Personal data protection

VERY IMPORTANT:
The data subject has the right to object to the processing of your personal data.
The right to object to the processing of your personal data can be exerted by the data subject, in the following two circumstances, as follows:
1) The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
2) Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

1. The identity and contact information of controller of your personal data
Uttis Industries S.R.L. (“Uttis Industries”) is controller of personal data.
Uttis Industries S.R.L. with headquarters in Vidra village, 20 Calea Bucuresti, Ilfov county, is registered at Trade Registry Office under no. J23/1769/2010, VAT no.6561690.
Name and contact details of the controller:
Address: Vidra village, 20 Calea Bucuresti, Ilfov county
Phone: +40-21-332.19.56
Fax: +40-21-301.84.87
Email: office@uttis.com

2. Contact details of the Data Protection Officer
Uttis Industries appointed a Data Protection Officer of which contact email address is dataprotection@uttis.com
Where the data subject do not agree to contact the Data Protection Officer by email, any other correspondence can be followed by using the contact details of the controller shown at Chapter 1.

3. Categories of personal data processed
Depending on the category of persons you belongs and depending on how your personal data are collected, we can fully or partially process, the following categories of personal data
1) identification data (e.g. surname, name, residence)
2) identification data, remote (e.g. phone no., e-mail address, device IP)
3) job/occupation identification data(e.g. position, job etc);
4) professional activity identification data (e.g. how you negotiate a contract with us, content of an e-mail transmitted to us from your job’s e-mail address)
5) graphoscopic data (e.g. your signature in a contract with us, your signature in a document transmitted to us)
6) biometric data (e.g. your image stored in one on our video camera, your image enclosed in an identity card stored by us etc);
7) financial data (e.g. your Bank account, Bank name, payment date, payment justification etc)
8) your opinions (e.g. your opinions about our products/services etc);
9) other personal data categories, including data with special character, depending on circumstances (e.g. to the extent that you inform us that you will not arrive to a meeting commonly agreed, due to medical reasons, we will process the data transmitted related to your health condition etc);

4. Personal data sources
The sources available for collecting your personal data are various, from circumstance to circumstance, and could be:
1) data subject (e.g. you send an email to us, contact us by phone, transmit us a CV for a job in our company)
2) company/entity where you work (e.g. your company transmit is your personal data in order to contact you in order to start and maintain a dialogue on a certain subject etc);
3) other company/entity you are connected (e.g. you are the supplier of some goods or services to this company without being a employee)
4) other persons/entities which hold your personal data (e.g. a friend, a company where you worked before, another client of us etc);
5) public sources (e.g. the data provided by the Trade Registry Office, the results of searches displayed by a search engine etc).

5. How we process your personal data
Uttis Industries can fully or partially process your personal data, as follows:
1) data collection (e.g. receiving of a contract/email signed by you)
2) data storage (e.g. storage of a document from you)
3) data record (e.g. your record in our client’s data base etc);
4) data visualisation (e.g. visualisation of your contact data in order to transmit you an e-mail etc);
5) data modification (e.g. when you asked us to modify your contact data etc.);
6) data encryption (e.g. when we encrypt the devices which store your personal data etc);
7) data transmitting/disclosure (e.g. when we transmit your contact data to a currier etc);
8) data destroying (e.g. when we delete you from our database of active clients etc);
9) any other operations on your personal data (e.g. restricted access, pseudo-minimizing, anonymization)

6. Purposes of personal data processing and legal bases
Uttis Industries process a series of personal data with the basis of one or more purposes, as well as one or more legal bases, according to those further specified.
To understand the purposes and legal bases considered for processing your personal data please access the category of persons you belongs (6.1 Potential clients / clients / former clients, 6.2 Potential suppliers / suppliers/ former supplier, 6.3 Potential partners / partners / former partners and other related persons, 6.4 Other people).

6.1. Potential clients/clients/former clients of Uttis Industries and other related
Uttis Industries process the personal data of its potential clients / clients / former clients and other related persons as follows:
1) individuals which are potential clients / clients / former clients;
2) individuals which are the representatives of potential clients / clients / former clients (e.g. administrator, managing director, economic director etc);
3) individuals which are the employees of potential clients / clients / former clients (e.g. employees, public employees, contractual personnel etc);
4) individuals which are the representatives of suppliers / partners / subcontractors/ consultants / etc, of potential clients / clients / former clients (e.g. the administrator of an externalized audit company, the director of a bank where the client has an account etc);
5) individuals which are the employees of suppliers / partners / subcontractors/ consultants / etc, of potential clients / clients / former clients (e.g. the employee of a Bank where the Client has account, the employee of an externalized audit company etc);
6) individuals which are the representatives of a public authority/public institution connected with potential clients / clients / former clients (e.g. an ANAF manager etc.)
7) individuals which are the employees of a public authority/public institution connected with potential clients / clients / former clients (e.g. an ANAF inspector etc.)
8) any other individual bearing any type of connection with potential clients / clients / former clients (e.g. a former employee of a client etc.)

6.1.1. Pre-contractual period

Purposes of processing
Uttis Industries aims to offer / supply its services / products to a large number of persons / companies / entities.
During the pre-contractual period, Uttis Industries will process your personal data for the following purposes:
1) in order to start and maintain a dialogue;
2) in order to show our services / products;
3) in order to get the information on which basis of we can propose the most suitable services / products;
4) in order to draft the documents related to the pre-contractual period (e.g. NDA, offer, contract model, etc.);
5) in order to understand the demands and trends of the related market (e.g. what services / products are requested, by which categories of customers, at what prices etc.);
6) in order to understand how we can improve our services / products (e.g. evaluating our internal employees, analyzing the opportunity of hiring additional staff etc.);
7) in order to understand how we could organize our activity from all points of view (commercial / marketing / HR / IT / financial etc.) (e.g. evaluation of contracts concluded within one month against those contracts that could be concluded, evaluating how our employees fulfil their duties, analyzing how the company presents etc.);
8) in order to protect the achieving of our rights and interests (e.g. in order to contract a new client, in order to carry out our own activities, in order to realize our activity field, in order to carry out our activities in an optimal way for us from any technical / economic point of view etc);
9) in order to fulfil some legal obligations (e.g. in order to fulfil some legal obligations regarding the provision of information at the request of a public authority / institution, such as ANAF etc).

Legal bases of processing
The legal bases of processing are:
1) the processing is necessary with the view to reply to your request (e.g. we formulate a contract model, we formulate a customized offer, we provide the requested information etc.);
2) the processing is necessary with the view to fulfil some legal obligations in our charge (e.g. under the law we may be obliged by a public authority / institution to provide certain information etc.);
3) the processing is necessary with the view to achieve our legitimate interests to achieve the purposes set out above (the purposes of processing).
Taking into consideration those mentioned above, Uttis Industries will contact you, on basis of own initiative (e.g. we will send you an e-mail) or on basis of your initiative (e.g. you contact us by phone, you visit our website etc), or on basis of another person / entity initiative (e.g. both you and we receive an email from an intermediary).
In the extent that you will be a client of Uttis Industries or an individual connected through any kind of relationship / rapport with one of our clients, your personal data will be processed according to Cap. 6.1.2.

Data storage period
Uttis Industries will only store your data for the period necessary to achieve the purposes set out above (Purposes of processing).
This period varies from case to case depending on a number of circumstances (e.g. category of data provided, purpose of supply, specific purpose of processing, legal obligations, incidental etc.).
For example, when you represented a potential client or representative / employee of a potential client of us, your data will be permanently deleted within 60 calendar days from the time when it is certain that we will not be contracted anymore (e.g. if you send us an informative e-mail, or interrupt the communication with us for a period of time that exceeds a reasonable duration, we will inform you that we cannot offer the requested services / products, etc.).

6.1.2. Contractual /post-contractual period

Purposes of processing
Uttis Industries supplies services / products to its clients, fulfils a series of legal / conventional obligations and adapts its business strategy according to the demands of the related market. During the contractual /post-contractual period,
Uttis Industries will process your personal data for the following purposes:
1) in order to start and maintain a dialogue;
2) in order to execute a contract in force;
3) in order to draft the documents related to the contractual period (e.g. additional documents, protocols, invoices, confirmation of balances etc.);
4) in order to fulfil some legal obligations (e.g. the obligation to draw up the primary accounting documents, the obligation to store the accounting documents for a certain period of time etc.);
5) in order to get information necessary to propose other services / products that might be suitable, other than those already contracted;
6) in order to present our services / products, other than those already contracted;
7) in order to understand the demands and trends of the related market (e.g. what services / products are requested, by what customers categories, at what prices etc.);
8) in order to understand how we can improve our services / products (e.g. evaluating internal employees, analyzing the opportunity of hiring additional staff etc.);
9) in order to understand how we could organize our activity from all points of view (commercial / marketing / HR / IT / financial etc.) (e.g. evaluation of contracts concluded within one month against those contracts that could be concluded, evaluating how our employees fulfil their duties, analyzing how the company presents etc.);
10) in order to protect and realize our rights and interests (e.g. if the value of the invoices issued is not paid and we are forced to initiate a civil action, in order to carry out our own activities, in order to realize our activity field, in order to in order to carry out our activities in an optimal way for us from any technical / economic point of view etc);

Legal bases of processing
The legal bases of processing of your personal data are:
1) the processing is necessary for the execution of the contract concluded;
2) the processing is necessary in order to fulfil some legal obligations in our duty (e.g. the obligation to draw up and keep primary accounting documents, such as the contract concluded, the invoices issued, etc.);
3) processing is necessary in order to achieve our legitimate interests to achieve the purposes shown above (Purpose of processing).

Data storage period
Uttis Industries will only store your data for the period necessary to achieve the purposes set out above (Purposes of processing).
This period varies from case to case depending on a number of circumstances (e.g. category of data provided, purpose of supply, specific purpose of processing, legal obligations, incidental etc.).
As a general rule, your personal data will be stored by us during whole contractual period, as well as after the termination of the contractual relations for a period of 10 calendar years, calculated from January 1 of the year following the one where the contract terminates.
To the extent that the purposes of processing your personal data are achieved before the above deadline is met, they will be stored only until the time the purposes are achieved.
To the extent that the purposes of processing your personal data require their storage also after the implementation of the above mentioned period, they may continue to be stored by us until the purposed of storage are achieved (e.g. the Fiscal Code would require the storage of your personal data for a period of 7 years, etc.)
The main reasons for which your personal data will be stored for the period mentioned above are:
1) over the contract duration, your personal data are requested in order to initiate and maintain a dialogue;
2) over the contract duration, your personal data are requested in order to know the parameters that we have to respect and to execute the contract (e.g. what we have to provide, where, terms, costs, etc.);
3) over the contract duration and after, your personal data are included in a series of financial-accounting documents which are requested to be kept according to the law (e.g. contract, invoices issued, payment orders, bank records, receipts etc.);
4) over the contract duration and after, your personal data are requested in order to be able to provide information on the opportunity to offer also other services / products than those already contracted;
5) over the contract duration and after, your personal data are requested in order to be able to analyze the viability / technical efficiency / cost efficiency / any technical problems regarding the services / products quoted, such as to understand better all the technical / economic aspects of the services / products quoted;
6) over the contract duration and after, your personal data are requested in order to provide information regarding the contracted goods / services and / or others that are part of our product range;
7) over the contract duration and after, your personal data are requested in order to understand the market trends, what type of services / products are requested, what is available on the market, what are the costs the customers are ready to allocate, etc., knowledge on this information will help us to adapt our business strategy in order to remain in the related market in the most competitive way and as closest is possible to the real needs of our clients;
8) over the contract duration and after, there is the possibility to appear certain misunderstandings / litigations regarding the execution of the contract, in which case your personal data are requested to protect our rights (e.g. in the case of a trial we can prove that we fulfilled our obligations, in the case of non-payment of an invoice according to the payment terms we can prove that we provided / performed the services / products invoiced etc);
9) over the contract duration and after, your personal data are requested in order to analyze the own activity and development mode of it (internal analysis) such as to adapt to the market in the most appropriate way (e.g. we analyze: the necessity of new employments and in which department, the efficiency of our employees, the knowledge and expertise of our employees, etc.);
10) after contract duration, there is the possibility that a client / former client of us and / or us to be subjected to a control by the fiscal bodies / other authorities / public institutions, in which case it is necessary to prove the contractual relations between us and how they have been executed.

6.2. Potential suppliers/suppliers/former suppliers of Uttis Industries and others related
Uttis Industries processes the personal data of its potential suppliers / suppliers / former suppliers, as well as of other related persons which are in certain relation/rapport with these, as they are defined in Cap. 6.1.
To the extent that you are a potential supplier / supplier / former supplier or you are a person in a certain relation/rapport with a potential supplier / supplier / former supplier of ours, we will process your personal data.
During the pre-contractual period, we will process your personal data according to those set out in Cap. 6.1.1. with the following mention:
1) regarding the purposes of the processing, the purposes of the no. 3 and 5 are not applicable to you.
During the contractual / post-contractual period we will process the data according to the ones described in Cap. 6.1.2. with the following exceptions:
1) regarding the purposes of the processing, the purposes no. 5, 6 and 7 are not applicable to you;
2) regarding the reasons underlying the duration of data storage, the reasons no. 4 and 6 are not applicable to you.

6.3. Potential partners/partners/former partners of Uttis Industries and others related
Uttis Industries processes the personal data of its potential partners / partners / former partners, as well as of other related persons which are in certain relation/rapport with these, as they are defined in Cap. 6.1.
To the extent that you are a potential partner / partner / former partner or you are a person in a certain relation/rapport with a potential partner / partner / former partner of ours, we will process your personal data.
During the pre-contractual period, we will process your personal data according to those set out in Cap. 6.1.1.
During the contractual and post-contractual period, we will process your personal data according to those set out in Cap. 6.1.2.

6.4. Other persons
To the extent that you do not belong to any of the categories defined at Cap. 6.1. – 6.3., the provisions set out in this chapter are applicable.
Uttis Industries processes the personal data of other persons, than those defined in Cap. 6.1. – 6.3 get in contact with the company such as:
1) representatives of public authorities / institutions (e.g. ANAF inspectors etc);
2) Visitors of our headquarters;
3) visitors of our site;
4) other persons, Uttis get in contact (e.g. persons get in contact with Uttis in an exhibition or workshop, etc.).

Purposes of processing
Uttis Industries aims to offer / supply its services / products to a large number of persons / entities, to fulfil its own legal / contractual obligations, as well as to keep visible and performance the company on the related market.
Uttis Industries processes your personal data for the following purposes:
1) in order to initiate and maintain a dialogue;
2) in order to present our services / products;
3) in order to evaluate you such as to determine if we are interested in a certain collaboration (e.g. to the extent that you send us a CV for employment in our company, etc.);
4) in order to get information on basis of which we can propose the most suitable services / products;
5) for the drafting of the documents related to the pre-contractual period (e.g. .offer, contract model, etc.);
6) in order to understand the requirements and trends of the related market (e.g. what services / products are requested, which clients categories, at what prices etc.);
7) in order to understand how we can improve our services / products (e.g. evaluating internal employees, analyzing the opportunity of hiring additional staff, etc.);
8) in order to fulfil some legal obligations (e.g. the obligation to provide the documents and information requested by a public authority / institution that initiates a control regarding Uttis);
9) in order to understand how we could organize our activity from all points of view (commercial / marketing / HR / IT / financial etc.) (e.g. evaluation of contracts concluded within one month against those contracts that could be concluded, evaluating how our employees fulfil their duties, analyzing how the company presents etc.);
9) in order to understand how we have to organize our activity from all points of view (commercial / marketing / HR / IT / financial, etc.) (e.g. evaluating the contracts concluded within a month against the contracts that could be concluded, evaluating how our internal employees fulfil their duties, analyzing how we present as a company, etc.);
10) in order to protect and realize our rights and interests (e.g. in order to ensure the security of our headquarters, to ensure the security of the data existing on our site, to prove our claims in a court or a trial etc).

Legal bases of processing
The legal bases of processing of your personal data are:
1) the processing is necessary in order to fulfil some legal obligations in our duty (e.g. if the law requires us to disclose certain information to a public authority / institution, etc.);
2) processing is necessary in order to achieve our legitimate interests to achieve the purposes shown above (Purpose of processing).

Data storage period
The storage period varies from case to case depending on the particularities of the data processed (e.g. the number of visitors of our site can be kept for a period of 3 months necessary to carry out a specific survey or for a period of 2 years necessary for the analysis of an evolution etc.).
However, we assure you that we will not keep your data after the moment when the purposed of processing have been achieved.

7. Recipients / categories of recipients of your personal data
In some cases, depending on the circumstances, your personal data can, can be transmitted by us to the:
1) the persons who act under our careful guidance (e.g. our employees);
2) our associated operators of personal data (e.g. a partner company which provides the services / products supplied by us etc);
3) the persons who act under the careful guidance of our associated operators of personal data (e.g. employees of a partner company which provides the services / products supplied by us etc);
4) the persons authorized to process the personal data on our behalf (e.g. a courier company, a company that provides externalized IT services, an accounting company that provides us externalized services etc.);
5) the persons who act under the careful guidance of the persons empowered to process the personal data on our behalf (e.g. a driver employed by a courier company, an IT engineer employed within the company that provides us IT services, etc.);
6) you, to the extent that you agree to exert one of the rights foreseen by law (e.g. the right of access);
7) any other person / entity other than those defined at articles 1 to 6, for example a distinct operator of personal data (e.g. ANAF).
The communication of personal data to the persons mentioned above will be carried out only and only to the extent that this communication:
1) either it is required by the necessity to achieve the purposes of processing your personal data;
2) either it is required by law.

8. Transferring your personal data outside the European Union
Uttis Industries will keep your personal data, either in physical or digital format, or in both formats, within the European Union.
However, in certain situations, Uttis Industries will communicate your personal data outside the European Union.
In these last two cases, Uttis Industries will ensure that the data transfer will be carried out only to the extent that the conditions claimed by the European legislation on the protection of personal data are fulfilled (e.g., there is a compliance decision issued by the European Commission, an agreement is concluded to provide the necessary guarantees, etc.).

9. Data subject rights
As it concerns your personal information you have or a number of rights:
1) right to access the data;
2) right to correct the data;
3) right to obtain the data deletion;
4) right to obtain the data processing restriction;
5) right to object to data processing;
6) right to complaint to the competent data processing authority.
For more details about the content of every right please do not hesitate to contact us.
Uttis Industries will facilitate the exert of your rights, therefore please do not hesitate to contact us at the email address: dataprotection@uttis.com

10. Your obligation or refuse to provide your personal data
As a general rule, Uttis Industries cannot oblige you to transmit your personal data.
However, in certain situations, if you do not transmit your personal data to us, we cannot fulfil the purposes defined above.
For example, as long as you will not send us the contract bearing your signature, we cannot consider that a valid contract has been concluded between you and us.

11. The absence of an automatic decision-making process
Uttis Industries does not own / use any automatic decision making process, including profiling of you and all decisions / actions / lack of actions / measures taken / adopted / implemented by our company are based solely on the human factor.
Although we use a series of IT equipment, the decisions in relation to you are adopted only by the people of our team, based on their own thoughts and appreciations, and not automatically by an IT equipment.

12. Change of the regulation
Uttis Industries informs you that the current regulation for processing your personal data describes how we are processing your personal data, at this point of time when you read this material.
There is the possibility to update this regulation in time (e.g. due to legislative changes, due to processing of your data for other purposes and / or based on other legal bases etc.).
In these last cases, the update of the regulation will be carried out without affecting, in any way, your legitimate rights and interests regarding the protection of personal data.

13. Regulation exclusivity
The present regulation for processing of personal data is the exclusive property of Uttis Industries.
Reproduction, in whole or in part, of this regulation is expressly prohibited without the prior written consent Uttis Industries.