This confidentiality policy aims to provide information regarding the collection, use, and disclosure of personal data to third parties by the “RADU STANCA” NATIONAL THEATRE (organizer of FITS), based in Sibiu, Bb. Corneliu Coposu, nr. 2, jud. Sibiu, e-mail: firstname.lastname@example.org
, (hereinafter collectively referred to as “the Organiser”), as owner of the website www.sibfest.ro (hereinafter referred to as “the Website”).
Your confidentiality is important to us. Therefore, we strive to process your personal data according to the principles set out in the laws regarding the protection of personal data applicable in Romania, including the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”). Personal data is any data about an identified or identifiable natural person, while an identifiable person is a person that can be identified directly or indirectly, especially by reference to an identification number or one or several physical, psychological, mental factors, or to economic, cultural, or social culture.
This confidentiality policy refers to the personal data of our providers, our business partners, of the website visitors, of other persons who contact and visit us and their representatives, potential collaborators and partners, and applies to the data collected through the website, as well as to all the other personal data collected via e-mail, the contact form, competitions, by using the website or by other offline contacts.
This confidentiality policy describes
- The categories of personal data we collect and process,
- The purposes for which we collect and use your personal data,
- The reasons why we process to these ends,
- The duration of the processing of this data,
- Your rights as visitors and how to exercise them,
- To whom we may disclose your personal data.
CATEGORIES OF PERSONAL DATA; PROCESSING PURPOSES AND REASONS
In the context of your interaction with the organizer, you, as a natural person, may be the object of the processing of the personal data we collect. We hereby inform you that we use your personal data in the cases below.
1. For website visitors
The purposes of the processing are:
- To communicate with you.
It is possible that you may ask for assistance or send us comments, suggestions or questions about our website, the articles posted on the Website and the processing or your personal data. In this case, we use your contact data to communicate to you about your requests. In this case, the purpose of the processing is to analyse your requests and offer answers thereto.
- Data processing as a legal requirement
We may process some of your data in the context of providing the products and the services based on legal requirements (for example, the requirement to observe tax rules). In this case, the grounds for processing is the fulfilment of a legal obligation.
- Sending newsletters
We may also use your contact data to send you specialized electronic newsletters about the events, the conferences, the competitions and/or the promotions we organize, but only if you subscribed and thus granted your express consent for such processing. You may withdraw you consent at any moment and opt out of the newsletter in the future by clicking “Unsubscribe” when receiving such e-mail or by contacting us at email@example.com. - Competitions and raffles
Should you register to the competitions and/or the raffles organized by us, we will process the personal data provided to us by registering. In this case, we rely on your consent to take part in these events organized by us.
- To monitor website traffic and improve content
In this data processing activity, we rely on our legitimate interest to ensure the proper functioning of our website, as well as its improvement.
The categories of data processed in this context are the time and date when you access the website and the IP address used to access our website.
- Refunding tickets to our events
Should you request for a refund of a ticket to an event organised by us, we process the personal data mentioned under the refund form available at [——]. In this case, the grounds for processing is your consent, i.e. the fulfilment of a request submitted by you.
The categories of data processed in the context of our relationship with you are set out below:
*When you register on the website to receive our newsletters, we process the following data: e-mail address.
When you take part in competitions or raffles, we process the following data: your name, your e-mail address:, your telephone number, and your address. (In this latter case, only if necessary, for instance, to deliver your prizes.)
To register to our competitions and/or raffles, you have to fill in a form providing the above-mentioned data.
-When you fill in the refund form, we process the following data: e-mail address, first and last name, IBAN and account holder name, signature.
When you come to our office to talk to our representatives, we may process the following data: your name, e-mail address, telephone number, and your image.
2. For the organizer’s business partners or providers
The purposes of the processing are set out below:
- Maintaining our contractual relation
We use your relevant personal data to maintain our contractual relationship with you. In this case, we rely on contract performance as grounds for processing.
- Communicating to you
We use your personal data to communicate to you about any relevant aspects related to our contractual relationship. In this case, we also rely on the fulfilment of our contract as grounds for processing.
- Processing data as a legal requirement
We may process some of your data in the context of providing the services based on the fulfilment of a legal requirement, if the case may be. In this case, the grounds for processing is the fulfilment of a legal obligation.
- The categories of data processed in the context of our relationship with you are: your name, e-mail address, telephone number, address, bank details, and any other personal data that you may provide to us directly.
3. If you are a representative, contact, employee, or any other collaborator of an organizer’s business partner
- The purposes of the processing are set out below:
Maintaining our contractual relationship with our business partner
We use your relevant personal data to maintain the contractual relationship with our business partner (including a provider). In this case, we rely on the legitimate interest to ensure that the contractual relationship is properly managed.
- Communicating to you
We use your personal data to communicate to you about any relevant aspects related to our partnership. In this case, we rely on the legitimate interest to ensure that the contractual relationship is properly managed.
- Processing data as a legal requirement
- We may process some of your data in the context of providing our services and products, on the grounds of fulfilling a legal obligation.
The following categories of data are processed in this context: name, position, e-mail address, telephone number, address, and any other personal data provided to the organizer, usually by you, if necessary to fulfil the above-mentioned purposes.
In all cases, the data is provided either directly by you, or by the business partner.
4. When you apply for a job
We use the personal data in the CVs we receive in order to evaluate if the applicants qualify for a position with the organizer. In this case, the grounds are related to fulfilling the necessary steps to conclude and perform a contract. The categories of data processed in the context of our relationship to you are: your name, e-mail address, telephone number, address, the personal data included in the CVs, details about education and training, professional qualifications, and any other personal data that you may provide to us directly. Once the position is filled, we destroy all the CVs received within 45 days from the date when the position was filled.
MAKING PERSONAL DATA AVAILABLE
When the data is requested directly from you, the organizer asks that you provide all the categories of personal data we need for the above-mentioned purposes, as otherwise we are unable to unfold our activity. When you provide other natural persons’ personal data to us, before such disclosure, please inform them of how the organizer intends to process their personal data, as per this Confidentiality Policy.
DISCLOSING PERSONAL DATA
Although we normally do not disclose your personal data to third parties, we may:
a. if necessary, transfer your data, by disclosure or providing remote access, only via secure applications, to certain third parties, such as the organizer’s commercial partners, who act as data processors for and on behalf of the organizer (for example, for hosting, IT, accounting services, payment processing services, legal and financial advisors, shipping assistance service suppliers of providers), with which the organizer concluded the necessary contractual agreements, in accordance with EU and national regulations. We will transfer the data to third parties only to the necessary extent so as to serve the applicable processing purposes for which your data is collected and processed.
b. disclose the data to comply with the law or in response to a request made by a court or any other legal authority, such as a warrant or a subpoena. The organizer may also share the data in good faith if we deem it necessary to prevent or to manage frauds or to protect the organizer.
c. if necessary, disclose relevant personal data to the competent authorities, in the context of providing the services you requested from us.VE GLOBAL ROMANIA LIMITED
DURATION OF PROCESSING
We intend to keep hold of your personal data throughout and after the duration of the contract concluded with you, in accordance with our internal policies and legal obligations. Should the data not be collected in the context of such an agreement, such data will be kept for as long as necessary to fulfil the purpose of the expected data collection or for any other longer periods required by law, by a regulation on record-keeping or by public authorities.
Immediately after the end of the applicable archiving period, the data will be:
- safely deleted or destroyed;
- transferred into an archive (except if forbidden by law or by the regulation on record-keeping).
The personal data collected and used to subscribe to our newsletter will be deleted immediately if you opt out of our newsletter.
As a data subject, GDPR confers you a series of rights, including:
right to access – allows you to obtain a confirmation that your personal data is processed by us and, if so, the relevant details of such processing actions,
right to rectification – allows you to obtain from us without undue delay the rectification of inaccurate personal data concerning you, thus having the right to have incomplete personal data completed, including by means of providing a supplementary statement,
right to erasure/“right to be forgotten” – allows you to obtain the erasure of your personal data in certain situations (for example, if the data is no longer necessary in relation to the purposes for which it was collected or you withheld your consent if the processing was grounded on your consent or your data was processed illegally, etc.),
right to restriction – allows you to obtain from us the restriction of the processing of your personal data in certain situations (for instance, when you contest the accuracy of the personal data, for a period enabling us to verify the accuracy of such personal data),
right to object – grants you the right to object to the further processing of your personal data, under the conditions and limits of the law,
right to data portability – allows you to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format or to transmit that data to another controller.
We are happy to ensure the exercise of these rights.
You may exercise your above-mentioned rights freely and at any given moment and find out more about these rights by submitting to us, as data controller, a written request addressed to the organizer based in Sibiu, Bd. Corneliu Coposu, nr. 2, jud. Sibiu, e-mail: firstname.lastname@example.org
Moreover, you are entitled to submit a complaint to the National Supervisory Authority for Personal Data Processing.
Should you think that your personal data was provided without your consent, you are encouraged to get in touch immediately. We undertake to always treat your request very carefully and to answer your questions as rapidly as possible.
In the context of managing our Website, we have taken technical and organizational measures to ensure an appropriate level of security considering the risks posed by processing, especially arising from the improper use or the destruction, loss, alteration, disclosure, purchasing, or access, intentional or accidental handling, third party access, deletion, or modification.
You will be notified about a data security breach in a reasonable interval of time after the discovery of such a breach, except for the case when a competent clerk determines that such notification would hinder a criminal investigation or would harm national security. In this case, the notification will be delayed according to the instructions of the competent clerk. We will promptly answer your request about such a data security breach.
This confidentiality policy takes effect starting 1 May 2021. This confidentiality policy may be updated.
When we do so, we will post the changes on our website so that you may always access detailed information about the data we collect, how and in what circumstances we use and, if the case may be, disclose it. Such modifications, whether substantive or otherwise, will come into effect within 2 days from the publication of the new version on our website.
Should we, at any time, decide to use the personal data in a way other than as stated at collection, we will notify you via e-mail. You will be able to choose whether we can or cannot use the data in the different way. Otherwise, if possible, we will use the data according to the Confidentiality Policy based on which the data was collected.
Our website includes links to other websites. This confidentiality policy refers exclusively to this Website, so that, when you connect to other websites, you must read their own confidentiality policies.
Should you have other questions on how we use your personal data, or should you wish to exercise any of your rights according to this policy, please send us a written request at email@example.com
. We will make sure to take the proper measures to answer your request without undue delay and anyhow within 30 (thirty) days from receiving your request. If possible, the information will be provided electronically, unless you expressly request for it to be sent in writing.