- GENERAL PROVISIONS
By accepting this Policy, you agree to the processing of your personal data for the purpose of creating the user profile and an account in the database of Societe Generale European Business Services SA (hereinafter referred to as “SG EBS”).
Thus, you agree that your identification and contact details will be processed by SG EBS for the purposes described below.
- APPLICABLE DEFINITIONS
Data controller – the natural or legal person, the public authority, the agency or other body which, alone or together with others, establishes the purposes and the means of processing the personal data;
Data Processor – the natural or legal person, the public authority, the agency or other body that processes the personal data on behalf of the Data controller;
Personal data – any information about an identified or identifiable natural person (“data subject”);
Data subject – the person whose personal data are collected and processed – in case of this Policy, the participant in the Urban Seekers Event holds the quality of “data subject”
GDPR – European Regulation No. 679/2016 regarding the protection of the natural persons regarding the processing of personal data and the free movement of these data;
Applicable Law – GDPR, Law 190/2018, Civil Code and Civil Procedure, Decisions of the National Supervisory Authority for the Processing of Personal Data (“ANSPDCP” or “Authority”)
- CATEGORIES OF DATA PROCESSED
SG EBS will collect and process your identification data (eg last name, first name, e-mail address, contact telephone number) in order to carry out the necessary steps for completing the registration process for the Urban Seekers event as well as for the situation in which you have expressed your agreement, to initiate a possible recruitment process between you and SG EBS.
To the extent that you do not agree with the processing of your personal data represented by your telephone number for the purpose of contacting you in order to initiate a recruitment process for a position within SG EBS, the provision of the telephone number in the form of registration for the event is not mandatory. However, if you have expressly consented to SG EBS being able to contact you for the purpose of submitting an interview invitation, the provision of the contact telephone number is mandatory.
Also, within the limits of your express consent by means of the event registration platform, SG EBS will collect and process photographs illustrating your image for the purpose of promoting through the social networks (eg LinkedIn, Facebook) the Urban Seekers event from 19.10.2019. To the extent that you do not want your image which is collected and processed through the photographs taken during the event, to be used by SG EBS, SG EBS will take note of your option. Thus, please express your agreement/disagreement by means of the registration form for the event.
The organizer will also process the personal identification number of the winning participants, in order to pay the taxes and fees related to the prizes. Thus, the organizer will forward this data to ANAF and will not process / store it for other purposes. By registering for this event and by reading this Policy on data processing, you declare that you have been informed about the Organizer's possibility to collect and process the personal identification number, to the extent that you have won and also under the legal obligation of the Organizer derived from Law 227/2015 regarding the Fiscal Code.
- WHERE DO WE COLLECT YOUR PERSONAL DATA FROM
To the extent that you have expressed your consent to the possibility of SG EBS to contact you for the purpose of including you in the recruitment processes for vacancies opened by SG EBS, in addition to the personal data obtained directly from you by means of the event registration form, we can obtain and process relevant data for the recruitment process from the following sources:
- online recruitment platforms (we obtain contact details, as well as data related to the candidate’s professional history/experience);
- THE PURPOSE FOR PERSONAL DATA PROCESSING
SG EBS processes your personal data for the purpose of:
- The registration of the participants in the Urban Seekers event that will take place on 19.10.2019, in accordance with the Terms and Conditions of the event that you can access to: https://www.urbanseekers.ro/, the organization and development under optimal and safe conditions of the event;
- For the situation in which you have given your express consent, for taking the necessary steps in order to start and begin the recruitment process for one of the vacancies opened within SG EBS. Fulfilling this purpose will consist, on the one hand, of verifying the above information (identification and contact data, information from public sources such as recruitment sites, and on the other hand, of interviews between you and representatives of SG EBS).
- Photographs collected during the event and under your express consent, will be processed by SG EBS for the purpose of promoting the event and the company.
Your refusal to provide personal data represented by last name, first name and e-mail address makes it impossible for you to register in the Urban Seekers event organized by SG EBS. However, your refusal to provide your personal telephone number does not lead to the impossibility of registering for the event, however, unless you agree to the processing of the data in order to contact you for any open vacancies within the SG EBS, the failure to provide the telephone number leads to the impossibility of registration, as the registration to the event cumulated with your consent for such processing gives rise to the need to provide the phone number.
- THE GROUND OF PERSONAL DATA PROCESSING
|Processing purpose||Processing basis|
|Registration of participants in the Urban Seekers event in accordance with the Terms and Conditions of the event
|The conclusion of a contract or performing the necessary steps to conclude a contract to which the data subject is party
|Organizing and conducting the event in optimum and safe conditions||The legitimate interest of SG EBS|
|Making the necessary steps to start and begin the recruitment process for one of the vacancies opened within SG EBS by contacting you for this purpose||Your consent as a data subject|
Promotion of the Urban Seekers event by processing photographs containing the participants’ image
|Your consent as a data subject|
- PERSONAL DATA RETENTION PERIOD
The personal data presented in the previous paragraphs and processed by SG EBS for the purposes set out above will be processed by SG EBS for a period of one year from the date of the Urban Seekers 2019 event. However, to the extent that you have expressly consented to the possibility of SG EBS to collect and process your image through the photographs taken during this event, in case you do not withdraw this consent, the photos that present you will be processed by the SG EBS for a period of 3 years from the date of the event, the photos being processed by publishing them in the online environment as well as on socialization sites such as Facebook and LinkedIn, from where they will be deleted upon the expiry of a term of 3 years from the event date.
- CATEGORIES OF DATA RECIPIENTS
Your personal data, as described in the previous paragraphs, will be processed by SG EBS entities for the purposes presented above, an entity that carries out its data processing activity in the territory of Romania.
Also, your personal data will be stored on the data infrastructure of the Societe Generale Group located in Paris, France as well as on the MailChimp infrastructure, (“The Rocket Science Group LLC d / b / a Mailchimp”) which provides electronic communications services such as e-mail, this infrastructure being located in the United States of America and benefiting from the Privacy Shield certification. Moreover, to the extent that you have consented to the possibility of SG EBS to process your image and publish photos that present you by means of online platforms/sites and social media, we hereby inform you that your personal data represented by your image will be processed by the entities owning these platforms in accordance with their own Data Processing Policies, these data being stored in the storage environments and locations chosen by these third parties (eg Facebook/LinkedIn). If you want to find out more information about the location of data processing and storage by Facebook and LinkedIn, please access and read the Facebook and LinkedIn Data Processing Policy. Also, to the extent that you wish to exercise your rights regarding the processing of your personal data, we inform you that you will have to exercise these rights both with respect to SG EBS as a Personal Data Controller, as well as with respect to Facebook and/or LinkedIn as Independent Controllers.
- THE RIGHTS WHICH YOU BENEFIT FROM FOLLOWING THE PERSONAL DATA PROCESSING BY SG EBS
- The right of access to data
As a data subject you have the right to request and obtain from SG EBS a confirmation of whether or not your data is processed by SG EBS, and if so, you have the right of access to the respective data as well as to information such as: the purposes of the processing, the categories of data processed, the recipients or categories of recipients of the data, the period of storage of the data thus processed. Also, to the extent that SG EBS has obtained your personal data from other sources and not from you directly, you may request any available information regarding the source of the data thus collected.
- The right to rectification
As a data subject you have the right to obtain from SG EBS the rectification and/or completion of inaccurate and/or incomplete personal data concerning you.
- The right to erasure of data (“The right to be forgotten”)
As data subject you have the right to obtain from SG EBS the deletion of personal data concerning you, and SG EBS has the obligation to delete personal data without undue delay if one of the following reasons applies:
- personal data are no longer necessary for the purposes for which they were collected or processed;
- You withdraw the consent on the basis of which the processing takes place, where the basis of the data processing is represented by your consent;
- You exercise the right to object;
- personal data were processed illegally;
- personal data must be deleted in order to comply with a legal obligation incumbent on SG EBS pursuant to Union or national law;
- personal data were collected in connection with the provision of information society services.
SG EBS’s obligation to erase your personal data will not apply to the extent that the processing is necessary:
- for the exercise of the right to free speech and information;
- to comply with a legal obligation which provides for processing under Union or national law;
- for finding, exercising or defending a right in court.
- The right to restrict processing
As a data subject you have the right to request SG EBS and to obtain from it the restriction of the processing of the data that belong to you if one of the following applies:
- you object to the accuracy of the data, for a period that allows SG EBS to verify the accuracy of data;
- the processing is unlawful and you object to the deletion of your personal data, requesting instead the restriction of their use;
- SG EBS no longer needs the personal data for the purpose of processing, but you request them for finding, exercising or defending a right in court; or
- you have objected to the processing of the data for the time period in which it is checked whether the legitimate rights of SG EBS prevail over those claimed by you.
- The right to data portability
As a data subject you have the right to receive personal data concerning you and which you provided to SG EBS in a structured format (by means of through an online form), commonly used and readable automatically and you have the right to transmit this data to another controller, without obstacles from SG EBS, if:
- processing is based on consent; and
- processing is performed by automatic means.
- The right to object
At any time, you may object, for reasons related to your particular situation, to the processing carried out on the basis of the public interest or the legitimate interest followed by SG EBS or by a third party. SG EBS will no longer process the personal data that belong to you as a result of your exercise of this right, unless SG EBS has legitimate and compelling reasons to justify the processing or when the purpose of further processing of the data is represented by the finding, exercise or defence of a right in court of SG EBS.
You can also contact the National Supervisory Authority for Personal Data Processing (ANSPDCP)
28-30 G-ral Gheorghe Magheru Blvd., District 1, zip code 010336, Bucharest, Romania
- THE LOCATION WHERE YOUR DATA ARE PROCESSED OR STORED
In order to fulfil the purposes presented above, your personal data will be processed in Romania. However, SG EBS, as part of the Societe Generale Group, benefits from part of the technical infrastructure of the Societe Generale Group, infrastructure located in France as well as from technical support from other entities in the Group located in the European Union as well as in other states outside the EU, including USA for Mailchimp as e-mail services provider. Thus, your personal data will be stored within the infrastructure located in France, and in the event that any transfers to states that do not provide an adequate level of protection are required, these will be achieved with the observance of the adequate guarantees, as these are provided by the European Regulation no. 679/2016 on the protection of natural persons with regard to the processing of personal data and the free movement of these data.
To the extent that you have consented to SG EBS’s ability to process your image and to publish photographs featuring you through online platforms/sites and social media, we inform you that your personal data represented by your image will be processed by the entities owning these platforms in accordance with their own Data Processing Policies, these data being stored in the environments and storage locations chosen by these third parties (eg Facebook / LinkedIn). If you want to find out more information about the location of data processing and storage by Facebook and LinkedIn, please access and read the Facebook and LinkedIn Data Processing Policy. Also, to the extent that you wish to exercise your rights regarding the processing of your personal data, we inform you that you will have to exercise these rights both with respect to SG EBS as Personal Data Controller, as well as with respect to Facebook and/or LinkedIn as Independent Controllers.
- TECHNICAL AND ORGANIZATIONAL MEASURES APPLIED BY SG EBS IN ORDER TO ENSURE THE SECURITY OF PERSONAL DATA
SG EBS has implemented a series of technical and organizational measures to ensure the protection of personal data processed. These measures include the following:
- Limiting the personal data collected and processed to those strictly necessary for organizing the Urban Seekers event, undertaking the necessary steps to register the participants, starting the recruitment process, within the limits of your agreement and promoting the SG EBS image based on your consent;
- Granting access to personal data only to the personnel who require such access according to the duties held within SG EBS as well as according to the need to know and to have;
- Pseudonymizing and/or encrypting personal data where such processing allows the purposes for which the data were initially collected to be achieved;
- Providing the necessary courses for the personnel involved in the operations of data processing so that they know exactly the internal procedures and the legal provisions applicable in the matter of the protection of personal data;
- Implementation of the technical measures necessary to ensure the backup and to restore the access to data in a timely manner in case of an incident of a physical or technical nature;
- Ensuring the confidentiality, integrity, availability and resilience of personal data processing systems by implementing the necessary technical and organizational measures such as Computer Security and Physical Security measures in order to ensure the prevention of unauthorized disclosure of data and unauthorized access to data.
- CONTACT INFORMATION OF DATA PROTECTION OFFICERS WITHIN SG EBS
Societe Generale European Business Services – firstname.lastname@example.org