PRIVACY POLICY

This confidentiality commitment explains all aspects regarding the processing of personal data and ensures compliance with the principles related to processing, as well as compliance with your rights regarding this data, when you interact with us in connection with our services, in your capacity as visitors or users of our website, aspects established by the provisions of European and national legislation in force, namely the General Data Protection Regulation (EU) 679/2016 (GDPR), Law 190/2018 on measures to application of the GDPR and/or with any other decisions that the National Personal Data Protection Supervisory Authority (ANSPDCP) may issue as the supervisory authority regarding the protection of personal data.

1. WHO ARE WE?

The company LOGICASSA CONFORT SRL, with headquarters in Bacau, Bacau county, STR. CARPATI 29 Sc. E Ap. 5, Romania, registered at the Trade Registry under no. J04/1574/2005, CUI RO 17904521 (hereinafter referred to as the “Company” or the “Operator” or “we”) offers veneer and wood panel manufacturing services through the website www.logicassa.ro.

For any processing carried out in whole or in part by automated means, as well as the processing by other than automated means of personal data, which is part of a data record system or which is intended to be part of a record system of data, we assure you that your data is:

• processed legally, fairly and transparently;
  collected for specific, explicit and legitimate purposes and not further processed in a way incompatible with these purposes; further processing for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes is not considered incompatible with the original purposes;
• adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  accurate and, where necessary, updated we will take all necessary steps to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is deleted or rectified without delay;
  kept in a form that allows your identification for a period that does not exceed the period necessary to fulfill the purposes for which the data are processed;
• personal data will be stored for longer periods to the extent that they will be processed exclusively for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes;
• processed in a way that ensures adequate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, by taking appropriate technical or organizational measures.

Our Services are dynamic and we frequently introduce new functionality, which may require the collection of new information. If we collect personal data with material differences or make material changes to the way we use the data, we will notify you and change this privacy policy accordingly.

2. WHAT ARE THE CATEGORIES OF TARGETED PERSONS?

There are different categories of data subjects, depending on the quality that the data subjects have in their relations with our Company, we process the data of these data subjects for various processing purposes, always based on a legal basis:

• www.logicassa.ro visitors, the anonymous persons who only access and browse our website;
  the visitors of www.logicassa.ro, the people who can contact us quickly in order to purchase the services offered by the Company or who access various services made available by the Company by: using and registering various requests (e.g. wooden panel manufacturing services in order to construction of various wooden structures) in the Contact Form, newsletter subscription;
• potential clients or business partners of the Company, persons who have the capacity of employee, collaborator, representative or other potential partner, or direct or indirect shareholder or real beneficiary, of a potential client/customer, potential supplier/supplier or other potential partner/partner business of the Company.

3. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

The main purpose for which we process your personal data is to ensure that the contractual agreements between us can be properly implemented, so that contractual relationships can function smoothly and comply with legal requirements.

The company processes personal data for the following purposes:

• providing access and use of www.logicassa.ro services by ensuring the proper functioning of the website;
• operating, protecting, improving and optimizing www.logicassa.ro and the user and customer experience, such as conducting analyses, statistics and research;
• displaying testimonials on www.logicassa.ro of representatives of various clients or business partners;
• conclusion of sales contracts for wooden panel manufacturing services for the construction of various wooden structures and other related services offered by the Company, by taking orders and concluding service contracts, including their invoicing; the transmission of messages regarding the purchased services (changes of any nature to the legislation in force); the resolution of various requests/complaints of any nature regarding the purchased services;
• managing the business relationship between us and a potential customer/customer, potential supplier/supplier or other potential partner/business partner, where you are a collaborator, representative or contact person of that customer, supplier, business partner.
• preventing, detecting or investigating fraud, security breaches and activities that are or may be prohibited or illegal, and to defend and exercise our rights under the law;
• resolving requests from public authorities or to fulfill legal requirements (e.g. those specific to financial-accounting, fiscal legislation or money laundering prevention);
• marketing and advertising.

If we intend to further process your personal data for a purpose other than that for which it was collected, we will provide you, prior to such further processing, with information regarding the purpose of the processing and any additional relevant information requested by you.

4. WHAT LEGAL BASES DO WE USE FOR PROCESSING YOUR PERSONAL DATA?

The legal grounds for processing your data are:

• consent (art. 6 (1) a) of GDPR) in case of displaying testimonials on www.logicassa.ro of representatives of various clients or business partners, including name, position and company, which can be used by us to promote our services;
  the execution of a contract to which the data subject is a party (art. 6 (1) b) of the GDPR) for the purposes of concluding sales contracts for our services; resolving various requests/complaints of any nature regarding the purchased services; the transmission of messages regarding the purchased services (changes of any nature to the legislation in force);
• the execution of a contract to which the data subject is a party (art. 6 (1) b) of the GDPR) for the purpose of managing the business relationship between the Operator and a potential client/customer, potential supplier/supplier or other potential business partner/partner, if you are a collaborator, representative or contact person of the respective client, supplier, business partner;
• the legitimate interest (art. 6 (1) f) of the GDPR) for the purposes of providing access and use of the www.logicassa.ro website services through its proper functioning; operating, protecting, improving and optimizing www.logicassa.ro and the experience of users and customers; marketing and advertising; fraud prevention, detection or investigation;
• compliance with legal obligations for the purposes of security breaches and activities that are or may be prohibited or illegal;
• defending and exercising our rights; resolving requests from public authorities or to fulfill legal requirements (e.g. those specific to financial-accounting, fiscal legislation or money laundering prevention).

5. WHAT TYPES OF DATA DO WE COLLECT?

We collect data to operate efficiently and provide you with the best experiences related to our products. You can opt out of the data we collect. When you are asked to provide personal data, you can refuse. If you choose not to provide data that is necessary to provide a product, you may not be able to use that product.

For each processing purpose, we need certain personal data from you, as follows:

• providing access and using the services of the www.logicassa.ro website – it is possible to collect information during your visit to the online store website, through our automatic data collection tools (Cookies): protocol address internet (IP), domain name (URL), access data, client access history (pages viewed, links clicked), HTTP response code, web page data from which the access is made, quality of bytes used during the visit, the data of the pages viewed or the type and language of the browser used;
• concluding sales contracts for wooden panel manufacturing services in order to build various wooden structures and other related services offered by the Company, by taking orders and concluding service contracts, including their invoicing; sending messages regarding the purchased services (changes of any kind to the legislation in force): name, surname, email address, telephone number, address, bank details (in the case of clients of authorized natural persons) or name, surname, function, address email, phone number (in the case of representatives/contact persons of legal entities clients); Failure to provide this information will make it impossible to enter into a sales contract between us and you; issuing the tax invoice;
• managing the business relationship between us and a potential customer, client, potential supplier or other potential partner/business partner, if you are a collaborator, representative or contact person of that customer, supplier: name, surname, function, email address, telephone number, mailing address; Failure to transmit this information will make it impossible to carry out the contract concluded between the Company and you in good conditions;
• marketing and advertising: name, surname, email address, phone number, data collected from cookie modules; Failure to provide this information will make it impossible for us to send you newsletters and/or offer you personalized marketing campaigns containing general and thematic information, information about services similar to those you have purchased , information on offers and promotions;
• marketing and advertising: name, surname, function, used in order to display the testimonials of our customer representatives, both on our website www.logicassa.ro and within social networks and various offline and online media communication channels; Your non-acceptance of the use of this personal data will make it impossible to promote our services;
• resolving various requests/complaints of any nature regarding the purchased services: personal data necessary to resolve your requests. We note that there are no audio recordings of telephone conversations regarding these requests/complaints.

We may obtain your data directly from you or from persons acting on behalf of the Operator’s customer, supplier or business partner or from public authorities and institutions or publications and databases that are publicly or contractually available.

We may combine your personal information with information about your online transactions and other interactions with us. We may also combine personal information with information we receive from other sources, such as marketing partners, public databases, publicly accessible pages on social platforms and other third parties.

6. OTHER IMPORTANT INFORMATION

Analysis of communications within/through our website www.logicassa.ro

We may examine, scan or analyze communications within our website www.logicassa.ro (e.g. via contact form, email) for fraud prevention, risk assessment, regulatory compliance, investigation, service development, research, analysis and customer support. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may scan, review or analyze messages to troubleshoot, improve and expand our service offerings. We use automated methods where possible. However, we may occasionally need to manually review some communications, such as fraud and customer support investigations, or to evaluate and improve the functionality of these automated tools. We will not review, scan or analyze your communications in order to send third-party marketing messages to you, and we will not sell reviews or analyzes of those communications.

These activities are carried out based on the Company’s legitimate interest in ensuring compliance with laws and our Terms and Conditions, preventing, detecting and fraud, security breaches and activities that are or may be prohibited or illegal, promoting safety and improving and ensuring the proper performance of our services.

Third party partners and integration

Our website www.logicassa.ro may contain links to third-party sites or services, such as third-party integration, co-branded services or third-party branded services (“Third-Party Partners”). We do not own or control these third-party partners, and when you interact with them, you may provide information directly to the third-party partner or to us or both. These third party partners will have their own rules regarding the collection, use and disclosure of information. We encourage you to review the privacy policies of other websites you visit.

Parts of our website www.logicassa.ro may use third-party services, such as Google Analytics, Google Tag Manager, Facebook, LinkedIn, HotJar. The use of these services is subject to their privacy policies, such as the additional Terms and Conditions of Google Analytics, Google Tag Manager, Facebook, LinkedIn, HotJar.

7. HOW DO WE USE YOUR PERSONAL DATA?

We may use, store and process personal information to (1) provide, understand, improve and develop www.logicassa.ro (2) create and maintain a trusted and more secure environment (such as complying with legal obligations and ensuring compliance www.logicassa.ro policies) and (3) providing, customizing, measuring and improving our advertising and marketing.

Providing, improving and developing our website www.logicassa.ro. We may use personal information to provide, improve and develop www.logicassa.ro/ to:

• allows you to access and use www.logicassa.ro;
• operate, protect, improve and optimize www.logicassa.ro and the user and customer experience, such as conducting analyses, statistics and research;
• provide own services or those of third-party partners for customers;
• sends you messages regarding purchased services, security alerts;
• inform you, take orders for the services offered and resolve various requests/complaints of any nature regarding the purchased services.

We process this personal information for these purposes, taking into account our legitimate interest in improving www.logicassa.ro and our customers’ experience of it and where necessary for the proper performance of the contract with you.

Creating and maintaining a trusted and more secure environment. We may use personal information to create and maintain a trusted and safer environment, such as:

• detecting and preventing fraud, security breaches and activities that are or may be prohibited or illegal, spam, abuse and other harmful activities;
• conducting security investigations and risk assessments;
• conducting database and other information source checks, including background or police checks, to the extent permitted by applicable laws and with your consent;
• compliance with legal obligations;
• resolving any dispute with any of our customers and enforcing our agreements with third parties;
• compliance with our Terms and Conditions and other policies.

We process this personal information for these purposes, taking into account our legitimate interest in protecting www.logicassa.ro and to measure the proper performance of our contract with you and compliance with applicable laws.

Providing, customizing, measuring and improving advertising and marketing. We may use personal information to provide, personalize, measure and improve our advertising and marketing, such as:

• sending you promotional messages, marketing, advertising and other information that may be of interest to you based on your preferences (including information about our or partner campaigns and services) and media
• advertising through social platforms such as Facebook, LinkedIn;
• customize, measure and improve our advertising;
• administering surveys, contests or other promotional activities or events sponsored or managed by us or third party partners;
• subscription to the newsletter by e-mail; this will not affect the frequency of administrative emails we may send in relation to any service you have purchased. There is no charge for sending promotional emails to you.
• invitations to local events, promotions and opportunities, experiences within www.logicassa.ro;
• displaying testimonials of our customer representatives through written statements, video recordings; postcasts through audio voice recordings, both on our website www.logicassa.ro, as well as within social networks and various offline and online media communication channels.

We will process your personal information for the purposes listed in this section, given our legitimate interest in carrying out marketing activities to provide you with services that may be of interest to you.

8. HOW LONG DO WE STORE YOUR PERSONAL DATA?

We store your personal data for as long as necessary to provide the services you have purchased, carry out the transactions you have requested or for other essential purposes, such as complying with legal obligations, resolving disputes and enforcing our agreements. Because these needs may vary for different types of data in the context of different products, actual retention periods may vary. The criteria used to determine retention periods include:

• maintaining and improving the performance of our services, keeping our systems secure and maintaining appropriate business and financial records;
• the period for which you have expressed your consent or until you express your intention in one of the ways provided in this policy to stop keeping them;
• if your data is considered sensitive, then it will be stored for a shorter period;
• the situation where a law requires the retention of personal data, to maintain data relevant to an investigation or data that must be kept in the event of litigation.

The storage periods of your personal data differ depending on the purpose for which they are used, as follows:

• concluding sales contracts for our services – for a period of 10 years; with the mention that the personal data that can be found in any supporting documents that are the basis of the records in the financial accounting are kept in our archive for 10 years from the closing date of the financial year in which the supporting documents were drawn up, according to the provisions of the accounting law; within the framework of the defense and exercise of our legal rights and interests, the personal data necessary to achieve this purpose will be kept according to the general limitation periods;
• managing the business relationship between us and a potential customer/customer, potential supplier/supplier or other potential partner/business partner, if you are a collaborator, representative or contact person of that customer, supplier, business partner – during the performance of the contract or if there is a legal obligation to do so;
• marketing and advertising – until the moment when your objections to this processing are resolved; or during the period of subscription to the newsletter until the date of unsubscribing from this service;
• for the processing of personal data where your consent is required – personal data will be processed and kept until the date of withdrawal of consent, unless the law provides for another data retention period or data retention is necessary for the exercise or defense of the Operator’s rights ;
• resolving various requests/complaints of any nature regarding the purchased services – during the resolution of various requests/complaints; within the framework of the defense and exercise of our legal rights and interests, the personal data necessary to achieve this purpose will be kept according to the general limitation periods.

9. WHERE DO WE TRANSMIT/TRANSFER YOUR PERSONAL DATA?

Your personal data may also be processed by other operators, associated operators or authorized persons of the Operator, in full compliance with the legislation on the protection of personal data:

• IT service providers, as well as all companies in these categories of recipients from whom the Operator will contract services and products and which have taken adequate protection measures, according to legal provisions, to ensure that they comply with their data protection obligations personal. If the authorized persons subcontract part of the activities involving the processing of personal data, the subcontractors will be subject to the same obligations regarding the implementation of the security, technical and organizational measures provided by the EU General Regulation on data protection, but also of internal normative acts approved in order to implement the EU General Regulation;
• the contracting parties of the Operator, who have the capacity of associated operator, for the performance of outsourcing services to them;
• the state authorities based on their competences provided by the applicable law;
  we may share your information with our service providers who manage customer information and perform services on our behalf, such as conducting promotions, sending messages to customers, conducting surveys, targeting
• and retargeting, etc. We have not authorized any of these service providers to do any other operations with your information;
• we may share your information when we partner with another company to offer or offer services, contests or promotions to our customers;
• we may share information about you if necessary or appropriate in good faith to comply with laws or regulations or to respond to a valid subpoena, order or government request or to protect our operations, privacy, safety, property or the rights of the Operator;
• in the unlikely event of a sale or merger of the Company, our customers’ personal information and other information we have collected as described in this policy may be among the transferred assets.

Your data will not be transferred abroad. If your data will be transferred to other companies/entities in other countries outside the EU/EEA, you will be informed accordingly.

10. HOW DO I CHOOSE WHAT PROMOTIONS I RECEIVE?

Our company wants to communicate with you only if you have expressed or express your agreement (consent) in this regard.

However, there is also the possibility that our company may send you personalized offers if you have used the Contact Form of our website www.logicassa.ro, based on our legitimate interest for marketing and advertising purposes (art. 6 (1 ) f of the GDPR).

If you prefer not to receive promotional information, such as information about special offers and sales events, you can let us know by contacting our customer service as described in the section entitled “How can you contact us?”: www.logicassa. ro or you can click on the unsubscribe links present in each newsletter sent by us.

11. HOW DO WE PROTECT CHILDREN’S DATA?

We expressly warn visitors and users that all processing of personal data relates exclusively to persons who have reached the age of 16. The use or purchase of the services offered through our website www.logicassa.ro by children who have not reached the age of 16 is prohibited. In exceptional situations, in which personal data of children under 16 will be processed, we will stop this processing as soon as we learn about such situations. The responsibility for the use of our website by children belongs exclusively to the parents.

12. WHAT HAPPENS IF I USE DIFFERENT DEVICES TO VISIT THE SITE?

To provide you with a more efficient and convenient shopping experience, you may have access to various content from several different devices. If you use different devices (such as your home computer, laptop, mobile device and/or smart personal assistance device) to access our site and/or request our services, the applications may associate you personally with each of your devices.

The information we have collected from your various devices may be combined with other information you have provided to us, including details about: how you use our site and services, the services you view or services and features. We may use such information to provide you with more tailored experiences and consistent services and experiences across all of your devices, as explained in this privacy policy.

See our Cookie Policy to learn how you can exercise cookie-based tracking options to learn more about your online advertising choices.

13. WHAT OTHER DATA DO WE COLLECT?

Our website uses cookies or similar technologies to provide the best experience for you and to analyze trends, administer the website, track customer use of the website and collect demographic information about the base of users as whole.

Cookies are small text files that are placed on the customer’s device to track usage and record preferences. Our cookies do not contain information that can identify individuals. We collect certain information automatically through the use of cookies and tracking technologies such as Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, pages viewed on our site ( e.g. HTML pages, graphics), operating system, date/time and/or series of clicks to analyze the trend as a whole and administer the website. Website users can control the use of cookies at the browser level, but if the user decides to disable cookies this action will result in a limitation of certain features and functions in our website and services.

A detailed description of how we use cookies in the relationship with the user can be found in the Cookies Policy section found at the following link: Cookies Policy

14. HOW IS MY INFORMATION USED FOR BEHAVIORAL ADVERTISING AND WHAT CHOICES DO I HAVE?

We also work with third-party companies that use tracking technologies (including cookies and pixel tags) on our site to deliver personalized advertising on our behalf and on behalf of other Internet advertisers. These companies may collect information over time about your activity on our site and other sites, as well as your interaction with our advertising and other communications, and use this information to determine what ads you see on the sites and apps third party. These technologies and the information collected about you may also be used to track your activity across multiple devices. For more information about this practice and to understand your options, including how to opt out of receiving these personalized ads, visit http://www.aboutads.info.

Note that regardless of whether you opt out, these tracking technologies may still collect data and you will still see ads, but they will not be targeted based on the information collected through these tracking technologies.

15. WHAT SECURITY MEASURES HAVE WE TAKEN?

We guarantee that the processing of your data is carried out under conditions of legitimacy, while implementing appropriate technical and organizational measures to ensure the integrity and confidentiality of the data according to the Regulation.

The company has implemented a personal data security policy. We assure you that the processing of your data is carried out by personnel trained in this regard, to the highest standards of confidentiality. We have certain physical, electronic, contractual and managerial safeguards to help protect the security and privacy of your personal information.

When you enter your personal information on our website www.logicassa.ro, we use encryption technology to protect your information as it is transmitted to us.

16. WHAT IS PHISHING?

“Phishing” is a scam designed to steal your personal information. If you receive an email that appears to be from us asking for personal information, please do not respond. We will never ask for your password, username, credit card information or other personal information via email.

17. WHAT LINKS TO OTHER SITES DO WE HAVE?

Our website may contain links to other websites, which may have privacy policies that differ from our own. We are not responsible for the content or practices of any linked site. We recommend that you review the privacy policy of any site you access through our website www.logicassa.ro

18. HOW DO YOU ACCESS OR CHANGE THE INFORMATION YOU HAVE TRANSMITTED TO US?

You can ask us to update your personal information by contacting us as described in the section entitled “How can you contact us?” below. Please note that any request to update your personal information may take up to 30 days for your email request and 6-8 weeks for your request via regular postal services.

19. HOW CAN YOU CONTACT US?

For questions about the privacy policy, to make choices about receiving promotional communications, to update your personal information you can contact us by email, phone or electronic mail.

20. WHAT RIGHTS DO YOU HAVE?

According to the legislation on the protection of personal data, you have the following rights:

• the right to information: the right to receive information regarding the personal data processing operations carried out by us;
• the right to access data: the right to obtain confirmation that we are processing your personal data or not, and if so, access to data and the provision of information regarding data processing;
• the right to rectification: the right to obtain, without undue delay, the rectification of inaccurate personal data concerning you or the completion of personal data that is incomplete;
• the right to delete data, without undue delay, in the following situations: (1) personal data are no longer necessary to fulfill the purposes for which they were collected or processed; (2) withdraw your consent for consent-based data processing; (3) you object to the processing of personal data; (4) personal data were processed illegally; (5) personal data must be deleted to comply with a legal obligation that the Operator.
• the right to restrict processing, in any of the following situations: (1) you dispute the accuracy of the data; (2) the processing of the personal data is illegal and you do not want the deletion of the personal data, but request the restriction of its use; (3) The operator no longer needs the personal data, but you request it for establishing, exercising or defending a right in court; (4) you object to the processing. If you have obtained the processing restriction, you will be subsequently informed by us before the processing restriction is lifted;
• the right to data portability: the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format and to transmit this data to another operator, when the technical means allow this. You can only exercise this right when the processing is based on your consent and is carried out by automated means;
• the right to object: the right to object, for reasons related to your particular situation, to the processing carried out by us with our legitimate interest as the legal basis.
• the right not to be subject to an automated individual decision, including profiling: (any automated processing that uses personal data to evaluate certain personal aspects of you), which produces legal effects concerning you or similarly affects you in -a significant measure.
• the right to withdraw your consent at any time and without giving any reason.

For additional details regarding the processing activities carried out by us, as well as for the exercise of the rights you benefit from in this context, please send a request in electronic format, by e-mail to commercial@logicassa.ro or on paper at the Company’s headquarters, in Bacau, Bacau county, STR. CARPATI 29 Sc. E Ap. 5, Romania

Your request will be analyzed and you will be answered within 30 days from the receipt of the request by the Operator. In the case of complex or very numerous requests, this term can be extended by two months.

Equally, you have the right to contact the Personal Data Processing Supervisory Authority (ANSPDCP), based in B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, in the form of a written address, at the institution’s headquarters or by e-mail at anspdcp@dataprotection.ro. You are also recognized as having the right to go to court for the defense of any rights guaranteed by the applicable legislation in the field of personal data protection, which have been violated.

This Privacy Policy was revised and amended on 19.10.2019.

This confidentiality commitment explains all aspects regarding the processing of personal data and ensures compliance with the principles related to processing, as well as compliance with your rights regarding this data, when you interact with us in connection with our services, in your capacity as visitors or users of our website, aspects established by the provisions of European and national legislation in force, namely the General Data Protection Regulation (EU) 679/2016 (GDPR), Law 190/2018 on measures to application of the GDPR and/or with any other decisions that the National Personal Data Protection Supervisory Authority (ANSPDCP) may issue as the supervisory authority regarding the protection of personal data.