Politica de confidentialitate

Ultima actualizare: 03 mai 2018

This privacy policy is in line with national and EU legislation, including Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, Directive 95/46 / EC “GDPR”), and applies to both the Foundation Development Management Center and CDM Consulting SRL, hereinafter CDM.

Your privacy is one of our core CDM commitments, therefore, CDM employees follow a clear procedure of not disclosing to any person, other than the participant (including the participant’s organization), personalized information about the content of the CDM delivery program discussions.

CDM processes personal data in accordance with the principles set out in the applicable data protection legislation in Romania and the EU and has developed the confidentiality policy published in this document.

Personal data is any information relating to an identified or identifiable individual and an identifiable person is that person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more physical, psychological, mental, economic, cultural or social identity.

This privacy policy concerns the personal data of our customers, business partners, other people who contact us and who visit us and their representatives, potential employees, trainees or associates, and applies to the data collected through our www.cdm.ro site with respect to all other personal data collected by e-mail or other off-line contacts.

TYPES OF SERVICES PROVIDED BY CDM

The above-mentioned CDM legal entities offer various services (hereinafter referred to as CDM services) that consist of customized programmes for the needs of a client organization such as consulting services, training, coaching sessions, mentoring sessions, team efficiency programs team building, efficient teams, etc.) and open programmes for the participation of more organizations and individuals (individuals) such as conferences, seminars, workshops, etc. These services are funded on a commercial basis, through projects funded by a donor (eg European funds), or from CDM own resources.

TYPES OF INFORMATION PROCESSED BY CDM

On the basis of the CDM services, through its employees or collaborators, CDM can request information from people with whom they come in direct contact, or service recipients, based on:

  1. Certain one-to-one or group discussions, or questionnaires applied before, during or after service delivery
  • information on certain aspects of everyday life at work
  • certain behavioral preferences specific to certain situations mentioned
  1. Presence lists at attendance sessions or participation in events organized by CDM
  • Signatures of participants, date and time of arrival and departure
  1. Other documents requested by client organizations, funders (according to their regulations) or other relevant organizations or authorities (eg ANC – National Authority of Qualifications, Labor Department)

The Privacy Policy describes:

  • the purposes for which we collect and use your personal data;
  • the reasons for processing for such purposes;
  • the categories of personal data that we collect and process;
  • the processing time of these data;
  • your rights as individuals and how you can exercise them;
  • to whom we disclose personal data collected;

 

OBJECTIVES, GROUNDS FOR PROCESSING AND PERSONAL DATA CATEGORIES

In the context of the interaction of an individual with CDM we can submit you to the activity of personal data processing. We therefore use your personal data in the following cases:

 

  1. If you are a client or potential customer of CDM:
    • Provision of CDM services

We use your personal data relevant to the preparation and provision of the requested services from us. For example, in preparing the necessary CDM-specific materials, we may rely on personal data relevant to your case. We rely in this case on your agreement to our privacy policy as a matter of personal data processing.

  • Communicating with you

We use contact information to communicate with you about your requests and any other relevant issues related to our professional / business collaboration. We also rely, in this case, on your agreement to our privacy policy as a matter of processing personal data

  • Sending informative emails

We may also use your contact information to electronically provide you  with information about CDM services or specific information in our field of activity but only if you have subscribed and therefore have agreed to us processing personal data. You can withdraw your consent at any time by expressing the option of no longer receiving emails by clicking “Unsubscribe” when you receive the e-mail or write to office@cdm.ro

The categories of data processed in the context of our relationship with you are your name, the company you are working with, your position in the company, your email address, your phone number, and other personal data you provide us directly.

  1. If you are a representative or person of contact for a client or prospective CDM customer
    • Provision of CDM services

We use your personal data relevant to the preparation and provision of required CDM services. For example, we may use your personal data to manage the relationship with the client you represent, or we may rely on your personal data in preparing the necessary materials specific to our industry. In this case, we rely on legitimate interest in providing our services according to our field of activity and managing the relationship with our customers.

  • Communicating with you

We use contact information to communicate with you about your requests and any other relevant issues related to our professional / business collaboration. We also rely in this case on your agreement to our privacy policy as a basis for personal data processing and legitimate interest in providing our services according to our business and customer relationship management.

  • Sending informative emails

We may also use your contact information to electronically provide you with information about events organized by CDM or specific information in our field of activity but only if you have subscribed and therefore have expressed your consent with view to the processing of personal data. You can withdraw your consent at any time by expressing the option of no longer receiving emails by clicking “Unsubscribe” when you receive the email or write to office@cdm.ro

The categories of data processed in the context of our relationship with you are your name, the company you are working with, your position in the company, your email address, your phone number, and other personal data you provide us directly.

  1. If you are an employee or other collaborator of a CDM client or potential client
    • Provision of CDM services

We use your personal data relevant to preparing and providing the CDM services requested from us. For example, we may use your personal data to manage the relationship with the client you represent, or we may rely on your personal data in preparing the necessary materials specific to our industry. We also rely in this case on your agreement to our privacy policy as a basis for personal data processing and legitimate interest in providing our services according to our business and customer relationship management.

  • Communicating with you

We use contact information to communicate with you about your requests and any other relevant issues related to our professional / business collaboration. We also rely, in this case, on your agreement to our privacy policy as the basis for processing your personal data.

  • Sending informative emails

We may also use your contact information to electronically provide you with information about events organized by CDM or specific information in our field of activity but only if you have subscribed and therefore have expressed your consent with view to the processing of personal data. You can withdraw your consent at any time by expressing the option of no longer receiving emails by clicking “Unsubscribe” when you receive the email or write to office@cdm.ro

The categories of data processed in the context of our relationship with you are your name, the company you are working with, your position in the company, your email address, your phone number, and other personal data you provide us directly.

  1. If you are a CDM business partner
    • Maintaining our contractual relationship with you.

We use your personal data relevant to maintaining our contractual relationship with you for the delivery of contracted CDM services. In this case, we rely on your agreement to our privacy policy as a basis for personal data processing and the legitimate interest in providing our services according to our business and relationship management with our customers.

  • Communicating with you

We use your contact information to communicate with you about any relevant aspects of our collaboration for delivering CDM services. We also rely, in this case, on your agreement to our privacy policy as the basis for processing your personal data.

  • Sending informative emails

We may also use your contact information to electronically provide you with information about events organized by CDM or specific information in our field of activity but only if you have subscribed and therefore have expressed your consent with view to the processing of personal data. You can withdraw your consent at any time by expressing the option of no longer receiving emails by clicking “Unsubscribe” when you receive the email or write to office@cdm.ro

The categories of data processed in the context of our relationship with you are your name, the company you are working with, your position in the company, your email address, your phone number, and other personal data you provide us directly.

  1. If you are a representative, person of contact, employee or other collaborator of your CDM business partner
    • Maintaining our contractual relationship with our business partner

We use your personal information relevant to maintaining our contractual relationship with you. In this case, we rely on your agreement to our privacy policy as a basis for personal data processing and the legitimate interest in providing our services according to our business and relationship management with our customers.

  • Communicating with you

We use your contact information to communicate with you about any relevant aspects of our collaboration for delivering CDM services. We also rely, in this case, on your agreement to our privacy policy as the basis for processing your personal data.

  • Sending informative emails

We may also use your contact information to electronically provide you with information about events organized by CDM or specific information in our field of activity but only if you have subscribed and therefore have expressed your consent with view to the processing of personal data. You can withdraw your consent at any time by expressing the option of no longer receiving emails by clicking “Unsubscribe” when you receive the email or write to office@cdm.ro

The categories of data processed in the context of our relationship with you are your name, the company you are working with, your position in the company, your email address, your phone number, and other personal data you provide us directly.

  1. If you are an applicant for a job or a period of internship:

We use the personal data contained in the CVs we receive to assess the qualifications of the applicants for a position within CDM, including in relation to our internship programs. In this case, we rely on your agreement to our privacy policy as the basis for processing personal data. The data categories processed in the context of our relationship with you are your first and last name, e-mail address, telephone, home address and all other personal identification data included in your resume, details regarding education and training, professional qualifications, and other personal data that you can provide directly to us.

  1. If you are a visitor to our headquarters:

We use your personal data to ensure the security of our premises, property, and staff. In this case, our data processing is based on the legitimate interest of CDM, namely the protection of these premises, assets and personnel.

The data categories processed in this context are your name and other personal data that you can provide us directly.

  1. If you are a visitor of our cdm.ro website or Linkedin pages – CDM Romania, Facebook – CDM Romania, Twitter – CDM_Romania, Youtube – CDM Romania.

We use the personal data we collect from you when you visit our website www.cdm.ro or the social networking pages mentioned above to monitor traffic and improve their content. This data collection activity is done in our legitimate interest in ensuring the proper functioning of our website and social networking sites and improving them.

The data categories processed in this context are the time and date of access, as well as the IP address from which they were accessed.

For all the above mentioned categories of individuals, we can process your data in the context of structural changes or similar transactions involving CDM entities. In this case, the reasons for processing may be the legal obligation (if CDM has a legal obligation to disclose certain personal data to public authorities), the execution of CDM’s contract in the context of such a transaction (if you are a party to such an agreement) or CDM’s legitimate interest in making the transaction in the most efficient way (in the remaining cases).

OFFERING PERSONAL DATA

When data is requested directly from you, CDM requires you to provide all of the above mentioned personal data categories, otherwise we will not be able to do our business (including, among others, provide you with our services).

If you provide the personal data of other individuals to CDM, please tell them before this disclosure how CDM intends to process personal data as described in this privacy policy.

DIVULGATION OF PERSONAL DATA

Although, as a rule, we will not disclose your personal data to third parties, we may:

  • to disclose your contact details to our CDM affiliates.
  • if it is in your interest and necessary, we will disclose the relevant personal data to the relevant authorities in the context of providing the services you have requested from us.

PROCESS DURATION

We intend to retain your personal data during both the assistance agreement and thereafter in accordance with our internal policies and legal obligations.

If data is not collected in the context of a support agreement, these data will be retained for as long as is necessary to achieve the intended purpose of collecting the data.

YOUR RIGHTS

As individuals, GDPR gives you a series of rights, including:

  • the right of access – allows you to obtain confirmation that your personal data is processed by us and, if so, the relevant details of these processing activities;
  • the right to rectification – allowing you to rectify your personal data if it is incorrect;
  • the right to delete – allowing you to obtain the deletion of your personal data in certain cases (for example, if the data are no longer necessary for the purposes for which they were collected);
  • the right to restrictions – allowing you to obtain restriction of processing of your personal data in certain cases (for example, when you dispute the accuracy of your personal data for a period that allows us to verify such accuracy);
  • the right to object – by allowing you to oppose further processing of your personal data under the conditions and limits set by law;
  • the right to data portability – by allowing you to receive the personal data about you that you have provided to us in a structured, frequently used and readable form of any type of computer.

 

We are glad to assure you of the exercise of these rights.

You may exercise the above-mentioned rights and learn more about these rights by submitting a written request to us as a Data Controller at the Center for Development in Management, or CDM Consulting SRL, Nicolae Titulescu Blvd. 34, Bl. P16, Sc. 1, Parter, Ap. 5, Cluj-Napoca, Romania, or by e-mail at office@cdm.ro.

You also have the right to file a complaint with the data protection authority.

The Center for Development in Management is registered in the personal data processing registry under no. 17229.

CDM Consulting SRL is registered in the register of personal data processing under no. 35815.

We are committed to always treating your requests with the utmost care and answering any questions you may have in the shortest possible time.

VERSIONS OF THIS CONFIDENTIALITY POLICY

This Privacy Policy is in effect starting on May 4, 2018.

This Privacy Policy may be updated from time to time. Any update will become applicable within 15 days of the publication of the new version on the CDM website.