TO WHOM DOES THIS INFORMATION NOTE APPLY?
This Information Note applies to the processing of personal data of:
- Our contractual partners such as suppliers, customers (“Partners”);
- Visitors and users of our website (“Users”);
WHAT DATA DO WE COLLECT ABOUT YOU?
We collect and process your personal data as follows:
- from the information you provide by filling in the forms on our website: the form on the Contact page, the form on the Login page, the form for creating a new user account.
- by mailing with us by phone, email or in any other way.
The information you provide may include the name, e-mail address and telephone number, as well as other information, as the case may be. We will also collect information on how your user account and site are being used, such as the date and time you visited the website, including the public IP address.
Through our activity on the site, we will not collect or process sensitive personal data related to you (e.g., information about racial or ethnic origin, political opinions, religious confession or philosophical beliefs, health, sexual life, or sexual orientation), unless which:
- we are obliged to do so by law; and / or
- if you have given us your explicit consent separately.
If you voluntarily provide us with personal data (including sensitive personal data) through your interaction with the http://www.FWFcompany.com site or by contacting us by phone, e-mail or in any other way, we will erase such personal data from our systems if we do not believe that processing is necessary for a legitimate purpose of FWF, unless you made this data public (for example, in – a message forum that is visible to the public), in which case we will delete this data from http://www.FWFcompany..com only if the law imposes this or if we do not want to keep it.
Every time you visit www.FWFcompany.com, 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, login information, browser type and version, time zone setting, browser plug-ins types and versions, the operating system and platform, device type, and mobile device markup; this data is collected and processed on our behalf through third-party cookies, and you can find more information about this at the Cookies Policy
- data about your visit, for example, this may include URL data, a sequence of clicks to, through, and from http://www.FWFcompany.com (including date and time), the information or products you viewed, or searched on the site.
FWF collects your personal data in the following ways: directly from you (granted on site, email, social networks or other means of communication), traffic reports registered by the servers hosting the site, social networks as well as through cookies. If we obtain your personal data from a third party, we will provide you with all relevant information on processing as soon as possible but no later than one month after you obtained your personal data.
WHAT ARE THE PURPOSES OF THE PROCESSING OF PERSONAL DATA AND WHAT IS THE LEGAL BASIS OF THE PROCESSING?
We may process your personal data to the extent permitted or required by applicable law 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 that we have concluded with you;
- when complying with a legal obligation (ie, applicable laws in employment, accounting, auditing);
- when necessary for our legitimate (or third party) interests and your interests (fraud detection and prevention, or IT security and IT security), 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 content is presented in the most effective way for you;
- to improve the http://www.FWFcompany.com site including its functionality;
- to manage the site www.FWFcompany.com;
- for internal operations, including troubleshooting, data analysis, testing, research, statistics and research purposes;
- to keep the http://www.FWFcompany.com site safe;
- for advertising and marketing, including for specific marketing purposes, so as to provide content, including personalized content, that may be of greater interest to you.
In order to process your Personal Data, FWF is based on various legal bases, as follows:
- Execution of a contract or for the conclusion of a contract: The processing is necessary for the performance of the contract to which the data subject is a party or for making the necessary steps to conclude the contract between you and FWF (e.g., in the case of the expansion partners being the contract of collaboration, in the case of customers being the contract of sale – purchase, in the case of suppliers being the supply contract). Also, processing of your personal data may be necessary to take steps before concluding a possible contract, as you are a potential partner and would like to contact us for a possible collaboration;
- Legitimate Interests: We may use the information for our legitimate interests, such as providing the best site content, emails and newsletters to improve and promote our products and services as well as site content ours, and for legal, administrative and fraud detection purposes.
In some cases, we will process your personal data only with your consent (i.e., in the case of advertising and marketing). In these cases, we will separately request your consent in a transparent manner when providing your personal information. Subsequently, you can withdraw your consent at any time by sending a request to dpo@FWFcompany.com. Withdrawal of consent will not affect the lawfulness of the processing that took place before its withdrawal.
When requesting personal data to comply with legal or contractual obligations, the provision of such personal data by you is required. This means that if such personal data is not provided, we will not be able to manage the contractual relationship or comply with the legal obligations imposed on us. In all other cases, the provision of personal data is optional and you are not required to provide it.
We may process your personal data, such as identification data, contact details and address of residence, for the purpose of the possible exercise of our rights or claims against you in the future. This processing is based on our legitimate interest, and we need to exercise our rights in the event of possible litigation.
Specifically, we will use your personal information as follows:
Users and customers:
For the purpose of providing services, delivering goods and making payments based on relevant contracts, we may process your personal data, such as identification data, contact details, bank details.
This processing is based on:
- Execution of a contract to which Users (especially Customers) are part of, or
- A legal obligation imposed on us.
We may process your personal data so that we can provide you with information about goods or services that we believe you are interested in. If you are an existing customer, we will only contact you by email, phone or sms with information about goods and services similar to those that were previously sold unless you have previously opted in.
If you are a new customer, we will contact you electronically only if we have your prior consent. If you do not want us to use your data in this way, check the appropriate box in the form by which we collect your data form to create a new user account.
We will not send your personal data to third parties for marketing purposes without your explicit consent to this effect.
We may also use your personal data to measure or understand the preferred content linked to our products; and to make suggestions and recommendations to you and other Users of our site about products that may be of interest to you or them.
For the purpose of providing services, delivering goods and making payments based on relevant contracts, we may process your personal data, such as identification data, business contact details, bank details and tax identification code, for persons registered in VAT purposes.
This processing is based on:
- executing a contract to which you, as a Partner, are a party;
- legal obligations imposed on us;
- our legitimate interest.
In some cases, we process personal data such as the names and contact details of employees or contractors of the Trading Partners for the purposes of communications relating to the execution of a specific contract with the Partners.
This processing is based on:
- execution of a contract to which the Partners are party;
- the legal obligations imposed on us;
- our legitimate interest.
As a Partner, we can provide you with communications about our new products and services. If you no longer wish to receive these communications, you may opt-out by sending us an e-mail to dpo@FWF.com.
Candidates for jobs published by FWF:
In connection with your participation in the recruitment and selection process for one or more of the listed jobs as part of FWF, we may collect and process your personal data (e.g., the CV data you have send) for the purpose of selecting, evaluating professional skills for the job(s) you apply, and communicating with you during the recruitment process.
This processing is based on the legitimate interest of FWF.
- TO WHOM DO WE TRANSMIT PERSONAL DATA?
FWF will not transmit (by selling or renting) your personal information to third parties.
Within FWF, staff members are subject to privacy concerns with respect to personal data. FWF staff members have the right to manage their personal data only on the basis of instructions given by FWF in connection with their service responsibilities.
Appropriate technical and organizational measures are taken to protect personal data. This site uses security measures against the loss, alteration or misuse of information under our control. FWF, however, does not accept responsibility for the loss of information caused by software errors with which the site is designed and hosted. Also, we are not responsible for server security errors that host the site.
Personal data may be communicated 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 for the protection of our legitimate interests (including the legitimate interests of third parties) in accordance with the applicable laws.
Your personal data may also be disclosed to third parties as follows:
- To business partners, suppliers and subcontractors for the execution of all the contracts we conclude with you in order to provide the products and services requested by you
- To service providers that provide administrative, professional, and technical support to the Company for IT, security and commercial resources support;
- To external consultants (e.g., lawyers, accountants, auditors), for specific purposes, when necessary
FWF performs an appropriate prior assessment of the selection of third-party service providers and requires these service providers to maintain adequate technical and organizational security measures to protect personal data and process personal data only in accordance with the instructions specified by FWF. Service providers will have the right to use subcontractors to provide services to FWF, provided that each subcontractor respects the same data protection obligations as service providers.
- WHAT IS THE PERIOD FOR KEEPING PERSONAL DATA?
We will retain your personal data for the period necessary to meet the purposes listed in this Policy or for the period required by applicable national law, in accordance with the applicable legal minimum retention periods and / or as necessary to exercise our legitimate rights and legitimate rights of others).
If you are a Customer or a Partner, we will retain your personal data during your contractual relationship with you.
If we have a continuous relationship with you as a Partner we will continue to keep this personal data until our relationship is terminated and for the minimum retention period imposed by law.
If you are a user of the http://www.FWFcompany.com site (that is, you have created a user account on the site), we will keep your personal data for as long as the user account is active.
If you are a candidate for one or more of the jobs published in the Career section of www.FWFcompany.com, we will keep your personal data throughout the recruitment and selection process, plus a period of 2 years after completing the recruitment process (if the candidate was not employed in the company).
If we process your personal data under your consent, such personal data will be processed only for the period of your consent, unless you withdraw or limit your consent before the expiration of that period. In such cases, we will cease processing of that 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 purposes of our legitimate rights (including the legitimate rights of others).
Basically, we will retain your personal data for as long as required or permitted by applicable law. Later, we will remove / delete your personal data from our systems and records and / or take steps to anonymize them, so that you can no longer identify them based on them. In all cases, personal data from the contracts, communications and other documents identified may be subject to legal storage requirements requiring up to 10 years.
STORING PERSONAL DATA AND TRANSFERRING PERSONAL DATA OUTSIDE THE COUNTRY
The site http://www.FWFcompany.com is managed and maintained by SC Future Work Force SRL and hosted by SonikiT Solution’s servers located on the territory of Romania.
We intend not to transfer your personal data outside the EEA unless there are adequate safeguards, including:
- a decision on the suitability of the European Commission with regard to the country or countries of destination;
- a “privacy shield” certification;
- appropriate corporate governance rules;
- an approved code of conduct, together with the binding and enforceable commitments of the data controller or person authorized by the data controller in the country outside the EU and EEA;
- an approved certification mechanism, together with the binding and enforceable commitment of the data controller or the person empowered by the data controller in a non-EU country and the EEA to apply the appropriate safeguards; or
- EU standard contract clauses approved by the European Commission.
WHAT RIGHTS DO YOU HAVE?
You have the following rights according to the relevant legislation:
- The right to confirm that your personal data is processed by us or to provide you with a copy of your personal data;
- The right to request the rectification or deletion of personal data processed by www.FWF.com;
- The right to request the restriction of personal data processing by www.FWF.com;
- The right to oppose the processing of personal data by the http://www.FWF.com website (e.g., the use of direct marketing processing);
- The right to request the portability of personal data;
- The right to withdraw your consent at any time without affecting the lawfulness of the processing under consent prior to its withdrawal;
- The right to file a complaint with the National Supervisory Authority for Personal Data Processing.
Please be aware that your rights described above may be limited in certain situations and subject to the applicable laws and regulations on the protection of personal data. For example, the right to oppose 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 outweighs your interests. You will need to prove your identity and give us further details to help us respond to your request.
We will not charge a fee to meet your request unless this is permissible by law and, if such fee is charged, it will be reasonable and proportionate to your request.
In order to exercise one or more of these rights, please contact us at e-mail dpo@FWFcompany.com.
You can also exercise your rights by making a written, dated and signed application filed to FWF at the Brasov 2-4, Cluj Napoca, Romania – to the attention of the Data Protection Officer. In the request, you can show if you want the information to be sent to a specific address, which may be e-mail, or a mail service to ensure that you will only be handed over personally. Please note that prior to any such request; we reserve the right to verify your identity to ensure that the request comes from you.
FWF will provide the requested information within 30 days of receipt of the request, in compliance with your request for communication.
PERSONAL DATA SECURITY
We keep your personal data on Sonik IT Solutions servers located on the territory Name Country of Romania.
In accordance with European data protection law, we use reasonable procedures to prevent unauthorized access and misuse of personal data.
We use appropriate systems and procedures to protect and secure the personal data you transmit to us. We use appropriate technical and organizational measures to protect your personal data and prevent unauthorized access to it. We have entered into contractual relationships with third parties providing hosting services and these contracts include obligations on organizational and technical security of personal data. Only authorized personnel can access your personal information while working.
You are responsible for maintaining the confidentiality of all authentication means (e.g., username, passwords, etc.) used by you to access parts of www.FWFcompany.com. Data transmission over the Internet is not entirely secure. While we do our best to protect your data, we cannot guarantee 100% the security of your data transmitted to our site; any personal data transmission is at your own risk. Once we receive your data, we will use strict security procedures to try to prevent unauthorized access.
If you have any questions or concerns regarding the processing of your personal data by http://www.FWFcompany.com or if you want to exercise one or more of your rights, you can contact us at e-mail dpo@FWFcompany.com
Please do not disclose sensitive personal data (e.g., information about racial or ethnic origin, political opinions, religious or other beliefs, health or membership of a trade union), social security numbers when contact us.
Last updated: May 23rd, 2022.
Note: We may periodically update this Policy and we will notify you of any change by posting the new version on www.FWFcompany.com