INTRODUCTION

This Privacy Policy describes the categories of your data that we process, the manner and purposes for which we collect them, in what situations we transfer and/or disclose personal data, and the various rights and options you have in this regard.

Please also consult our Terms and Conditions available at http://circulario.ro/terms-and-conditions/, and the Cookie Policy (http://circulario.ro/cookie-policy/), which explain the use of cookies/other web tracking devices through our website.

Normally, the website can be used without entering personal data. When personal data are collected on the site (such as: name, first name, email address, company, position), they are collected because the interested person voluntarily provides this data.

As a rule, Pivot Circular Solutions S.R.L. collects and processes the data that website users of http://circulario.ro/ freely choose to provide.

The privacy policy of Pivot Circular Solutions S.R.L. applies to any visitor/user of the site, as well as to any personal data processed by Pivot Circular Solutions S.R.L.

If you do not want your personal data to be processed by Pivot Circular Solutions S.R.L., we advise you not to access our website, not to register, or not to send us documents/information that contains personal data.

 

WHO PROCESSES YOUR PERSONAL DATA?

The operator of your data is Pivot Circular Solutions S.R.L., with its registered office in Bucharest, Sector 1, Semicercului Street, No. 10, Building A, registered at the Trade Register under no. J40/24492/2023, having the tax registration code 49314910.

 

WHAT CATEGORIES OF DATA DO WE PROCESS?

Pivot Circular Solutions S.R.L. collects and processes only personal data that users/visitors of the website provide to Pivot Circular Solutions S.R.L. by accessing and visiting the website, by requesting our services, or by completing the contact form.

Additionally, third parties, acting as providers of applications, tools, widgets, and plugins on our website, may use automated means to collect data regarding your interaction with those platforms. In this situation, the data is collected directly by those providers, which means that regarding the data collection performed by those providers, individuals whose data are processed by them should consult the data protection policies and information notes of those providers as the policies of the providers apply in the case of such processing. Subject to applicable law, Pivot Circular Solutions S.R.L. is not responsible for the data protection practices of these providers.

We may also use analytical services provided by third parties on the website, such as those of Google Analytics. The providers managing these services use technologies such as cookies, web server logs, and web beacons to help us analyze how you use our website. Data collected through these means (including IP addresses) may be transmitted to these providers or other relevant third parties who use this data, for example, to evaluate the use of the website.

The following types of personal data may be processed by Pivot Circular Solutions S.R.L.:

  • First name, last name, phone number, email address, company, position, and the content of the message sent through the contact form;
  • Email address provided through the request form for published reports.

 

The data will not be disclosed to third parties and will be used exclusively for the mentioned purpose, under conditions of security and confidentiality.

 

HOW DOES PIVOT CIRCULAR SOLUTIONS S.R.L. COLLECT YOUR PERSONAL DATA?We may collect personal data about you in certain circumstances, including:

  • When you browse, request information, or interact on our website;
  • When you contact us through the contact form to request information and/or details about a service;
  • When you provide us with information about yourself in any way.

 

In certain circumstances, we collect personal data about you from a third-party source. For example, we may collect personal data from social media channels. Please read the privacy terms and conditions of those platforms. In any case, regarding the data we collect from third parties, these terms apply accordingly.

 

LEGAL BASIS FOR PROCESSING PERSONAL DATA

Any operation that constitutes processing, as defined by law (including, but not limited to, collection, storage, recording, structuring, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, destruction) of your personal data will be carried out based on one of the following legal bases:

 

  • Processing is necessary for the performance of a contract with you;
  • Processing is necessary for compliance with a legal obligation;
  • Processing is necessary for the purposes of the legitimate interests pursued by Pivot Circular Solutions S.R.L., except where such interests are overridden by your fundamental rights and freedoms.

 

IN WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

 

We can use your personal data only for the following purposes:

  • Facilitating your participation in events organized by Pivot Circular Solutions S.R.L;
  • Providing any requested information through the contact form;
  • Providing materials/reports requested by you;
  • Providing the services offered by Pivot Circular Solutions S.R.L.;
  • Handling any requests and/or complaints regarding the services provided;
  • Compliance with our legal obligations (such as record-keeping obligations)
  • Analyzing and improving our services and communications to you;
  • Protecting the security and managing access to the headquarters, IT and communication systems, website, and other systems;
  • Monitoring and evaluating compliance with our policies and standards;
  • For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data has been provided to us.

 

We will not use your personal data in automated decision-making processes that affect you or create other profiles than those described above.

 

SHARE YOUR PERSONAL DATA

 

We may share your personal data in the following circumstances:

 

  • We may share your personal data with courts, law enforcement authorities, regulatory authorities, or lawyers if it is necessary in order to establish, exercise, or defend a legal right.
  • We may use aggregated and statistical personal data for monitoring the use of the Pivot Circular Solutions S.R.L. website.
  • We may share your personal data with authorized entities – primarily service providers within or outside Pivot Circular Solutions S.R.L. (providers for various services such as website administration and hosting, advertising services) – for processing personal data for the purposes mentioned above, on our behalf and only in accordance with our instructions. Pivot Circular Solutions S.R.L. will retain control over your personal data and will use appropriate protection measures, in accordance with applicable law, to ensure the integrity and security of your personal data when requesting the respective service providers.

 

Pivot Circular Solutions S.R.L. also reserves the right to transfer your personal data in the event of reorganization operations and/or transfer of assets or parts of assets to third parties, in compliance with the applicable legal provisions regarding the processing of personal data.

Data collected through third-party plugins and widgets on websites are collected directly by the providers of the plugins and widgets. These data are subject to the data protection policies of the respective providers, and Pivot Circular Solutions S.R.L. bears no responsibility for the processing of data by these providers.

Otherwise, we will only disclose your personal data when instructed or authorized by you, when required by applicable law or regulations, or by requests from judicial or official authorities, or as required for the investigation of fraudulent or criminal activities.

Your personal data will not be transferred to third parties or partners for direct marketing purposes.

 

 

STORING PERSONAL DATA

Personal data may be stored on our technology systems or those of our contractors. We have taken all necessary measures regarding the individuals who come into contact with the data, the spaces where the data is processed, and the technical equipment used in connection with data processing to ensure that the data is processed securely, with confidentiality ensured, and to prevent unauthorized access or loss of data.

 

 

UPDATE OF PERSONAL DATA

If any of the personal data you have provided to us undergoes changes, for example, if you change your first name, last name, or email address, or if you wish to cancel any request to Pivot Circular Solutions S.R.L., or if you become aware that we hold any incorrect personal data about you, please notify us by sending an email to office@circularpivot.com.

 

 

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Pivot Circular Solutions S.R.L. has implemented technical and organizational measures for organizing the process and criteria provided for the deletion or elimination of your personal data. Your personal data will be deleted or removed when they are no longer necessary for the purposes for which they were received, or when you request the deletion of the data by exercising the right to be forgotten, and Pivot Circular Solutions S.R.L. no longer has a legal obligation to continue storing the respective data. However, we will retain your personal data when it is necessary for Pivot Circular Solutions S.R.L. to exercise or defend a right in court, until the end of the relevant retention period or until the resolution of such legal actions.

 

Unless you expressly request us to store your personal data for a longer period or unless the personal data is necessary for the defense of a potential right in court without a retention period, personal data will be deleted within 3 years from the last interaction with you

 

YOUR RIGHTS REGARDING THE PROCESSING OF PERSONAL DATA

 

Subject to certain legal conditions, you have the following rights regarding the processing of your personal data:

  1. Right to request access to your data

You have the right to obtain from Pivot Circular Solutions S.R.L. confirmation as to whether or not personal data concerning you is being processed, and, if so, access to that data and the following information: what data we process, for what purpose, if they have been disclosed to third parties and to whom, as well as the storage period of this data. We will also inform you about your rights regarding personal data, rights detailed in this information. You have the right to receive a free copy of the personal data being processed. For any additional copies requested, we reserve the right to charge a fee. You can request the communication of the above information in electronic format, in which case the data will be provided in an electronic format commonly used by us, unless you request them in a different format.

 

  1. Right to request Pivot Circular Solutions S.R.L. to rectify the data

 

You have the right to obtain, without undue delay, the rectification of inaccurate personal data concerning you and/or to obtain the completion of incomplete personal data, including by providing a supplementary statement. You may exercise this right at any time by sending an email to office@circularpivot.com.

 

  1. Right to request Pivot Circular Solutions S.R.L. to delete your data.

 

You have the right to request Pivot Circular Solutions S.R.L. to delete your personal data without undue delay, and Pivot Circular Solutions S.R.L. has the obligation to delete personal data concerning you if one of the following reasons applies:

  • Personal data is no longer necessary for the purposes for which it was collected or processed;
  • You exercise your right to object, as described in the right to object, and there are no overriding legitimate grounds for the processing;
  • You exercise your right to object to the use of your data for direct marketing purposes;
  • Personal data has been processed unlawfully;
  • Personal data must be deleted to comply with a legal obligation of the controller under European or national law.

 

  1. Right to request Pivot Circular Solutions S.R.L. to restrict the processing of your personal data under the following conditions:
  • If you contest the accuracy of the processed data, for a period that allows us to verify the accuracy of the data;
  • If the processing is unlawful, and you have not exercised your right to deletion, you have the right to request the restriction of processing;
  • If the controller no longer needs the personal data for processing purposes, but you request them for the establishment, exercise, or defense of a legal claim;
  • If you have objected to processing, during the period while it is verified whether the legitimate interests of the controller override those of the data subject;
  • If you have obtained the restriction of processing, we will inform you before lifting the restriction.

 

  1. Right to object

At any time, you have the right, for reasons relating to your particular situation, to object to the processing of your personal data. We will cease processing your data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or if the processing is necessary for the establishment, exercise, or defense of legal claims.

Additionally, you have the right to object at any time to the processing of your personal data for direct marketing purposes, including profiling related to such direct marketing. If you object to such processing, your personal data will no longer be processed for those purposes.

 

 

  1. Right to data portability

 

You have the right to receive the personal data concerning you that you have provided to us knowingly and actively, or that we have observed as a result of your use of our services, in the structure used by Pivot Circular Solutions S.R.L. currently, and you have the right to transmit this data to another controller, being able to request the direct transmission of this data from Pivot Circular Solutions S.R.L. to another controller if this is technically feasible.

The rights mentioned above can be exercised by a written request addressed to Pivot Circular Solutions S.R.L., at the email address office@circularpivot.com. In this case, we may ask you to prove your identity by providing us with more information to allow us to identify you, in order to comply with the security obligations we have and prevent unauthorized disclosure of data.

We will consider any requests or complaints we receive and will provide you with a timely response.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing.

 

UPDATES TO THE PRIVACY POLICY

This Privacy Policy was last updated in January 2019. We reserve the right to periodically update and modify this Privacy Policy to reflect any changes in how we process your personal data or any changes in legal requirements. In the event of any such changes, we will post the modified version of the Privacy Policy on our website and/or make it available in another way.

 

CONFIDENTIALITY

We assure you that your data is processed in accordance with the law, under conditions of security and confidentiality. We have taken all necessary measures, both internally and with regard to collaborators, to ensure compliance with this principle. We require our partners to fulfill the same Security and confidentiality conditions regarding personal data. In the event that, based on your consent, we disclose data to third parties, we require them to comply with the legal requirements regarding the processing of personal data.

 

CONTACT

If you wish to contact us regarding any questions related to this privacy policy, as well as the processing of your data, please send us an email at office@circularpivot.com.