Protection of personal data
Trutzi S.R.L.
External policy - Information note

1 Summary description of the policy

This document outlines, in general terms, the way in which the company Trutzi S.R.L., acting as personal data operator, processes personal data in the light of Regulation 679/27.04.2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) issued by the Council of the European Union and the European Parliament.

Throughout this document, information is presented on: the identity of the personal data operator, the categories of personal data processed, the sources of data acquisition, the ways of data processing, the purposes and grounds for data processing, the recipients of the data, the rights of the data subjects, and other relevant information.

We inform you that, according to the legislation in force, any individual whose personal data are processed has the right to object to the processing under the conditions of the law.

Management of Trutzi S.R.L.

2 Identity and contact details of your personal data operator

Trutzi S.R.L. ("Trutzi") is a personal data operator.

Trutzi S.R.L. has its registered office in Sat. Scheia, Comuna Scheia str. Aleea Vamii nr. 26, jud. Suceava, is registered with the trade register under no. J33/1094/2005 and has the tax identification number 17898144.

Trutzi’s contact details are as follows:

Address: Sat. Scheia, Comuna Scheia str. Aleea Vamii nr. 26, jud. Suceava
Phone number: 0752.111.845
Email: suceava@trutzi.ro
Website: www.trutzi.ro   
You can also contact us through the contact form on our website: https://www.trutzi.ro/shop/contact-us

3 Contact details of the person responsible for the protection of your personal data

Trutzi has appointed a data protection officer, who can be contacted at gdpr@trutzi.ro

Insofar as you do not wish to contact the data protection officer by e-mail, you may use any other type of correspondence using the Trutzi contact details mentioned in Chapter 2 above.

4 Categories of personal data we process

Depending on the category of persons to which you belong, and depending on how your personal data comes into our possession, we may process all or part of the following categories of personal data:

1. identification data (e.g. surname, first name, address, etc.);

2. identification data using remote communication means (e.g. telephone number, e-mail address, IP address of a device);

3. data relating to place of work/profession (e.g. position, place of work, etc.);

4. data on how you carry out your activity (e.g. how you negotiate a contract with us, the content of an e-mail sent from an address related to your workplace, etc.);

5. handwritten data (e.g. your signature on a contract with us, your signature on a document sent to us, etc.);

6. data concerning the products / services we provide (e.g. design / models of the products / services offered, location where you want us to deliver / assemble the products etc.);

7. financial data (e.g. 7. financial data (e.g. your bank account, the bank where it is opened, the date of a payment, justification of a payment, etc.);

8. your opinions (e.g. your opinion regarding the services/products provided by our company etc.);

9. other categories of personal data, including special data, depending on the circumstances (e.g. to the extent that you inform us that you are unable to attend a scheduled appointment with us due to medical reasons, we will process the data submitted on your health).

5 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. you send us an e-mail or contact us by phone, send us a CV with a view to employment with our company, come within the range of our cameras, etc.);

2. the company/entity where you are employed (e.g. your company sends us your personal data so that we can contact you to initiate and support a dialogue on a certain topic, etc.);

3. the company/entity with which you are in a certain relationship (e.g. the company for which you provide certain goods and/or services without being an employee, etc.);

4. other persons/entities that hold your personal data (e.g. a friend, a company where you have been employed, another customer of ours, etc.);

5. public sources (e.g. data provided by the Trade Register Office, search results displayed by a search engine etc.).

6 Ways in which we process your personal data

Trutzi may process your personal data, in whole or in part, in the following ways:

1. collection ( e.g. receiving a contract signed by you, receiving an email from you etc );

2. storage (e.g. storing an e-mail received from you, storing a document sent by you, etc.);

3. registration (e.g. registering you with our customer database, etc.);

4. viewing (e.g. viewing your contact details in order to send an e-mail etc.);

5. modification (e.g. when we modify your contact details etc.);

6. encryption (e.g. when we encrypt the devices that store your personal data etc);

7. transmission / disclosure (e.g. when we transmit your contact data to a courier etc.);

8. destruction (e.g. when we delete your data etc);

9. any other operations carried out on / in relation to your personal data (e.g. restriction of access, pseudonymisation of data, anonymisation of data, etc.).

7 Purposes for which your personal data are processed and legal grounds for processing personal data

Trutzi processes a range of personal data based on one or more purposes and one or more legal grounds, as set out below.

In order to understand the purposes and legal grounds for which we process your personal data, please go to the category of persons to which you belong ( 7.1 Potential customers/existing customers/former customers, 7.2 Potential suppliers/existing suppliers/former suppliers, 7.3 Potential partners/existing partners/former partners and other related persons, 7.4 Other persons ).

7.1 Potential customers / existing customers / former customers Trutzi and other related persons

Trutzi processes the personal data of its potential customers / existing customers / former customers and other natural persons in a certain relationship / relation with them such as:

1. natural persons who are representatives of potential customer/existing customers/former customer (e.g. director, general manager, economic manager, etc.);

2. natural persons who are employees of potential customers/existing customers/former customers (e.g. employees, civil servants, contract staff, etc.);

3. natural persons who are representatives of suppliers / partners / subcontractors / consultants / etc. of potential customers / existing customers / former customers (e.g. the manager of a transport company, the manager of a bank with which the customer has an account, etc.);

4. natural persons who are employees of suppliers / partners / subcontractors / consultants / etc. of potential customers / existing customers / former customers (e.g. employee of a transport company, employee of an outsourced audit company, etc.);

5. natural persons who are representatives of a public authority / institution in contact with potential customers / existing customers / former customers (e.g. an ANAF inspector etc.);

6. natural persons who are employees of a public authority/institution in contact with potential customers/existing customers/former customers (e.g. an ANAF inspector etc.);

7. any other natural person in any kind of relationship with potential customers /existing customers / former customers (e.g.: a former employee of a customer etc.).

7.1.1 Pre-contractual period

Purposes of processing

Trutzi aims at offering / providing its services / products to as many persons / companies / entities as possible.

During the pre-contractual period Trutzi processes your personal data for the following purposes:

1. in order to initiate and sustain a dialogue;

2. in order to present our services / products;

3. in order to obtain information on the basis of which we can propose the most suitable services/products;

4. in order to draw up the documents related to the pre-contractual period (e.g. quotation, draft contract, etc.);

5. in order to understand the requirements and trends of the market (e.g. what services/products are sought, by what categories of customers, at what prices, etc.);

6. in order to understand how we can improve our services/products offered (e.g. evaluation of internal employees, analysis of the opportunity to hire additional staff, etc.);

7. in order to understand how we should organise our activity from all points of view (commercial / marketing / HR / IT / financial etc.) (e.g. evaluation of the contracts concluded in one month compared to the contracts that could have been concluded, evaluation of how our employees perform their duties, analysis of how we present ourselves as a company etc.);

8. in order to protect and realise our rights and interests (e.g. in order to contract a new customer, in order to carry out our own activities, in order to achieve our object of activity, in order to carry out our activities in the most optimal way for us from any technical/economic point of view, etc.);

9. in order to fulfil legal obligations (e.g. in order to fulfil legal obligations concerning the provision of information at the request of a public authority/institution, such as ANAF etc.).

Legal grounds for processing

The legal grounds for processing your data are:

1. processing is necessary in order to take actions at your request (e.g. we formulate a draft contract, we formulate a quotation customized to your company’s needs, we provide you with the requested information, etc.);

2. processing is necessary for the fulfilment of legal obligations incumbent on us (e.g. we may be obliged by law to provide certain information by a public authority/institution, etc.);

3. processing is necessary for the purposes of our legitimate interests in achieving the purposes set out above (purposes of processing).

In consideration of the above it is possible that Trutzi may come into contact with you, either on its own initiative (e.g. we send you an e-mail), or on your initiative (e.g. you contact us by phone, visit our website etc.), or on the initiative of another person/entity (e.g. both you and we receive an e-mail from an intermediary).

To the extent that your company is a customer of Trutzi or a person in any kind of connection / relationship with a customer of ours, your personal data will be processed according to Chapter 7.1.2.

Data retention period

Trutzi will keep your personal data only for the period necessary to achieve the purposes set out above (Purposes of processing).

This period varies from case to case depending on a number of circumstances (e.g.. The period varies from one period to another depending on a number of circumstances (e.g. the category of data provided, the purpose of the provision, the specific purpose of the processing, the legal obligations involved, etc.).

For example, to the extent that you were a representative/employee of a potential customer of ours, your data will be permanently deleted when it becomes certain that we will not be contracted (e.g. you send us an e-mail informing us, you interrupt communication with us for a period of time that exceeds a reasonable period of time, we inform you that we cannot provide the requested services/products, etc.).

7.1.2 Contractual / post-contractual period

Purposes of processing

Trutzi provides services / products to its customers, fulfils a number of legal / conventional obligations and adapts its business strategy according to the requirements of the market.

During the contractual / post-contractual period Trutzi processes your personal data for the following purposes:

1. in order to initiate and sustain a dialogue;

2. in order to execute the concluded contract;

3. in order to draw up documents related to the contractual period (e.g. additional documents, minutes, invoices, balance confirmations, etc.);

4. in order to fulfil legal obligations (e.g. the obligation to draw up primary accounting documents, the obligation to store accounting documents for a certain period of time, etc.);

5. in order to obtain information on the basis of which we can propose other services/products that might be suitable, other than those already contracted;

6. in order to present our services/products other than those already contracted;

7. in order to understand the requirements of market trends (e.g. 7. to understand the market trends (e.g. what services/products are sought, by which categories of customers, at what prices, etc.);

8. in order to understand how we can improve our services/products (e.g. evaluation of internal employees, analysis of the opportunity to hire additional staff, etc.);

9. in order to understand how we should organise our activity from all points of view (commercial / marketing / HR / IT / financial etc.) (e.g. evaluation of the contracts concluded in one month compared to the contracts that could have been concluded, evaluation of how our internal employees perform their duties, analysis of how we present ourselves as a company etc.);

10. in order to protect and realise our rights and interests (e.g. in case of non-payment of invoices issued and we are forced to initiate a civil lawsuit, in order to carry out our own activities, in order to achieve our object of activity, in order to carry out our activities in the most optimal way for us from any technical/economic point of view, etc.).

Legal grounds for processing

The legal grounds for processing your data are:

1. processing is necessary in order to take actions at your request (e.g. you ask us to change the technical solution proposed by us, you ask us to change the due date of invoices issued etc. );

2. processing is necessary for the performance of the contract concluded with you (e.g. we provide you with the products/services as contractually agreed, we deliver the products to the address mentioned in the contract, etc.);

3. processing is necessary for the fulfilment of legal obligations incumbent on us (e.g. the obligation to draw up and keep primary accounting records, such as the contract concluded, invoices issued, etc.);

4. processing is necessary in order to accomplish our legitimate interests in order to achieve the purposes set out above (Purposes of processing).

Data retention period

Trutzi will keep your personal data only for the period necessary to achieve the purposes set out above (Purposes of processing).

This period varies from case to case depending on a number of circumstances (e.g. the category of data provided, the purpose for which it is provided, the specific purpose of processing, the legal obligations involved, etc.).

As a general rule, your data will be kept by us for the entire contractual period, as well as after the termination of the contractual relationship for a period of 5 calendar years, calculated from 1 January of the year following the year in which the contract ends.

To the extent that the purposes for which your data have been processed are achieved before the expiry of the above-mentioned period, they will be kept only until the purposes are achieved.

To the extent that the purposes for which your data were processed require that your data be kept after the expiry of the period set out above, it will continue to be stored by us until the purposes are achieved (e.g. The Tax Code may require us to keep your data for a period of 7 years, etc.).

The main reasons why we store your data for the above period are the following:

1. during the contract period the data is necessary for us to be able to initiate and sustain a dialogue;

2. during the contract period the data is necessary for us to know which parameters we have to respect and execute the contract (e.g. what we have to supply, where, under what conditions, at what cost, etc.);

3. during and after the contract, the data are contained in a series of financial-accounting documents that the law obliges us to keep (e.g. contract, invoices issued, payment orders, bank records, receipts, etc.);

4. during the contract and afterwards, the data is necessary for us to provide information on the opportunity to offer other services / products than those already contracted;

5. during and after the contract, the data is necessary for us to be able to analyse the viability / technical efficiency / cost efficiency / possible technical problems concerning the services / products offered, so that we can better understand all the technical / economic aspects of the services / products offered;

6. during the contract and afterwards, the data is necessary for us to understand the market trends, what kind of services / products are sought, what is available on the market, what are the costs that customers are willing to pay, etc., knowing this information helps us to adapt our business strategy to stay in the market in a more competitive way and as close as possible to the real needs of our customers;

7. during the performance of the contract, as well as afterwards, there may be certain misunderstandings / disputes regarding the performance of the contract, in which case the data is necessary for us to protect our rights (e.g. in case of a lawsuit we can prove that we have fulfilled our obligations, in case of non-payment of an invoice on time we can prove that we have provided / performed the services / products invoiced etc.);

8. during the contract and afterwards, the data are necessary for us to analyse our own activity and the way we carry it out (internal analysis) so that we can adapt to the market in the most appropriate way (e.g. we analyse if new employments are necessary, if so in which department, we analyse the efficiency of our employees, we analyse the knowledge and professionalism of our employees etc.);

9. after the contract has been concluded, there is a possibility that an existing customer/former customer of ours and/or we may be subject to an inspection by the tax authorities/other public authorities/institutions, in which case it is necessary to be able to prove the contractual relations between us and the way in which they were executed.

7.2 Potential suppliers/existing suppliers/former suppliers of Trutzi and other persons connected with them

Trutzi processes the personal data of its potential suppliers/existing suppliers/former suppliers and other persons in a certain relationship with them, as listed in Chapter 7.1.

To the extent that you are a person in a particular relationship with a potential supplier/existing supplier/former supplier of ours, we process your personal data.

During the pre-contractual period we process your data as set out in Chapter 7.1.1. with the proviso that

1. with regard to the purposes of processing, purposes 3 and 5 do not apply to you.

In the contractual/post-contractual period we process your data as set out in Chapter 7.1.2. with the following exceptions:

1. with regard to the purposes of processing, purposes 5, 6 and 7 do not apply to you;

2. with regard to the reasons for the duration of data retention, reasons 4 and 6 do not apply to you.

7.3 Potential partners/existing partners/former partners Trutzi and other persons connected with them

Trutzi processes the personal data of its potential partners/existing partners/former partners, as well as other persons in a certain connection/relationship with them, as they are named in Chapter 7.1.

To the extent that you are a potential partner/existing partner/former partner of ours or a person in a certain relationship with a potential partner/existing partner/former partner of ours, we process your personal data.

During the pre-contractual period we process your data as set out in Chapter 7.1.1.

In the contractual / post-contractual period we process your data as set out in Chapter 7.1.2. .

7.4 Other persons

To the extent that you do not fall into any of the categories set out in Chapters 7.1 - 7.3, the provisions set out in this chapter apply to you.

Trutzi processes the personal data of persons other than those set out in Chapter 7.1. - 7.3. with whom it comes into contact, such as:

1. representatives of public authorities/institutions (e.g. ANAF inspectors, etc.);

2. visitors to our premises;

3. visitors to our website;

4. other persons with whom we come into contact (e.g. persons with whom we come into contact at an exhibition, etc.).

Purposes of processing

Trutzi aims to offer / provide its services / products to as many people / entities as possible, to fulfil its legal / contractual obligations, as well as to maintain itself in a more visible and performing way on the market.

Trutzi processes your personal data for the following purposes:

1. in order to initiate and sustain a dialogue;

2. to present our services/products;

3. in order to evaluate you in order to determine whether we are interested in a specific collaboration (e.g. if you send us a CV with a view to employment within our company, etc.);

4. in order to obtain information on the basis of which we can propose the most suitable services/products;

5. in order to draw up the documents related to the pre-contractual period (e.g. quotation, draft contract, etc.);

6. in order to understand the requirements and trends of the market (e.g. what services/products are sought, by what categories of customers, at what prices, etc.);

7. in order to understand how we can improve our services/products (e.g. evaluation of internal employees, analysis of the opportunity to hire additional staff, etc.);

8. in order to fulfil legal obligations (e.g. obligation to provide documents and information requested by a public authority/institution initiating an inspection concerning us);

9. in order to understand how we should organise our activity from all points of view (commercial / marketing / HR / IT / financial etc.) (e.g. evaluation of the contracts concluded in one month compared to the contracts that could have been concluded, evaluation of how our internal employees carry out their duties, analysis of how we present ourselves as a company etc.);

10. in order to protect and realise our rights and interests (e.g. in order to ensure the security of our premises, in order to ensure the security of the data on our website, in order to prove our claims before a court of law or a criminal prosecution body, etc.).

Legal grounds for processing

Legal grounds for processing your data:

1. the processing is necessary in order to comply with legal obligations incumbent on us (e.g. where the law requires us to disclose certain information to a public authority/institution etc.);

2. the processing is necessary for our legitimate interests in order to achieve the purposes set out above (purposes of processing).

Retention period

The retention period varies from case to case depending on the particularities of the data (e.g. the number of visitors to our website may be kept for a period of 3 months necessary to carry out a specific survey or may be kept for a period of 1 year for the analysis of a development etc.).

However, we assure you that we will not keep your data after the time when the purpose for which we have processed it has been fulfilled.

8 Recipients/categories of recipients of your personal data

Your personal data may and in some cases, depending on the circumstances, will be transmitted by us to:

1. persons acting under our careful guidance (e.g. our employees);

2. our associated personal data operators (e.g. a partner company in the provision of services/products offered by us etc.);

3. persons acting under the careful guidance of our associated personal data operators (e.g. employees of a partner company in the provision of services/products offered by us etc.);

4. persons empowered to process personal data on our behalf (e.g. a security company, a courier company, etc.);

5. persons acting under the careful guidance of persons authorised to process personal data on our behalf (e.g. an employee of a security company, an employee of a transport company, etc.);

6. you, to the extent that you intend to exercise one of your rights under the law (e.g. right of access);

7. any other person/entity other than those set out in points 1 - 6, for example a separate personal data operator (e.g. ANAF).

The transmission of personal data to the above-mentioned persons will be made solely to the extent that this transmission:

1. is either required by the necessity to achieve the purposes for which we process your personal data;

2. or is required by law.

9 Transfer of your personal data outside the European Union

Trutzi stores your personal data, either in physical or digital format, or both, on the territory of the European Union.

However, in certain circumstances, Trutzi will transfer your personal data outside the European Union.

In the latter cases, Trutzi will ensure that the transfer of data will only be carried out to the extent that the conditions required by European legislation on the protection of personal data are met (e.g. there is a conformity decision issued by the European Commission, an agreement is concluded to ensure the necessary guarantees, etc.).

10 Your rights

With regard to your personal data, you have a number of rights:

1. the right of access to the data;

2. the right to obtain rectification of the data;

3. the right to have the data deleted;

4. the right to obtain restriction of data processing;

5. the right to object to data processing;

6. the right to lodge a complaint with the competent authority concerning the processing of personal data.

For more details on the content of each right, do not hesitate to contact us.

Trutzi facilitates the exercise of your rights, so please do not hesitate to contact us at gdpr@trutzi.ro

11 Your obligation or lack thereof to provide us with your personal data

As a general rule, Trutzi does not oblige you in any way to provide us with your personal data.

However, in certain circumstances, if you do not provide us with your personal data, we may not be able to fulfil the purposes set out above.

For example, to the extent that you do not provide us with the contract bearing your signature, we cannot consider that a valid contract has been concluded between us.

12 No automated decision-making process

Trutzi does not own/use any kind of automated decision-making process, including profiling in relation to you, and all decisions /actions /inactions /measures taken /adopted /performed by our company are human based.

Although we use a range of IT equipment, the decisions we make about you are made solely by the people in our team, based on their own beliefs and judgements, and not automatically by IT equipment.

13 Modification of this policy

Trutzi informs you that this policy for processing your personal data is an outline of how we, today, when you read this material, process your personal data.

We may update this policy from time to time (e.g. due to legislative changes, because we wish to process your data for other purposes and/or on other legal grounds, etc.).

In the latter cases, the updating of the policy will be done without in any way affecting your legitimate rights and interests in the protection of personal data.

14 Exclusivity of this policy

This personal data processing policy has been developed by “Dumitru, Popescu si Asociatii” S.P.A.R.L. ( DPA Legal Team ) in collaboration with members of the Trutzi team, exclusively for Trutzi and is the exclusive property of Trutzi.

Reproduction, in whole or in part, of this policy may be made only with the express written consent of Trutzi.

Management of Trutzi S.R.L. & Management of “Dumitru, Popescu si Asociatii” S.P.A.R.L.