DSL Software Engineering policy on processing personal data

 

VERY IMPORTANT:

You have the right, at any time, to oppose the processing of personal data by us.

The right of opposition may be exercised by the person concerned (ie by you) only in one of the following two cases:

  1. “At any time, the person subject shall have the right to oppose, on grounds relating to his/her particular circumstances, the processing of data by virtue of Article 6 (1) (e) or (f) of the GDPR its staff, including the creation of profiles based on those provisions. An operator shall no longer process personal data unless the operator demonstrates that he has legitimate and compelling reasons justifying the processing and which prevails over the interests, rights and freedoms of the data subject or that the purpose is to establish, exercise or defend a right in court. “
  2. “Where the processing of personal data is for the purpose of direct marketing, the data subject may at any time object to the processing of personal data relating to him, including profiles, in so far as it relates to direct marketing. “

1. The identity and contact details of the operator of your personal data

DSL Software Engineering S.R.L. (DSL Software Engineering) is a personal data operator.

DSL Software Engineering S.R.L. has its headquarters in Bucharest, Sector 5, Uranus Street no. 98, cam. 1, building U8, entrance C, floor 7, ap. 67, is registered with the Trade Registry under no. J40/15810/2015 and has the VAT number  RO35365824.

Contact details of DSL Software Engineering S.R.L. are the following:

Bucharest, Sector 5, Uranus Street no. 98, cam. 1, building U8, entrance C, floor 7, ap. 67.

Telephone: +40723.799.036

Email: office@dslse.ro

2. Contact details of the person responsible for protecting your personal data

DSL Software Engineering has appointed a person responsible for personal data protection that can be contacted at e-mail: dpo@dslse.ro. To the extent that no personal data protection officer is contacted by e-mail, any other type of correspondence may be used using the DSL Software Engineering contact data mentioned in previous Chapter 1.

3. The categories of personal data we process

Depending on the category of people you are part of, and depending on how your personal data is in our possession, we may process, in whole or in part, the following categories of personal data:

  1. identification data (eg name, surname, domicile, personal identification number, etc.),
  2. data on identification using remote means of communication (eg telephone number, e-mail address, IP of a device),
  3. data on job/profession (eg. the company where you work, your position etc.)
  4. data on how you carry out the activity (eg the content of an e-mail sent from an address related to your work place, etc.),
  5. any data you understand to store in virtual machines/databases/programs/applications that we would be allowed to access (e.g., a user’s name etc.), including sensitive personal data (e.g., political views, etc.),
  6. graphoscopic data (eg your signature applied to a contract concluded with us),
  7. biometric data (e.g., your image contained in your identity document stored by us),
  8. financial data (e.g., your bank account, the bank it is open to, the date of a payment, the justification of a payment etc.),
  9. your opinions (eg your opinion on the services provided by our company).

4. The sources from which we obtain your personal data

The sources from which we obtain your personal data are varied, on a case-by-case basis, and may consist of:

  1. your person (e.g. send us an email or contact us by phone, send us a CV for employment within our company, etc.),
  2. the company/entity where you are hired (eg, your company sends us your personal data will be able to help with a specific problem related to the functionality of a software etc),
  3. the company/entity with whom you are in a particular relationship (eg, the company for which you provide certain goods and/or services without being its internal employee),
  4. other people/entities that own your personal data (e.g., a friend, a company you’ve been hired, another client of us, etc.),
  5. public sources (e.g., trade register contact details, search results displayed by a search engine, etc.).

5. The ways in which we process your personal data

DSL Software Engineering may process your personal data in whole or in part in the following ways:

  1. collecting (eg receiving a contract signed by you, receiving an e-mail from you, etc.),
  2. storage (eg keeping an e-mail received from you, keeping a contract signed by you, etc.),
  3. registration (eg your registration in our customer database, etc),
  4. visualization (e.g., viewing your contact data from our database, etc.),
  5. modification (eg when you ask us to modify your contact details etc),
  6. encryption (eg when encrypting devices that store your personal data, etc),
  7. transmission/disclosure (eg when we send your contact information to a courier, etc),
  8. destruction (eg when we delete an email received from you, etc),
  9. any other operations performed on/relating to your personal data (eg translation of a contract into an international language, etc).

6. The purposes of processing your personal data and the legal grounds for processing personal data

DSL Software Engineering processes a series of personal data based on one or more purposes, as well as one or more legal grounds, as outlined below. In order to understand the legal purposes and purposes for which we will process your personal data, please access the category of persons you are part of.

6.1.Potential Clients/Clients/Former DSL Software Engineering Clients and others persons related to them

DSL Software Engineering processes the personal data of its potential clients/clients/former clients, as well as other persons in a certain liason/relationship with them such as:

  1. natural persons,
  2. representatives of legal entities and/or other entities without legal personality (eg administrator, general manager, economic director, internal IT engineer etc.),
  3. employees of legal entities and/or other entities without legal personality (eg employees, civil servants, contract staff, etc),
  4. representatives of suppliers/partners/subcontractors/consultants/etc. (eg: the accounting firm’s manager, etc),
  5. employees of suppliers/partners/subcontractors/consultants/etc (eg: the employee of the Internet Service Provider, etc),
  6. representatives of a public authority/institution linked to them (eg an ANAF director, etc),
  7. employees of an authority/public institution related to them (eg an ANAF inspector, etc),
  8. any other physical person in any way connected with them (eg: an external IT consultant, etc).

6.1.1. Pre-contractual period

The purposes of processing

DSL Software Engineering aims to provide/ensure its services to as many people/entities as possible.

During the pre-contractual period, DSL Software Engineering will process your personal data for the following purposes:

  1. In order to initiate and sustain a dialogue with you,
  2. In order to present our services,
  3. in order to obtain from you some information on the basis of which we can offer you the services that best fit you,
  4. in order to draft acts related to the pre-contractual period (eg offer, sample contract etc),
  5. in order to understand the requirements and trends of the market (for example, what services are being sought, by which categories of clients, at what prices etc.),
  6. in order to understand how we can improve our services (eg, assessing internal staff, analyzing the opportunity to hire additional staff, etc.),
  7. in order to understand the way we have to organize our business from all points of view (commercial/marketing/HR/IT/financial etc) (eg evaluation of the contracts concluded in one month compared to the contracts that could have been concluded, in which our internal employees perform their job duties, analyzing how we present ourselves as a company, etc),
  8. in order to protect our rights and interests (eg if you consider yourself prejudiced in any way how we presented our services).

Legal bases of processing

The legal bases for processing your data:

  1. the need to take action at your request (eg, make a sample contract, make a customized offer to your needs, etc.),
  2. our legitimate interests to achieve the goals outlined above.

In consideration of the above, it is possible that DSL Software Engineering will contact you either on your own initiative (eg sending an e-mail) or at your own initiative (eg contact us by phone, visit our website etc.) or at the initiative of another person/entity (eg you and we receive an email from an intermediary).

Insofar as you become a DSL Software Engineering client, your data is processed as described in the next Chapter. 6.1.2.

Data storage period

Insofar as you do not become a DSL Software Engineering customer, your data will be, permanently, removed within 90 calendar days from when it becomes certain that you will not become our customer (eg, send us an email through which you inform us, interrupt our communication with us for a time exceeding a reasonable period, we inform you that we can not offer you the requested services, etc).

6.1.2. Contractual period/post – contractual period

The purposes of processing

DSL Software Engineering provides/ensures  services to its clients, fulfils a number of legal/conventional obligations and adapts its business strategy according to the requirements of the market.

During the contract/post-contract period, DSL Software Engineering will process your personal data for the following purposes:

  1. in order to execute the contract with you and/or the company you are employed with,
  2. in order to initiate and sustain a dialogue with you and/or the company you are employed with,
  3. in order to present our services other than those you have already contracted / which the company you employ is contracted,
  4. in order to obtain from you/your company you are hired some information on which to offer you other services that may fit you other than those already contracted and/or might fit your company to which you are hired,
  5. in order to draft the acts relating to the contractual period (eg timesheets, invoices, additional documents, balance statements, etc.),
  6. in order to fulfils legal obligations (eg the obligation to prepare the primary accounting documents, the obligation to store a certain accounting period, etc.),
  7. in order to understand the requirements and trends of the market (for example, what services are being sought, by which categories of clients, at what prices, etc.),
  8. in order to understand how we can improve our services (eg, assessing internal staff, analyzing the opportunity to hire additional staff, etc.),
  9. in order to understand the way in which we have to organize our business from all points of view (commercial/marketing/HR/IT/ financial etc) (eg evaluation of the contracts concluded in one month compared to the contracts that could have been concluded, the way our internal staff perform their job duties, analyzing how we present ourselves as a company, etc),
  10. in order to protect our rights and interests (eg if you do not pay the value of the invoices issued and we have to initiate a civil lawsuit).

Legal bases of processing

The legal bases for processing your data:

  1. processing is necessary for the execution of the contract concluded with you,
  2. processing is necessary to meet legal obligations that we incur (eg the obligation to prepare and keep primary accounting documents, such as the contract concluded with you, invoices issued to you, etc.)
  3. our legitimate interests (the interests to achieve the goals outlined above).

Data storage period

Your data is to be stored by us for the entire contractual period as well as after the termination of the contractual relations for a period of 5 calendar years, calculated from January 1 of the year following that in which the contract expires.

By way of exception, some of your data will be stored either for a longer period or for a shorter period, as a regulatory/administrative act that applies to us will impose such an obligation (e.g. The Tax Code requires/could impose the retention of your data for a period of 7 years, etc.).

The reasons for storing the data for the period above are the following:

  1. during the course of the contract, the data are necessary to know what parameters we have to respect towards you / the company you are employed for (eg: what we need to provide, where, under what conditions, what costs, etc.),
  2. during the course of the contract and afterwards, the data are contained in a series of financial and accounting documents which the law compels us to keep (eg contract, invoices issued, payment orders, bank records, receipts, etc.),
  3. during the course of the contract, and thereafter, the data are necessary for us to be able to inform you/to inform the company you are hired about the opportunity to provide services that may fit and/or match you better to the company you are hired, more than the ones originally contracted,
  4. during the course of the contract and afterwards, the data are necessary to be able to analyze the viability/technical efficiency/cost effectiveness/possible technical problems regarding the services offered, so that we can understand all the technical/economic aspects of the offered services,
  5. during the course of the contract and afterwards the data are necessary to understand the market trends, what type of services are sought, what is available on the market, what are the costs that the clients are willing to allocate, etc., knowing this information by helping us to adapt our business strategy to stay on the market as competitive and as close to your real needs and/or the company as you are employed,
  6. during the course of the contract, and then there is the possibility that there may be some misunderstandings/disputes between our company and you/your company to which you are employed in relation to the execution of the contract, in which case the data are necessary to protect our rights eg in the case of a process, we can prove that we have fulfilled our obligations, in the case of non-payment in due time of an invoice, we can prove that we have provided the invoiced services, etc),
  7. during the course of the contract and afterwards the data are necessary for us to analyze our own activity and how we do it (internal analysis) so that we can adapt to the market in a most appropriate way (eg we analyze if new employment is needed , in the affirmative case in which department, we analyze the efficiency of our employees, analyze the knowledge and professionalism of our employees, etc),
  8. After the contract is executed, it is possible for you/the company to which you are employed with or us to be subject to control by the tax authorities/other public authorities/institutions in which case we must be able to fully prove the contractual relations between us and how they were executed both by you /the company you are employed with, and by us.

6.2. Suppliers of DSL Software Engineering and other people related to them

DSL Software Engineering processes the personal data of its potential vendors/suppliers/former suppliers as well as other people in a connection/report with them as they are nominated in the chapter 3.1..

Chap. 6.1.1. – 6.1.2. applies accordingly to DSL Software Engineering providers.

6.3. DSL Software Engineering partners and other people related to them

DSL Software Engineering processes the personal data of its potential partners/partners/former partners as well as other persons in a conection/report with them as nominated in the chapter 3.1.

Chap. 6.1.1. – 6.1.2. also applies to DSL Software Engineering partners.

6.4. Other persons

DSL Software Engineering processes the personal data of others other than those exposed to the chapter 6.1. – 6.3. such as:

  1. representatives of public authorities/institutions (eg ANAF inspectors, police bodies, etc.),
  2. visitors to our headquarters and work point,
  3. visitors of our site,
  4. other persons with whom we can contact, etc.

The purposes of processing

DSL Software Engineering aims to provide/ensure its services to as many people/entities as possible, but also to fulfil its legal obligations, and to maintain it as visibly as possible on the market.

DSL Software Engineering will process your personal data for the following purposes:

1. In order to initiate and sustain a dialogue with you/the company to which you are employed with,

2. In order to present our services,

3. In order to obtain from you/the company to which you are employed with  of the information that we can offer you that best suits you and/or best suits the company you are employed with,

4. In order to draft the documents related to the pre-contractual period (offer, sample of contract, etc.)

5. In order to understand the requirements and trends of the market (for example, what services are being sought, by which categories of clients, at what prices etc.)

6. In order to understand how we can improve our services (eg internal staff assessment, consideration of additional staffing opportunities, etc.)

7. In order to fulfil legal obligations (eg the obligation to provide the documents and information requested by an authority / public institution that initiates a control regarding us),

8. In order to understand how we should organize our business from all points of view (commercial/marketing/HR/IT /financial etc. – eg evaluation of the contracts concluded in one month compared to the contracts that could have been concluded, assessing how our internal employees perform their job responsibilities, analyzing how we present ourselves as a company, etc.)

9. In order to protect our rights and interests.

The legal bases for processing

The legal bases for processing your data:

1. processing is necessary to meet legal obligations that we incur (eg if we are subjected to fiscal control, we provide the documents and information regarding your tax inspector, etc.),

2. our legitimate interests (the interests to achieve the goals outlined above).

Storage period

The storage period varies from case to case depending on the particulars of the data (eg number of visitors to our site may be held for a period of 3 months required to carry out a particular survey or may be held for a period of 1 year to analyze a evolutions, etc.).

However, we will ensure that we do not hold your data after the moment when the purpose for which we collected was made.

7. Recipients/categories of recipients of your personal data

Your personal data may and, in some cases, will, depending on circumstances, be passed on to:

  1. persons acting under our care (eg our employees),
  2. our personal data co-operators (e.g., the company you are employed with, our partner companies, our PFAs with contractual relations, etc.)
  3. people acting under the care of our personal data co-operators (eg employees of the company you work with, employees of our partner company, etc.)
  4. Empowered persons to process personal data on our behalf (e.g., a courier company, a PFA that is in collaborative relationship with us),
  5. persons who act under the care of persons empowered to process personal data on our behalf (eg, a courier company),
  6. You, insofar as you understand to exercise one of the rights provided by law (eg right of access),
  7. any other person / entity other than those listed in points 1-6, for example a distinct personal data carrier (eg ANAF).

The transmission of personal data to the persons listed above will only be made and to the extent that this transmission:

  1. Whether it is imposed by the need to achieve the purposes in which we process personal data,
  2. either it is imposed by law.

8. Transferring your personal data outside the European Union

DSL Software Engineering keeps your personal data, either in physical form, in digital format or in both formats, across the European Union.

However, in certain situations, DSL Software Engineering will transmit your personal data outside of the European Union (eg by sending an email to your company owning your e-mail server outside the European Union).

In these latter cases, DSL Software Engineering will ensure that the data transfer will be performed only to the extent that the conditions imposed by the European legislation on personal data protection (eg a European Commission conformity decision is fulfilled, is concluded an agreement to ensure the necessary guarantees, etc.).

9. Your rights

As far as your personal data is concerned, you have a number of rights:

1. the right of access to your data,

2. the right to rectify your data,

3. the right to obtain the deletion of your data,

4. the right to obtain restriction of the processing of your data,

5. the right to oppose your processing of your data,

6. the right to submit a complaint with the competent authority in the field of processing personal data.

DSL Software Engineering will facilitate the exercise of your rights, so do not hesitate to contact us at office@dslse.ro

10. Your obligation or your failure to provide us with your personal data

As a general rule, DSL Software Engineering will not compel you in any way to submit your personal data. However, in certain situations, if you do not send us your personal data, we can not fulfil our stated goals. For example, to the extent that you do not forward your contract with your signature, we can not consider that a valid contract has been concluded between us.

11. The inexistence of an automated decision-making process

DSL Software Engineering does not own/use any automated decision-making process, including creating profiles for you, and all decisions/ actions/inactions/measures taken/adopted/conducted by our company are based solely on the human factor.

Although we use a range of IT equipment, the decisions that we take for you are only adopted by our team members based on our own beliefs and appreciations, not automatically, based on the information provided by IT equipment.

12. Changing this policy

DSL Software Engineering informs you that this privacy policy of your personal data is a presentation of how we, today, when reading this material, process personal data.

There is a possibility that we may update this policy from time to time (eg because of regulatory changes because we want to process your data for other purposes and/or other legal grounds, etc.). In these latter cases, the policy update will be achieved without affecting in any way the rights and legitimate interests of personal data protection.

13. The exclusive nature of this policy

The present personal data processing policy was developed by Dumitru, Popescu si Asociatii S.P.A.R.L. (DPA Legal Team) in collaboration with members of the DSL Software Engineering team, exclusively for DSL Software Engineering and is the exclusive property of DSL Software Engineering.

Reproduction in whole or in part of this policy may be accomplished only with the express and written consent of DSL Software Engineering.

Privacy Settings
We use cookies to enhance your experience while using our website. If you are using our Services via a browser you can restrict, block or remove cookies through your web browser settings. We also use content and scripts from third parties that may use tracking technologies. You can selectively provide your consent below to allow such third party embeds. For complete information about the cookies we use, data we collect and how we process them, please check our Privacy Policy
Youtube
Consent to display content from Youtube
Vimeo
Consent to display content from Vimeo
Google Maps
Consent to display content from Google
Spotify
Consent to display content from Spotify
Sound Cloud
Consent to display content from Sound
en_USEnglish
ro_RORomână en_USEnglish