Electronic Roads cares about the way in which your personal information is treated and is committed to protecting your privacy. This Privacy Notice explains how we collect and use your personal data and which rights and options you have in this matter. This notice may vary from time to time so please check it regularly – the changes will take effect as soon as they are posted on this website or app.
We welcome your views about our website and our Privacy Notice. If you would like to contact us with any queries or comments, please: (i) send an email to [email protected]; or (ii) send a letter to Bacau, 9 Mai Street, no. 58, D, flat 7, Romania; or (iii) by telephone 0040 751 886689
1. WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?
Electronic Roads S.R.L. (a Romanian company, headquartered in Bacau, 9 Mai street, no. 58, D, flat 7, Romania, registered with the Trade Registry under no. J4/1199/23.11.2012, having the sole registration code no. 30941780) is responsible for and controls your personal data, as data controller.
2. WHAT PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT?
Electronic Roads collects and uses information which you provide to us, for example when you are using our website or mobile app functionalities or creating user accounts or subscribing to newsletters. Such personal data may be your name, phone number, email address, home address and personal data related to your preferences.
When you visit our website we automatically collect certain information, on a no name basis. This includes your IP address, the date and time you accessed our services, the hardware, software or internet browser you use and information about your computer’s operating system, like application versions and your language settings. We also collect information about clicks and which pages have been shown to you.
If you are using a mobile device, we collect data that identifies your mobile device, device-specific settings and characteristics, app crashes and other system activity.
We may also receive information about you from public sources, or from third parties such as social media partners. For example when you link your Electronic Roads user account to your social media account, personal data may be shared with Electronic Roads by that social media provider, but only when it’s OK with you for them to do so.
3. FOR WHAT PURPOSE WE USE YOUR PERSONAL DATA?
We may use your personal data for the following purposes only (“Permitted Purposes”):
- Use of our website and mobile app functionalities;
- Set up of Electronic Roads user accounts and management of such accounts, allowing you to do a number of useful things (such as save preferences, interests, tailor newsletter content, share information and feedback);
- Marketing activities, such as sending you news of events and services or manage participation to promotions. You can unsubscribe from email marketing communications quickly, easily and at any time – just click on the “Unsubscribe” link included in each newsletter;
- Communicating with you including by email, by post, by phone or by texting you – which method we choose depends on the contact information you’ve previously shared with us;
- Market research and analytical purposes, in order to improve our services and enhance the user experience, and also for testing purposes, troubleshooting and to improve the functionality and quality of our website functionality;
- For legal purposes, to handle and resolve legal disputes, for regulatory investigations and compliance or to comply with lawful requests from law enforcement.
4. WHAT ARE THE LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA?
Depending for which of the above Permitted Purposes we use your personal data, we may process your personal data on one or more of the following legal grounds:
- To provide you with an Electronic Roads user account and the functionalities of our website;
- Our legitimate commercial business interest such as to provide you with website functionalities, increase awareness on the market, to prevent fraud and to improve our services. When using personal data to serve Electronic Roads or a third party’s legitimate interest, Electronic Roads will always balance your rights and interests in the protection of your personal data against Electronic Roads rights and interests or those of the third party;
- To comply with our legal and regulatory obligations;
- For the establishment, exercise or defence of legal claims or proceedings;
- Your consent where you have expressly given that to us.
5. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
We may share your personal data with certain trusted third parties in accordance with contractual arrangements in place with them and confidentiality closes (where the case), including:
- Our professional advisers and auditors;
- Suppliers to whom we outsource certain support services such as marketing;
- IT and telecom service providers;
- Law enforcement insofar as it is required by law or is strictly necessary for the prevention, detection or prosecution of criminal acts and fraud or if we are otherwise legally obliged to do so. We may need to further disclose personal data to competent authorities to protect and defend our rights or properties, or the rights and properties of our business partners;
- Business partners, which distribute or advertise our service or may provide you with further services. Such is the case when you fill in certain information or search criteria on our website or app for transport, accommodation, tickets etc. and you are redirected to our partners’ websites – there we forward and load in the information and search criteria that you have already put in on our website or app. Please also take the time to read our partners privacy policies when you are redirected to them.
6. HOW DO WE STORE YOUR PERSONAL DATA?
We take appropriate technical and organisational measures to keep your personal data confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to personal data. Personal data may be kept on our personal data technology systems, those of our contractors or in paper files.
Your personal data will be deleted when it is no longer reasonably required for the Permitted Purposes or you withdraw your consent (where applicable) and we are not legally required or otherwise permitted to continue storing such data. However, we will retain your personal data where required for Electronic Roads to assert or defend against legal claims until the end of the relevant retention period or until the claims in question have been settled.
7. YOUR RIGHTS
The European Union’s General Data Protection Regulation and other applicable data protection laws provide certain rights for data subjects.
You are entitled to request details of the information we hold about you and how we process it. You may also have a right in accordance with applicable data protection law to have it rectified or deleted, to restrict our processing of that information, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organisation.
You may also have the right to lodge a complaint in relation to Electronic Roads’ processing of your personal information with a local supervisory authority from your domicile or residence, working place or place where you consider that data protection rules were breached.
In general, it is entirely your free will if you provide us with your personal data – there are generally no detrimental effects for you if you choose not to consent or to provide personal data. If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above or that you may not be able to make use of the services and products offered by us. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.
We must ensure that your personal information is accurate and up to date. If any of the personal data that you have provided to us changes, for example if you change your email address or if you wish to cancel any request you have made of us, or if you become aware we have any inaccurate personal data about you, please let us know. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
8. HOW DO WE TREAT PERSONAL DATA OF CHILDREN?
The services offered by Electronic Roads are not directed at children under 16 years old. For children younger than 16 years old, the use of any of our services is only allowed with the valid consent of a parent or a guardian. If we become aware that we process information of a child under 16 years old without the valid consent of a parent or guardian, we reserve the right to delete it.
9. TRANSFER ABROAD OF YOUR PERSONAL DATA
We may transfer your personal data abroad if required for the Permitted Purposes as described above. This may include countries which do not provide the same level of protection as the laws of your home country (for example, the laws within the European Economic Area). When doing so we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of your personal data.
We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the General Data Protection Regulation (EU) 2016/679 or other relevant laws. This includes entering into the EU Standard Contractual Clauses which are available here.
We will also require our agents, consultants and sub-contractors and others who are outside the European Economic Area and to whom we transfer your personal data to ensure a similar level of data protection.