PRIVACY POLICY

PRIVACY POLICY

Dear Buyer,


As of 25.05.2018, Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, also known as GDPR (General Data Protection Regulation), shall enter into force in all European Union (EU) Member States.

GDPR strengthens the old legislation and makes it uniform throughout the EU. Romania currently has Law no. 677/2001 for the protection of natural persons with regard to the processing of personal data and on the free movement of such data, the provisions of which have already been applied by IELM (FILIP AND FAMILY). In any and all contractual documents, references to Law no. 677/2001 shall be replaced by references to GDPR.

1) We respect your confidentiality and your choices.

2) We ensure that security and safety are incorporated in everything we do.

3) We will send you marketing communication only after you request that we do so. And you may change your mind at any time.

4) We will not pass on or sell your data.

5) We only work with trustworthy partners, in order to ensure that we keep your data safe and that we provide the best services.

6) 6) We are transparent in the way we use your data.

7) We only use your data for the purposes which you have previously authorized.

8) We will respect your rights and do our best to always satisfy your requests as efficiently as possible, as per our legal and operational responsibilities.

In order to find out more information about our privacy practices, below we set out the types of personal data we might receive from you or from our interactions with you, how we can use it, who we can share it with, how we protect and keep it safe, as well as your rights regarding your personal data. Of course, not all situations may apply in your case. This privacy policy provides an overview of all possible scenarios where we might interact.

The more you interact with us, the more you allow us to get to know you better and the more personalized services we are able to provide you with.

When you provide us with your personal data or when we collect your personal data, we shall use it as per the provisions of Law no. 677/2001 for the protection of natural persons with regard to the processing of personal data and on the free movement of such data and of Regulation (EU) 2016/679 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.

Should you have any questions or concerns regarding your personal data, please contact us at  dataprotection@ielm.co.uk.

 

  1. Who is iELM?

  1. What is personal data?

"Personal data" is represented by any and all information by which you can be identified. Such information includes items such as your name, an identification number, your phone number, e-mail address, postal address, username, location data, online identifier, one or more elements specific to physical, physiological, genetic, psychological, economic, cultural or social identity, personal preferences and browsing habits, generated content, your computer’s IP address, your device’s MAC address, as well as information from your cookies, as regulated via the General Data Protection Regulation, whose purpose is that of protecting all EU citizens’ confidentiality and preventing data violations.

  1. What is personal data processing?

Any operation or set of operations conducted on personal data or on sets of personal data, with or without the use of automated means, such as: collection, recording, organization, structuring, storage, adapting, modifying, extracting, consulting, revealing through transmission (including to third parties), dissemination or making available in any other manner, adjoining/alignment, blocking/restricting, deleting or destroying.

  1. What are the categories of natural persons whose data can be processed?

Personal data processed by IELM (FILIP AND FAMILY) comprises the following categories of natural persons: clients (even after contract termination), legal or conventional representatives of the client, persons with proxy powers on the account, additional card users, co-debtors, endorsers, real beneficiaries, as well as their family members.

  1. What data do we collect from you and how do we use it?

How do we collect or receive data?

We collect data from you via websites, forms, orders. You provide data to us directly when you contact us, when you purchase from our websites, and we receive data indirectly from cookies, in order to understand how you use the website and to provide you with relevant data.

Why do we collect data?

- to fulfill contractual terms (e.g. to process orders and deliver to you the products you order on our websites);

- to reply to your requests (e.g. to answer a question you sent via the contact form);

- to send you regular updates (should you explicitly request this);

- to respect legal requirements (such as for billing).

Depending on the purpose your data is used for, the legal basis for the processing of your data may be:

Your consent;

General presentation of information regarding interactions with us and their consequences for your data

Interaction What personal data can we receive from you directly or which results from your interaction with us? How and why would we use your data? What is the legal basis for us to be able to collect your data?
Newsletter and commercial information subscription Your e-mail address.
  • To send you marketing communications (when requested) which can be adapted to your “profile” based on personal data we know about you and your preferences; These are based on consent.
  • Executing analyses or collecting statistics.  This is based on legitimate interest.
  • Maintaining an updated block list if you have asked not to be contacted.  This is based on the legal basis.
  • Consent: to send you direct marketing communications.
  • Legitimate interest: to adapt our marketing communications, understand their effectiveness and ensure that you benefit from the most relevant experience; in order to help us better understand your needs and expectations and so improve our services and products.
  • Legal basis: To maintain your details on a block list if you have asked us not to send you any more direct marketing communications.
  • Online navigation. Information collected via cookies* or similar technologies as part of your navigation of the iELM websites. * Cookies are small text files stored on your device (computer, tablet or mobile phone) when you go online, including on iELM websites. Depending on how much you interact with us, this data may include: your e-mail address, your first and last names. We use cookies, where appropriate, together with other personal data you have already shared with us (such as prior purchases or if you’re already registered for our e-mail newsletters) for the following persons:
    • to allow the good operation of websites:
      • correctly displaying content; creating and retaining your authentication data;
      • interface personalization such as language;
      • parameters related to your device, including screen resolution, etc.
    • In order to ensure that the websites are safe and secure and that they are protecting you against fraud or incorrect use of our websites or services;
    • In order to collect statistics: to avoid the double registration of visitors, to know the users’ reaction to our advertising campaigns, to improve our offers, to learn how you discovered our websites. These are based on legitimate interest.
    • In order to provide behavior targeted online advertising: to show you online ads for products that may be of interest to you, based on your past behavior; in order to display ads and content on social platforms.
    • In order to personalize our services for you: send you recommendations, marketing material or content based on your profile and interests; to display our websites in a manner adapted to you, such as in your language, personalized cookies for user interface (namely the parameters related to your device, such as screen resolution, font preference, etc.); in order to allow the distribution of our content on social media websites (share buttons meant to display the website). These are based on consent.
  • Consent: : for all the other cookies.
  • Legitimate interest: to make sure we provide you with appropriate websites, advertising and communications and which are constantly improved for cookies which are (i) essential for the operation of websites, and (ii) to keep them entirely safe.
  • Legal basis: in order to maintain your details on a block list if you have asked that we no longer send you any direct marketing.
  • Requests. Information collected when you ask questions (e.g. via the contact form) regarding our products and their characteristics. Depending on how much you interact with us, this data may include: your first and last name; your e-mail address; other information you have shared with us (which may include personal data).
  • In order to be able to answer your questions; When necessary, to connect you with relevant services. These have a consent basis.
  • For statistical purposes. This has as a basis legitimate interest.
  • Consent: to answer your questions.
  • Legitimate interest: to help us better understand the needs and expectations of our clients and, therefore, improve our services and products.
  • A. Interaction: Newsletter and commercial information subscription

    What personal data can we receive from you directly or which results from your interaction with us?

    Your e-mail address.

    How and why would we use your data?

    To send you marketing communications (when requested) which can be adapted to your “profile” based on personal data we know about you and your preferences; These are based on consent.

    Executing analyses or collecting statistics. This is based on legitimate interest.

    Maintaining an updated block list if you have asked not to be contacted. This is based on the legal basis.

    What is the legal basis for us to be able to collect your data?

    - Consent: to send you direct marketing communications.

    - Legitimate interest: to adapt our marketing communications, understand their effectiveness and ensure that you benefit from the most relevant experience; in order to help us better understand your needs and expectations and so improve our services and products.

    - Legal basis: To maintain your details on a block list if you have asked us not to send you any more direct marketing communications.

    B. Interaction: Online navigation

    Information collected via cookies* or similar technologies as part of your navigation of the iELM websites.

    * Cookies are small text files stored on your device (computer, tablet or mobile phone) when you go online, including on iELM websites.

    What personal data can we receive directly from you or which results from our interaction with you?

    Depending on how much you interact with us, this data may include: your e-mail address, your first and last names.

    How and why would we use your data?

    We use cookies, where appropriate, together with other personal data you have already shared with us (such as prior purchases or if you’re already registered for our e-mail newsletters) for the following persons:

    to allow the good operation of websites:

    - correctly displaying content; creating and retaining your authentication data;

    - interface personalization such as language;

    - parameters related to your device, including screen resolution, etc.

    In order to ensure that the websites are safe and secure and that they are protecting you against fraud or incorrect use of our websites or services;

    In order to collect statistics: to avoid the double registration of visitors, to know the users’ reaction to our advertising campaigns, to improve our offers, to learn how you discovered our websites. These are based on legitimate interest.

    In order to provide behavior targeted online advertising: to show you online ads for products that may be of interest to you, based on your past behavior; in order to display ads and content on social platforms.

    In order to personalize our services for you: send you recommendations, marketing material or content based on your profile and interests; to display our websites in a manner adapted to you, such as in your language, personalized cookies for user interface (namely the parameters related to your device, such as screen resolution, font preference, etc.); in order to allow the distribution of our content on social media websites (share buttons meant to display the website). These are based on consent.

    What is the legal basis for us to be able to collect your data?

    - Consent: for all the other cookies.

    - Legitimate interest: to make sure we provide you with appropriate websites, advertising and communications and which are constantly improved for cookies which are (i) essential for the operation of websites, and  (ii) to keep them entirely safe.

    - Legal basis: in order to maintain your details on a block list if you have asked that we no longer send you any direct marketing.

    C. Interaction: Requests

    Information collected when you ask questions (e.g. via the contact form) regarding our products and their characteristics.

    What personal data can we receive from you directly or which results from your interaction with us?

    Depending on how much you interact with us, this data may include: your first and last name; your e-mail address; other information you have shared with us  (which may include personal data).

    How and why would we use your data?

    In order to be able to answer your questions; When necessary, to connect you with relevant services. These have a consent basis.

    For statistical purposes. This has as a basis legitimate interest.

    What is the legal basis for us to be able to collect your data?

    - Consent: to answer your questions.

    - Legitimate interest: to help us better understand the needs and expectations of our clients and, therefore, improve our services and products.

    1. Profiling

    When we send or display personalized communications or content, we may use certain techniques known as “profiling” (any form of automatic personal data processing resulting in the use of this data to evaluate certain aspects regarding a natural person, especially in order to analyze or intuit aspects regarding the preferences, interest, economic status, behavior location, health, financial status or personal travels of the individual). This means that we may collect personal data on you in certain situations (sending newsletters, re-targeting with ads viewers who have accessed iELM websites, grouping at web interest level those who enter iELM websites and use this information for marketing purposes) mentioned in the table above. We centralize this data and analyze it in order to evaluate and anticipate your personal preferences and/or your personal interests.

    Based on our analysis, we send or display communications and/or content adapted to your interests/needs.

    You are entitled to refuse processing of your data for “profiling” in certain circumstances” Please see the section “Your rights and options” below.

    1. Who could have access to your personal data?

    Your personal data may be processed on our behalf by our trusted suppliers..

    We rely on trusted third-parties to conduct a series of operations on our behalf. We shall provide them with the information they need to provide the service and we ask that they do not use your personal data for any other purpose. We shall always make every necessary effort to ensure that all third parties we work with shall keep all personal data secure. For example, we may entrust services that require the processing of personal data:

    1. 8. Where do we store your personal data?

    Your data is stored in a country located in the European Economic Area ("EEA").

    It may be transferred to providers working for us, such as detailed above. Some of these are located outside the European Economic Area, namely in the United States of America (as per the European Union-United States Privacy Shield). The transfer of this data may be done solely in a secure manner and in accordance with applicable regulations.

    Should we transfer your data to countries that do not provide an adequate level of protection for the data sent, we undertake to take any and all measures necessary to ensure that the third parties to whom it is transferred respect the terms and conditions of this Policy. These measures may include the direct control of standards applied by these third parties as an element of data protection and security and/or the execution of corresponding agreements (e.g. the standard contractual clauses adopted by the European Union Commission). Should such a transfer occur, you shall be notified regarding the transfer and transfer beneficiaries (third parties).

    For additional information, please contact us via email at dataprotection@ielm.co.uk.

    1. How long do we store your personal data?

    We store your data solely for the amount of time necessary to achieve the purpose for which we store the data, to satisfy your needs or to meet our legal obligations.

    To know how long your data may be stored, we use the following criteria:

    We may store certain personal data to conform to legal and regulatory obligations, as well as in order to manage our rights (e.g. to back up our claims in courts of law) or for statistical or historic purposes.

    When we no longer have to use your personal data, it is eliminated from our systems and our records are anonymized, so that you may no longer be identified from them.

    1. Is your personal data secure?

     

    We undertake to maintain your personal data safe and we take any and all necessary and reasonable measures to respect legislation. Also, we hereby undertake that third parties involved in this activity, who manage your personal data, shall respect current legislation in good standing.

    We shall respect legal requirements for protecting personal data, and once we receive the personal data, we shall follow strict procedures and safety measures to stop unauthorized access.

    Websites may contain, from time to time, links to and from our partner network websites. Should you follow any of these links to any of these websites, please remember that these websites have their own privacy policies and that we are in no way responsible nor liable for them. Please read these policies prior to sending your personal data to these websites.

    1. Your rights and options

    iELM respects your right to privacy: it is important that you control your personal data. You have the following rights:

    The right to be informed: You have the right to receive clear, transparent, easy to understand and easily accessible information regarding the way in which we use your data and regarding your rights. This is the purpose of the information included in this policy.

    The right of access: You have the right to access the personal data we hold. Upon request, iELM shall release a copy of any and all personal data processed, additional copies may be subject to payment depending on the real costs borne by iELM.

    To do this, please contact us using the details below.

    The right to rectification: You have the right to ask that your data be rectified if it is inexact or old and/or to complete it if it is incomplete.

    To do this, please contact us using the details below.

    The right to erasure and the right to be forgotten: In certain cases, you have the right to obtain the deletion or destruction of your data. This is not an absolute right, because sometimes we may be obliged to store your data for legal or judicial reasons.

    Should you want to delete your personal data, please contact us using the details below.

    The right to stop direct marketing, including profiling: You may unsubscribe or stop our direct marketing communication at any time.

    It is easier to do this by clicking the “unsubscribe” button in any e-mail or communication we send you. Alternatively, you may contact us using the contact details below.

    If you wish to stop any and all profiling activity, please contact us using the details below.

    The right at any time to withdraw your consent for the processing of data based on consent: You may at any time withdraw your consent for the processing of your data when such processing is based on consent. Withdrawal of consent shall not affect the legality of processing the data obtained prior to its withdrawal. Consult the table located in the section “What data do we collect from you and how do we use it", especially the column “What is the legal basis as per which we may process your data?" to identify cases in which the processing is based on consent.

    Should you wish to withdraw your consent, please contact us using the details below.

    The right to oppose processing based on legitimate interests: You may at any time oppose the processing of your data when such processing is based on legitimate interest. Please consult the tables inserted in the section "What data do we collect from you and how do we use it", especially the column " What is the legal basis as per which we may process your data?" to identify situations in which our processing is based on a legitimate interest.

    To do this, please contact us using the details below.

    The right to complain to the appropriate authority: You have the right to submit a complaint with the data protection authority in your country in order to dispute the data protection practices provided by iELM.

    The right to data portability: : You have the right to move, copy, or transfer data of interest to you from our database to another. This applies solely to data provided by you, when processing is based on your consent or on a contract and is implemented via automated means. You can read the table added in the section " What data do we collect from you and how do we use it?" especially the column " What is the legal basis for us to be able to process your data?” to know whether our processing is based on contract or consent.

    The right to restriction of processing: You have the right to request the restriction of processing of your data. This means that the processing of your data is limited, so that we may keep the data but we may not use it or process it. This right applies in specific circumstances specified by the General Data Protection Regulation, namely in cases where the exactness of the data is disputed for the time period necessary to determine the error or if the processing is illegal and data deletion is not desired, but just restriction.

    Should you wish to request restrictions, please contact us using the details below.

    The right to deactivate cookies: Beside the right to withdraw your consent for cookies for which consent was necessary (as per the table above), you have the right to deactivate cookies. Internet browser settings are usually programmed to default to accepting cookies, but you may adjust them modifying your browser settings.

    Many cookies are used to enhance the degree of use or the functionality of websites; therefore, deactivating cookies may prevent you from using certain parts of our websites, as detailed in the relevant Cookie table.

    Should you wish to restrict or block all cookies set by our websites (though this may also prevent you from using certain parts of the website) or of other websites, you may do so via your browser settings. Your browser’s Help function should tell you how to do this. For more information, please consult the following link:

    http://www.aboutcookies.org/;

    For complete details about what cookies we store, for what specifically and how you may deactivate them, please visit the Cookie policy web page.

    In order to support your request, we may ask you for proof of identity.

    1. Contact

    Should you have any questions or concerns regarding the way in which we treat and use your personal data or should you wish to exercise any and all of your rights as mentioned above, please contact us at dataprotection@ielm.co.uk.