As of May 25, 2018, the provisions of Regulation (EU) 679/2016 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC ("GDPR") are applicable.
Personal data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2. Who we are?
ROMGAZ is committed and constantly strives to ensure and maintain a high level of personal data protection, by adopting appropriate technical and organisational measures with regard to all processing activities, aimed at securing and protecting the fundamental rights and freedoms of individuals, in particular the right to privacy, family and private life, aiming at permanent compliance with legal provisions.
3. This policy applies to:
- Romgaz employees and/or trainees/interns;
- Our contractual partners such as suppliers, clients (“business partners”);
- Candidates for Romgaz vacant positions;
- Visitors on our website www.romgaz.ro (“visitors”);
- ROMGAZ visitors.
4. What data are collected?
We collect and process your personal data:
- from the information provided by filling in forms on our website: the contact page form, the career page form, the form requesting information subject to Law 544/2001;
- by corresponding with us by telephone, e-mail or in any other way.
The information provided may include the name and surname, e-mail address and telephone number, as well as other information, as the case may be.
Through the activity on the site, we will not collect or process sensitive personal data about you (i.e. information concerning race or ethnicity, political opinions, religious or philosophical beliefs, health, sex life or sexual orientation) unless:
a) it is required by law and/or
b) you explicitly consented thereto, separately.
If you voluntarily provide personal data (including sensitive personal data) through interaction with www.romgaz.ro or through our correspondence by telephone, email or otherwise, by your own will and not at our request, we will delete such personal data from our systems if we do not consider that processing is necessary for a legitimate purpose of Romgaz, unless you have made this data public (for example, in a publicly visible message board), in this case we will delete such data from www.romgaz.ro, if provided by law or if we do not want to keep such data.
5. What is the scope and legal basis for personal data processing?
We process personal data:
- for communication purposes whenever necessary to answer to potential requests received through contact forms on Romgaz website, by phone, e-mail or any other manner;
- for communication purposes, to take all endeavours to conclude a contract with you or the company you represent;
- for communication purposes when we have to perform a contract concluded with you or the company you represent;
- in order to comply with a legal obligation (i.e. laws applicable to labour, accounting, audit;
- if necessary for the public interest or in official purposes.
It is mandatory to provide personal data when required subject to law or contractual obligations. If such personal data are not provided, it will be difficult to manage contractual relationships or to comply with legal obligations. In all other situations, the provision of personal data is optional and you are under no obligation to provide it.
We process personal data such as identification data, contact details and address for potentially exercising our future rights or claims against you. Data processing is based on our legitimate interest, as it is necessary to exercise our rights in the event of a potential litigation.
If certain personal data are requested directly for the above-mentioned purposes, please provide them correctly and fully, otherwise our relationship will be defective.
Specifically, we use personal data, as follows:
Employees and/or trainees/interns at ROMGAZ
We use personal data in order to perform the applicable individual or collective labour agreement, namely the agreement related to trainees/interns. In this case, the basis for processing data is signing the contract.
Data processing as legal obligation
It is possible to process some of your personal data for providing information to state authorities under legal applicable provisions or for fulfilling legal obligations. In this case, data are processed under legal obligations.
We use your contact details to communicate with you regarding the company's business and any other matters relevant to the relationship between the parties. In this case, we rely on the legitimate interest of the company to ensure fair and full information of employees and good running of business.
Data processed in this case are: name, e-mail, telephone, address, personal data included in education and training details, professional qualifications, health, signature, employee ID number as well as any other personal data provided that are necessary for fulfilling the above mentioned purpose.
For concluding or executing contractual relationships with ROMGAZ's business partners, as manager or representative of the business partner, we may process your personal data, such as: name, surname, e-mail address, telephone.
This processing is based on:
- execution of a contract to which you as manager or business partner are party;
- legal obligations;
- our legitimate interest.
Candidates for ROMGAZ vacant positions:
We use personal data included in CV’s and letters of intent to evaluate the qualification of applicants for a position within the company and for traineeship and internship programs. In this case, the basis for data processing is our legitimate interest and subject to your consent.
We may use your personal data (name, surname, e-mail address or other personal data provided in the message) whenever necessary to provide answers to any requests received through contact forms on www.romgaz.ro.
This processing is based on our legitimate interest to know the person we communicate with.
We use your personal data to ensure security of our sites, goods and personnel. In this case, we base our processing of personal data on the legitimate interest of the company namely the protection of personnel, assets and premises.
Categories of data processed in this regard are as follows: your name, series and number of your identity card, image, signature as well as other personal data that you may provide to us and which are necessary to accomplish the above mentioned purposes.
6. To whom we share personal data?
ROMGAZ will not transmit (through sale or lease) your personal data to third parties. Only a limited number of members of our personnel have access to your personal data on a need to know basis. These employees are bound by confidentiality obligations regarding personal data. ROMGAZ employees have the right to manage personal data only based on the instructions of the executive management in relation to work responsibilities.
Your personal data may also be disclosed to third parties, such as:
- Business partners, suppliers and subcontractors in order to carry out all contracts concluded with you for the supply of products and services requested by you;
- Service suppliers providing ROMGAZ with administrative, professional and technical support, IT, security and commercial resources;
- External consultants (lawyers, accountants, auditors), for specific purposes, when necessary.
ROMGAZ carries out an adequate assessment prior to selecting third parties and requires such service providers to maintain adequate organizational, technical and security measures in order to protect personal data and to process personal data solely pursuant to ROMGAZ instructions. Service providers shall have the right to engage subcontractors to provide services to ROMGAZ on the condition that each such subcontractor complies with the same data protection obligations as the service providers.
We will take all technical and organizational measures to ensure security, protection against destruction, modification, disclosure of or unauthorised access to personal data.
7. For how long will personal data be retained?
We will retain your personal data for the period necessary to fulfil the purposes set out in this Policy or for the period required by the national law in force, pursuant to the applicable minimum legal periods of retention and/or as long as necessary to exercise our legitimate rights (and the legitimate rights of other persons).
If you are a business partner, we will retain your personal data for the term of our contractual relationship.
If you are a candidate for one or more jobs published under the Careers section of our website www.romgaz.ro, we will retain your personal data for the entire duration of the recruiting and selection process plus a period of 3 years after the end of the recruiting process (in the event the candidate was not hired by the company).
If we process your personal data based on your consent, such personal data will be processed only for the period provided under your consent, unless you withdraw or limit your consent before expiry of such period. In these cases, we will cease processing such personal data for the relevant purposes, conditional upon any legal obligation to process such personal data and/or our need to process such personal data in order to exercise our legitimate rights (including the legitimate rights of other persons).
8. Personal data storage and transfer outside the country
www.romgaz.ro website is administered and maintained by ROMGAZ and hosted by company servers in Romania.
We will not transfer your personal data outside EEA.
9. What rights do you have?
As a data subject, “GDPR” grants you several rights including:
- right of access – entitles you to obtain the confirmation that your personal data are processed by us and, if so, the relevant details of such processing activities;
- right to rectify – entitles you to rectify your personal data if inaccurate;
- right to delete – entitles you to have your personal data erased in certain cases (for example, if data are not necessary anymore in connection with the purposes for which they were collected);
- right to restrict processing – entitles you to restrict processing of your personal data in certain cases (for example, when you challenge the accuracy of your personal data, for a period that allows us to check the accuracy);
- right to oppose – entitles you to oppose further processing of your personal data under the conditions and within the limits permitted by law;
- right of data portability – entitles you to receive your personal data that you provided to us, in a structured form, commonly used and which can be automatically read or to send such data to another data controller.
Please note that the above mentioned rights may be limited in certain circumstances and are subject to the applicable laws and regulations on protection of personal data. For example, the right to oppose processing of your personal data can be limited if we can demonstrate that we have convincing legitimate reasons to process your personal data which prevail over your interests. You should be able to provide proof of your identity and other details which help us answer your request.
In order to exercise one or more of these rights, please contact us at firstname.lastname@example.org .
Moreover, you have the right to submit a complaint with the National Supervisory Authority for Personal Data Processing.
If you have questions or ambiguities regarding processing of your personal data by ROMGAZ or if you wish to exercise one or more of your rights, please contact us at the following e-mail address email@example.com.
We kindly ask you not to share sensitive personal data (e.g. information on race or ethnicity, political opinion, religion or otherwise, health or trade union membership), social security numbers when you contact us.