Privacy Policy
WHO ARE WE?
A. We are the Ministry of Investments and European Projects of Romania, a ministry part of the Government of Romania ("We" or "M.I.P.E.");
M.I.P.E. is an official governmental body, part of the Government of Romania, located at 1-1B Bucharest-Ploiești Blvd, Victoria Office, Staircase Str. Menuetului 7, Sector 1, Bucharest. The official platform of M.I.P.E. and the contact details of M.I.P.E. can be accessed by following this link. ANY REFERENCES CONTAINING THE WORDS "OURS", "WE" OR SIMILAR MUST BE UNDERSTOOD AS REFERENCES TO M.I.P.E..
B. M.I.P.E. exclusively owns and operates the Attractive Romania Platform ("Platform" or "Attractive Romania Platform");
The Platform represents a dedicated software solution for publishing and promoting the "Attractive Romania Program", which can be accessed both as a mobile application (available for download through the Apple App Store and Google Play Store) and as a web version (available at www.romania-atractiva.ro). Throughout this document, the term "Platform" will refer to either version, unless explicitly stated otherwise.
THE PURPOSE OF THIS DOCUMENT IS to establish the rules for processing personal data related to the Attractive Romania Platform.
The Ministry of Investments and European Projects processes personal data as the controller in connection with the Platform.
THIS POLICY APPLIES TO YOU:
A. If you access and navigate the Platform - as a Visitor; and/or
B. If you use the Platform based on a user account - as a User.
Any terms capitalized in this document and not defined herein shall have the meaning ascribed to them in the terms and conditions of the Platform, available here: link
Please refer to the full document in the following pages.
1. WHAT PERSONAL DATA DO WE PROCESS?
1.1. During visits to the Platform (Visitors);
Processed Personal Data | We do not process any other personal data, except for those provided in our cookie policy, available here
1.2. When registered with a user account (Users);
a. registration of a user account;
Processed Personal Data | (depending on the chosen registration method)
· name, email;
or
data associated with an account (Google/Apple) if you register with the data associated with your account in the respective platform
Processing Purpose | To provide you with the functionalities of the Platform, as developed.
Legal Basis | Execution of a contract to which you are a party as the data subject (pursuant to Art. 6, para. 1, lit. b of the GDPR).
Duration of Processing | Throughout the existence of the user account until its deletion, regardless of the circumstances under which the deletion is initiated
To whom do we transfer them, during processing | To the persons identified in section 6 below.
· name, email;
or
data associated with an account (Google/Apple) if you register with the data associated with your account in the respective platform
Processing Purpose | To provide you with the functionalities of the Platform, as developed.
Legal Basis | Execution of a contract to which you are a party as the data subject (pursuant to Art. 6, para. 1, lit. b of the GDPR).
Duration of Processing | Throughout the existence of the user account until its deletion, regardless of the circumstances under which the deletion is initiated
To whom do we transfer them, during processing | To the persons identified in section 6 below.
b. Saving a route in your User account;
Processed Personal Data | The data from point 1.1 li. a above, as well as the details of the objectives or routes saved by you in the User account.
Processing Purpose | To be able to provide you with the functionalities of the Platform.
Legal Basis | The legal basis is your consent as a data subject (according to Art. 6, para. 1, lit. a of the GDPR), given at the time of creating your User account.
Duration of Processing | Throughout the existence of the user account or until consent is withdrawn.
To whom do we transfer them, during processing | To the persons identified in section 6 below.
Processing Purpose | To be able to provide you with the functionalities of the Platform.
Legal Basis | The legal basis is your consent as a data subject (according to Art. 6, para. 1, lit. a of the GDPR), given at the time of creating your User account.
Duration of Processing | Throughout the existence of the user account or until consent is withdrawn.
To whom do we transfer them, during processing | To the persons identified in section 6 below.
c. Publishing ratings, descriptions, and/or reviews of a cultural-touristic objective;
Processed Personal Data | Your name, title, description, and/or review about a cultural-touristic objective, as well as their publication date in the Platform.
Processing Purpose | We process the data in order to provide you with the functionalities of the Platform.
Legal Basis | The legal basis is your consent as a data subject (according to Art. 6, para. 1, lit. a of the GDPR), given at the time of creating your User account.
Duration of Processing | For the entire duration of the User account or until consent is withdrawn.
To Whom We Transfer Them, During Processing | To the persons identified in section 6 below.
Processing Purpose | We process the data in order to provide you with the functionalities of the Platform.
Legal Basis | The legal basis is your consent as a data subject (according to Art. 6, para. 1, lit. a of the GDPR), given at the time of creating your User account.
Duration of Processing | For the entire duration of the User account or until consent is withdrawn.
To Whom We Transfer Them, During Processing | To the persons identified in section 6 below.
d. Publishing Content Regarding a Cultural-Touristic Objective;
Processed Personal Data | Your name, surname, and your image if the content you publish through reviews (for example, a photograph of you at a specific location) contains your image.
Purpose of Processing | We process the data so that we can provide you with the functionalities of the Platform.
Legal Basis | The basis is the performance of a contract to which you are a party as a data subject (according to art. 6, para. 1, lit. b of the GDPR).
Duration of Processing | For the entire duration of the user account.
To whom we transfer them, for the duration of processing | To the persons identified in section 6 of this Privacy Policy.
Your rights | You can exercise the rights referred to in section 7 of this Privacy Policy.
Purpose of Processing | We process the data so that we can provide you with the functionalities of the Platform.
Legal Basis | The basis is the performance of a contract to which you are a party as a data subject (according to art. 6, para. 1, lit. b of the GDPR).
Duration of Processing | For the entire duration of the user account.
To whom we transfer them, for the duration of processing | To the persons identified in section 6 of this Privacy Policy.
Your rights | You can exercise the rights referred to in section 7 of this Privacy Policy.
e. Contacting Users;
Processed Personal Data | Name, surname, email address.
Purpose of Processing | We process data to be able to communicate regarding any question or issue related to the Platform.
Legal Basis | The basis is the execution of a contract to which you are a party as the data subject (according to Art. 6, para. 1, lit. b of the GDPR), namely to be able to respond to the question asked and related to which you seek a solution.
Duration of Processing | Throughout the existence of the user account
To Whom We Transfer Them, During Processing | To the persons identified in section 6 below.
Purpose of Processing | We process data to be able to communicate regarding any question or issue related to the Platform.
Legal Basis | The basis is the execution of a contract to which you are a party as the data subject (according to Art. 6, para. 1, lit. b of the GDPR), namely to be able to respond to the question asked and related to which you seek a solution.
Duration of Processing | Throughout the existence of the user account
To Whom We Transfer Them, During Processing | To the persons identified in section 6 below.
1.3. In the Event of Dispute Resolution Regarding the Use of the Platform
Processed Personal Data | Name, surname, and/or email and, if applicable, other data or information necessary in accordance with our cookie policy, available here, in connection with your use of the Platform.
Purpose of Processing | We process data for the defense of our legitimate rights and interests and support of any claims made by us before the judiciary or any other public authorities.
Legal Basis | The basis is our legitimate interest (Art. 6, para. 1, lit. f of the GDPR)
Details: Our legitimate interest in defending our rights or legitimate interests or in supporting claims arising from or closely related to the conclusion or performance of a contract or for the purpose of exercising the right to defense in the event of initiation of legal proceedings against us.
Duration of Processing | For the entire duration of the user account
To whom we transfer them, for the duration of the processing | To the persons identified in section 6 below.
Purpose of Processing | We process data for the defense of our legitimate rights and interests and support of any claims made by us before the judiciary or any other public authorities.
Legal Basis | The basis is our legitimate interest (Art. 6, para. 1, lit. f of the GDPR)
Details: Our legitimate interest in defending our rights or legitimate interests or in supporting claims arising from or closely related to the conclusion or performance of a contract or for the purpose of exercising the right to defense in the event of initiation of legal proceedings against us.
Duration of Processing | For the entire duration of the user account
To whom we transfer them, for the duration of the processing | To the persons identified in section 6 below.
1.4. Commercial Messages (e.g., email marketing)
Processed Personal Data | Name, surname, and/or email.
Purpose of Processing | We process data to keep you informed about news related to the Platform and the Attractive Romania Program.
Legal Basis | The basis is your consent as a data subject (according to art. 6, para. 1, lit. a of the GDPR), given when creating your User account.
Duration of Processing | Until you withdraw your consent.
Recipients, Duration of Transfer | To the individuals identified in Section 6 below.
Purpose of Processing | We process data to keep you informed about news related to the Platform and the Attractive Romania Program.
Legal Basis | The basis is your consent as a data subject (according to art. 6, para. 1, lit. a of the GDPR), given when creating your User account.
Duration of Processing | Until you withdraw your consent.
Recipients, Duration of Transfer | To the individuals identified in Section 6 below.
2. WHERE DO WE GET THIS DATA FROM?
The data is provided directly by you as a User or, as the case may be, indirectly, in accordance with our cookie policy, available here
You can refuse to provide certain Personal Data but, in such a case, you may not be able to benefit from certain functionalities or specific services of the Platform.
3. ABOUT THE LEGAL BASES
The legal basis for processing varies depending on the specific situation from point 1 above, as well as the processed Personal Data.
In situations where we will process your Personal Data based on consent, we will request your freely given, informed, specific, and unambiguous consent for that processing. By expressing your consent, you agree that we may process Personal Data in accordance with this Policy.
4. AUTOMATED PROCESSING OF PERSONAL DATA
Your Personal Data will not be processed for the purpose of generating decisions based solely on automated processing that would produce legal effects concerning you or significantly affect you, within the meaning of Article 22(1) of the GDPR.
5. DURATION OF PROCESSING
The duration of processing Personal Data varies depending on the specific processing operation.
In certain circumstances, we may retain Personal Data for longer periods of time to maintain accurate records of your relationships with us in the event of any complaints or if we reasonably believe there is a prospect of litigation.
6. TRANSFER OF PERSONAL DATA
We may transfer Personal Data, to the extent necessary, to the following categories of recipients:
a. IT service providers, as authorized persons by the Ministry in connection with the provision of certain services related to the Platform and, if applicable, with respect to the Attractive Romania Platform, such as Terra Building SRL, headquartered in Orlat, Jud. Sibiu, str. Nouă, Nr. 815, tel. 0269.571.477, fax, 0269.571.555, e-mail: office@sistemedepavaje.ro, registered with the Sibiu Trade Register under no. J32/611/2011, unique registration code RO14232426 and Eventya Co SRL, headquartered in Sibiu, str. Viile Sibiului, nr. 1, jud. Sibiu, tel: 0786.509.683, e-mail: contact@eventya.net, registered with the Sibiu Trade Register under no. J32/408/2013, tax identification code RO31611012;
b. IT service providers, including notification management or marketing service providers (such as MailChimp), other platforms (including those associated with the User account such as Google or Apple);
c. in some cases, if the law requires us to do so, we may share your Personal Data with government or other authorities.
These recipients may be located in the European Union and/or the European Economic Area, as well as outside them, including in countries not recognized as providing an adequate level of protection, in which case the transfer of Personal Data is made only if there are adequate guarantees in accordance with applicable law (such as standard contractual clauses issued by the European Commission). You can request a list of recipients from third countries, as well as a copy of the agreed provisions ensuring an adequate level of protection of Personal Data.
7. SECURITY OF PERSONAL DATA
The security of your Personal Data is important to us. Therefore, your Personal Data will be processed by applying reasonable technical and organizational measures to protect them, such as limiting access to Personal Data, encrypting or anonymizing Personal Data, storing them on secure media. However, despite the efforts made, we cannot always guarantee the effectiveness of the security measures implemented, and therefore, we cannot guarantee the security of Personal Data at all times.
8. RIGHTS REGARDING THE PROCESSING OF PERSONAL DATA
8.1. Right of access: You have the right to obtain confirmation from us that your Personal Data is being processed by us, as well as information about the specifics of the processing such as: purpose, categories of Personal Data processed, recipients, retention period, their source, whether we transfer them abroad and how we protect them, your rights, the right to lodge a complaint with the supervisory authority.
8.2. Right to rectification: You have the possibility to request the rectification of your Personal Data, provided that the applicable legal requirements are met. In case of errors, after notification, we will immediately correct your Personal Data.
8.3. Right to erasure: In certain cases, you have the right to request the erasure of Personal Data, such as when: (i) they are no longer necessary for the purposes for which we collected and processed them; (ii) you have withdrawn your consent for the processing of Personal Data and we cannot process Personal Data on other legal grounds; (iii) Personal Data are processed unlawfully; (iv) you exercise a legal right to object. We are not obligated to comply with your request for erasure if the processing of Personal Data is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims. There are also other circumstances in which we are not required to comply with this request for erasure of Personal Data.
8.4. Restriction of processing: You may request the restriction of the processing of your Personal Data in the following situations: (i) when you contest the accuracy of Personal Data, for a period that allows us to verify the accuracy of the Personal Data in question; (ii) when the processing is unlawful, and you oppose the erasure of Personal Data, requesting instead the restriction of their use; (iii) when we no longer need Personal Data for the purpose of processing, but you request them for legal action; (iv) when you have objected to the processing, for the time period while verifying whether our legitimate interests as a controller override those of the data subject. We may continue to use Personal Data following a request for restriction, where: (i) we have your consent; (ii) to establish, exercise, or defend a legal right in court; or (iii) to protect the rights of another natural or legal person.
8.5. Right to data portability: You have the right to receive your Personal Data, which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit this Personal Data to another controller, where technically feasible. This right does not adversely affect the rights and freedoms of others.
8.6. Right to object: In certain situations, such as when we process your Personal Data based on legitimate interests, you have the right to object to the processing of your Personal Data by us. In case of unjustified objection, the Company is entitled to continue processing Personal Data. You can also object to the processing of your Personal Data for the purpose of sending commercial messages.
8.7. Withdrawal of consent: Insofar as we process your Personal Data on the basis of your consent, you can revoke your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
8.8. Automated individual decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you in a significant way. This right does not apply if the decision: (i) is necessary for the conclusion or performance of a contract between you and us; (ii) is authorized by law that provides for adequate safeguards for your rights and freedoms; (iii) is based on your explicit consent.
8.9. Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (“ANSPDCP”) regarding any breach of your rights regarding the processing of your Personal Data. The contact details of the ANSPDCP are: G-ral. Gheorghe Magheru Blvd 28-30, Sector 1, postal code 010336 Bucharest, Romania; email: anspdcp@dataprotection.ro.
To exercise the rights mentioned above, please contact us at the email address: contact@romania-atractiva.ro.
9. CONTACT
If you have any questions or concerns about this Policy or its implementation, you can contact us at the email address: contact@romania-atractiva.ro.