POLITICS

ON THE PROCESSING OF PERSONAL DATA

Respecting your privacy is one of our fundamental commitments and that is why we pay the utmost attention to the processing of your personal data in accordance with applicable law.

HEUZA ADVERTISSIMO S.R.L., having its registered office in Bucharest, Sector 3, registered at the Trade Register Office under no. J40/2323/2021 ("HEUZA ADVERTISSIMO S.R.L.", "we", "us") processes, as a controller, your personal data ("Personal Data"). The purpose of this information notice ("Policy") is to detail how HEUZA ADVERTISSIMO S.R.L. processes your Personal Data.

1. THE PERSONAL DATA PROCESSED, THE PURPOSES OF PROCESSING AND THE GROUNDS FOR PROCESSING

Data will be processed on the basis of the performance of a contract, the consent of the data subject or the legitimate interest of the company.

1. Contact user

Personal data processed: name, surname, e-mail address, telephone number.

These data are the usual ones in the case of any commercial discussion between representatives of companies, partnership, purchase of services of Heuza Advertissimo SRL, information on the estimated cost of them and so on

1. Marketing and Analysis
   1. Marketing

Personal data processed: name, surname, e-mail address.

The data is used to subscribe to the Heuza Newsletter service, sent by e-mail. Any marketing message from us is preceded by your consent to receive such messages: newsletter, promotions, offers.

1. Analysis

Processed personal data: Personal data such as name and surname are not collected, the applications store and process only actions taken on the heuza.ro website: duration of a visit, how many and which pages were visited, ip.

Apart from the cookies that are mandatory for the proper functioning of the site, all the others are used exclusively by expressing your consent: either by clicking on the "Accept All" button or by clicking on the "Cookies Settings" button, followed by managing the settings according to your own free choice.

1. Dispute resolution
   1. Litigation

Personal data processed: name, surname, home address.

2. PROVISION OF PERSONAL DATA

You may refuse to provide certain Personal Data but, in such a case, you may not be able to benefit from certain services specific to the relationship described in this Policy.

3. ABOUT THE LEGAL BASES

The legal basis for processing differs depending on the concrete situation and the Personal Data processed.

Where we will process your Personal Data on the basis of consent, we will seek your free, informed, specific and unambiguous consent to that processing. By expressing your consent, you agree that we may collect, use, disclose, process and transfer Personal Data in accordance with this Policy.

4. SOURCE OF PERSONAL DATA

The source of Personal Data is: the user of Heuza Advertissimo online or offline services

5. AUTOMATIC PROCESSING OF PERSONAL DATA

Your personal data will not be processed for the purpose of generating decisions based solely on automated processing that would produce legal effects on you or significantly affect you within the meaning of Article 22 para. (1) of the GDPR.

6. PROCESSING DURATION

The duration of processing of Personal Data differs depending on the specific processing operation:

In certain circumstances, we may retain Personal Data for longer periods of time in order to have an accurate record of your dealings with us in the event of any complaints or if we reasonably believe that there is a prospect of litigation.

7. TRANSFER OF PERSONAL DATA

We may transfer Personal Data, to the extent necessary, to the following categories of recipients: IT service providers, marketing service providers, state authorities.

These recipients may be located in the European Union and/or the European Economic Area, as well as outside the European Union and/or the European Economic Area, including in countries that are not recognized as providing an adequate level of protection, in which case the transfer of Personal Data will only be made if there are adequate safeguards in place in accordance with applicable law (such as standard contractual clauses issued by the European Commission). You may request a list of recipients in third countries, as well as a copy of the agreed provisions ensuring an adequate level of protection of Personal Data.

Service providers include Google Workspace webmail application, Google Analytics (for statistics), Facebook, Instagram Ads (for advertising), Google Adwords (for advertising), Youtube (video broadcasting and advertising) and the inbound marketing platform Hubspot.

We believe, based on publicly known information, that all of them have put in place laborious and verified procedures in order to be able to process the collected data securely. We note that we do not collect, process or provide sensitive data to internal or external third parties with whom we have a contractual relationship for purposes that serve our legitimate or legal interest.

8. SECURITY OF PERSONAL DATA

The security of your Personal Data is important to us. Therefore, your Personal Data will be processed by applying reasonable technical and organizational measures to protect it, such as limiting access to Personal Data, encryption or anonymization of Personal Data, storage on secure media. However, despite our best efforts, we cannot always guarantee the effectiveness of the security measures put in place, and therefore cannot guarantee the security of Personal Data at all times

9. RIGHTS REGARDING THE PROCESSING OF PERSONAL DATA

Right of access: you have the right to obtain confirmation from us that your Personal Data is being processed by us, as well as information on the specifics of the processing such as: the purpose, the categories of Personal Data processed, the recipients of the Personal Data, the period for which it is kept, the source of the Personal Data, whether we transfer it abroad and how we protect it, your rights, the right to lodge a complaint with the supervisory authority.

Right to rectification: You have the possibility to request rectification of your Personal Data, provided that the applicable legal requirements are complied with. In the event of errors, after notification, we will correct your Personal Data immediately.

Right to erasure: In certain cases, you have the possibility to request erasure of Personal Data, such as when: (i) it is no longer necessary for the purposes for which we have collected and processed it; (ii) you have withdrawn your consent to the processing of Personal Data and we can no longer process Personal Data on other lawful grounds; (iii) Personal Data is processed contrary to the law; (iv) you assert a legal right to object. We are under no obligation to comply with your request for erasure where the processing of Personal Data is necessary for compliance with a legal obligation, or for the establishment, exercise or defense of legal claims. There are also other circumstances in which we are not obliged to comply with your request for erasure of Personal Data.

Restriction of processing: You may ask us to restrict the processing of your Personal Data in the following situations: (i) if you contest the accuracy of the Personal Data, for a period that allows us to verify the accuracy of the Personal Data in question; (ii) if the processing is unlawful, and you object to the erasure of the Personal Data, requesting instead the restriction of its use; (iii) where we no longer need the Personal Data for the purpose of the processing, but you request it from us for legal action; (iv) where you have objected to the processing, for the period of time during which it is verified that our legitimate rights as controller prevail over those of the data subject. We may continue to use Personal Data following a restriction request, if: (i) we have your consent; (ii) to establish, exercise or defend a legal claim; or (iii) to protect the rights of another natural or legal person.

Right to data portability: to the extent that Personal Data are processed on the basis of your consent or for the performance of the contract and the processing is carried out by automated means, you have the right to have your Personal Data provided to you in a structured, commonly used and machine-readable format and you have the right to transmit these Personal Data to another controller. This right does not adversely affect the rights and freedoms of others.

Right to object: In certain situations, such as when we process your Personal Data on the basis of a legitimate interest, you have the right to object to the processing of your Personal Data by us. In the event of unjustified opposition, HEUZA ADVERTISSIMO S.R.L. is entitled to continue to process the Personal Data. You may also object to the processing of your Personal Data for the purpose of sending commercial messages.

Withdrawal of consent: To the extent that we process your Personal Data on the basis of your consent, you may withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to the withdrawal of consent.

Automated individual decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you to a significant extent. This right does not apply if the decision: (i) is necessary for the conclusion or performance of a contract between you and us; (ii) is authorized by law that also provides adequate safeguards for your rights and freedoms; (iii) is based on your explicit consent.

Right to complain to the supervisory authority: You have the right to lodge a complaint before the National Authority for the Supervision of Personal Data Processing ("ANSPDCP") about any violation of your rights regarding the processing of your Personal Data. The contact details of the ANSPDCP are: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336 Bucharest, Romania; e-mail: .anspdcp@dataprotection.ro

To exercise the above mentioned rights, please contact us by e-mail office@heuza.eu

10. CONTACT

If you have any questions or concerns about this Policy or its implementation, you can contact us by email office@heuza.eu