The following information is designed to inform you about the processing of your personal data and your rights regarding this processing in accordance with the General Data Protection Regulation 2016/679 (“GDPR”) and national legislation in force.

1. General information

We, the company CTP INDUSTRY SERVICES S.R.L., with its registered office in JUD. PRAHOVA, SAT BUCOV COM. BUCOV, STR. PETRE ISPIRESCU, NR.68, registered under no. J29/508/2022, CUI 45685508, (“the Company”), represent the controller in accordance with the GDPR. The contact details of the Company’s data protection officer are e-mail: contact@ctpgroup.eu, telephone: +40 344 142 592.

2. When do we collect data about you?

We will collect your personal data when, for example:

• You are the customer/beneficiary of a commercial activity that we purchase/provide;

• You purchase or use any of our products and services;

• You visit or browse our website or other websites of CTP INDUSTRY SERVICES S.R.L.;

• You register for a specific product or service (example: creating a user account on the Site https://www.ctpgroup.eu/);

• You contact us through various channels, or request information from us regarding a product or service, including communication channels associated with social media applications such as Facebook, LinkedIn, etc.;

• You have granted permission to other companies, such as our commercial partners or associates, as well as our third-party suppliers or contractors, to exchange information with us about you;

• You subscribe to marketing communications (Newsletters), alerts or other services offered by us;

• When your personal data is public;

• We also collect information from certain organizations, where applicable and to the extent that we have a legal basis for doing so. These include fraud prevention agencies, trade directories, verification/control agencies, billing agencies and contracted service providers;

• We use cookies (small text files stored in your browser) and other techniques such as web beacons (small, transparent image files used to track your movements on our site). For further details on this and how to opt out of them, please see the Cookies section on our website https://www.ctpgroup.eu/.

3. Purpose of processing

The Company processes your personal data for the following purposes:

• in order to ensure interaction and establish a relationship with you when we have a contractual relationship or a legitimate interest;

• to provide products / services; 

• in order to fulfill the Company's legal obligations;

• in order to pursue the Company's legitimate interests;

• for the following purposes, all relating to the IT field, to the extent that you have agreed to each of them:

• Providing information regarding commercial offers;

• Providing information regarding test drives;

• Providing information regarding Company events;

• Providing information;

• Participation in opinion polls regarding the Company's products and services regarding the degree of customer satisfaction.

4. Categories to be processed

In CTP INDUSTRY SERVICES S.R.L. the following categories of data are processed:

• Name, personal identification number, date of birth, identity document, function, address, e-mail, landline and/or mobile telephone numbers, fax number

• Your contact with us, such as a note or recording of a call you made to one of our contact centers, a Customer Relations service, an e-mail or letter sent or other evidence of a contact with us;

• Information regarding your account, such as payment dates due or received, subscriptions you use, account numbers or other information related to your account or which is included in our portal for managing the commercial relationship with each customer;

• Information regarding the legitimacy of access – we will collect passwords, clues and similar security information used for authentication and access to accounts and services (for online accounts opened by each customer on our company's website);

• Your preferences for certain products, services and lifestyle when you tell us what these are or when we assume what they are, based on how you use the products and services CTP INDUSTRY SERVICES S.R.L.;

• Marketing preferences.

• Your browsing history. If you have given us permission, CTP INDUSTRY SERVICES S.R.L. collects the categories of websites you have browsed on your mobile, device or PC, for example sports, music or news. However, we do not have a history of the websites you browse, which is limited to a short period of time to enable the connection. We use this information about interests to send you personalized marketing offers or to show you personalized advertisements. You can opt out of advertising according to the Cookies section on our website https://www.ctpgroup.eu/ or, in the case of marketing, through the Data Protection Settings section;

• Information we obtain from other sources, such as public or private authorities, fraud prevention agencies, and other data providers. This includes demographic data, data related to interests, and online browsing behavior;

• In order to improve the services offered, the conversation with our consultants may be recorded and transcribed into text format. If you agree to authorize the recording and transcription, continue the call with our consultants. If you do not want this, please end the call and contact us through other means of communication as presented in this document;

• For the loyalty program consisting of offering advantages, discounts, and rebates to reward customer loyalty.

• The level of services provided to you – for example, operational issues and other events that may affect our services;

• Responses to invitations and confirmations of participation in events.

The personal data we process are, in particular, your identification, transactional, financial, demographic, location or other personal data that we collect directly from you or from other sources when you become our customer, or when you use our products or services. Sensitive personal data reveals your racial and ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning life or sexual orientation. CTP INDUSTRY SERVICES S.R.L. does not intentionally collect sensitive personal data from you for storage. CTP INDUSTRY SERVICES S.R.L. does not intend to process this type of data unless you explicitly provide us with sensitive personal data (for example, specific requirements regarding trade union membership or biometric data, in situations where you are our employees).

5. Legal basis for processing

• The legal basis for collecting and processing your data for each of the purposes mentioned above is:

• The contract for the supply or provision of services to which you are a party or your request before entering into a contract;

• The legitimate business interests of the Company, for example, preventing fraud, maintaining the security of our services, direct marketing and improving our services. Whenever we rely on this legal basis to process your data, we assess our business interests to ensure that they do not override your rights. In addition, in some cases you have the right to object to this processing. The legitimate interest of the Company to allow us to exercise the rights provided by law in our favor, to take legal action against any illegal activity or that is prejudicial to the Company;

• Compliance with a mandatory legal requirement, for example, accounting and tax requirements, which are subject to strict internal policies (such as retention periods), procedures and your right to restrict the use of your data, which control the scope of our services to be provided;

• In addition, to the extent that you have agreed, your consent. The processing of personal data based on consent is an additional purpose to the processing of personal data for the performance of the contract to which you are a party and does not condition the provision/performance of the contractual services;

• The processing is necessary for the performance of a task carried out in the public interest.

6. The categories of recipients to whom the collected personal data may be disclosed:

To achieve the above-mentioned purposes, we use the following categories of product and service providers/processors:

• suppliers directly/indirectly involved in the provision of products and services in the online field;

• state authorities (including tax authorities);

• accountants, auditors, legal experts, lawyers or other such external advisors of the Company or to third parties who provide products and services to the Company (security service providers, IT systems providers, financial consultants);

• the Company's suppliers directly/indirectly involved in the marketing and promotion process.

7. Automatically collected data

When you visit the Site, we automatically collect data through your browser or device, through the use of cookies and similar technologies. Please consult the Cookie Policy for additional information regarding these practices https://https://www.ctpgroup.eu//ro/cookie-policy .

8. Marketing Controls

If you no longer wish to receive marketing communications from us (Newsletters), please update your preferences in your profile or account, or access the “Unsubscribe” section. If you opt out of receiving marketing communications from us, we may continue to send you messages related to your orders, or other messages related to the administration of your user account or updating our policies, which you cannot opt ​​out of, as long as you have an active user account or an ongoing contract/order with us.

9. Retention Period

We will retain your personal data for as long as necessary, or permitted, in light of the purpose(s) for which it was obtained and in accordance with the terms set out in this Notice. The criteria used to determine the lengths of retention periods include:

• the length of time we have an ongoing relationship with you;

• the period of time necessary to perform the obligations and rights assumed contractually, respectively for a period equal to the period established by the legal requirements for the retention of information, tax/financial legislation, other laws, regulations and/or other specific provisions;

• if there is a legal obligation to which we fall;

• if retention is advisable in light of our legal position (such as the enforcement of the Terms and Conditions, applicable statutes of limitations, litigation or regulatory investigations). When we no longer need your personal data, we will delete or securely destroy it. We will also analyze whether and how we can minimize over time the personal data we use and whether we can anonymize your personal data so that it can no longer be associated with or identify you, in which case we may use this information without further notice.

10. Transfer to third countries and security measures

10. Transfer to third countries and security measures

Depending on the locations of the servers of CTP INDUSTRY SERVICES S.R.L. or its agents, on which the data will be stored, or depending on the location of certain recipients of the data, personal data may be transferred, as the case may be, to other Member States of the European Union or the European Economic Area. Unless the law expressly requires otherwise or it is strictly necessary for CTP INDUSTRY SERVICES S.R.L. to fulfill the contract or the obligations assumed, we will not transfer personal data outside the European Economic Area.consecinta.

In the event that CTP INDUSTRY SERVICES S.R.L., in order to execute the contract and the obligations assumed, must transfer data to third countries, we will transfer only those personal data strictly necessary for the execution of the contract and/or the obligations assumed. In situations other than those mentioned above, if, exceptionally, in order to execute a contract with a third party and/or obligations assumed towards third parties, CTP INDUSTRY SERVICES S.R.L. carries out, on its own initiative or at the initiative of a third party, a transfer of personal data concerning you, to a third country, determined protection measures will be implemented in the event of such a transfer, and the data subjects will be notified in

11. Third Party Services

This Notice does not address, and we are not responsible for, the data collection, use, disclosure or security practices, or other practices, of any third party, including any third party that operates a service to which our Site provides links. The inclusion of a link on our Site does not imply that we endorse the service to which the link directs.

12. Use by Minors

Our Site and Services are not directed to persons under the age of sixteen (16) years, and we do not knowingly collect Personal Data from such persons. If you are under the relevant age of consent in your jurisdiction, you will need the permission of your parent or legal guardian to use our Site and Services. Please consult with your parent or legal guardian before using our Site or services. If you provide us with personal data of individuals under the age of sixteen (16), you represent that you have the appropriate authority to do so and that you can demonstrate this authority upon request by the company.

13. Changes made

Information notice on the processing of personal data Our Information Notice on the processing of personal data may change from time to time and any change to the statement will be communicated via an e-mail or an announcement on our website. You will receive the e-mail as long as you are registered in our databases with an e-mail address.

14. Security of personal data

We respect strict security procedures regarding the storage and disclosure of your personal data and protect it against accidental loss, destruction or damage. We may disclose your information to trusted third parties for the purposes set out in this Information Notice. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in accordance with EU legislation on data protection rules.

15. Your rights

The Regulation grants individuals whose personal data are processed a series of rights. Thus, in addition to the rights currently existing, we also find the right to data portability and the right to data erasure. In short, the rights you have:

• The right to withdraw consent at any time in order to stop data processing that is based on your consent. Withdrawal will not affect the lawfulness of processing based on consent granted before withdrawal, for the performance of a contract, for the fulfillment of a legal obligation or for the purpose of pursuing our legitimate interests.

• The right of access - means that you have the right to obtain confirmation from us as to whether or not we are processing personal data concerning you and, if so, you have access to that data and to information regarding the way in which this data is processed.

• The right to data portability - refers to the right to receive personal data in a structured format, commonly used by us and which can be read automatically, but also to the right to have these data transmitted directly to another controller, if this is technically feasible.

• The right to object - refers to your right to object to the processing of personal data when the processing is necessary for the performance of a task carried out in the public interest or when it is based on a legitimate interest of the controller. When the processing of personal data is for direct marketing purposes or processing carried out on the basis of express consent, you have the right to object to the processing at any time.

• The right to rectification - refers to the correction, without undue delay, of inaccurate personal data. The rectification will be communicated to each recipient to whom the data was transmitted, unless this proves impossible or involves disproportionate efforts.

• Right to erasure ("right to be forgotten") - means that you have the right to request the erasure of personal data, without undue delay, if one of the following reasons applies: they are no longer necessary for the purposes for which they were collected or processed; you withdraw your consent and there is no other legal basis for the processing; you object to the processing and there are no other legitimate reasons that prevail; the personal data have been processed unlawfully; the personal data must be erased for compliance with a legal obligation; the personal data have been collected in connection with the provision of information society services.

• The right to restrict processing - can be exercised if the person contests the accuracy of the data, for a period necessary to verify the accuracy of the data; the processing is unlawful, and you oppose the deletion of personal data, requesting restriction instead; if CTP INDUSTRY SERVICES S.R.L. no longer needs the personal data for the purpose of processing, but the person requests them for the establishment, exercise or defense of a right in court; if the person has opposed the processing for the period of time in which it is verified whether the legitimate rights of the operator prevail over those of the person concerned.

• The right to file a complaint – can be exercised if you consider that your rights as a data subject have been violated. You can contact the National Authority for the Supervision of Personal Data Processing at any time with a complaint or notification in this regard, with headquarters at B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania (fax: +40 318 059 602, email: anspdcp@dataprotection.ro). You can also file a lawsuit before the competent courts.

To exercise these rights, as well as for any additional questions regarding this information or in connection with the Company's use of personal data, please contact our data protection officer, choosing any of the communication methods described below. You can contact us:

• By email - to the address: contact@ctpgroup.eu; or

• In person or by a request sent by post - to the Company's Headquarters (at the address mentioned in point 1); or

• By phone - to the number: +40 344 142 592 Additional details as well as any updates to this information regarding the protection of your data - can be found on the Company's website - Data Protection section.