IMPORTANT: When this Policy is presented to you, at the time of visiting the site www.en.hragile.ro (“Site”), we consider that you have understood how your personal data (“PD”) are used within the Site. Furthermore, in the event that you are required to agree to this Policy and the processing of PD in accordance with this Policy, this agreement signifies your agreement to the processing of PD for which such agreement is required in accordance with the provisions of this Policy.

If you have questions about your PD or this Policy, or suggestions for improving our product and how PD information is presented, please email us at contact@hragile.ro.

 

SUMMARY

We want to give you the opportunity (you, the “User”), through the Site, to find out relevant information about the labor market, to be able to provide relevant information for the provision of services and to be able to apply for jobs offered through The site. In order to achieve these goals, we need to access several types of PD.

Therefore, please read this Policy to understand the relationship between PD, which belongs to you and the Site; more precisely: who processes and who has access to the PD, for what purpose and on the basis of which the processing is carried out, what are your rights in relation to PD that belong to you and other relevant details.

What PD do we mean? The site processes information obtained from you both directly (for example, when you fill out a form or a text box on the Site, such as the Request Talent form, the Contact form or the Submit Resume form) and indirectly (for example, due to the fact that you use the Site from a specific device identified by a specific IP address).

Some of this information is PD (meaning information that can identify you or lead to your identification). Of these:

– a category is required to make the Site work (for example, the e-mail address is required in order to register to access the email list);

– another category is used on the basis of a legitimate interest of ours (we, the “Company”, defined below) – for example, the name, username are used to limit the situations in which a User could publish an anonymous contribution as a comment, the veracity of which would be questionable by other Users of the Site;

– finally, a last category of PD are processed with your explicit and prior consent, the existence of which we store in relation to the moment we obtain it from you. You can find more details about PD processed in Section 3 below.

Who can process your PD through the site? First of all, the entity that operates the Site, called “Company”: Joy of Life Consulting SRL, a company registered and operating in Romania. You can find out more about us and our identification data in the section below called Operator Details.

Secondly, in the development and operation of the Site, we use products and services developed and operated by third parties. They have the technical capacity to store / access / process a part of the PD taken over by us through the Site and process them according to the purposes indicated by us. All of these third parties and their role in the architecture of the Site and PD processing are described in Section 4.1 below.

All PD belonging to you are processed by third parties who are either located and process PD in the territory of the European Union, or process these PD in accordance with the provisions of European Union law. Thus, we want to collaborate only with entities that process PD through systems located in the territory of the European Union or that comply with the provisions of European Union law and to use PD storage services that offer us the possibility to store them in the territory of the European Union or in accordance with regulations. European Union.

You have a number of rights related to PD, which we are open to help you exercise. You can learn more about these rights in Section 5 of this Policy.

If you have any questions or concerns regarding the content of this Policy, or suggestions for improving it, you can contact us at contact@hragile.ro.

 

1.  Operator Details

Joy of Life Consulting S.R.L., Romanian legal entity, headquartered in Bucharest, Str. Burnitei no. 60, registered at the Trade Register under no. J40 / 6355/2017, fiscal code 37508408, Email: contact@hragile.ro, (hereinafter referred to as “the Company”), holder of all rights to the Site (as defined below), respects the character private and the security of the processing of personal data of each user of the Site, having the quality of operator of personal data, in accordance with the provisions of Law no. 677/2001 for the protection of individuals with regard to the processing of personal data and the free movement of such data and of the General Regulation of the European Union on the Processing of Personal Data no. 2016/679 (“GDPR”)

 

2.  Definitions

In this document, capitalized words will have the following meanings:

a) “Site” means the site associated with the domain name hragile.ro, whose rights are owned exclusively by the Company, through which Users (as defined below) can find relevant information about the labor market and, requires resources apply to jobs listed on the Site using one of the available contact and data entry forms;

b) “User” means any natural person over the age of 16 who is in one of the following situations: (1) accesses the Site without entering personal data; (2) accesses the Site by entering personal data in order to have specific contributions to a User but also answers to comments and evaluations submitted by other Users. To avoid any doubt, the Site is not intended for use by individuals who do not meet the conditions described in this definition and, explicitly, is not intended for use by minors (within the meaning of the legislation that is applicable to a particular user);

c) “Third Party” means a site, other than the Site, whose content is available within the Site, the character of Third Party being highlighted distinctly along with the content that belongs to it, in the section of the Site where this content appear;

d) “Personal Data”, “Personal Data” or “PD” means any information relating to an identified or identifiable natural person; an identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity;

 

3.  Personal data and the purpose of data processing

For and in connection with the operation of the Site, Personal Data are processed on the basis of several legal grounds and for several purposes:

3.1  Based on the legitimate interest of the Company, we process the following Personal Data:

3.1.1  the IP address of the device used to access the Site (strictly in order to be able to make a connection between unusual activities on the Site – for example, a large number of comments sent by a User at the same time, which make the operation of the Site – and a certain User, so that we can evaluate to what extent those activities are manual or automatic, created by a software product that tries to affect the functioning of the Site and to take the technical measures imposed by the situation);

3.2  Based on the need to provide a service to Users who have engaged in the use of the Site, respectively to make and keep the Site functional and to provide the Services, we process the following Personal Data:

3.2.1  name, surname, e-mail address and / or telephone number (in order to be able to send notifications and other information to a User and to provide the Company with the information strictly necessary for the performance of the services);

3.2.2  name, surname, e-mail address (in order to be able to give authenticity to the comments and contributions added by a User within the Site, this being essential for the most complete and correct reflection of the existing information on the Site about the labor market ). Given the profile of the Site, the expectations of Users are to find updated and real information within the Site.

3.3  The site also uses cookies in its operation, about which you can find out more by accessing the cookie policy accessible here

 

4.  Who processes PD

4.1  Power of attorney of the Company

Personal data processed through the Site are made available to the following third parties, whose products / services are necessary for the development and operation of the Application:

4.1.1  Google LLC, for the Google Analytics product, used to analyze the city from which and the device from which a User accesses the Site;

Google Analytics’ personal data processing policy is available here.

4.1.2  HotJar Ltd, for the HotJar product, used to analyze the sections of the Site in which a User spends the most time;

HotJar’s policy on the processing of personal data is available here.

4.1.3  Romarg SRL, for the hosting service of the Site;

The policy regarding the processing of personal data by Romarg SRL is accessible here.

In choosing these entities, the Company considers the observance by them of the applicable provisions regarding the processing of Personal Data. To the extent that the Company decides to add new entities and products or to replace these entities and products, you will be notified in advance, having the possibility to refuse to continue using the Site if you consider that the processing of Personal Data by a certain entity is to your detriment.

 

5.  Users’ Rights

Users benefit from the following rights in connection with the Personal Data that belong to them, which they can exercise by sending an e-mail to contact@hragile.ro:

5.1  The right of access to Personal Data

5.1.1  Any User may request from the Company, free of charge once every 6 months, the confirmation of the fact that there are Personal Data related to the User processed or not by the Company. If so, the Company must inform the User about: the purposes of processing; what categories of Personal Data are processed and, insofar as these Personal Data are not current / updated / relevant, the right to request the rectification, deletion or restriction of the processing of these Personal Data, or to oppose the processing of Personal Data; which natural / legal persons have access to Personal Data; the term for storing Personal Data; the right to file a complaint with the National Authority for the Supervision of Personal Data Processing, insofar as the User considers that he cannot exercise his rights in relation to the Operator.

5.1.2  The company may charge a fee for the provision of this information, insofar as requests from a User are more frequent than a request once every 6 months, a fee that will be communicated to the User at the time he makes a new request. within the mentioned term, having the same object.

5.2  The right to rectify Personal Data

Any User may request from the Company, free of charge, the rectification of inaccurate Personal Data concerning him. If it deems it necessary, following the Company’s response, the User may request the completion of Personal Data, and the Company may either make the necessary changes to the User’s account on the Site, or indicate to the User the steps by which it can make this rectification.

5.3  The right to the deletion of Personal Data

5.3.1  The User may request the Company to delete the Personal Data concerning him, following that the Company will comply with this request in the following situations:

5.3.1.1  if the Personal Data whose deletion is requested is no longer necessary for the Company to fulfill the purposes for which it was collected or processed (for example, the User requests the deletion of a resume or request uploaded to the Site). In this sense, the Company will send a response to the User, explaining the need to process the Personal Data in question in relation to the purposes of processing, but also the consequences of deletion. To the extent that the User considers that this processing is no longer in accordance with the purposes indicated by the Company, he may maintain his position regarding the deletion of Personal Data, assuming responsibility for any effects related to the use of the Site as a result of deleting such Personal Data;

5.3.1.2  if the User withdraws his consent for the processing of Personal Data, if the Personal Data in question is processed based on the User’s agreement, as a legal basis (you can find more details about the grounds on which we process Personal Data in Section 3 above) ;

5.3.1.3  if the User objects to the processing of Personal Data, in accordance with the provisions of this Policy; The Company will send a response to the User, indicating the extent to which there are legitimate reasons for further processing of Personal Data. In the event that the Company sends a newsletter to Users or other methods of commercial communication, the User will have at any time and for any reason, the opportunity to opt out of receiving such communications;

5.3.1.4  if the User considers that the processing of Personal Data has been carried out illegally; The company will send a response to the User, explaining to what extent there is a legal basis for the processing of Personal Data; To the extent that the User considers that this processing is no longer in accordance with the purposes indicated by the Company, he may maintain his position regarding the deletion of Personal Data, assuming responsibility for any effects related to the use of the Site as a result of deleting such Personal Data;

5.3.2  The Company may refuse to comply with the User’s request if the Personal Data whose deletion is requested cannot be deleted due to a legal obligation regarding the Company’s activity (in which case the Company will indicate to the User the basis of this legal obligation), or archiving or statistical reasons (in which case the Company will indicate to the User what measures it can take to ensure that the Personal Data of the User is processed in a secure manner and, at the same time, that the processing takes place only to provide aggregate information about the behavior. Users in connection with the Site)

5.4  The right to restrict the processing of Personal Data

The user has the right to request the Company to restrict the processing of Personal Data, in one of the following cases:

5.4.1  The User indicates that the Personal Data concerning him are not correct, and the Company cannot rectify the Personal Data indicated on the spot, at the moment of receiving the communication in this respect from the User;

5.4.2  The user indicates that the processing is not legal, but does not want to delete the data, only wanting to restrict the processing;

5.4.3  The user indicates the wish that the Personal Data be accessible within the Site in order to be able to use it in the defense / exercise / ascertainment of a right before an authority, but does not wish that the Personal Data be processed for other purposes. ;

5.4.4  The User disputes the legitimate interest in the processing of Personal Data (which are processed on the basis of this legitimate interest) by the Company, and the Company cannot assess, upon receipt of the request from the User, to what extent the legitimate interest of the Company prevails over exercised by the User.

If the right to restrict the processing will be exercised, the Company will inform the User in advance, as the case may be, before the moment when the restriction of processing will no longer be applicable, the Personal Data will be processed again.

5.5  The right to request the portability of Personal Data

The User may request the Company to transmit to him all the Personal Data that the User has provided to the Company (therefore only the Personal Data that the User has entered, directly, in the Site, or that refer to his preferences from within the Application), in a format that allows the User to transmit this Personal Data to another entity, in order to access new services or products. This right is exercisable only in the case of Personal Data processed on the basis of the User’s agreement, or for the execution of the contract with the User.

5.6  Right of opposition

5.6.1  The User has the right to object to the processing of Personal Data which are processed on the basis of the legitimate interest of the Company, according to the provisions of this Policy. In this sense, the User may send an e-mail to the Company at contact@hragile.ro, mentioning the reason for opposing the processing of Personal Data concerning him (in whole or in part).

5.6.2  The Company will respond to the User within 30 days of receiving the request, indicating to what extent it considers that the legitimate interest of the Company prevails over the reason for opposition indicated by the User.

5.6.3  If the User does not wish to receive marketing and / or promotional messages from the Company (to the extent that the Company sends such messages to the User), he may express his option at any time, absolutely.

5.6.4  If the exercise of the right by the User is legitimate, the Company will take the necessary steps to stop processing the Personal Data of the respective User;

5.7  The user has the possibility to address the National Authority for the Supervision of National Data Processing insofar as he considers himself unjustified by the answer received from the Company / lack of a response to his request to exercise one of the rights mentioned in this Policy.

5.8  Correspondent

5.8.1  In order to exercise the rights provided above, the User may contact the Company at contact@hragile.ro.

5.8.2  The company will analyze each request separately and will communicate with the User in order to be able to fulfill his requests in a way as close as possible to the User’s expectations.

5.8.3  The Company will respond to Users’ requests within 30 calendar days from the date of receipt of the request. To the extent that an extension of this term will be necessary, the Company will inform the requesting User about this need, prior to the expiration of the initial term.

 

6.  Confidentiality of Personal Data

6.1  The Company uses only the Personal Data it needs and only for the purposes described in this Policy. To the extent that we no longer need to process certain Personal Data, we will discontinue their processing and inform you of such changes regarding the processing of Personal Data.

6.2  In the processing of Personal Data, the Company offers access only to the employees / collaborators of the Company who need access to certain Personal Data in order to be able to carry out their activity based on the relationship with the Company.

6.3  Apart from the entities mentioned in this Policy, we will not give access to the Personal Data to other third party entities without informing you in advance about this aspect.

 

7.  Processing security

7.1  The Company has the obligation to safely manage the Personal Data provided by Users through the Site.

7.2  Personal data is protected as follows:

7.2.1  from the point of view of the possibility to view and access the Personal Data, these are stored on the servers of the hosting service provider, being accessible only by a person from the senior management of the Company;

7.2.2  in terms of personal data storage, in addition to storage on the servers of the hosting service provider, there is a copy of them, also stored on the same servers, accessible by password by a single person from the senior management of the Company;

7.3  The security of a User’s account also depends on the maintenance of the confidentiality of the connection data in the platform by the User. In this regard, the Company recommends to Users:

7.3.1  use a strong password and renew it at regular intervals;

7.3.2  avoid using the same password for multiple applications;

7.3.3  implementation of automated systems for devirusing and securing the computer systems used to access the Site (for example, antivirus software installed on the device from which the Site is accessed);

7.3.4  avoiding the storage of the password for the User account in unprotected documents or accessible to third parties;

7.3.5  avoid disclosing password details for the User account to other persons.

7.4  The company will not be held responsible for the negligence or inaction of the User that lead to compromising the security of the account within the Site.

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