Privacy Policy

Generalități

Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, in this document – GDPR, Regulation or RGPD) was adopted by the European Parliament and the Council of the European Union on April 27, 2016, its provisions being directly applicable starting from May 25, 2018. This Regulation expressly repeals Directive 95/46/CE, thus replacing the provisions of Law no. 677/2001 (currently repealed).

The regulation is directly applicable in all member states, protecting the rights of all natural persons located on the territory of the European Union. From a material point of view, the Regulation applies to all operators who process personal data. The Regulation does not apply to the processing of personal data concerning legal entities and, in particular, enterprises with legal personality, including the name and type of legal entity and the contact details of the legal entity.

Personal data is defined as any information regarding an identified or identifiable natural person (“data subject”); an identifiable natural person is a person 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 one or more specific elements, specific to his physical, physiological, genetic, psychological, economic, cultural or social identity.

The processing of personal data involves any operation or set of operations performed on data or sets of personal data, with or without the use of automated means, such as collection, registration, organization, structuring, storage, adaptation or modification, extraction , consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, deletion or destruction.

Identity of the operator

Taking into account article 4 point 7 of the Regulation, which defines the notion of “operator” as the natural or legal person, public authority, agency or other body that, alone or together with others, establishes the purposes and means of personal data processing , the operator that processes personal data through this website is SC IMCREATIVE SRL, based in Str. Carpati 24 Bl. O1 Sc. C Et. 1 Ap. 45 Code 731209, Loc. Bârlad, registered at the Trade Registry Office J37/264/2020, having CUI 42506829, with contact details [email protected].

Collection of personal data

What personal data is collected

The operator of this website collects, stores and processes the following personal data of / about you:

Name, first name
Contact details (such as email, phone, fax)
IP
Date and time of access;
The name and URL of the accessed file;
The website from which www.imcreative.ro is accessed; The browser used, the operating system of your computer and the name of the access provider

Obtaining Consent

Generalități

In order for the processing of personal data to be legal, the GDPR requires that it be carried out on the basis of a legitimate reason, such as the execution or conclusion of a contract, the fulfillment of a legal obligation, or on the basis of the valid consent expressed by the data subject in advance. In the latter case, the operator is required to be able to prove that the person in question has given his consent for the respective processing. The consent expressed under the rule of Directive 95/46/EC remains valid if it meets the conditions provided by the GDPR.

Consent must be given by a statement or by an unequivocal action that constitutes a freely expressed, specific, informed and clear manifestation of the data subject’s consent to the processing of his personal data. If the data subject’s consent is given in the context of a statement, in electronic form or in writing, which also relates to other matters, the request for consent must be presented in a form that clearly differentiates it from the other matters, can be done even by checking a box. In order for the processing of personal data to be legal, the GDPR requires that it be carried out on the basis of a legitimate reason, such as the execution or conclusion of a contract, the fulfillment of a legal obligation, or on the basis of the valid consent expressed by the data subject in advance. In the latter case, the operator is required to be able to prove that the person in question has given his consent for the respective processing. The consent expressed under the rule of Directive 95/46/EC remains valid if it meets the conditions provided by the GDPR.

Cookies

Cookies are used on this site. They do not harm your computer and do not contain viruses, but have the role of contributing to an easier, more efficient and safer use of the site. They are small text files that are saved on your computer and are saved by the browser you use.

Many of the cookies used are called “session cookies”, which are automatically deleted after visiting this site. Others remain in your computer’s memory until you delete them, making it possible for your browser to recognize them on a subsequent visit.

You can configure your browser to inform you about the use of cookies so that you can decide on a case-by-case basis whether to accept or reject a cookie. Alternatively, your browser can be configured to automatically accept cookies under certain conditions or to always reject them, or to automatically delete cookies when you close your browser. Disabling cookies may limit the functionality of this website.

Cookies that are necessary to enable electronic communications or to provide certain functions that you want to use (such as the shopping cart) are stored in accordance with the provisions of art. 6 paragraph 1 lit. f) of the GDPR, according to which the processing is legal only if and to the extent it is necessary for the purposes of the legitimate interests pursued by the operator or a third party. Therefore, the operator of this website has a legitimate interest in storing certain cookies, to ensure an optimization without technical errors. Other cookies (such as, for example, those used to analyze your browsing behavior) are also stored and will be treated separately in this document.

Formular de contact

If you send us questions via the contact form, we will collect the data entered in the form, including the contact data you provide, in order to answer your and others’ subsequent questions. We do not transmit this information without your permission. Therefore, we will process all the data you enter in the contact form only with your consent [in accordance with the provisions of art. 6 para. 1 lit. a) GDPR1]. You can revoke your consent at any time, an informal email to this effect is sufficient. Data processed before receiving your request may be processed lawfully. We will keep the data you provide on the contact form until:

request data deletion;
revoke consent to their storage or if
the purpose for storing it is no longer valid.

Any mandatory legal provisions, in particular those relating to mandatory data retention periods, are not affected by the above.

Contact by email, phone or fax

If you contact us by e-mail, telephone or fax, your request, including all the personal data you will provide, will be stored and processed by us for the purpose of solving your request, based on your consent.

Therefore, we will process all the data you provide based on the following legal provisions contained in the GDPR, respectively:

only with your consent – in accordance with the provisions of art. 6 para. 1 lit. a) GDPR
for the execution of a contract or in the pre-contractual stage – in accordance with the provisions of art. 6 para. 1 lit. b) GDPR
for the fulfillment of the purpose and the legitimate interest pursued by us, respectively that of efficient processing of the requests sent by you – in accordance with the provisions of art. 6 para. 1 lit. f) GDPR.

We will keep the data you provide in this way until:

request data deletion;
revoke consent to their storage or if
the purpose for its storage is no longer valid, in all situations except for the mandatory data retention periods.

Purpose of processing the collected data

Part of the data collected on this site is used to:

Optimum operation and optimization of this site (statistical and analytical) – We constantly want to give you the best experience on our site, which is why we may collect and use certain information related to the degree of satisfaction you – you had while browsing this site, we can invite you to fill in questionnaires of suggestions or the like.
Advertising and promotion activities in the online environment. You can ask us at any time, through the means described in this document, to stop processing your personal data for marketing purposes, and we will comply with your request as soon as possible.
Periodic user information – We want to keep you informed about our offers. In this regard, we may send you any type of message containing general and topical information, information regarding offers or promotions, as well as other commercial communications such as market research and opinion polls. For communications of this type, we have as a basis the consent previously obtained from you. You can change your mind and withdraw your consent at any time.
To defend our legitimate interests. There may be situations where we will use or share information to protect our rights and business. These may include: measures to protect the website and the user of our website from cyber attacks; measures to prevent and detect fraud attempts, including the transmission of information to the competent public authorities; measures to manage other types of risks.

The processing of personal data is carried out in accordance with the provisions of the General Regulation on Data Protection, based on both the consent of the data subject and reasons for the compliant execution of contracts or the realization of the legitimate interests of the operator (unless the interests prevail or the fundamental rights and freedoms of the data subject, which require the protection of personal data, especially when the data subject is a child).

User rights

Your rights regarding personal data and the means of exercising them are: The right to information, The right to access, The right to rectification, The right to delete data, The right to restrict processing, The right to data portability, The right to opposition, The right not to is the subject of a decision based exclusively on automatic data processing, Right to lodge a complaint and address to the courts, Right to withdraw consent.

The right to information – you can request information on the processing activities of your personal data, on the identity of the operator and its representative or on the recipients of your data;
The right of access – you can obtain from the operator a confirmation that personal data concerning you is being processed or not and, if so, access to the respective data and the following information: the purposes of the processing ; the categories of personal data concerned; recipients or categories of recipients to whom the personal data have been or will be disclosed, especially recipients from third countries or international organizations; where possible, the period for which the personal data is expected to be stored or, if this is not possible, the criteria used to establish this period; the right to request the operator to rectify or delete personal data or restrict the processing of personal data or the right to oppose the processing, etc.
The right to rectification – you can rectify inaccurate personal data or complete them;
The right to delete data – you can obtain data deletion, if their processing was not legal or in other cases provided by law;
The right to restrict processing – you can request the restriction of processing if you dispute the accuracy of the data, as well as in other cases provided by law;
The right to data portability – you can, under certain conditions, receive the personal data you have provided to us in a machine-readable format, or you can request that that data be transmitted another operator
Right to opposition – you can object, in particular, to data processing based on the legitimate interest of the operator;
The right not to be the subject of a decision based solely on automatic data processing – you can ask for and obtain human intervention regarding that processing or express your own point of view about this type of processing;
The right to file a complaint and address to the courts – you can file a complaint against the manner of personal data processing to the National Authority for the Supervision of Personal Data Processing and / or you can the address of the courts to respect your rights;
Right to withdraw consent – in cases where the processing is based on your consent, you can withdraw it at any time. The withdrawal of consent will have effects only for the future, the processing carried out prior to the withdrawal still remaining valid.

Obligations of the data controller

Găzduire/Hosting

The personal data registered on this website are stored on the servers of Hosterion SRL. The processing of the data provided and stored complies with the following legal provisions:

Art. 6 para. 1 lit. b) GDPR – data processing by Hosterion SRL takes place with the purpose of fulfilling the assumed contractual obligations;

Art. 6 para. 1 lit. f) GDPR – data processing by Hosterion SRL is carried out for the purposes of the legitimate interests pursued by the operator

Regardless of the purpose for which personal data is processed, the principles of legality, fairness and transparency are respected, but also that the personal data processed are adequate, relevant and limited to what is necessary in relation to the purposes for which are processed.

For more information on the processing of personal data by Hosterion SRL, go to https://hosterion.ro/acord-prelucrare-date

We have a contract/a convention/legal act (including the possibility of including and agreeing to the clauses of the Terms and Conditions of the website) concluded with Hetzner Online GmbH to ensure the processing of personal data in accordance with the legal regulations in the field. We comply with our obligations according to Article 28 of the GDPR, by choosing an external service provider that offers sufficient guarantees for the implementation of appropriate technical and organizational measures, so that the processing complies with the requirements set out in the regulation and ensures the protection of your rights.

Data encryption

This site uses SSL encryption for security reasons and to protect the transmission of confidential information. This encryption can be recognized by you by the lock window (“lock icon”) that appears in the browser bar and by changing the address of the respective browser from http:// to https://. Once encryption of this type is activated, the transmitted or transferred data will not be able to be seen by third parties.

According to the GDPR, if the breach of the security of personal data is likely to generate a high risk for your rights and freedoms, the operator of this website will inform you, without undue delay, about this breach, unless the supplementary provisions become applicable from the same Regulation (art. 34 paragraph 3).

Data Protection Officer

As the provisions of the GDPR are not applicable (art. 37 paragraph 1 – according to which the Operator and the person authorized by the operator appoint a data protection officer whenever:

the processing is carried out by a public authority or body, with the exception of courts acting in the exercise of their jurisdictional function;
the main activities of the operator or the person authorized by the operator consist of processing operations which, by their nature, scope and/or purposes, require a periodic and systematic monitoring of the persons concerned on a large scale; or
the main activities of the operator or the person authorized by the operator consist in the large-scale processing of special categories of data under Article 9 or of personal data relating to criminal convictions and offences, referred to in Article 10)

Regarding the obligation to appoint a Data Protection Officer, for any information or clarifications regarding the operation of this website, please contact us on the following dates:

E-mail: [email protected]
Mailing address: Str. Carpati 24 Bl. O1 Sc. C Et. 1 Ap. 45 Code 731209, Loc. Barlad

Records of processing activities

According to the GDPR Regulation, the operator or the person authorized by the operator should keep, for a reasonable period, records of the processing activities under his responsibility. Thus, these records will include all the following information:

the name and contact details of the operator
the purposes of the processing;
description of categories of data subjects and categories of personal data;
the categories of recipients to whom the personal data have been or will be disclosed;

if applicable/possible:

personal data transfers
the expected deadlines for the deletion of different categories of data
a general description of technical and organizational security measures

The obligation detailed above does not apply to an enterprise or organization with less than 250 employees, unless the processing it carries out is likely to generate a risk for the rights and freedoms of the data subjects, the processing is not occasional or the processing includes special categories of data or personal data relating to criminal convictions and offences.

Appropriate technical and organizational measures

Taking into account the current state of technology, the context and purposes of the processing, as well as the risks to the rights and freedoms of natural persons, the operator implements appropriate technical and organizational measures to ensure that, by default, only personal data that are necessary for each specific purpose of the processing.

Notification of the supervisory authority in case of breach of personal data security

According to art. 33 para. 1 of the GDPR, if there is a breach of personal data security, we will notify the National Authority for the Supervision of the Processing of Personal Data without undue delay and, if possible, within 72 hours at most from the date we became aware of it, unless it is unlikely to generate a risk for the rights and freedoms of natural persons.

Informing the data subject about the data security breach of personal data

Related to the provisions of art. 34 of the GDPR, if the breach of the security of personal data is likely to generate a high risk for the rights and freedoms of natural persons, we will inform the data subject without undue delay about this breach, except in situations where:

adequate technical and organizational safeguards have been implemented and these measures have been applied to personal data affected by the personal data breach, in particular measures to ensure that personal data becomes unintelligible to any unauthorized persons to access them, such as encryption;
subsequent measures have been taken to ensure that the high risk for the rights and freedoms of the previously mentioned data subjects is no longer likely to materialize;
would require a disproportionate effort. In this situation, a public information is carried out instead or a similar measure is taken by which the persons concerned are informed in an equally effective way.

Plugins and Tools

Google Web Fonts

This site uses Web Fonts provided by Google to ensure uniform use of fonts on this site.

When you access a page on this website, your browser will load, as a result of establishing a connection with Google’s servers, the web fonts necessary for the correct display of text and fonts. So,

The use of Google Web Fonts is based on Art. 6 para. 1 lit. f) GDPR, there is a legitimate interest in the uniform presentation of the font on this website. If there is a consent expressed in this regard (for example, consent to the archiving of cookies), the data will be processed exclusively on the basis of art. 6 para. 1 lit. a) GDPR.

For more information on how Google Web Fonts handles user data, see the Privacy Policy available at: https://policies.google.com/privacy?hl=en.

Google reCaptcha

We use “Google reCAPTCHA” (hereinafter referred to as “reCAPTCHA”) on our website. The provider is Google Inc., located at 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”). The purpose of reCAPTCHA is to determine whether data entered on our site (for example, information entered in a contact form) is provided by a human user or an automated program. To determine this, reCAPTCHA analyzes the behavior of website visitors based on a variety of parameters. This analysis is automatically triggered as soon as the website visitor enters the website. For this analysis, reCAPTCHA evaluates a variety of data (eg IP address, time the website visitor spent on the website or user-initiated cursor movements). The data tracked during these analyzes is sent to Google. reCAPTCHA analyzes run entirely in the background. Site visitors are not alerted that an analysis is in progress. The data are processed based on art. 6 para. 1 lit. f) GDPR. Website operators have a legitimate interest in protecting the operator’s web content against misuse by automated industrial espionage systems and against SPAM.

Considering the Judgment of July 16, 2020 (pronounced in case C-311/18 – Data Protection Commissioner/Facebook Ireland Limited, Maximillian Schrems), the European Court of Justice ruled that the protection offered by the EU – US Privacy Shield (Privacy Shield) does not have an appropriate character.

Therefore, the transmission of personal data to the USA and other countries outside the European Economic Area (EEA) is based on the Standard Contractual Clauses (SCC) of the European Commission. The Commission has issued two sets of Standard Contractual Clauses for data transfers from EU data controllers to data controllers established outside the EU or the European Economic Area (EEA). It also issued a set of contractual clauses for data transfers from EU operators to processors established outside the EU or EEA. For more information on these Terms, we recommend that you visit https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses -scc_ro.

Google reCatpcha uses Standard Contractual Clauses as an adequate data protection guarantee, in accordance with the level of protection guaranteed by the GDPR. For more information, see Google’s Data Privacy Statement available here: https://policies.google .com/privacy and here https://policies.google. com/terms?hl=en

Advertising and Analytics

GOOGLE ANALYTICS

This website uses the functions of the web analysis service Google Analytics. The provider of this service is Google Inc., based in the United States of America, 1600 Amphitheater Parkway, Mountain View, CA 94043.

Google Analytics uses so-called cookies. Cookies are text files that are stored on the computer and that allow an analysis of the use of the website by users. The information generated by the cookie about your use of this website is usually transferred to a Google server in the United States, where it is stored.

The storage of Google Analytics cookies and the use of this analysis tool is based on Art. 6 para. 1 lit. f) GDPR. The operator of this website has a legitimate interest in analyzing user patterns in order to optimize both the online services offered and the operator’s advertising activities.

The transfer of data to the United States of America is based on the Standard Contractual Clauses (SCC) of the European Commission.

Anonymize IP

On this site we have activated the IP anonymization function. As a result, the IP address will be abbreviated by Google in the member states of the European Union or in other states that have ratified the Convention on the European Economic Area before it is transmitted to the United States. The full IP will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google will use this information to analyze your use of this website, to generate reports on website activities and to provide other services to the operator of this website in connection with the use of the website. The IP address transmitted together with Google Analytics from your browser will not be merged with other data held by Google.

Archiving period

User- or incident-level data stored by Google related to cookies, user IDs or advertising IDs (eg DoubleClick cookies, Android advertising IDs) will be anonymized or deleted after 50 months. For details, click on the following link: https:// support.google.com/analytics/?hl=en#topic=3544906

Other advertising and analytics services

Google Analytics Remarketing

Our website uses Google Analytics Remarketing functions in combination with Google AdWords and Google DoubleClick functions, which work on all devices. The provider of these solutions is Google Inc., based in the United States of America, 1600 Amphitheater Parkway, Mountain View, CA 94043.

This function allows the connection of advertising target groups generated with Google Analytics Remarketing with the functions of Google AdWords and Google DoubleClick, which work on all devices. This makes it possible to display personalized interest-based advertising messages based on past usage and browsing patterns on a device (e.g. mobile phone) in a manner tailored to both you and any of your devices. (eg tablet or PC).

If you have given us your consent, Google will link your web browser and app progress to your Google Account for this purpose. Therefore, the same personalized advertising messages may be displayed on each device you sign in with your Google Account.

To support this feature, Google Analytics records the authenticated user IDs of temporarily logged in Google Analytics data to define and compile target groups for ads to be displayed on all devices.

You have the option to permanently object to remarketing / targeting across all devices by opting out of personalized advertising in your Google Account. To do this, follow this link: https://www.google .com/settings/ads/onweb/.

The consolidation of the data recorded in your Google account will take place exclusively on the basis of your consent, which you can give to Google and also revoke (Article 6 para. 1 lit. GDPR). Data registration processes that are not consolidated in your Google account (for example, because you do not have a Google account or you have opposed data consolidation), data registration is based on Art. 6 para. 1 lit. f) GDPR. Legitimate interest resides in the fact that the website operator has a legitimate interest in the anonymous analysis of the website visitor for advertising purposes.

The transfer of data to the United States of America is based on the Standard Contractual Clauses (SCC) of the European Commission.

For more information and pertinent data protection regulations, see Google’s Data Privacy Policies at: https://policies.google.com/technologies/ads?hl=en.

GOOGLE ADS AND GOOGLE CONVERSION TRACKING

This site uses Google Ads. Ads is an online promotional program of Google Inc. – 1600 Amphitheater Parkway, Mountain View, CA 94043, United States of America (“Google”).

In connection with Google Ads, we use a tool called Conversion Tracking. If you click on an ad published by Google, a cookie will be placed for conversion tracking purposes. Cookies are small text files that the web browser places on the user’s computer. These cookies expire after 30 days and are not used to personally identify users. If the user visits certain pages of this website and the cookie has not yet expired, Google will be able to recognize that the user has clicked on an ad and has been connected to this page.

Another cookie is assigned to each Google Ads client. These cookies cannot be tracked through Ads customer websites. The information obtained with the help of conversion cookies is used to generate conversion statistics for Ads customers who have opted in to use conversion tracking. Users receive the total number of users who clicked on their ads and were linked to a page equipped with a conversion tracking tag. However, they do not receive any information that would allow them to personally identify these users. If you do not wish to be involved, you have the option to object to this use by easily deactivating the Google conversion tracking cookie through your web browser in accordance with your user settings. If you do this, you will not be included in your Conversion Tracking statistics.

The storage of “Conversion” cookies and the use of this tracking tool are based on Art. 6 para. 1 lit. f) GDPR. The website operator has a legitimate interest in analyzing user patterns in order to optimize the operator’s web offers and advertising.

The transfer of data to the United States of America is based on the Standard Contractual Clauses (SCC) of the European Commission.

To see more detailed information about Google Ads and Google Conversion Tracking, see Google’s Data Privacy Policies at: https://policies.google.com/privacy?hl=en.

You can configure your browser in such a way that you are notified at any time when cookies are placed and you can allow cookies only in certain cases or exclude the acceptance of cookies in certain cases or for all situations and you can, of also enable the automatic deletion of cookies after closing the browser. If you disable cookies, the functions of this website may be limited.

Facebook Pixel

To measure conversion rates, our website uses the Facebook visitor activity pixel, operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”).

This tool allows the tracking of page visitors after they have been connected to the provider’s website after clicking on a Facebook ad. This makes it possible to analyze the effectiveness of Facebook ads for statistical and market research purposes and to optimize future advertising campaigns.

For the operators of this site, the data collected is anonymous. We are not in a position to reach any conclusions about the identity of the users. However, Facebook archives the information and processes it so that the connection to the respective profile is possible, and Facebook is able to use the data for its own promotional purposes in accordance with the Facebook Data Usage Policy. This allows Facebook to display ads both on and off Facebook pages. The operators of this site have no control over the use of this data.

The use of Facebook Pixel is based on Art. 6 para. 1 lit. f) GDPR. The website operator has a legitimate interest in effective advertising campaigns, which also include social media.

The transfer of data to the United States of America is based on the Standard Contractual Clauses (SCC) of the European Commission. In Facebook’s data privacy policies, you will find additional information about protecting privacy at: https: //www.facebook.com/about/privacy/.

You also have the option to disable the “Custom Audiences” remarketing feature in the Ad Settings section under https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you must first log in to Facebook.

If you do not have a Facebook account, you can opt out of user-based advertising through Facebook on the website of the Interactive Digital Advertising Alliance: http://www.youronlinechoices.com/ro/optiunile-mele.

Conclusion

This policy regarding the processing of personal data is generated in accordance with the provisions of Regulation no. 679/2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, but also with the other applicable national legal provisions.

We reserve the right to make any additions or changes to this policy. We recommend consulting the Policy regularly for correct and up-to-date information regarding the processing of personal data.

For more details regarding this GDPR Policy, as well as to exercise any of the aforementioned rights, a written notification can be sent to the contact details indicated above.

Privacy Policy

Generalități

Identity of the operator

Collection of personal data

What personal data is collected

Obtaining Consent

Generalități

Cookies

Formular de contact

Contact by email, phone or fax

User rights

Obligations of the data controller

Găzduire/Hosting

Data encryption

Data Protection Officer

Records of processing activities

Appropriate technical and organizational measures

Notification of the supervisory authority in case of breach of personal data security

Informing the data subject about the data security breach of personal data

Plugins and Tools

Google Web Fonts

Google reCaptcha

Advertising and Analytics

GOOGLE ANALYTICS

Other advertising and analytics services

Google Analytics Remarketing

GOOGLE ADS AND GOOGLE CONVERSION TRACKING

Facebook Pixel

Conclusion

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