General Provisions
The purpose of this policy is to explain what data we process, why we process it, and what we do with it when you enter into a legal relationship with Smart ID Dynamics SA (for example, when you sign a Project Execution Contract with Smart ID or when you visit this website). These provisions are supplemented by the Terms and Conditions applicable to this website.
We take privacy seriously and never sell email lists or addresses. We understand that personal data belongs to you, and therefore, we make every effort to store it securely and process it carefully. We do not share personal data with third parties without informing you, except for the IT service provider that performs maintenance activities for this website, other recipients depending on the type of processing as mentioned herein, as well as Smart ID Dynamics SA employees who are responsible for processing personal data.
To ensure your data is processed safely, we have made every effort to implement appropriate measures to protect the personal data you provide to us.
In the course of its activities, Smart ID Dynamics SA processes personal data of certain categories of natural persons. These may include personal data of website users, customers, or collaborators/contractual partners of Smart ID Dynamics SA.
Personal data refers to information about an identified or identifiable natural person, meaning information about a person whose identity is either obviously clear or can be established by obtaining additional information.
If data about such a person is processed, this person is referred to as the "data subject" within the meaning of data protection legislation.
Purposes, Legal Grounds, and Categories of Personal Data
In accordance with the provisions of Regulation No. 679 of April 27, 2016, on the protection of natural persons regarding the processing of personal data and the free movement of such data, repealing Directive 95/46/EC ("GDPR"), and Law No. 506/2004 regarding the processing of personal data and the protection of privacy in the electronic communications sector, the data processed by Smart ID Dynamics SA may be used for purposes such as:
- For the purpose of processing equipment or accessory orders or fulfilling a Project Execution Contract and managing the customer relationship, as well as fulfilling legal obligations, which include operations such as design and development/reservation/production/sales/order fulfillment/transport and deliveries, installation, warranties, and service, processing payments, and preparing financial and accounting documents, as appropriate (legal basis: Art. 6(1)(a), (b), (c), and (f) of the GDPR, i.e., your consent, contract execution, fulfillment of legal obligations, and the legitimate interest of Smart ID Dynamics SA, as appropriate).
- To process the order for equipment or accessories or the conclusion of the Project Execution Contract and related acquisitions made by Smart ID Dynamics SA, personal data such as name, surname, email address, phone number, company name, message addressing your requests, and others, as appropriate, will be processed.
- For the transportation and installation of equipment or the implementation of a solution, Smart ID Dynamics SA processes personal data such as name and surname, home/office address, identification data, and contact details.
- By submitting a request for a quote or information on the website, you agree to the communication form (contact form, live chat form, email, SMS, phone) through which Smart ID Dynamics SA conducts its website operations.
- Creating a customer account to ensure efficient internal management through the use of specific applications containing data about our customers (legal basis: Art. 6(1)(b) and (f) of the GDPR, i.e., contract execution or steps taken at the request of the data subject before the contract is concluded, and Smart ID's legitimate interest, as appropriate). For this purpose, Smart ID Dynamics SA processes your name and contact details.
- The administration and maintenance of this website, which also involves the use of cookies, to ensure quick and easy interactions between users and the website (legal basis: Art. 6(1)(a) and (f) of the GDPR, i.e., your consent and Smart ID Dynamics SA's legitimate interest, as appropriate).
Through cookies, Smart ID Dynamics SA collects personal data such as: device identification data, location, technology used, user’s preferred language, gender, interests, and browser information. For more details on the use of cookies by Smart ID Dynamics SA, please refer to the Cookie Policy available on this website.
We draw your attention to the fact that by entering your personal data in one of the sections of this website, you expressly and unequivocally agree that the website owner may use this data for the purpose for which you provided the respective data.
Conducting recruitment activities, including filling out the form available in the Careers section of the website with your name, surname, email address, phone number, and the information contained in your CV (legal basis: Art. 6(1)(a) of the GDPR, i.e., your consent).
For statistical purposes, which may include profiling (automated decision-making), monitoring, and sending personalized communications and offers, we collaborate with third parties specialized in remarketing/retargeting, such as Google LLC, Facebook Inc., Google, and other companies offering similar services ("Remarketing/Retargeting Service Providers"). For promoting Smart ID's offers, we collaborate with third parties such as Google, LinkedIn, Facebook, and for sending newsletters, platforms like ZOHO, MailChimp.
For the processing, monitoring of activities, and interaction with the website, the following personal data is automatically collected and stored: email, phone number, name, surname, gender, date of birth, city, county, address, geolocation data/device data, pages visited on our website, interests, socio-professional category (legal basis: Art. 6(1)(a) of the GDPR, i.e., your consent);
Protection of Smart ID Dynamics SA's assets, people, and spaces through the use of video surveillance devices in the event of visits to Smart ID Dynamics SA's headquarters in Bucharest and other locations across the country (legal basis: Art. 6(1)(c) and (f) of the GDPR, i.e., fulfillment of a legal obligation and Smart ID Dynamics SA's legitimate interest). For this purpose, Smart ID Dynamics SA processes your personal data, namely your image through automated means, your name and surname, and your vehicle's registration number, as appropriate;
Addressing your requests, questions, or complaints (legal basis: Art. 6(1)(a), (b), and (f) of the GDPR, i.e., your consent, contract execution, or steps taken at the request of the data subject before the contract is concluded, and Smart ID's legitimate interest, as appropriate). For this purpose, Smart ID Dynamics SA processes the name and contact details provided by you;
Conducting employment relationships, which involve processing data for the execution of employment contracts, fulfillment of legal obligations, and/or fulfillment of a legitimate interest, whereby Smart ID Dynamics SA processes its employees' personal data as detailed in the information notice provided to employees. In certain specific situations that exceed the execution of the employment contract, Smart ID Dynamics SA processes employees' data based on their consent (legal basis: Art. 6(1)(a), (b), (c), and (f) of the GDPR, as applicable);
Communication with collaborators and contractual partners of Smart ID Dynamics SA (legal basis: Art. 6(1)(b) and (f) of the GDPR, i.e., contract execution or steps taken at the request of the data subject before the contract is concluded, and Smart ID's legitimate interest, as appropriate). For this purpose, Smart ID Dynamics SA processes the name, surname, and contact details provided by you.
Methods of Processing Personal Data and the Transfer of Such Data
Smart ID Dynamics SA processes your personal data for the period necessary to fulfill contracts, comply with legal obligations specific to our field of activity, or according to applicable statute of limitations or archiving obligations imposed by the applicable legislation (for example, those specific to the fiscal and financial-accounting field). In the case of CVs submitted via this website, they are stored for a maximum of 2 years. Personal data processed through video surveillance will be stored for a period of 30 days for each recording.
Your personal data from webinars will be retained for one year from the last communication unless you become our client.
Your personal data from the newsletter will be retained for the lifetime of the newsletter or until you choose to withdraw your consent.
After the storage period ends, personal data will be destroyed or deleted from the computer systems or transformed into anonymous data if necessary for scientific research or statistical purposes.
Your personal data may be transferred to collaborators for the purpose of executing contracts for the acquisition of equipment, accessories, or licenses, or for the purpose of completing/delivering orders. For example, your data will be shared with courier companies if you choose to have your order delivered by courier.
There are situations where your data may be shared with lawyers, consultants, experts, courts, public institutions or authorities, and our auditors, as well as service providers and IT system providers and remarketing/retargeting service providers. In special cases, at the request of judicial bodies or public authorities, your personal data may also be shared with them.
When consent is the basis for the processing of personal data, Smart ID Dynamics SA will inform you about this before consent is given. You have the right to withdraw your consent at any time, noting that this does not affect the legality of the processing based on consent before its withdrawal.
The website is available only to individuals or legal entities who can enter into valid contracts in accordance with applicable law or who are already in contractual relationships with Smart ID. The website and the services offered through it are not intended for minors. Thus, no personal data of minors is collected through the website. If we discover that we have inadvertently collected personal data from a minor, we will promptly delete the minor's personal data from our records, unless we have a legal basis that allows us to store such data. If you believe your child is using this website, please contact us at GDPR@smartid.ro.
Smart ID Dynamics SA does not encourage SPAM, nor does it provide, sell, or transfer email addresses to third parties (individuals or legal entities). Likewise, Smart ID Dynamics SA does not disclose your personal data to others accessing this site's pages. Any user who has explicitly provided their email address on our website can choose to have it removed from our database.
In the event that Smart ID Dynamics SA intends to use your data for purposes other than those for which it was collected, Smart ID Dynamics SA will inform you in advance about the secondary purpose, providing any additional mandatory information as required by law.
Your personal data will be processed by Smart ID Dynamics SA personnel who are responsible for handling such data.
This website also uses Google Analytics, a web analytics service provided by Google, Inc., which in turn uses cookies.
Data Subject Rights
Your rights regarding the processing of personal data, as stipulated in the GDPR, are as follows:
- The right to information;
- The right to access data;
- The right to rectify data;
- The right to erase data;
- The right to restrict data processing;
- The right to be notified about the rectification or erasure of personal data;
- The right to data portability;
- The right to object;
- The right not to be subject to an individual decision;
- The right to address the competent data protection authority and competent courts;
- The right to withdraw consent at any time regarding processing based on consent (however, the exercise of the right to withdraw consent will not affect the lawfulness of personal data processing based on the freely given consent before its withdrawal).
In certain cases (see the above-mentioned statistical purpose), your personal data may be subject to an automated decision-making process (profiling). In such cases, you have the right to request human intervention from Smart ID Dynamics SA, to express your point of view, and to contest the decision made through automated processing (profiling).
The above-mentioned rights are not absolute. There are exceptions, and each request will be analyzed to decide whether it is justified or not. If the request is justified, we will facilitate the exercise of your rights. If the request is unfounded, we will reject it, but we will inform you of the reasons for the refusal, your right to file a complaint with the Supervisory Authority, and your right to seek justice.
Who can you contact?
To exercise these rights, you can submit a written, dated, and signed request addressed to our Data Protection Officer at the email address GDPR@smartid.ro. The Data Protection Officer will contact you to address the issue raised.
In the request, please specify if you would like the information to be communicated to a specific address (including email) or through a correspondence service that ensures personal delivery.
We will make every effort to respond to your request within 30 days. However, the deadline may be extended in accordance with the law, depending on various factors such as the complexity of the request, the large number of requests received, or the inability to identify you in a timely manner.
If we make every effort but are unable to identify you, and you do not provide additional information for identification, we are not obliged to comply with the request.