Privacy Notice

Welcome to our website! 

At Data2Code, we take the protection of your privacy and personal data very seriously. We want you to understand how we protect your privacy when we obtain personal data from you, how we use your data, what your rights are in this respect and how we safeguard it while you visit this website or use its functionalities. For this reason, we are providing you with this Privacy Notice which we kindly ask you to read before you navigate on our website.  

1. INTRODUCTION 

This Privacy Notice explains how your (hereinafter “you”, “your”, “user”) personal data are processed by Datatwocode SRL (hereinafter “Data2Code”, “we”, “us”, “ours”), a limited liability company incorporated under the Romanian Laws, Unique Registration Code 46750353, RC Registration No.: J23/5900/2022, the Data Controller of this website and personal data you are sharing with us.  

By browsing, navigating and interacting with us through our website, you acknowledge that you have read our Privacy Notice and understood that any personal data you provide to us is supplied at your own free will and shall be used in accordance with the purposes described in this Notice. 

If you do not understand this Privacy Notice, please do not share your personal data with us. 

We reserve the right to change and/or update our Privacy Notice at our discretion and at any time.  We recommend you regularly review this Notice for any changes, which we kindly ask you to read carefully and make sure you understand and agree with. Any such changes will be notified accordingly. 

2. DEFINITIONS 

“Personal data” means any information regarding a natural person who can be directly or indirectly identified. 

“Controller” means the natural or legal person that determines the purposes and means of the processing of personal data processing. 

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, storage, adaptation, consultation, use, disclose or deletion. 

“User” and/or “visitor” means any individual who visits and navigates the website www.data2code.eu. 

“Website” means www.data2code.eu  

3. APLICABILTY 

This Privacy Notice only applies to the processing of Personal Data provided by you for which Data2Code is a Controller as described under the General Data Protection Regulation 2016/679/EU. 

4. WHAT DATA WE COLLECT ABOUT YOU AND WHY? 

The categories and volume of personal data that we collect vary depending on the activities in relation to which the data is collected as follows: 

4.1. Cookies 

When you visit our Website, we will process your data collected through cookies. The cookies used on our website do not collect directly identifiable personal data such as name, address, email address etc. However, certain cookies may collect information which relate to details about the device used, journal information like IP, searches, browser, browser’s language, hardware settings, date and time of the request, method used to send requests to the server, file capacity obtained in response, and other parameters regarding the user’s operating system, which, when combined with other information, it becomes personal data and can indirectly identify you. 

Cookies allow us to understand your interaction with our website in order to enhance your navigation and customize your experience, improve our Services and obtain statistical information regarding the use of the Website and to check that is working properly.  

We will process these data only based on your consent and for the period while your consent is valid, except where cookies are strictly necessary for the Website to work correctly. You can withdraw your consent anytime without any constrains and without affecting the legality of the processing based on your consent prior to its withdrawal. For more information on what are cookies and how we use them, please consult our Cookie Policy. 

4.2. Contact Form 

You have the possibility to contact us in multiple ways: through e-mail, through our contact form or pop-up, or through social media messages. For this, we will process your first and last name, e-mail address, your company, your device type and language and any other information that you willingly provide to us within the message. 

In this case, we will use your personal data to communicate with you to provide response and support for your request, a quotation for using our services and/or negotiate the terms of the agreement with you.  

For these purposes, we will rely on our legitimate interest to: 

1. promote our services; 
2. enable business development; 
3. assess and (re)screen (potential) business partners; 
4. client satisfaction and retention. 

Where the communication does not give rise to a service agreement between us and you/your company, we will retain your personal data and copies of communications for 3 years from the date of the last interaction with us. 

We do not collect nor is our intention to collect personal data regarding racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. We recommend you avoid sending such personal data. In instances where we receive such personal data, we will immediately and securely delete it from our IT ecosystem. 

4.3. Marketing Campaigns 

From time to time, we launch marketing campaigns. While we try to use aggregated data for targeted campaigns, there are instances where we will process your first and last name, e-mail address, phone number, your role, your company and your LinkedIn account. 

We use these personal data to send dedicated marketing messages in order to promote our services. 

We will process your personal data only if you have provided your consent and only for the period while your consent is valid. You can withdraw your consent anytime without affecting the legality of the processing based on your consent prior to its withdrawal. 

4.4. Service Offering and Agreement 

Where the communication and negotiation stages lead to an agreement between us and you/your company and services are delivered as part of the agreement, we will process your personal data: first and last name, business phone number, e-mail, role, company and company’s address, interaction data (such as enquiries and complaints handling, management of business relationships and communications), signature and other personal data inferred or provided as part of business relationship management.  

This data is necessary to sign a service agreement with the company that you represent, deliver its associated services and comply with our obligations arising from such agreement. Without this data, it would be impossible to sign an agreement and deliver its associated services. 

We rely on our legitimate interest to:  

1. conclude, execute and administer agreements with you or your company; 
2. assess and (re)screen (potential) business partners; 
3. exercise the rights and perform the obligations incumbent on us under the above-mentioned agreement (such as, invoice payments, etc.);                 
4. for Financial and accounting management, archiving as well as and possible dispute resolution 
5. comply with applicable laws, including the disclosure of personal data to government institutions or supervisory authorities, and 
6. exercise or defend our commercial interests and rights, or legal claims  

We will retain your personal data for the duration of the service agreement and for as long as necessary after the termination of the agreement to comply with our obligations as specified above and in accordance with our fiscal obligations (between 10-11 years). 

Where we rely on legitimate interest as a ground for processing your personal data, we always carry out an assessment to ensure that your fundamental rights, interests and freedoms are not outweighed by our legitimate interests. You have the right to object at any time and we will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. 

4.5. Recruiting

If you apply to any of our job openings posted on external professional and social media platforms, we will process the following personal data: information contained in your CV,  contact details and information related to your performance of your current profession provided during the recruitment interview. 

This data is necessary for recruiting purposes based on our legitimate interest: i) to evaluate your level of suitability for a position within the company; ii) to document our hiring processes; and iii) to comply with applicable legal requirements; and to take steps at your request to conclude an employment contract with us if your application is successful. 

Your data will be retained for the entire duration of the recruitment process and until the position has been filled in. After we have found the right candidate for our job openings, and in the event your application is not successful, we will securely delete your data, unless you allow us to retain a copy of your CV and your contact details for a period of 1 year after the job opening has been filled in for further opportunities by providing us your consent.  

5. SOURCE OF PERSONAL DATA 

In general, we will collect your personal data directly from you. However, there may be situations where data will be collected indirectly from social networks such as LinkedIn or ads platforms, from the website of the company you represent or from a third party who recommended you. 

Where personal data is not collected directly from you, we will inform you within the legal timeframe of such processing through a dedicated Privacy Notice. 

6. SHARING OF PERSONAL DATA 

We will never share your personal data with any third party who intends to use it for commercial purposes, unless we have expressly informed you and you have given us explicit permission to do so. In certain circumstances described below, we will share a minimum amount of personal data about you with: 

1. Legal and consulting service providers authorised to process personal data who are acting as our contractors (such as law firms, accounting firms, consulting companies, auditing, etc.); 
2. Software or Hardware vendors authorised to process personal data who are acting as our contractors (such as IT Providers, IT license providers, etc.); 
3. Other entities who enable the provision of our services and are under contractual obligation, such as payment providers, archiving companies, market research companies, marketing companies, etc.; 
4. Local authorities or other competent authorities where we have an obligation to share such data if required by applicable laws. We may also share your personal data in good faith in order to protect, secure or prevent the loss of our rights or in the legitimate interests of Data2Code, its customers or the general public, or to respond to complaints from others; 
5. Other entities upon your request; 

Your personal data will be kept, processed and stored by us and our service providers in the following territories: the European Union. Each of our service providers who process and store your personal data have a contractual obligation to keep it confidential, protected and secured, in accordance with applicable industry standards and legal obligations. 

Where such recipients of data are located in third countries for which the European Commission has not issued an adequacy decision, Data2Codehas in place contractual relationships with each such recipient that include standard contractual clauses intended to ensure an adequate level of protection. A copy of the standard contractual clauses used by Data2Code can be found at: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj. 

7. SECURITY OF PERSONAL DATA 

The security and protection of Personal Data is crucial for us. We have implemented all necessary technical and organizational measures, whether physical, electronic or procedural, to protect the confidentiality and security of the Personal Data you share with us. These measures have been implemented to protect Personal Data against unauthorized access, destruction, loss, alteration, access, disclosure or use. Our security controls are designed to maintain an adequate level of confidentiality, integrity and data availability of Personal Data.  

Despite the security measures outlined above, we want you to know that the Internet is not a perfectly secure medium and there will always be the chance that your Personal Data could potentially be subject to unauthorized acts by third parties.  Although we take reasonable steps and employ appropriate security measures to safeguard your Personal Data, no method of transmitting or storing data is completely secure. We cannot guarantee the security of your Personal Data and any transmission of your Personal Data through the Internet is at your own risk. We cannot be responsible for the acts of those who gain unauthorized access to your Personal Data, and we make no warranty, express, implied or otherwise, that we will prevent such access or abuse.

8. YOUR RIGHTS AND HOW TO EXERCISE THEM 

At any given time, you will have the following rights regarding your personal data processed by us. Please note, other than your right to object to us using your information for direct marketing (and profiling for the purposes of direct marketing), your rights are not absolute in case of other applicable laws.  

1. The right to information: you have the right to be provided with information on the identity of the personal data controller, on the reasons for processing you personal data and other relevant information necessary to ensure the correct and transparent processing of your personal data. 
2. The right of access: you have the right to make a request for details of your personal information and a copy of that personal information. 
3. The right of rectification: you have the right to have inaccurate information about you corrected or removed without undue delay.  
4. The right of erasure ("right to be forgotten"): you have the right to have certain personal information about you deleted from our records subject to exceptions. 
5. The right to restriction of processing: you have the right to ask us to use your personal information for restricted purposes only. 
6. The right to data portability: you have the right to ask us to transfer the personal information you have given us to you or to someone else in a format that can be read by computer. 
7. The right to object: you have the right to object to us processing (including profiling) your personal information in cases where our processing is based on a task carried out in the public interest or where we have let you know it is necessary to process your information for our or a third party’s legitimate interests. You can object to us using your information for direct marketing and profiling purposes in relation to direct marketing. 
8. The right in relation to automated decisions: you have the right not to have a decision which produces legal effects which concern you or which has a significant effect on you based only on automated processing, unless this is necessary for entering into a contract with you, it is authorised by law or you have given your permission for this. Your personal data will not be subject to solely automated decision making.  

In order to exercise any of the above rights, you can contact us at: contact@data2code.eu. Your request will be reviewed and answered within one calendar month from receipt, in accordance with our legal obligations. If we receive a large number of requests, or particularly complex requests, the deadline can be extended by a maximum of another two months. In certain circumstances as prescribed by data protection law (i.e. excessive requests), we might refuse to act upon your request.  

As a rule, you can exercise your rights for free. However, we reserve the right to charge a reasonable fee if your requests are manifestly unfounded or excessive, in particular because of their repetitive nature.

We pay the utmost attention to the confidentiality of all personal data and reserve the right to verify your identity if you submit a request for personal data and such identification is needed. 

In the event your personal data is processed based on your consent, you have the right to withdraw your consent at any time, without prejudice to the lawfulness of the processing carried out on the basis of the consent before its withdrawal. 

You also have the right to lodge a complaint with the National Authority for the Supervision of Personal Data Processing (Address: 28-30 General Gheorghe Magheru Blvd., sector 1, Bucharest, postal code 010336, tel: 0040318059211) or any competent court to defend the rights guaranteed by the applicable legislation. 

9. CONTACT 

If you have any questions, comments, complaints or suggestions relating to this Notice, or any other concerns about the way in which we process personal data about you, please contact our Data Protection Officer by emailing contact@data2code.eu.  

10. CHILDREN`S PERSONAL DATA

Our Website and services are not intended for individuals below the age of 18. We do not want nor is our intention to solicit and collect personal information for this type of audience. 

We do not intentionally collect Personal Information from individuals below the age of 18. If you are the parent or guardian of a child below the age of 18, and believe your child has provided us with personal information, please contact us to request the deletion of these personal data. If we confirm that we have collected this kind of personal information, we will delete that information as soon as possible. 

Last updated on August 2022.