Confidentiality Policy

mindit.io acknowledges the importance of the confidentiality in terms of the personal data of our website visitors. This Confidentiality Policy („the Policy”) sets out the basis on which we manage and store the personal information that we collect on our website https.mindit.io („Website”).

The new European Regulation in terms of the protection of the personal data consists in the Regulation 2016/679/EU of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as “The Regulation”) and repealing Directive 95/46/EC (General Data Protection Regulation).

Our Confidentiality Policy lays out the principles and the measures taken in order to provide the conformity of the data processing according to the Regulation. Thus, we plan to have with our clients, partners and our website visitors a relation based on good faith, ethics, trust and transparency.

‍The Purpose and the Legal Ground of the Processing

The purpose of your personal data processing consists in replying to the request conveyed by you on our website. The legal ground of the personal data processing is represented by your consent given as per the art. 6 in EU Regulation 2016/679 of the European Parliament and of the Council on Personal Data Protection and our lawful interest. If it is required that the data be processed subsequently to other purpose than those for which they were collected, we undertake to provide you with information on the new purposes and any relevant further information before any such new processing.

‍The Data Categories 

mindit.io processes as far as you are concerned, the following personal data categories: surname; first name; email address; telephone number and other information transmitted by the data subject by means of the request.
‍How Your Personal Data from the Website are Processed- If you download certain articles or materials from our website or other types of business content in relation to our products and services, we will collect the email address;
- If you contact us with a comment, a question or complaint, you may be requested information in order to be identified, such as your name, address and telephone number, together with further required information in order to help us to give you promptly a reply. We'll preserve such information for maximum 3 years since they were collected in order to help you in the future and to improve our services to clients, service offers and website and also in order to help solving possible litigations that may involve our company;

‍Warning! You are not obliged to give us such information, but unless you provide them to us, we may not provide you relevant or detailed replies to your business requests. The methods by means of which we get in touch with you, we will always provide you with the possibility of requesting the removal of your personal data from the future communications.

‍Cookies Policy

Our website stores and processes information from browser using its own cookies. Insofar as such information may be considered as personal data, they are used exclusively for the purposes of managing our website. The cookies that we use are functional or computer ones, but in order to understand better why we need them, please be aware of the below listed explanations:
The functional or computer cookies are placed by us and used so that we provide that you may use our website correctly and efficiently as a dynamic instrument which you may interact with. As a general rule, they are set up only as a reply to the actions you carry out in order to request services, such as the set-up of your preferences over confidentiality, connection or fill-out of the contact forms, newsletter subscription. As a rule, they improve the navigation experience, they make the website remember the user’s choices, such as the preferred language, location or whether we have already displayed to you an information window – for example, precisely the information on the use of cookies. You may select from Settings not to accept such cookies, but without them some parts of our website or requested services may not be provided. Such cookies do not collect information by means of which you may be identified personally or that might be used for advertising or monitoring your Internet activity.

The cookies of third parties: there are two categories

- Performance cookies – are used for reviewing how our website operates and how we can improve it. They provide information related to: to the website visits, the type of visitors – new or recurrent ones, the duration of a session, the average sessions per visitor, the visited pages and the average pages per session, the place from which our website has been accessed, the periodicity of visits and retention of visitors in time, the language and the geographical location, the devices from which the website is accessed, the browser types, the operating system, the screen resolution, statistical demographic data – sex and age, the visitors’ interests and their affinity to our website, the visitors’ behaviour – how they interact with the website, how they respond to different types of content, the traffic sources – direct, organic and paid searches, references, social media and other statistical data on how our website is used and what our visitors are interested in. All the information collected by such cookies are aggregate, therefore anonymous and may be set by third parties, among which Google – Analytics, Tag Manager and Search Console.
- Advertising cookies – although we do not display third parties’ advertisements on our website, there may be cookies related to the online advertising campaigns that we display, that are intended for providing to us statistical information on the performance of such campaigns.

‍The Categories of Recipients to Which Data are Transmitted 

Your personal data are stored and preserved in our database corresponding to the company website. No third party has access to your data, save where there is a legal or contractual obligation.
The contractual obligation will be designed according to how the verification process is carried out that would require the transmission of the data to the company’s contractual partners. The data will be transmitted to the contractual partners only if they provide they comply with the data processing obligation and the implementation of adequate technical and organizational measures.

‍The Rights of the Data Subjects 

In connection with the processing of the Personal Data and based on the conditions specified by the Regulation on data protection, you may exercise any of the following rights:
- The right of access to the personal data concerning you: you may request that you will be communicated the categories of personal data that are processed, the purpose of the processing, the recipients to whom they have been or will be disclosed, the envisaged for which they will be stored or, if not possible, the criteria used to determine that period; the existence of an automated decision-making, including profiling;
- The right to rectification or update when the data are inaccurate or incomplete throughout the processing and before the issue of the final report; if there are errors related to your processed data, you may request their rectification; if the data are incomplete, you may request their completion. The rectification will be communicated to each recipient to whom such data were disclosed, unless it proves impossible or involves disproportionate efforts;
- The right to erasure of data under certain circumstances (e.g. when the personal data are no longer necessary in relation to the aforementioned purposes): you may request the erasure of the processed data, if such data are no longer necessary in relation to the purposes for which they were collected or processed, if you withdrew your consent and there is no other legal ground for the processing; if you object to the processing and there are no overriding legitimate grounds for the processing; the personal data have been unlawfully processed; the personal data have to be erased for compliance with a legal obligation; the personal data have been collected in relation to the offer of information society services;
- The right to restriction of the processing under certain circumstances: you have the right to restriction of the data processing in the following cases: you have contested the accuracy of your personal data for a period enabling us to verify the accuracy of data; if the processing is unlawful and you oppose the erasure of personal data and request the restriction of their use instead; if the company no longer needs the personal data for the purposes of the processing, but you request them for the establishment, exercise or defence of legal claims; if you objected to processing pending the verification whether the legitimate grounds of the company override yours;
- The right to object to processing: you have the right to object to processing of your personal data if they refer to direct marketing. Therewith, you may object to processing, unless the company demonstrates legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims;
- The right to withdraw consent, at any time, for the processing of data concerning you under a request sent to the email office@mindit.io;
- The right to your data portability, in the sense of the transfer of your personal data to another controller designated by you;
- The right not to be subject to a decision based exclusively on the automated data processing: You will not be subject to a decision based exclusively on the automated data processing.

For additional questions regarding the processing of personal data or in connection with the use of the personal data by the Operator, please contact the Data Protection Officer at the following e-mail addresses: office@mindit.io.

If you believe that your rights have been violated, you may file a complaint with the National Supervisory Authority for Personal Data Processing.

‍The Update of the Confidentiality Policy

This Confidentiality Policy may be updated from time to time, for example following the amendment of the relevant legislation. We encourage the visitors of our website to verify this page periodically in order to get informed on the latest news as to our confidentiality practices.

INFORMATION ON THE PROCESSING OF PERSONAL DATA OF CANDIDATES FOR A POSITION IN MINDIT SERVICES S.R.L.

Protecting your personal information is very important to us. That is why we are committed to comply with European and national legislation on personal data protection, in particular Regulation (EU) 679/2016 (hereinafter referred to as GDPR), Law 190/2018 and the following principles:

• Legality, fairness and transparency

We process your data lawfully and fairly. We are always transparent about the information we use, and you are properly informed. 

• Control is yours

Within the limits of the law, we offer you the ability to review, amend, delete personal data you have shared with us and exercise your other rights.

• Data integrity and purpose limitation

We only use the data for the purposes described at the time of collection or for new purposes compatible with the original purposes. In all cases, our purposes are compatible with the law. We take reasonable steps to ensure that personal data is accurate, complete and up to date.

• Security

We have implemented reasonable security measures to protect your data to the best of our ability. However, please note that no website, no application and no internet connection is completely secure.

MINDIT SERVICES S.R.L., with registered office: Bucharest, Sector 2, Intrarea I. L. Caragiale, No. 5, registered with ord.reg.com./an: J40/15908/2020, C.U.I. RO34234340, as the Operator, processes your personal data in accordance with what is stated in this Information:

1. Purpose of processing:

We process your personal data in order to carry out a recruitment process for the purpose of concluding an individual employment contract or a collaboration/services contract. 

2. Legal basis of processing:

The data processing is necessary in order to take steps at your request prior to the conclusion of an individual employment contract. We also process your personal data on the basis of the legitimate interest of the company. 

3. Categories of personal data processed:

Name, first name
/ date of birth
Marital status
E-mail address
Phone number
Home address
Professional experience
Education / qualifications / certifications
Language

We collect and use any of the following data about you within the company, and we refer to it as "personal data" throughout this notice: 

(a)      CV information: name, surname, home/residence address, email address, phone number, previous employers, training, professional qualifications, recommendations. We may use this data for the purpose of contacting you for interviews or to request, with your prior approval, references about you from former employers. Also, even if we do not enter into an employment/service/collaboration contract we will keep some of this information so that we can contact you later if an opportunity arises within our company. You can ask us at any time to stop this type of processing and to delete your data.

(b)      the information in the professional file: name, surname, home/residence address, professional history, analysis of professional development and skills, details of performance and adaptation to requirements.

(c       The images taken via the video surveillance system at our premises, in case the recruitment interview will take place at our premises. The data is stored on the company's internal systems and is only passed on to state authorities at their express legal request. 

4.       personal data collection:

Some of the personal data processed is provided directly by you, while other information is obtained indirectly from third parties (for example, if professional reference checks are carried out). 

5.       Recipients of personal data processed:

Access to your personal data is permitted only to those employees who need that information to fulfill their business purposes, including Human Resources, your potential supervisors, and people in management with decision-making authority in the recruitment process.

6.       Personal data provided will not be transferred to cross-border operators or organizations.

7.       Storage period of personal data provided

Your personal data is kept only as long as necessary to fulfill the purposes for which that information is processed: 

(a)      personal data of candidates who do not become employees/collaborators - for three years after the end of the recruitment process.

(b)      personal data of candidates who are employed/become collaborators - will be kept for the duration of the individual employment contract/contract of collaboration or provision of services, and after the end of the contract, the legal archiving period will be respected.

(c)      The footage taken from surveillance cameras is retained for 30 days from the date of recording, unless an incident is recorded, in which case the footage of those incidents is retained until the dispute is resolved. 

8.        Your rights regarding the personal data we process:

In accordance with the provisions of Articles 15-22 of EU Regulation 679/2016, you have the following rights regarding the processing of your personal data: 

1. right of access: the right to obtain confirmation from the Operator that personal data concerning you are being processed and, if so, access to such data and certain information in accordance with the law. 

2. the right to rectification: the right to obtain from the Controller the rectification of inaccurate personal data concerning you and/or the completion of personal data that is incomplete. 

3. the right to erasure of data (right to be forgotten): the right to obtain from the Controller the erasure of personal data concerning you only if:

(a) the personal data are no longer necessary for the purposes for which they were collected or processed;

(b) you withdraw your consent on the basis of which the processing takes place (provided that the processing was done on the basis of your consent) and there is no other legal basis for the processing;

(c) you object to the processing of personal data relating to you (including profiling) and there are no compelling legitimate grounds for the processing or the data subject objects to the processing for direct marketing purposes (including profiling); 

(d) personal data have been unlawfully processed; 

(e) personal data must be deleted in order to comply with a legal obligation incumbent on the Controller under Union law or the national law to which the Controller is subject; 

(f) the data is not necessary for and/or in connection with the performance of the contract;

(g) after the expiry of the period for which the Operator has a legal obligation to retain and/or archive personal data;

(h) the processing of the data is not necessary for the exercise of the right to free expression and information;

(i) the processing of the data is not necessary for compliance with a legal obligation providing for processing under Union or national law applicable to the Controller;

(j) the processing is not necessary for the establishment, exercise or defence of legal claims;

(k) in other cases provided for by law, under the conditions, within the limits and respecting the exceptions provided for by law. 

4. the right to restrict processing, if: 

(a) dispute the accuracy of the data, for a period that allows the Operator to verify the accuracy of the data; 

(b) the processing is unlawful, and you object to the erasure of your personal data and request instead that its use be restricted; 

(c) the controller no longer needs the personal data for processing purposes, but 

You ask us for them in order to establish, exercise or defend a right in court; or 

(d) you have objected to the processing in accordance with the legal provisions, for the period of time during which it is verified whether the legitimate rights of the Controller prevail over yours.

After the restriction of processing, personal data can only be processed (except for storage) with your consent and/or in cases provided for by law. You have the right to ask us for information about the recipients to whom personal data have been disclosed, to whom we have communicated any rectification or erasure of personal data or restriction of processing carried out at your request. 

5. the right to portability: the right to receive personal data concerning you that you have provided to the Operator in a structured, commonly used and machine-readable format and your right to transmit this data to another operator, without obstacles from the Operator, in the cases and under the conditions provided by law. 

You have the right to request that personal data be transmitted directly from one controller to another where technically feasible. 

The right to portability of personal data applies under the conditions and within the limits provided by law. 

6. the right to object: the right to object at any time, for reasons related to your particular situation, to the processing of personal data concerning you and to the creation of profiles, in accordance with the law, unless the Operator has legitimate and compelling reasons justifying the processing which override your interests, rights and freedoms or if the purpose is to establish, exercise or defend a right in court or before other authorities in accordance with the law. 

7. the right to withdraw consent: where processing is based on consent, consent may be withdrawn at any time without affecting the lawfulness of the processing carried out on the basis of consent prior to its withdrawal. 

Consent cannot be withdrawn with respect to personal data that are necessary for:

(a) performance of the contract;

(b) for the fulfilment of a legal obligation of the Operator;

(c) for the defence of legitimate interests pursued by the Operator or a third party, unless your interests or fundamental rights and freedoms prevail, which require the protection of personal data;

(d) to protect the vital interests of you or another natural person; 

(e) for the performance of a task serving a public interest;

(f) in other cases provided by law. 

8. in the case of automated decision making and profiling, your right to obtain human intervention by the Operator, to state your point of view and to challenge the decision.

The rights listed above are not absolute. There are exceptions, so each request received will be examined to decide whether it is justified or not. To the extent that your request is justified, we will make it easier for you to exercise your rights. If the request is unfounded, we will reject it, but we will inform you of the reasons for the refusal and of your rights to lodge a complaint with the Supervisory Authority and to take legal action.

We will try to respond to the request within 30 days. However, the deadline may be extended depending on various aspects, such as the complexity of the request or the large number of requests received.

• The right to lodge a complaint

As a data subject, you have the right to lodge a complaint with the Supervisory Authority about how your data are processed or how your rights in relation to such processing are respected, in accordance with the provisions of EU Regulation 679/2016.

In Romania operates the National Authority for the Supervision of Personal Data Processing ("ANSPDCP"), address:B-dul General Gheorghe Magheru, nr. 28-30, Sector 1, postal code 010336, website: www.dataprotection.ro.

9. Additional questions

If you would like further information on the above rights or if you wish to exercise any of these rights, please contact us.

We will provide you with a response within a maximum of 30 days, with the possibility to extend this period by another 30 days if your request is complex. 

However, please note that there are exceptions to some of the rights mentioned. If your request is refused we will provide you with an explanation as to why your request has been rejected. If any exception applies, we will notify you of this when we respond to your request. 

Before responding to any request made by you, we may request certain information necessary to confirm your identity.

If you have any questions about how we process your personal data, please contact us.

REQUEST FORM FOR THE DATA SUBJECT

(for exercising the rights set out in Articles 7, 12-22 of the GDPR)

 Details of the data subject (application holder): 

Subject of the application:

Please select the subject of your request:

The categories of personal data which are the subject of the request:

Details of your request:

Once completed, please submit this form:

- at the e-mail address: dataprotection@mindit.io or at the postal address: Bucharest, Sector 2, Intrarea I. L. Caragiale, Nr. 5.