2. Who are we?
We are Societate Dezvoltare Comercial Sudului (SDCS) S.R.L., the owner of the Sun Plaza shopping center and CPI Property Ro S.R.L., the administrator entrusted by the owner with the administration of the Sun Plaza shopping center. These two legal entities are the owner and the administrator of the Sun Plaza shopping center, respectively. Any references in this document to us, the undersigned and/or the Operator are made with respect to both of these two legal entities. Both entities undertake to protect the confidentiality of your personal data. CPI Property Ro S.R.L holds the status of person empowered by Societate Dezvoltare Comercial Sudului (SDCS) S.R.L associated operators, according to the definition given in Article 28 GDPR.
As controllers, we have concluded contracts to ensure that the processing of personal data takes place lawfully, in accordance with applicable law, including Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, (GDPR). This contract reflects the roles and responsibilities towards you and addresses the most appropriate position of each controller in order to fulfill its obligations towards you. This contract concluded between the two controllers does not affect your rights, according to the legal provisions on the protection of personal data.
3. Type of data collected and used
3.1. You can consult the Site without revealing your identity or providing any information regarding your Personal Data. However, information may be obtained automatically when visiting the Site, the web server recording the name of your internet service provider, as well as the IP address from which you visit us, but these cannot be automatically associated with you. Other Personal Data will only be stored if they are voluntarily provided by you.
3.2. At the time of subscribing to the Newsletter, as well as throughout the contractual period, we will inform you about:
the identity and contact details of the operators;
the contact details of the data protection officer;
the purposes for which the personal data are processed, as well as the legal basis for the processing;
the recipients or categories of recipients of the personal data;
if applicable, the intention of the operator to transfer personal data to a third country or an organization;
the period for which the personal data will be stored or, if this is not possible, the criteria used to determine this period;
the listing and explanation of your rights, according to the relevant legislation, also mentioned in the content of this Policy;
After which we will ask you for certain personal data, such as: a) Name and surname; b) Contact details (such as telephone number, e-mail address); c) Gender and age; d) Whether or not you have children, in order to provide you with information on products and services that may be of interest to you.
3.3. When you complete the Leasing Form, we will request certain personal data, in your capacity as a contact person, such as: a) Name and surname; b) Position in the company: c) Email address, in order to resolve your request.
3.4. When you complete the Opinion Form, we will request certain personal data, such as: a) Name and surname; b) Email address, in order to provide a response, if requested.
3.5. When you complete the Career Form, we will request certain personal data, such as: a) Name and surname; b) Email address, in order to contact you to complete the recruitment process.
c) telephone number in order to contact you to confirm your registration.
3.6. When you register to participate in various events, we will request certain personal data, such as: a) Name and surname; b) Email address, c) Telephone number for the purpose of contacting you to confirm your registration.
3.7. When accessing the Site, certain data is automatically transmitted by your browser and is collected and stored by us. This data includes, but is not limited to:
a) IP (internet protocol) addresses;
b) Browser type and version;
c) Type of device used and operating system;
d) Date and time of accessing the Site;
e) Your location.
3.8. You agree that your Data may be transferred for storage purposes to the server managed by the IT service provider or its subcontractors, provided that the technical, organizational and personal measures are maintained at the same level.
3.9. We will also collect and store all correspondence you send us, such as notifications, questions, requests.
4. Cookies
4.1. Certain information that is relevant to the use of the Site may be stored on your devices (desktop or mobile) in the form of cookies. These cookies help to improve the use of the Site, for example by remembering certain navigation options on the Site, such as the language in which the content of the Site is displayed, the type of filters that are applied when displaying certain pages. They also help us to better understand your interaction with our Site, your interests in certain areas or applications of the Site, which helps to improve it based on such Data and information, by introducing content relevant to you, etc. It is possible to disable the collection of this Data by blocking cookies in your browser settings, but certain functions of our Site may be affected.
4.2. Some of our business partners use cookies on our Site, for example, those who advertise. However, the Company does not have access to and cannot control these cookies.
4.3. First-time visitors to the Site have access to a cookie-disabled version with a banner informing them about cookies and that accessing the Site’s features implies acceptance of the use of cookies.
Legal notices
5. DATA COLLECTION
1.1 The Company collects your Data through various specific methods and tools such as: professional traffic tracking software, the Newsletter management application, by saving in databases the various contact forms available on the Site, which are completed by you, through online questionnaires, through social media accounts available on social networks: [Facebook, Instagram, Tik Tok], etc.
1.2 Any information provided by you will be considered and will represent express consent for the Personal Data to be used by the Company, in accordance with the above-mentioned purposes.
1.3 If you do not want your Data to be collected, you have the right not to provide it, but this implies unsubscribing from the Newsletter and the impossibility of receiving information about promotions in the shopping center owned by the Company and managed by CPI Property Ro S.R.L.
1.4 The legal basis for our use of Personal Data is the following circumstances:
In the following situations, we collect personal data only after obtaining your consent for this purpose, in order to:
send you marketing communications, if you have opted in to this;
advertising on social media channels;
using your mobile phone to confirm your presence at events;
using your location to send you certain messages with specific content; and
using your location to monitor the effectiveness of the messages sent.
1.5. In most cases, the collection and processing of personal data is in our legitimate interest to:
• provide you with a useful, enjoyable and beneficial service, to the extent possible, including by personalizing the way we welcome you, to ensure that we communicate to you all the offers of the tenants of the Sun Plaza shopping center stores and that they correspond to your preferences and to communicate information to you using your preferred method of communication; and
• better understand the Sun Plaza shopping center customer base, in order to improve our services and marketing activities, which may also be to your benefit.
1.6. When we rely on legitimate interest to collect and process personal data (including for the purpose of automated decision-making and profiling), we will need to consider whether these legitimate interests are not overridden by your fundamental rights and interests, and we will only continue to process the data if we decide that your interests, rights and freedoms do not override our legitimate interests.
1.7. We have considered these situations and in cases where we consider that there is a risk that one of your interests or fundamental rights and freedoms may be affected, we will not process your personal data, unless there is another legal basis to do so, such as if the processing is necessary to perform a contract with you or when you have given your consent. For example, we consider that the processing of your location outside the Sun Plaza mobile application and outside the Sun Plaza shopping center is intrusive and therefore we will not carry it out.
2. USE OF DATA
2.1 Your data will be used by the Company, as follows:
a) to produce statistical reports on your behavior on the Site;
b) to provide the requested information and to respond to correspondence received from you;
c) to send you information about us, our promotions and about our activities and events and those of the tenants of the Sun Plaza shopping center;
d) to deliver personalized content on the Site appropriate to your needs;
e) to involve all interested parties, on various occasions, in public participation activities and in order to maintain good relations with the community and fulfill various communication tasks;
f) to develop the loyalty program, intended for loyal customers;
g) for other specific uses within campaigns, promotions or local activations (please consult the specific regulations made available in these cases). We request optional data regarding whether or not you have children, in order to send you personalized information, which may be of interest to parents and less so to people without children;
h) to contact you when necessary;
i) to fulfill legal obligations and social responsibilities, according to Romanian and international laws.
2.2. Your data will be stored for the entire period of existence of the Newsletter subscription. The Company will delete your Data related to the Newsletter subscription as soon as you decide to unsubscribe from the Newsletter.
3. ACCESS TO DATA
3.1. We may disclose personal data to our subcontractors and other authorized persons who perform certain services for us. These third parties are those who:
-process information to determine whether you are eligible to benefit from a discount or offer within the shopping center; to the extent that you have given us consent to proceed accordingly:
– communicate with you by email or social media applications;
– use your personal data within social media applications (through our advertising agency) which uses this data only for the purpose of identifying other people who are similar to you and with whom you may have common preferences, in order to be able to offer them our products on social media platforms;
– use your location to provide you with a specific electronic communication service;
-use your location to provide you with specific website content.
3.2. In certain cases, the personal data we collect may be processed outside the European Union and such destinations will need to benefit from at least the same level of protection as those available within the European Union. We are obliged to treat your personal data that is processed by us or by our partners located outside the European Union confidentially and protected against unauthorized access, loss or destruction, unauthorized processing and processing that is inconsistent with the purposes mentioned in these policies.
3.3 These subcontractors of the company, with whom we share personal data, can be accessed by clicking on this link.
3.4. We may also disclose personal data in situations such as:
• to the extent that we are required by law to disclose such data or to protect our rights, interests, property or safety, our customers or other third parties. This includes in some cases exchanging information with other companies and organizations for the purpose of preventing money laundering or terrorist acts; and
• to our successors in title or in the event of a change of administrator or other authorized person.
3.5 We will take all necessary security measures to protect your Personal Data against unauthorized access to the Data or unauthorized modification, disclosure or destruction of the Data. This involves internal reviews of data collection, storage and processing practices and security measures, as well as physical security measures to protect against unauthorized access to the systems where we store personal data.
3.6. All personal information will be processed through secure pages that use the SSL encryption system, marked with a padlock symbol, positioned at the bottom of the browser window.
4. RIGHTS OF THE SITE USERS
4.1 In accordance with the provisions of the GDPR Regulation, persons who simply use the Site, who have subscribed to the Newsletter, as data subjects, have the following rights:
To obtain the transmission of Data to another operator in a readable manner by automated means (data portability);
To request that we transmit to you clear, transparent and easily understandable information on the ways in which we use your personal data and the rights you have (right to be informed).
To obtain confirmation from us as to whether or not we process Data concerning you and, if so, to access this data and to inform you as to how this data is stored. This right can be exercised once a year free of charge (right of access).
To request the rectification of personal data, if they are incorrect or incomplete (right of rectification).
To request the deletion of the Data without delay in any case or when they are no longer necessary for the purpose for which they were initially collected or processed; The User withdraws his/her consent and there is no overriding legitimate interest; The Data have been processed unlawfully; The Data must be deleted to comply with a legal obligation; The Data have been obtained solely for the purpose of providing information technology services (right to be forgotten);
To restrict the processing of personal data, meaning the right to block or suppress the further use of personal data. When processing is restricted, we may continue to store the data, but we will no longer be able to use it. We will keep a record of the persons who have requested us to restrict the processing of their data, in order to block them and to ensure that the restriction is respected in the future
To object to the collection, storage and processing of the Data, when the processing is necessary only for the performance of a task or obligation that serves a public interest or when it serves a legitimate interest of the Company. When the Company processes the Data for direct marketing purposes, this right can be exercised by the User at any time (right to object);
To request more information on the automation capacity (data export solutions, storage limits) through an access request and we are obliged to provide you with such data in a commonly used electronic manner;
To request that access to the data be suspended, while complaints are being resolved;
To be notified without delay in the event of any Personal Data breach.
If the Company receives such a notification by which the User exercises his rights, the Company must act within 2 weeks. If the request is complex, the Company must act within 1 month from the receipt of the request.
Such rights shall be addressed to the following address: Bucharest, sector 4, Calea Văcăreşti, no. 391, 2nd floor, room 1 or by email to the following e-mail address: [email protected]
5. OBLIGATIONS OF THE SITE USERS
5.1 As a User of our Site, you have the following obligations:
a) to provide true, accurate and complete Data about yourself, as required by the registration form on the Site. If your Data is not true, accurate and complete, you have the obligation to notify us as soon as possible in order to remedy this situation;
b) to maintain and update your Data to be true, accurate and complete, when the situation requires it;
c) not to publish obscene, defamatory, threatening or malicious materials towards another user, towards the Company’s Business Partners or towards third parties, materials or information prohibited by the legal provisions in force;
5.2 In case of failure to comply with these conditions, the Company will dissociate itself from their author, will delete the respective information and reserves the right to take legal action.
6. DURATION OF DATA STORAGE
6.1. The Company will store the Personal Data provided by you for the entire duration of the Newsletter subscription, in accordance with point 5.2. and until the resolution of your requests according to 3.3., 3.4. and 3.5. and until the completion of the event according to 3.6.
6.2. The Company will ensure that the personal data concerning you will also be deleted by the subcontractors who have access to them at the time of termination of the service contract with the respective subcontractor or upon receipt by us, in writing, of your option to unsubscribe or to object to the processing or the right to be forgotten or for a period of 3 years from your last interaction with us through accessing the site.
7. MODIFICATION/ADDITIONALITY OF THIS PRIVACY POLICY
7.1 We reserve the right to modify/addition to this Privacy Policy from time to time, as a result of legislative changes or the type of Site, and will update these Policies accordingly.
7.2 The updated Privacy Policy will be published on the Site and will enter into force from the moment of publication.
7.3 By continuing to use the Site after the entry into force of any modifications/additions, the User agrees to comply with them.
7.4 The User is advised to periodically check this Privacy Policy.
IF THE USER DOES NOT WANT TO ACCEPT THE PRESENCE OF THE PRIVACY POLICY, INCLUDING SUBSEQUENT MODIFICATIONS/ADDITIONALITY, THEY WILL NO LONGER BE ABLE TO USE THE SITE.
8. LEGAL CHANGES WITHIN THE COMPANY
In the event that we are involved in a reorganization, merger, acquisition or any other change in control of us or transfer of assets, your Personal Data may be transferred as part of that transaction, at which time we will notify you to inform you of your rights and request your consent to such transfer.
