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PERSONAL DATA PROTECTION POLICY - PPD
The new European Union law on the protection of personal data, GDPR (“General Data Protection Regulation”)
entered into force on May 25, 2016, but will begin to take effect as of May 25, 2018. This law is the biggest
change in personal data protection over the last 20 years and has objectives that go far beyond the mere
protection of the private space.
The protection of your personal data is important to us, therefore we pay special attention to protecting the
privacy of users visiting the firecredit.eu site, people who submit us personal data to process a request, and those
whose personal data have been provided to us by a third party or accessed from another source in accordance
with Regulation (EU) 2016/679 of the European Parliament and Council from April 27, 2016 on the protection of
individuals with regard to the processing of personal data and on the free movement of such data (hereinafter
referred to as “GDPR”).
Please pay special attention to reading the following Policy (hereinafter referred to as "PPD") to understand how
your information will be treated ("personal data”).
PPD explains the practices of Fire Credit S.R.L. (hereinafter referred to as “Fire Credit”), regarding the application
of GDPR provisions, as well as the rights you receive in relation to how your information is processed by Fire
Credit.
The processing of personal data by Fire Credit will always be done in accordance with the GDPR provisions as well
as with the personal data protection regulations specific to each country in which Credit Credit operates.
By PPD, Fire Credit wishes to inform the data subjects about the nature of the personal data we collect and
process, as well as about the purposes of the processing. In addition, the data subjects are informed via the PPD
about their rights.
WHO ARE WE?
We are Fire Credit S.R.L., a company with its registered office in Iași, str. Sf. Lazăr no. 66A, 8
th floor, offices
1,2,4,5,6, Iași county, Trade Register number J22/1955/2011 and unique registration code 29273858. Our main
field of activity, "Activities of collection agencies and credit bureaus", according to NACE code 8291, and our legal
representatives are the administrators: BICCHIERI ANTONINO, SCRIPNICIUC MARIUS DUMITRU and NISTOR
FLORIN.
OFFICER IN CHARGE OF PERSONAL DATA PROTECTION (DPO)
Fire Credit, as operator, appointed Mrs. Nuță Adela, as officer in charge of personal data protection (hereinafter
referred to as “DPO”), having the obligation to verify the compliance with GDPR provisions in the data processing
operations performed by the operator and to represent the operator in relation to the data subjects and the
Supervisory Authority.
The Persons concerned have the opportunity to address the DPO directly at any time on any matter related to this
PPD using the contact details below:
DPO nsmr: Nuță Adela
DPO e-mail: adela.nuta@jantea-law.ro
Tel. DPO: 0766753560
DPO mailing address: Bucharest, district 1, 9 Transilvaniei street.
WHAT ARE PERSONAL DATA?
"Personal data" means any piece of information or information that can identify you directly (for example, your
name) or indirectly (for example, by pseudonymous data such as a unique identifier). This means that personal
information includes things such as the email address, home, mobile phone, username, profile photos, personal
preferences and shopping habits, user-generated content, financial information, and financial status information.
This could include unique numeric identifiers, such as your computer's IP address or MAC address of your mobile
device, as well as cookies.
WHAT DOES PERSONAL DATA PROCESSING MEAN?
“Processing” means any operation or set of operations performed on personal data or on sets of personal data
with or without the use of automated means such as collecting, recording, organizing, structuring, storing,
adapting or modifying, extracting, consultation, use, disclosure by transmission, dissemination or otherwise
making available, alignment or combination, restriction, erasure or destruction.
WHICH OF YOUR PERSONAL DATA DO WE PROCESS?
Your personal data to be processed is as follows: surname, name, e-mail address, phone number, employer,
position, department, personal data contained in the Curriculum Vitae document.
PERSONAL DATA OPERATOR
The personal data operator (hereinafter referred to as the “operator”) is Fire Credit.
PRINCIPLES ON DATA PROCESSING
Fire Credit undertakes to comply with the principles of personal data protection (hereinafter referred to as the
"Principles") set out in the GDPR to ensure that all data are:
1. Processed in a fair, legal and transparent manner;
2. Collected for specified, explicit and legitimate purposes;
3. Adequate, relevant and limited in relation to the purposes for which they are processed;
4. Correct and updated;
5. Kept in a form which makes it impossible to identify the data subjects longer than is necessary in relation to
the purpose of the processing;
6. Processed in accordance with the rights of the data subject in a manner that ensures adequate processing
security so that the data are complete, confidential and available.
GROUNDS AND PURPOSES OF PERSONAL DATA PROCESSING
1. For the purpose of concluding and executing contracts - According to art. 6 par. 1 lit. b) from GDPR, personal
data may be processed for the purpose of concluding or executing the contract. In order to be able to offer
you our products and services, we need to process the personal data that you hold.
2. For the purpose of fulfilling legal obligations - According to art. 6 par. 1 lit. c) GDPR, personal data for the
purpose of fulfilling legal obligations may be processed. We request a series of personal data, including, in
some cases, the Personal Code, in order to fulfill our obligations imposed by tax authorities on invoicing and
reporting to tax authorities.
3. For marketing purposes - According to art. 6 par. 1 lit. a) GDPR, personal data may be processed if the data
subject has given his/her consent to the processing of his or her personal data for one or more specific
purposes. Thus, in some situations, your personal data will be used to send you marketing messages, offers,
news, future campaigns, invitations to various events.
CONTACT FORM PROCESSING
Fire Credit will use the information you provide in the appropriate contact section existing on the site solely for the
purpose of processing your request.
By providing any personal data through the Fire Credit site, you understand and agree that your data will be
processed in accordance with the PPD provisions of Fire Credit.
Please be advised that in order to be able to process your requests submitted under the site's contact section, it is
possible, under certain circumstances, to disclose your data to partners with which Fire Credit collaborates and/or
to other third-party service providers of Fire Credit.
However, Fire Credit has adopted appropriate technical and organizational measures to ensure data transfer
security, as well as the processing, under GDPR requirements, of your data by the abovementioned entities.
Fire Credit undertakes not to process personal data provided for any purpose other than that for which it was
transmitted, except in cases where you grant your express consent to use it for other purposes.
It is also possible for Fire Credit to have access to other personal data by establishing a connection with Fire
Credit by processing the data communicated via phone conversations, e-mail conversations, presentations at our
premises to obtain information, etc.
By contacting Fire Credit in any of the above ways or any other method that implies a mediated or direct
communication between you and Fire Credit, you understand and agree that your data will be processed in
accordance with the PPD provisions of Fire Credit.
RECRUITMENT
If you apply for a position within Fire Credit published in the "Work with Us" section of this site, your Curriculum
Vitae or other information you provide will only be used to process your request and for the management of the
recruitment process. Following the voluntary submission of the Curriculum Vitae through the Fire Credit site, Fire
Credit does not verify the accuracy of the content, will not automatically accept the application or make a job
offer.
The Fire Credit document you send will only be used for the internal selection process of the candidates. We will
not voluntarily distribute, rent or sell your data outside of Fire Credit, unless we are required to share your
information with third parties providing services on our behalf.
PROCESSING OF OTHER DATA YOU PROVIDE TO US
Fire Credit will use the information you provide through direct or indirect transmission or public disclosure in
electronic or material form solely for the purpose of processing your request or contacting you or sending you
offers, news, future campaigns, invitations to events held in connection with Fire Credit, only when we have your
express consent.
By providing any personal data in the ways described above you understand and agree that your data will be
processed in accordance with the PPD provisions of Fire Credit.
Please be advised that in order to be able to process your requests, it is possible that under certain circumstances
we will be required to disclose your data to partners with which Fire Credit collaborates and/or to other third-party
service providers of Fire Credit.
DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
Personal Data processed by Fire Credit may be disclosed and/or transferred to third parties only in the case of
your express consent to do so, unless there is a legal/contractual obligation for Fire Credit to proceed in this
manner.
Please be advised that it is possible under certain circumstances to disclose your personal data to partners with
whom Fire Credit collaborates and/or to other third-party service providers of Fire Credit.
PROCESSING OF DATA BY THIRD PARTIES, OTHER SITES AND SPONSORS
The Fire Credit site may contain, at some point, access links to other sites whose data processing policies may be
different from those of Fire Credit.
Please consider and consult the personal data protection policies of other sites, Fire Credit will not take
responsibility for the information sent or collected by these third parties.
AUTOMATED DATA PROCESSING. COOKIES
The Fire Credit site uses cookies. In this regard, you can review our Cookie Policy, available on the site, and
exercise the right to disable Cookies, as outlined below.
DATA STORAGE PERIOD
Fire Credit may keep the processed data for different periods of time deemed reasonable for the purposes
indicated above. We only retain your data for the period necessary to achieve the purpose for which we hold the
data, to meet your needs or to fulfill our obligations under the law.
In order to know how long your data can be stored, we use the following criteria:
1. When you purchase products and services, we retain your personal data for the duration of our contractual
relationship and for a later term if there exists a legal obligation for Fire Credit to store such data;
2. If you participate in a promotional offer, we retain your personal information during the promotional offer;
3. If you contact us for an inquiry, we keep your personal data for as long as your inquiries are processed, but no
more than 2 years after the last mail sent;
4. If you create an account, we retain your personal data until you ask us to delete it or after a period of
inactivity (without an active interaction with us). In this regard, please note that the data processed for this
purpose will be deleted 2 years after the last user account interaction (for example, login to your account);
5. If you have given your consent for marketing, we retain your personal data until you unsubscribe or ask us to
delete it or after a period of inactivity (without active interaction with our marks) defined in accordance with
local regulations and guidelines. In this regard, please note that the data stored in our databases for the
purpose of direct marketing communications are deleted from the database records after 2 years from the last
interaction with you;
6. If the cookies are stored on your computer, we keep them for as long as they are needed to reach their goals
(for example, during a session for shopping cart cookies or session IDs cookies) and for a period defined in
accordance with local regulations and guidelines. In this regard, we mention that the data processed through
the cookies used to provide online behavioral advertising, in order to personalize our services for you, and to
allow our content to be distributed to social sites (distribution buttons to display the site) will be retained for a
maximum of 2 years from their collection, based on your consent.
THE RIGHTS OF THE DATA SUBJECTS
Under the GDPR, you have a series of rights with respect to the personal data that Fire Credit processes:
1. The right of access to processed data - You have the right to access the personal data we hold. The
first information will be provided without any charge. If you will need copies of the information already
provided, we may charge a reasonable fee, taking into account the administrative costs of providing the
information. The manifestly unreasonable, excessive or repeated requests may not be answered.
2. The right to modify data - You may request that your data be modified if inaccurate or obsolete and/or
filled in if incomplete. If you have an account, it can be easier to correct your own data using the "My
Account" feature.
3. The right to delete data lor (“the right to be forgotten”) - In some 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
forced to keep your data for legal reasons.
4. The right to restrict the processing - You may request that you limit the processing of your data. This
means that your data processing is limited so we can keep the data, but not use or process it. This right
applies in the specific circumstances provided for in the General Data Protection Regulation, ie:
- the accuracy of the data is contested by the data subject (ie you) for a period that allows the Operator (ie
Fire Credit) to verify the accuracy of the data;
- the processing is illegal and the data subject (ie you) opposes the deletion of the data and requests the
restriction of their use;
- the operator (ie, Fire Credit) no longer needs data for processing, but they are required by the data
subject (ie you) for the establishment, exercise or defense of legal claims;
- the data subject (ie you) raised objections against the processing based on legitimate reasons on the part
of the Operator (in this case Fire Credit) in order to verify that the Operator's legitimate reasons (Fire
Credit) exceed those of the data subject (ie you).
5. The right to data portability - You may move, copy or transfer the data you are interested in from our
database to another. This applies only to the data you have provided when the processing is based on your
consent or contract and is implemented by automated means.
6. The right of opposition - You may oppose at any time the processing of your data when such processing
is based on a legitimate interest.
7. The right to withdraw consent at any time - You may withdraw your consent to the processing of your
data when such processing is based on consent. The withdrawal of the consent does not affect the
lawfulness of processing on the basis of consent prior to its withdrawal.
8. The right to file a complaint with the competent supervisory authority - You have the right to
complain to the data protection authority of your country of residence or domicile to challenge the data
protection practices offered by Fire Credit.
9. The right to oppose the processing of your data for direct marketing purposes - You may
unsubscribe from or opt out of our direct marketing communication at any time. It's easier to do so by
clicking the "unsubscribe" link in any email or communication we send you.
10. The right to oppose the processing of your data by us when conducting actions in the public
interest or in our legitimate interests or that of a third party - You may at any time oppose the
processing of your data when such processing is based on a legitimate interest.
11. The right to disable cookies - you have the right to disable cookies. Settings in Internet browsers are
typically programmed by default to accept cookies, but you can easily adjust them by changing your
browser settings. Many cookies are used to increase the usability or functionality of web sites/applications;
therefore, disabling cookies may prevent you from using certain parts of our sites or apps, as detailed in the
relevant Cookie table. If you want to restrict or block all cookies set up by our websites/apps (which may
prevent you from using certain parts of the site) or any other sites/apps, you can do so through your
browser settings. The Help feature in your browser will tell you how. For more information, see the
following links: http://www.aboutcookies.org/;
You may exercise any of these rights with respect to the personal data that Fire Credit processes by submitting a
simple request to the Fire Credit DPO. In such a situation, it is very possible to request proof of your identity.
LEGAL REQUESTS
We access, keep and provide your information to regulatory authorities, law enforcement or other entities:
1. In response to a legal request, when we believe in good faith that the law requires us to do so. We may also
respond to legal claims when we consider in good faith that the response required by the laws of that
jurisdiction affects users in that jurisdiction and complies with internationally recognized standards.
2. When we believe in good faith that it is necessary to: detect, prevent and respond to acts of fraud,
unauthorized use of any material belonging to us, violations of our terms or policies or other harmful or
unlawful activities, to protect us (including our rights, property or materials), yourself and others, including
within investigations or inquiries by regulatory authorities, or to prevent imminent death or injury. For
example, if relevant, we provide information to and receive third-party partner information about the reliability
of your account to prevent fraud, abuse and other harmful activities inside and outside of our materials.
The information we receive about you may be accessed and stored for a longer period of time when you are
subject to a legal, justice matter, governmental inquiry or investigation into possible violations of our terms or
policies, or in other cases to prevent damage.
RELATIONS WITH OTHER OPERATORS
Depending on the context, we may find ourselves in the situation of the absolute need to provide information at a
higher level, both globally and internally or externally, to our partners and to those with whom we transfer GDPR
data in the virtue of providing the most professional services possible. Information controlled by Fire Credit may
be transferred, transmitted or stored and processed in the EU or in countries other than the country where you
live for the purposes described in this policy. These data transfers are necessary to deliver the highest level of
service and to continue to provide you with our best professional content. We use standard contractual clauses
approved by the European Commission, and we rely on the appropriateness of the European Commission's
decisions concerning certain countries, as the case may be, for the transfers of EEA data to the United States and
other countries.
PROCESSING SECURITY
Fire Credit has adopted technical and organizational data processing measures, updated in accordance with GDPR
requirements, to protect your personal data against any unauthorized access, misuse or disclosure, unauthorized
modification, accidental destruction or loss. All Fire Credit employees and collaborators, as well as any third parties
acting in the name and on behalf of Fire Credit, are required to respect the confidentiality of your information and
the GDPR requirements, in accordance with the PPD provisions.
DISCLAIMER
The Fire Credit site may contain links to other sites and/or other web pages that are not the property of Fire
Credit. Fire Credit assumes no responsibility for the content of these sites and therefore cannot be held
responsible for the content, advertising, goods, services, software, information or other materials available on or
through these sites. Fire Credit will not be responsible for the loss of personal data, any adverse effects on the
visitors' personal data or other moral and/or patrimonial damage caused by the access to those sites.
UPDATING THE PERSONAL DATA PROTECTION AND PROCESSING POLICY
Please note that this Policy may be subject to periodic content changes by updating the Fire Credit site.
How will we let you know about the changes made to this Policy?
We will notify you before making any changes to this Policy and will give you the opportunity to review the revised
PPD before choosing to continue using our materials.
Please do not continue to use the Fire Credit site if you do not agree to such changes. We also recommend that
you check this page for any updates.
The PPD terms are interpreted according to the applicable legislation.
CONTACT
If you have any questions or concerns about how we treat and use your personal data or wish to exercise any of
your rights, please contact us by accessing our DPO's contact details.

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