Privacy Policy

Updated and Effective as of April 1, 2023

 

Who we are

How About Tech (further referred to as “HAT“, “we“, “us“, “our“ throughout this Privacy Policy) is a company established in Romania headquartered in Bucharest, administrated by Mr. Adrian Faur and Mrs. Mirela Neagu.

At HAT, we respect your privacy and are committed to protecting your personal data.  We take data protection very seriously and will ensure that we uphold the trust that our customers and others place in us when they provide us with their personal information.

This Privacy Policy explains how personal data is collected and used by HAT and any other entities within our group or under common ownership from time to time, and will inform you as to how we collect, use, handle and disclose your personal data, as well as telling you about your privacy rights and how the law protects you. If you need any more information about our data protection practices, please contact us using the details below.

E-mail address: [email protected] 

Telephone number:  +40 726 231 840

You have the right to make a complaint at any time to the Data Protection Officer (“DPO”), the EU supervisory authority for data protection issues (https://ec.europa.eu/consumers/odr). We would, however, appreciate the chance to deal with your concerns before you approach the ODR so please contact us in the first instance.

We keep this Privacy Policy under regular review and may amend it from time to time.  Please check back regularly to view the latest version.  Hard copies of this Privacy Policy are available from us on request.

2. WHAT PERSONAL DATA WE PROCESS AND WHERE WE OBTAIN IT FROM

This Privacy Policy has the role of informing you about how HAT processes the personal data of the following categories of data subjects:

  • Visitors and users of our web pages or our existing social networking pages;
  • Subscribers to any of our newsletters;
  • Respondents to our surveys;
  • Representatives of the companies we work with (actual or potential clients or suppliers).
  • Contact us via email, telephone, post or through social media; and/or
  • Submit an enquiry to us.

We process data that you or the devices you use provide to us, under circumstances such as: 

  • You access or use our site;
  • You contact us through the online form available on our site, through email or by telephone;
  • You purchase/access the services or other content on our Site;
  • You initiate contact through our social media pages;

We process your data only to the extent that we have reason to do so, such as: in order to deliver to you (or the company which you work for or represent) the requested HAT services in order to respond to the requests that you or your company/ the entities you work with or represent send us, to inform you about the latest tech news or to improve our services.

2.1. Data that you provide when you use our Site or our Social Media pages:

Many of the data we process about you is provided by you directly, such as:

  • Identification data such as name, surname, and email or telephone number, you provide to us when you contact us through the contact form available on the site;
  • Content that you generate through our site, such as the messages you send to us through the existing contact form on the site and the data contained in the documents so submitted by you;
  • The content of the generation when you contact us by email or telephone and the data contained in the documents so delivered;
  • Content that you generate through our existing social networking sites like LinkedIn, Instagram, or YouTube. In situations like when you like HAT’s page or our posts, when you post messages or post comments, such as your username, the image/picture or message content will be processed.
  • Third-party links – our site may include links to third-party sites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party sites, save for where these links are to our own brands, and are not responsible for their privacy statements. When you leave our site, we encourage you to read the privacy policy or notice of every site you visit.

2.2. Data that we process automatically when you access our Site:

When you access our site, we use the following services to collect information about your interaction:

  • Google Analytics
  • Google Tag Manager
  • Facebook Pixel
  • LinkedIn Insight Tag

This information allows us to provide access to our Site, but also to receive information on how visitors use our Site to improve our services.

  • Information on the use of the Site– we process information on how to use the Site to find the number of visitors on the various pages of our Site.
  • Information provided through Cookies and other technologies– a cookie is an alphanumeric identifier installed on your hard drive when you visit a site, mobile application, or advertisement. It stores information about your visit to our Site (visited pages, date, and duration of visits, etc.). The cookies used by HAT do not collect data such as your name or email address. You can set your browser to refuse all or some cookies or to warn you when Internet pages set or access cookies. If you disable or decline cookies, please note that certain parts of our Site may become inaccessible or may not work properly. For more information on the cookies we use, please refer to our Cookies Policy.

2.3. Data that we process in other contexts:

Within the current activity (i.e. supply of materials and the provision of services), HAT collects the following data regarding the HAT’s partners, irrespective of the location of the services or the supply of materials:

  • Identification data, name, surname, professional phone number, e-mail;
  • Your photo, if attached to your email address or communication applications you use in relation to HAT (e.g., WhatsApp, Skype, Messenger, etc.);
  • Data regarding your position, position, and activity in the company that your representatives represent in relation to HAT.

3. WHAT ARE THE PURPOSE AND LEGAL BASIS OF THE PROCESSING ACTIVITIES? 

Based on your agreement – when you send us messages via the existing contact form on the Site, we will use the data to respond to your messages. Also, if you ask us questions about a particular service, and for this reason, you provide us with information about your activity, your preferences or other issues, this data will be processed but only to the extent needed in order to answer your questions.

If you choose to opt for receiving newsletters and/or alerts, we will use the data to send you such commercial communications by email. Such communications will only be sent to you if you have given your prior consent.

Please note that under the applicable legal provisions in the field of electronic communications, we will be able to use your email address provided to us at the time of purchase of a service for the purpose of making commercial communications if they relate to services similar to those previously acquired from us.

You have the right to withdraw your consent at any time by submitting a request as set out below.

Because the law compels us to carry out such processing – e.g. we keep contracts, accompanying shipments, activity reports on HAT business operations – to meet our legal obligations in tax matters and other regulated areas.

Based on a legitimate interest – when your rights and freedoms are unaffected – we will use the data processed when you access the Site to identify and correct any malfunctions that may occur during the use of the Site and to be able to evaluate the security level of the Site, to make improvements and to evaluate, measure and improve our services as a result of analyzing your preferences on the Site.

Marketing – We may use your contact details to send you marketing communications if you are a consumer and you have expressly given consent to receive those marketing communications. If you are not a consumer and you have requested information from us or if you have signed up to one of our newsletters or publications, or we have obtained your information from a third-party source, we may also use your contact details to send you marketing communications unless you have opted-out of receiving that marketing.

We also process your data to record the company you are working within HAT’s suppliers and customers database or to notify the company you are working with orders/offers/confirmations of offers/invoices/newsletters about the contracts concluded between HAT and the company you are working for, or other documents and / or information relevant to the existing or potential business relationships between HAT and the company you are working for.

We have analyzed and compared our legitimate interest in carrying out the current activities listed above in relation to your legitimate rights and interests and the consequences this data processing has on you, and we have come to the conclusion that we do not violate your rights and interests because:

  • we have limited the purposes of the processing as well as the volume of processed data to the maximum extent and have taken the necessary steps to guarantee the exercise of your legal rights in relation to the data we process, including the right to oppose;
  • we have limited the access to the processed data of our employees and have instructed employees to only process the data that is strictly needed to be processed for the purposes indicated above; and
  • we keep your personal data in safe conditions and proper protection.

4. HOW LONG WILL WE STORE YOUR DATA?

We will keep your personal data as long as it is necessary in order to meet the purposes, we have collected them for, including for the purpose of meeting any legal, accounting, or reporting requirements. Most of your personal data will be retained for the entire duration of the activity / operation that generated the data collection, and for a reasonable time since the last activity, except for the information contained in the taxable documents that we retain 10 fiscal years from the date of the tax transaction to which these data refer.

5. WHO WILL HAVE ACCESS TO YOUR PERSONAL DATA

Within HAT, your personal data will be disclosed to HAT employees in the departments that need to know this data to conduct their business, the IT department employees, and the administrators only to the extent necessary for the activities and purposes for which we process your data.

For the purposes mentioned above, your personal data will possibly be disclosed and even processed by third parties such as:

  • Public institutions law enforcement authorities in accordance with relevant legislation;
  • Tax administration;
  • External suppliers of mailing services;
  • Cloud service providers;
  • Specialized service providers appointed by HAT for various services related to HAT affairs;
  • Other professional consultants.

Employees, managers and / or representatives of the above-mentioned service providers or service providers and the dedicated service providers designated by them must respect the confidentiality of your personal data and may use such data only in accordance with the HAT instructions.

6. WILL MY PERSONAL DATA BE TRANSFERRED OUTSIDE MY COUNTRY OF RESIDENCE OR OUTSIDE EEA?

We store your personal data on equipment (servers and back-up servers) located in non-EEA countries. In order to transfer your personal data in accordance with data protection principles, HAT has implemented appropriate safeguards in line with the GDPR. A list of companies to whom we transfer your data to be stored outside of the EEA includes: companies within Google Group.

7. WILL HAT MAKE USE OF AUTOMATED DECISION-MAKING?

Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects or that significantly affect the individuals involved.  As a rule, HAT does not make use of automated decision-making as described above.

8. WHAT ARE MY RIGHTS WITH REGARD TO THE PROCESSING OF MY PERSONAL DATA AND WHO CAN I CONTACT?

You have the right to contact HAT at any time in order to exercise the following rights you have under the GDPR regulation:

The ACCESS right, based on which, you may request and obtain from HAT a confirmation that your personal data is being processed or not, as well as complete set of information about the purpose, the means of processing the storage period and other information. At the same time, you can request and obtain from HAT, free of charge, a copy of the personal data that is subject to processing if this does not violate the rights of others.

The right to obtain the RECTIFICATION of your personal data, under which you can request and obtain from HAT the rectification or updating of your personal data that no longer corresponds to the reality (for example, if you have changed your name, address, phone number or e-mail).

The right to obtain the ERASURE of your personal data, under which, in certain circumstances (such as when the data are no longer required for the purpose for which they were collected or the data are processed illegally or in other situations prescribed by law), you may request, and HAT is bound to delete your personal data.

The right to RESTRICT the processing of your personal data, based on which, in certain circumstances (such as when you consider that the date processed by HAT is not accurate or in other situations provided by law), you may request and HAT temporarily suspends the use of your personal data, until the exact situation of this data is clarified.

The right to OPPOSE, based on which: 

  • When HAT processes your data in order to ensure a legitimate interest (based on art. 6 par. 1 letter. f of the GDPR), in addition to the rights listed above you have the right to oppose the processing of your personal data.
  • If you enforce this right, HAT will not be able to process your data unless it shows and can explain to you why the way and reasons for processing your data are very important and why processing your data further, will not violate your legitimate rights and interests and will not harm you.
  • If HAT cannot prove the above, HAT must stop processing your data immediately.

CONSENT WITHDRAWAL, which means that:

  • When HAT processes your personal data based on your express consent (pursuant to Article 6 paragraph 1 letter a of EC Regulation No. 679/2016), in addition to the above rights, you have the right to withdraw your consent regarding the processing of your personal data;
  • If you use this right, HAT can no longer process your personal data in regard to which you have withdrawn your consent;
  • In order to use this right, you only need to notify us by email or by other means (but in writing) that you no longer agree to the processing of your personal data on the basis of the previously given consent.

9. WHO CAN YOU ADDRESS TO IN THE EVEN THAT YOU CONSIDER THAT THE PERSONAL DATA IS PROCESSED UNLAWFULLY? 

If you consider that HAT has not complied with the legal provisions in force related to data protection you can contact or file a complaint at:

  • The National Supervisory Authority For Personal Data Processing headquartered No. 28-30 G-ral. Gheorghe Magheru Bld., District 1, postcode 010336, Bucharest, Romania; E-mail [email protected]; Telephone  +40.318.059.211;
  • The Administrative and Fiscal Section of the Courthouse (Sectia de Contencios Administrativ si Fiscal din cadrul Tribunalului) competent at your place of residence or at Tremend’s headquarters.

For more details on the processing of certain categories of personal data or on your rights in relation to the processing of your personal data, you can access our Cookies Policy and Privacy Policy – Marketing Processing Activities or you can contact Mrs. Mirela Neagu by telephone at +40 726 231 840 and by e-mail at [email protected].

10. TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Best regards,

HAT Team

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