said notification is made in a manner that ensures you are aware of them, for example by using the e-mail address on that you have provided us or any suitable means to ensure effective communication.