Privacy

Last updated: 25 February 2020

Starting with May 25, 2018, Regulation 2016/679/EU on the protection of individuals with regard to the processing of personal data and on the free movement of these data will be applicable by all the states of the European Union.

This privacy policy explain how Histria, HSM ( “ Histria”,“HSM”, “we” ) process and control the personal data about you ( “ your Personal Data”; “ your Data”) and which are the legal rights that you have in relation to our collection and processing of your Personal Data.

This Privacy Policy may be updated regularly. Therefore, you are recommended to refer to this Privacy Policy for any changes and updates in the purposes of the processing.

Protecting your Personal Data

Protecting the Personal Data of individuals that we interact with throughout our activity, with conscious respect for the legal relevant requirements, is a commitment and a responsibility of high value and importance for HSM. Because the company processes personal data both for contractual purposes and keep you up to date with our activities, we want to assure you that our organization has taken appropriate technical and organizational measures to protect your data. Therefore, we have a policy that defines how we process and protect your personal data.

Data Subjects from who we collect and process Personal Data

HSM collect Personal Data of our employees, potential employees (for example, job candidates, job applicants), clients, suppliers, client’s and supplier’s representatives and website users. If the Personal Data we collect are not listed in this Privacy Policy, we will give individuals, when required by law, appropriate notice of which other Personal Data will be collected and how they will be used.

Categories of Personal Data that we collect and process :

We may collect and process the following categories of Personal Data about you:

1. Contact data and Business Contact Information: name, company details, email address, postal address, other contact information, including your business contact information and your business bank account and any data that would enable us to maintain our business relationship with you;

2. Targeted data: age, interests, any postings, comments or other content that you upload or post on our website or webpage, movements and behavior on our webpage, website and online systems;

3. Automatically collected data: IP addresses, information about your browser, operating system and other Personal Data that are relevant and necessary for the use of the service;

4. Biometric Data: photographs and images captured on CCTV or other video systems when you access our location and offices.

5. Cookies and Tracking Technologies: Below is information about how we use cookies and other similar technology on this website. You agree that we can place cookies and other similar technology on your device, including mobile device. By continuing to use your mobile device to access this website, you agree that the following information may be collected: your unique device identifier, mobile device IP address, information about your device’s operating system, mobile carrier and your location information (to the extent permissible under applicable law).

What are cookies? :

The Company’s internet pages use cookies. Cookies are text files stored in the computer system through a browser. Most websites and services use cookies. Many cookie files contain an identifier, a so-called session cookie. This is a unique identifier of a cookie file. By using the cookie files, the Company has the possibility to offer to the users of the websites more easy to use services, which would not be possible without their use.

Through the cookies, the information and offers on the website can be optimized in the interest of the user. The data subject may, at any time, prevent the installation of cookies through our website, through an appropriate setting of the internet browser used, thus permanently prohibiting the installation of cookies. Moreover, the cookies already installed can be deleted at any time through the browser or another program.

We may use information collected from our cookies to identify user behavior and to serve content and offers based on your profile, and for the other purposes described below, to the extent legally permissible in certain jurisdictions.

Some of the cookies we use don’t collect information that identifies a visitor. For example performance cookies and targeting cookies. Some cookies we use are placed by third party companies, such as Internet Explorer, Mozilla Firefox, Chrome, Safari, IOS, and Android etc. These companies may use programming code to collect information about your interaction with our site, such as the pages you visit, the links you click on and how long you are on our site. This code is only active while you are on HSM website. You may delete cookies if you no longer wish to store them on your computer.

By using our site, you agree that we can place cookies on your device as explained below. If you want to remove existing cookies from your device you can do this using your browser options. If you want to block future cookies being placed on your device you can change your browser settings to do this.

Please bear in mind that deleting and blocking cookies may have an impact on your user experience as parts of the site may no longer work. Unless you have adjusted your browser settings to block cookies, our system may issue cookies as soon as you visit our site or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies.

TYPES OF COOKIES

The following types of cookies may be used when you visit the Site:

1. Cookies strictly required

Cookies strictly necessary - they are used to make our work more efficient on the site. These are stored only for the current session of the browser on your computer. Without these cookies absolutely necessary, the site will not work as well as we would like and we may not be able to provide the site or certain services or functions that you request. Cookie files that are not necessarily required cannot be disabled by the function of this page. However, these can be disabled at any time using the browser used. Please refer to the instructions below.

Cookie name Description
__cfduid Cookies to identify web traffic.
JSESSIONID Session cookies are used to maintain the state of the application.

2. Analytics Cookies

Analytics cookies monitor how users reached the Site, and how they interact with and move around once on the Site. These cookies let us know what features on the Site are working the best and what features on the Site can be improved.

Cookie name Description
_ga Statistical cookies are used to understand how visitors interact with the website.
_gat
_gid
p.gif

3. Our Cookies

Our cookies are “first-party cookies”, and can be either permanent or temporary. These are necessary cookies, without which the Site won’t work properly or be able to provide certain features and functionalities. Some of these may be manually disabled in your browser, but may affect the functionality of the Site.

4. Personalization Cookies

Personalization cookies are used to recognize repeat visitors to the Site. We use these cookies to record your browsing history, the pages you have visited, and your settings and preferences each time you visit the Site.

5. Security Cookies

Security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorized parties.

6. Site Management Cookies

Site management cookies are used to maintain your identity or session on the Site so that you are not logged off unexpectedly, and any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.

7. Third-Party Cookies

Third-party cookies may be place on your computer when you visit the Site by companies that run certain services we offer. These cookies allow the third parties to gather and track certain information about you. These cookies can be manually disabled in your browser.

You’re Consent

By using the website, you are consenting to our processing of your Personal Data and information, including the use of cookies and other tracking technology as well as the potential transfer of your Personal Data.

Purposes for Collecting and Processing your Personal Data

We might process your Personal Data for the below listed purposes:

  • Recruitment, for ensuring that we recruit the appropriate employees;
  • For providing you with our services and products according to agreed terms and as per your request, hence for the purpose of allowing the commercial terms to be executed between parties and to enable you to have a good customer experience.
  • For carrying through the specific transactions and bookings and for maintaining our contractual and business relationship with our customers, vendors, including for maintaining a routine administrative flow and a routine contractual relationship with our customers, vendors and their representatives thereto during the delivery and execution of a commercial engagement.
  • For facilitating our communication with you to ensure business continuity, including for providing you with necessary information, references and recommendations about our services and products.
  • For monitoring your use of our systems to enable us to personalize your experience on our website, including monitoring the use of our website and any apps and tools you use.
  • For improving the security and functioning of our website, networks and information, to ensure that you receive an excellent user experience whilst our networks and information are secure.
  • Marketing our products and services to you, unless you objected against such processing, so that we can ensure that we can conduct and increase our business.
  • Legal Basis for Collecting and Processing of your Personal Data

    Histria process your Personal Data for the purposes set out in this Global Privacy Policy based on one or more of the following legal basis:

  • Because we are required to do so for compliance with a legal obligation to which we are subject.
  • Because such data is necessary for the performance of a contract to which you and the company you represent are a party to.
  • Because the processing is necessary for the purposes of the legitimate interests pursued by us, by yourself or by a third party or necessary in order to protect the vital interests of any person. Based on your prior consent, to the extent such consent is mandatory under applicable laws.
  • Who is the Operator of Personal Data?

    The company is the exclusive operator of the Personal Data you transmit to us and is responsible for your Personal Data in accordance with the applicable Data Protection Legislation.

    Personal Data Retention

    We will retain the data for as long as you use the website and as long we have an ongoing relationship with you and for a reasonable time thereafter. Please note that some or all of the data may be required in order for the website to function properly, and we may be required to retain certain information by law.

    We might retain your Personal Data longer, based on your legitimate interest or consent.

    We maintain specific records management and retention policies and procedures, so that Personal Data are deleted after a reasonable time according to the following retention criteria:

  • We retain your data as long as we have an ongoing relationship with you.
  • We retain your data for as long as needed in order to comply with our global legal and contractual obligations.
  • In such a case we will retain your Personal Data for as long you request us to do so but no more than for a reasonable period of time, and in any case not more than 2 years. We may retain your Personal Data where this is advisable to safeguard or improve our legal position (for instance in relation to statutes of limitations, litigation or regulatory investigations). We delete or anonymize your Personal Data when it is no longer needed for the purposes for which it was collected and subsequently processed.

    Who has access to your Data?

    Your data may be transmitted within the Company’s services. Our institution will only act as the person empowered by the natural persons to hold certain Personal Data and will process the Personal Data exclusively in the activity established by law or specific working norms. We do not transmit or transfer your data to third parties for marketing purposes. The data transmitted to third parties are used only to supplement the services we offer you.

    Data Subjects Rights

    You are entitled, in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law, to:

  • Request access to the Personal Data we process about you: this right entitles you to know whether we hold Personal Data of you and, if so, obtain information on and a copy of those Personal Data.
  • Request rectification of your Personal Data: this right entitles you to have your Personal Data be corrected if it is inaccurate or incomplete.
  • Request the erasure of your Personal Data: this right entitles you to request the erasure of your Personal Data, including where such Personal Data would no longer be necessary to achieve the purposes.
  • You have the right to delete any personal data processed by the Company at any time, except:

  • You have an unresolved request for information;
  • You have a contract in progress
  • You have an ongoing contract, which is under maintenance;

  • If you have concluded a procurement contract with the Company, we will keep your Personal Data regarding your transaction in accordance with the accounting legislation
  • If you are an employee of the Company.
  • Request the restriction of the processing of your Personal Data: this right entitles you to request that we only process your Personal Data in limited circumstances, including with your consent.
  • You have the right to ask the Company to restrict the process of processingyour Personal Data in the following situations:

  • If you oppose the processing based on the legitimate interest, the Company will restrict any processing of this data until the legitimate interest is confirmed;
  • If you state that your Personal Data are incorrect, the Company must restrict any processing of this data until the correctness of the Personal Data is verified;
  • If the processing is illegal, you can oppose the deletion of Personal Data and request the restriction of your Personal Data;
  • If the Company no longer needs you’re Personal Data, but these are necessary to defend your rights in court.
  • Request portability of your Personal Data: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of Personal Data that you have provided to us, or request us to transmit such Personal Data to another data controller.
  • Object to the processing of your Personal Data: this right entitles you to request that we no longer process your Personal Data.
  • The right to oppose the processing based on legitimate interest: you have the right to oppose the processing of your Personal Data, based on the legitimate interest. The company will not continue to process your Personal Data unless we can prove a legitimate reason for the processing, a reason that prevails over your interests and rights or based on legal proceedings.
  • Note that most of the Personal Data that we hold about you comes from information you completed, therefore, please ensure that you keep your information correct and up to date by updating your information on the website.

    Please note, however, that certain Personal Data may be exempt from the above-mentioned rights pursuant to applicable data privacy or other laws and regulations.

    To the extent that the processing of your Personal Data is based on your consent, you have the right to withdraw such consent at any time by contacting our Data Privacy Officer. Please note that this will not affect our right to process Personal Data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.

    If you wish to exercise your right to access your Personal Data, to object to it being processed data, please contact dpo@histria.ro or send a letter to Oborului street, 24 number, Constanta, Romania, Att: Data Privacy.

    Security Measures

    In accordance with European Data Protection Legislation, we use reasonable procedures to prevent unauthorized access and inappropriate use of Personal Data.

    Therefore, we protect your Personal Data in accordance with applicable data privacy laws and our data privacy policies and principles. Further, we have implemented appropriate organizational and technical security measures to protect your Personal Data against unauthorized or unlawful processing and against accidentals loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto. We maintain organizational, physical and technical security arrangements for all the Personal Data we hold. We have policies, procedures and guidance to maintain these arrangements taking into account the risk associated with the categories of Personal Data and the processing we undertake. We store Personal Data on servers with limited access location in secured facilities, and our security measures are evaluated on an ongoing basis.

    The servers are protect by anti-virus and firewalls, among other measures.

    Please contact our Data Privacy Officer dpo@histria.ro if you have a general question about how Histria protects your Personal Data, if you wish to exercise your rights in relation to your Personal Data rights, if you wish to make a complaint about Histria use of your Personal Data.