1 INTRODUCTION
1.1 Important information and who we are
Welcome to Radburg Centre Privacy and Data Protection Policy (“Privacy Policy”).
At Radburg Centre (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the law and guidelines of the EU General Data Protection Regulation (“GDPR”).
This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.
1.2 Who is Your Data Controller
Radburg Centre is your Data Controller and is responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email at sales@radburg.ro or sent in a letter to 727296, County Suceava, Romania.
2 LEGAL BASES FOR DATA COLLECTION
2.1 Types of Data / Privacy Policy Scope
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
Profile/Identity Data: This is data relating to your first name and last name.
Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
We also collect, use and share Aggregated Data such as we (Radburg Centre) collect aggregated data in the form of our lead data. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used by this Privacy Policy.
We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may research your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
2.2 The Legal Basis for Collecting That Data
There are several justifiable reasons under the GDPR that allow the collection and processing of Personal Data. The main avenues we rely on are:
“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
“Contractual Obligations”: We may require certain information from you to fulfil our contractual obligations and provide you with the promised service.
“Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights,
freedom or interests. Examples could be your address so that we know where to deliver something to, or your name so that we have a record of who to contact moving forwards.
3 HOW WE USE YOUR DATA
3.1 Our Uses
We will only use your Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.
3.2 Marketing and Content Updates
You will receive marketing and new content communications from us if you have created an account and chosen to opt in to receiving those communications. From time to time, we may make suggestions and recommendations to you about goods or services that may be of interest to you.
3.3 Change of Purpose
We will only use your Data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
Please note that we may process your Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
4.1 How Does Radburg Centre Protect Customers’ Personal Data?
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Radburg Centre to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
4.2 Opting Out Of Marketing Promotions
You can ask us to stop sending you marketing messages at any time by contacting us at any time.
Where you opt-out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
4.3 How to Request your Data and the Process for obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information about your request to speed up our response.
5 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated 29 September 2021. By using Radburg Centre, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Radburg Centre will constitute your express acceptance of any modifications to this Privacy Policy.
6 Cookie usage and Automatic Data Collection Tools
We also collect information, via cookies, web beacons, pixels, tags or other tracking technologies, such as your Internet Service Provider and IP address, the date and time you access our website, the pages you accessed while visiting our website, and the Internet address from which you accessed our website. Some cookies exist only during a single session and some are persistent over multiple sessions over time. We use these technologies to remember user preferences, maximize the performance of our website and services, provide you with offers that may be of interest to you, measure the effectiveness of our email campaigns and personalize online content. These cookies and other technologies may be used to track you across devices.
To provide you with a more relevant and interesting experience, we may work with third-party companies to display ads or customize the content on the website and other websites. These companies may use cookies and similar tracking technologies as described in this Statement to gather information about your visits to the website, as well as your visits elsewhere on the Internet. These companies use this information to provide you with more relevant advertising known as interest-based advertising. The Digital Advertising Alliance (“DAA”) offers a choice mechanism concerning certain types of data collection and use by third parties available at www.aboutads.info. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives.
Some browsers have incorporated Do Not Track (“DNT”) preferences. Most of these features, when turned on, send signals to the website you are visiting that you do not wish to have information about your online searching and browsing activities collected and used. As there is not yet a common agreement about how to interpret DNT signals, we do not honour DNT signals from website browsers at this time. However, you may refuse or delete cookies. If you refuse or delete cookies, some of our website functionality may be impaired. If you change computers, devices, or browsers, or use multiple computers, devices, or browsers, and delete your cookies, you may need to repeat this process for each computer, device, or browser.
7 INTERPRETATION
All uses of the word “including” mean “including but not limited to” and the enumerated examples are not intended to in any way limit the term, which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).
Our staff are not authorized to contract on behalf of Radburg Centre, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Radburg Centre address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Radburg Centre rights, the email content will be read down to grant precedence to the latter.