Your Privacy is Important to Us
Our Privacy Policy

1. WHO IS THE CONTROLLER RESPONSIBLE FOR PROCESSING YOUR DATA? 

Softelligence is a software company with its main offices in Romania and the United Kingdom. Please find here the locations of our offices around the world.

The data controller responsible for the processing of your personal data is either (depending on which entity you establish a relationship with – contract, attending to events, collaboration as a partner):

1. Softelligence S.R.L., headquartered at Gara Herastrau Street, no. 4D, Green Court, Building C, 2nd floor, Bucharest, District 2, Romania, Trade Registry No. J40/1411/2008, Unique Identification Code (CUI) RO19333723;
2. Softelligence Engineering S.R.L., having its head office at 4D Gara Herastrau Street, Green Court, Building C, 2nd floor, Bucharest, sector 2, Romania, registered to the Trade Registry under the number J40/15675/28.11.2016, V.A.T. registration number RO36788806;
3. Softelligence UK Limited, a company incorporated in England (registered no. 10614103) and having its registered office at New Broad Street House, 35 New Broad Street, London, United Kingdom, EC2M1NH;
4. Softelligence MK Dooel Skopje, – Company with the main place of business at St. Orce Nikolov 206-1/17 Skopje (hereinafter referred to as “Softelligence”). 

For the data collected via the Website for its users, all Softelligence entities shall act as joint controllers. As per their agreement, Softelligence S.R.L. will have access to the data collected via the Website as the administrator. Also, any data collected in the context of surveys/marketing campaigns/events via the Website shall have the same regime. Once the data is shared with the relevant Softelligence entity, such shall be deemed as independent controller for that data. Hence the joint controllership relation only covers the collection, storage and sharing of the data collected via the Website between the entities by Softelligence S.R.L., depending on the connection of the data with them. So, the entities establish the means and purposes for the processing only for these specific activities. Softelligence S.R.L. will keep the data of the other entities only in the relevant correspondence proving it complied with its obligations and redirected your request, or, if the case, compliance with its own legal obligations as well as the backup and database of the Website to assist the relevant entity with any information it may need in relation with you. All entities will have access to the aggregate form of the Website performance, traffic, and other user related analysis.

The entities will inform you together on the manner they process your data via this Policy. The joint controllership only refers to the data collected via the Website, for which the details bellow apply. For the data collected via the Website you can address your concern to any relevant Softelligence entity which you consider is concerned by your request/complaint/query. All entities will collaborate in handling your requests. 

Separately from the Website, only one Softelligence entity acts as independent controller with respect to your Personal Data (the entity with which your relationship is established – e.g., which is your services provider, partner, event organiser, potential employer) and determines the purpose and manner in which your Personal Data is processed, as described below. Other Softelligence entities may also act as processors in the context of services provision – e.g. be involved in the services provision under the control of the Softelligence entity you collaborate with.

Softelligence cares about protecting the right to privacy of individuals and, while we may rely on local laws, we aim to uphold the Personal Data protection standards of the GDPR even for non-EU Softelligence’s entities, as possible. If you disclose data to us or share data with us about other individuals, such as family members, co-workers, etc., we assume that you are authorized to do so, and that the relevant data is accurate. Please make sure that these individuals have been informed about this Policy.

2. CATEGORIES OF DATA SUBJECTS

This Policy refers to:

• business clients: legal entities or individuals operating within a profession (for example, authorized natural persons, liberal professions, individual enterprises, etc.), as well as any potential Business Client to whom we address our commercial offers or communications, respectively former clients. 
• Clients Representatives: natural persons acting as legal or, as the case may be, conventional representatives, as well as contacts within potential, current or former Clients; 
• users of the www.softeligence.net website (“the Website”); 
• collaborators and / or business partners of Softelligence and/or their staff involved in the performance of the contractual obligations assumed by Softelligence; and
• persons attending events organized by or with the involvement of Softelligence.
• collectively referred to as “Data Subjects“).

3. WHAT ARE THE CATEGORIES OF PERSONAL DATA WE PROCESS?

Your personal data is usually collected directly via our Website, by e-mail, through social media accounts, through our call center, through the platforms & applications used by us, through the contracts signed with us and through the post / courier. Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all the categories of data listed below: 

• Identification data, for example: your name and surname, nationality, and signature, data regarding the capacity of representative / authorized representative of the Client, image, voice; Tax identification and similar unique identifiers – if you act as a Business Client; for example, the tax identification code; 
• Contact Details, for example your e-mail address, your domicile or residence, your number; landline and/or mobile phone as well as your I.P. address; e-mail; 
• Account data, for example the Client number, the invoices issued, the payments made and the payment history, the date of signing the contract, offers, returns, expressed permissions, benefits and advantages, etc.; 
• Financial data, for example information about your card, credit/debit, information about your account, banking and other banking information, return requests and their status, information on the reasons for requesting reimbursement of payments; 
• Qualification data, for example, profession or occupation (for example, in cases where you are acting as a representative or contact person for a Business Client); 
• Data collected by cookies and similar technologies. For details please visit the cookie policy of Softelligence, at https://www.softelligence.net/cookies-policy/. 
• Data related to your device (to access the Website): device type, I.P.; 
• Client Relationship Data, e.g. (i) notes or records of a phone call with customer service, or a live chat/e-mail correspondence, (ii) details of your complaints, questions, contract requests or feedback, (iii) requests for access to your personal data, personal and other requests to exercise your rights, according to the legislation on the protection of personal data, (iv) other records of your interactions with us, regardless of the medium (notes, records, etc.), including their average duration, (v) information regarding your level of satisfaction with our services and/or other services suppliers on the market, (vi) video recordings of your interaction with our agents, if the case; 
• User/Event participant Relationship Data, as applicable, e.g. (i) e-mail correspondence, (ii) details of your complaints, questions, services requests or feedback, (iii) requests for access to your personal data, personal and other requests to exercise your rights, according to the legislation on the protection of personal data, (iv) other records of your interactions with us, regardless of the medium (notes, records, etc.); (v) information regarding your level of satisfaction with our services and/or other services suppliers on the market; (vi) permissions to receive newsletters. 
• Service interaction data, e.g. (i) details of your use of our services; (ii) information about service errors, as well as other events that may affect our services quality, (iii) information about the benefits and offers accessed.
• Data regarding the relationship with our partners and their staff, as the case may be: for example: (i) notes or records of a phone call with the relationship service, or a live chat/e-mail correspondence, (ii) details of complaints, questions, requests related to the contract or your feedback, (iii) requests for access to your personal data and other requests to exercise your rights, according to the legislation on the protection of personal data, (iv) other records of your interactions with us, regardless of the medium (notes, records, etc.), including their average duration, (v) video recordings of your interaction with our agents. 
• Inferred data: this category includes data generated or inferred by us based on the data we hold about you, regardless of its source (i.e., obtained directly from you, from interaction with our services or from external sources, as the case may be). For example, we can anticipate your preferences or your areas of interest based on the services purchased, we can segment clients (as the case may be, nominal or pseudonymized).

4. WHERE DO WE GET YOUR DATA FROM?

We may obtain your personal data: 

• a. directly from you, i.e. (i) when you directly provide us with the information, either in writing (e.g., by filling out a form) or verbally (e.g., as a result of your telephone conversation) or (ii) by examining the interaction we have with you. For example, we will obtain your personal data when: (i) you buy any of our services, (ii) you enter into a service contract with us, (iii) you subscribe to receive commercial communications or other offers and information from us or our partners, (iv) you contact us through various channels or request information / offers regarding a service; (v) you participate in promotions, contests, sweepstakes, promotional lotteries, or various studies and analyses organized or sponsored by Softellingece or in partnership with us, (vi) visit or browse our Website. 
• b. from sources other than directly from you, namely: (i) from external sources, or (ii) Inferred data that we generate based on the data we hold about you. 

The external sources from which we can obtain your personal data Include: 

• Public sources, for example websites or social media pages, public databases (including the trade register database, the database of the Ministry of Finance, the Official Gazette for partners who are legal entities, etc.). 
• Third private entities, namely: (i) our suppliers or contractors (including financial service providers – for example, the status of a payment), (ii) Business Clients – when you act as their representative or contact person; (iii) survey and market research agencies, e.g., your telephone and feedback on our services; (iv) our business partners, when you act as their representative/employer/collaborator.
• Public authorities or institutions, for example in the context of judicial investigations, requests of courts of trial, requests related to your complaints (in which case we may find out certain information about you).
• People who represent you or contact us on your behalf 
• Inferred data that we generate based on the data we hold about you, such as: the level at which you benefit from the services – for example, failures in the context of delivery or other events that trigger service termination/suspension; details of your use of certain services;

5. WHAT ARE THE PURPOSES AND GROUNDS FOR WHICH WE PROCESS YOUR PERSONAL DATA?

5.1. We collect and use your Personal Data as a Business Client (acting within a proffession as individuals), including a Prospective Client for the following purposes:

A. Conclusion and management of Clients’ contracts

To facilitate the provision of services online (including the execution of the contract and the completion of the specific order, communication with the user of the Website and sending information messages about the stages of the contract, providing clarifications related to the order and, in general, information on the purchases made). For this purpose, we may collect the following data, within the limits of the needs: Identification data: name and surname, the company you represent, industry, you position; Contact details: phone number/e-mail address, delivery address, billing address, Financial data: payment data, Account data: services history, favorite services, Client relationship data and Services interaction data.

Legal grounds: conclusion and execution of the contract with you when we talk about processing operations that have a close connection with our contractual relationship and our legitimate interests: to prove the performance of our contractual obligations or the imputation of non-performance of the contract; to ensure the quality of our services and proper management of the relationship with Clients; to keep adequate records of the orders placed and/or the instructions specific to the related contractual relationships; proper communication with you to ensure the proper delivery of services and adequate information on our services; facilitating the placement of orders, their tracking and their modification/ cancellation; providing benefits for Clients loyalty.

How long do we keep your data (depending on the specific situation): the data closely related to the contract and the customer account will be kept for the entire duration of the contractual relationship, plus at least another 3 years after the termination; in the event of disputes/investigations/procedures, the data and documents will be kept for the duration of their development, and for a period of 3 years from the final settlement. 

What happens if you do not provide us with the data from the standard forms / or requested by our colleagues: the data we ask you for is mandatory for the proper conclusion / modification and execution of the contract. The refusal to provide those data marked by us as mandatory may prevent the conclusion of the contract, affect its proper performance, lead to the cancellation or suspension of the services, as the case may be.

B. Billing and payment processing

Such includes: (i) processing the payments you make – payment to our bank accounts or reimbursements made by us; (ii) issuing invoices for the services purchased, collecting the correct amounts, or repaying the correct amounts on request; (iii) communicating with you to ensure the correct payment of the services/clarify the status of a payment; 

We use the following categories of data: Identification data (such as your first and last name), position; Contact details (such as business address, e-mail address, telephone number); Account data (such as invoices, payment history, history of any other information related to the payment of the services, gift cards); Financial data, as well as any other information you request/provide to us or the person acting for you. 

Legal grounds: our legitimate interests: to ensure the payment in good conditions of the services, validate payments with errors, facilitate the delivery of orders on time in case of erroneous payments, ensure the processing of payments in an efficient and easy way for Clients; the conclusion and execution of the contract with you; our legal obligations: to include certain information in invoices or to request certain information in case of reimbursement of amounts of money, to keep records of orders and related payments, to make available information and report to public authorities.

How long do we keep your data (depending on the specific situation): billing-relevant information (including contracts), payment records and documents relating to the settlement of payments, will be kept for 10 years from the time of the end of the financial year in which it was issued/concluded; correspondences with you related to the above purpose will be kept for the duration of the relationship with you (as long as you have an active account with us), for a maximum of 10 years after creation; 

What happens if you do not provide us with the data from the billing order forms or requested by our colleagues: the requested data is mandatory for the proper processing of the payment and the issuance of invoices to you; without them we cannot issue you the invoices according to the law, respectively the payments cannot be processed properly and thus we will not be able to provide the services to you/the company you represent, your services being suspended/terminated, as the case may be.

C. Assistance and management of the relationship with Clients, respectively: 

• informing about the amounts owed to us, the status of payments and / or consequences of non-compliance with the contracts you have concluded with us; 
• managing any questions or requests, including complaints you or other persons may have regarding our services/contractual relationship with us, including to provide you with any information required by law; 
• sending messages about services purchased or benefiting from free of charge (so-called ‘functional messages’). 

We would like to keep you informed about various aspects related to the services you have bought, for example regarding the modification of our terms and conditions or the removal of some services from the Website, the termination of the contract, or other accessories for the services necessary for their operation. 

We use the following data: Identification data (such as name, surname); Contact details (such as e-mail address, telephone number, home address, mailing address); Client relationship data (such as delaying services delivery, services defects, payment errors and any other issues raised by you); any other data provided by you by means of the requests and documents submitted in support thereof; any other data in the categories listed above related to the relationship with you necessary for the settlement of requests.

Legal grounds: conclusion and execution of contract for orders placed by you or for you, in relation to activities closely related to the contract; our legitimate interests to ensure the proper performance of the contract and a good relationship with you and to defend our rights and interests in judicial, administrative or similar proceedings, or to properly manage any request you submit to us and to improve our services; specific legal obligations in the field (e.g., the processing of certain data on a mandatory basis in the form dedicated to the complaint and for settlement, the obligation to send you the invoice for your order, etc.); your consent if you contact us by phone and the call is recorded. 

How long do we keep your data (depending on the specific situation): during the resolution of your request and after the settlement for a duration of 3 years for the solved claims, respectively for the duration of any disputes / procedures and for a duration of 3 years after their final settlement, or, as the case may be, for other durations imposed according to our legal obligations. 

What happens if you do not provide us with the data from the standard forms / or requested by our colleagues: the data we request from you is mandatory for the proper resolution of your requests. Your refusal to provide that data may prevent or affect the full resolution of your request. (e.g., refusal due to lack of sufficient information, delays, partial settlement, etc.), and implicitly the services, if they depend on the resolution of your request. If you choose to contact us through another communication channel operated by a third party (e.g. WhatsApp, Facebook) we will share your personal data with the owner of this channel to confirm that you are a user of this service. We recommend that you check your privacy settings and read the privacy policy of the respective operators to obtain more detailed information on how they use the personal data of users of the services they provide. If you do not agree to the recording of calls, you can contact us on the other communication channels.

D. Promoting our image and services. Improving the relationship with Clients

For the purpose of communicating commercial materials, newsletters and / or alerts from Softelligence, consisting of information on service offers, invitations to participate in campaigns and lotteries, studies, questionnaires, opinion polls, vouchers and / or gift vouchers offered on birthdays sent by electronic mail (e-mail, SMS, M.M.S.), push notifications, social media platforms on which you have an account and / or phone call, for marketing purposes, respectively to promote Softelligence services and to improve the experience offered on our Website. 

What data we use: Identification data: name, surname; Contact details: e-mail address, telephone number, postal address; Data regarding your qualification; Client relationship data; Account details.

Legal grounds: regardless of the type of services we use: 

• calls (human or automated), e-mails, online channels – based on your consent; 
• mailing address to promote you our services and our activity (post / courier) – based on our legitimate interest in keeping you up to date about the services that may be of interest to you. If you no longer wish to receive such communications, please send us your opposition at the coordinates at the end of this Policy; 
• your choice marketing and respectively the proof of acknowledgment of this privacy policy – based on our legitimate interest in keeping a record of compliance with our specific obligations in the matter and in defending our rights and interests, if any.

You can unsubscribe from these communications at any time by clicking the “unsubscribe” link or button in our messages or by writing to us at privacy@softelligence.net .  If you withdraw your consent or do not provide us with contact details for this purpose from the start, you will no longer receive commercial communications from us by e-mail, telephone (including automated calls) or online channels.

How long we keep your data (depending on the specific situation): we keep your marketing option and respectively the proof of acknowledgment of this privacy policy during the period when it is not withdrawn, respectively for a period of 3 years from the withdrawal, and by way of exception, during any procedures / disputes / controls involving these data.

E. Improving your relationship with you and our services 

In order to carry out various analyzes, internal reports on the operation of the Website, the creation of basic profiles related to your data demographic and consumer preferences, for marketing purposes, mainly in order to improve the experience offered by Softelligence. These analytical data are aggregated data that cannot directly identify you and may be based on general information related to you. 

When you visit our Website, www.softelligence.net, we collect certain data to monitor the traffic and improve the content of the Website. For these purposes, we use cookies and similar technologies, as detailed in our Cookies Policy.

Information processed for these purposes can include: hour and date of accessing the Website and the I.P. address, details about the browser or operating system, country / city, various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system.

Legal grounds: The processing of your data for this purpose is based on the legitimate interest of Softelligence to permanently improve the Client experience and to help us understand their needs and expectations regarding the services we offer. The provision of your data for this purpose is voluntary. We base our data processing for monitoring the traffic and improving the Website on (i) your consent for accepting the required cookies (granted upon your interaction with the cookie banner implemented on our Website) and (ii) our legitimate interest in ensuring the proper functioning of our Website, as well as to help us design our Website to better suit our users’ needs, to help diagnose problems with our server and to analyse trends and gather broad demographic information that assists us in identifying visitor preferences.

How long we keep the data: the data underlying the analyses extracted from the main databases will be kept for a very short period of time, until the aggregated analyses are generated. Refusing to provide data for this purpose will not have negative consequences for you. In respect to the data processed via cookies/similar technologies see the duration reffered to in our Cookies Policy.

F. Surveys, market studies and other internal analyses 

To communicate with you in the process of conducting surveys about customer satisfaction for analysis purposes, for quality improvements, for service developments, to measure the success of advertising campaigns or to adapt our services to your requirements. 

We use the following data: Identification data: name, surname, contact details: telephone number and e-mail address, city of residence; Demographics: age range, gender; Customer value management data: type of services, utility, data related to your opinion on our services and your expectations from a supplier of such services; your feedback about the campaigns we run, communicating with you. 

Legal grounds: our legitimate interests to know the opinion and preferences of Clients regarding our services or other suppliers, as well as to optimize our activity and identify new opportunities for the development and promotion of services and activity in general; your consent expressed in the context of the surveys/market studies we conduct. Your participation in such surveys or market studies is voluntary. Consequently, it is your choice whether or not to provide us with the data by filling in the participation forms on our Website or other similar forms provided in the framework of the respective surveys or studies

We will ensure that we only use personal data if such use is necessary to achieve the intended purpose. As a rule, the result of internal analyzes and studies is in an anonymized format.

Where can we get the above data: in general, we use the data that: we receive from you. (directly or through our partners – such as marketing, promotion and market research agencies), or we generate or infer based on the information we hold about you.

How long we keep your data (depending on the specific situation): in the case of the data underlying the studies, surveys, analyses with anonymized results – for the time necessary to transform into anonymized statistics, but not more than 6 months after the survey / market study or the internal analysis / study. If they are not anonymized, the results of studies, surveys, analyzes will be kept for 1 year from the date of their generation and will not be made public. 

What happens if you do not provide us with the data: if you do not want to participate in our surveys or studies or, as the case may be, provide us with certain information for this purpose, we may not implement or take into account certain of your suggestions or other matters of interest to you. In any case, your refusal to do so will not in any way affect your relationship with Softelligence. Certain surveys may be conducted through our Website. For data processed through cookies and new technologies in this case see our Cookie Policy.

G. Economic, financial and administrative management. 

We process your personal data to optimally organize and streamline our work. In this regard, we can use the data, among others: to improve and optimize the activity of Softelligence as well as our services; to support our position in various investigations, administrative and judicial procedures, litigations, etc. in which Softelligence is involved; in the context of various analyses, internal audit procedures and/ or investigations carried out by Softelligence, on its own initiative or as a result of receiving a referral from a third entity (including public authorities); management of controls/investigations triggered by public authorities.  

We use Account Data, Identification Data, Contact Details, depending on the typology of the investigation / purpose pursued; Financial Data, Client Relationship Data.

Legal grounds: our legitimate interest to improve our services and relationship with Clients, to optimize and streamline our activity, including by sharing data with our affiliates, but also to defend our interests and rights, to properly manage the payment process for the services provided, to adequately research the activity and identify potential irregularities, respectively to comply with the requirements of public controls; our legal obligations, such as to issue invoices in a certain format, to transmit them in a certain way, to keep records and supporting accounting documentation. 

We can obtain the data from: the competent authorities (for example, the O.P.C.), when circulating with new notifications on complaints / referrals / other aspects; other persons, who may provide us with data according to your request, when acting as your proxies in relation to Softelligence; our financial and banking service providers, for payments made directly by you to our bank accounts; other service providers, depending on the specifics of the investigation. 

How long we keep your data (depending on the specific situation): during the investigations/procedures/audits, including the recovery procedures and after the settlement for a period of 3 years; during any disputes, if any, and 3 years after receipt of a final decision, for the duration imposed by the public authorities, within the limits of their competences. 

What happens if you do not provide us with the data: the data we request from you is mandatory for the proper resolution of the investigated situations. The refusal to provide data in line with the legal provisions may affect our contractual relationship.

H. Security. Preventing improper use of services and Clients’ data. Fraud and incident prevention and management.

We will process your personal data to ensure the security of your Client Data as well as our services. We may use your personal data personal to ensure the functionality and performance of the technical solutions we use in our work. Our systems detect and flag events that could constitute misuse or misuse of our systems and apps, as appropriate, that could affect the security of our systems, generate alerts and automatically cause specific actions to be taken. For example, when systems detect that there has been a repeated attempt to access an account without the password being hit and request that it be reset, they will alert us about these login attempts. 

We will process your personal data to combat and possible fraud regarding the fraudulent conclusion of a contract or use of services, which may take place in the context of the provision of our services. We may process any of the above data, depending on the specifics of the situation. Identification Data, Login Data, Contact Details, Account Details, Customer Relationship Data will most frequently be processed. 

Legal grounds: our legitimate interests to ensure the proper security of our services, to investigate, prevent and report any fraudulent, improper or abusive use and to prevent the risk of financial loss arising from illegal accesses or fictitious payments of services; our legitimate interests to comply with the legal obligations and requirements regarding the level of security provided to the data and information processed by us, respectively to identify and prevent incidents, minimize damages and exercise correlative rights in the context of situations of unauthorized access in any way to the systems / other locations where we keep information. 

How long we keep your data (depending on the specific situation): during the investigations/procedures/security audits, including the recovery procedures and after the resolution for a period of 3 years; during any disputes, if any, and 3 years after receipt of a final decision, for the duration imposed by the public authorities, within the limits of their competences; during the resolution of security complaints /incidents and for a period of 3 years after the closure of the settlement / investigation process.

What happens if you do not provide us with the data: The data we request from you is mandatory for the proper resolution of the investigated situations. The refusal to provide data in accordance with the legal provisions may affect our contractual relationship, namely the security of your data.

I. Trainings and evaluation of our personnel/collaborators’ performance

Conducting trainings and evaluating our personnel/collaborators’ performance. As a rule, for this purpose, we will process Clients Relationship Data, User Relationship Data and Inferred Data.

Legal grounds: our legitimate interest to train our personnel and to evaluate and improve their performance.

Your data will not be kept separately for this purpose.

J. Interacting through Social Media 

We process your personal data when using your profile registered in a social network, for example, Facebook, Instagram or LinkedIn or other similar portals (called “Social Media”) to interact with our professional pages on these social networks. We use these Social Media pages and the tools that are made available to us by the operators of these platforms for the following purposes: customer support and relationship, measuring the performance of Social Media pages, promoting the image of our company and personalizing the content and advertisements in Social Media and defending our rights and interests. The corelative details to these purposes apply accordingly.

K. Defending the rights and interests of Softelligence and our Clients

We use any of the data categories in the Softelligence systems, appropriate to the type of procedure/investigation/litigation/official audit. 

Legal grounds: our legitimate interests to defend our rights and interests in the context of situations in which Softelligence’s image and interests would be exposed or affected, respectively to keep evidence of our rights and interests as well as our compliance with specific legal obligations (for example, solving complaints within the time limit required by law or data protection, the manner of settlement, identification and proof of identification of clients/other individuals before making changes in orders/providing customer account data, etc.); our legal obligations, such as those to comply with the requests of public authorities / courts / other public institutions that have the power to impose certain processing operations on us; the obligation to archive certain documents/information according to the archiving rules or other regulations applicable to Softelligence; the obligation to notify confidentiality/security incidents to the competent authorities, etc. 

From where we may obtain the above data: from any of the sources mentioned in the above purposes, as well as from the authorities, institutions or courts involved.

How long we keep your data (depending on the specific situation): for the duration required by the specific legal provisions; where there are no rules, during the procedure/audit/investigation/dispute, and for a period of 3 years from the end of that procedure, taking into account the limitation period applicable to the specific situation; for the duration imposed by the competent authority/institution/court, according to the legal provisions; for the duration requested by you for the protection of your rights and interests or of a third person who has a legitimate interest in doing so. 

What happens if you do not provide us with the data: In certain situations, refusing to provide us with data may result in your contractual or civil liability in relation to Softelligence, other persons whose rights/interests would be affected.

L. Fulfillment of legal obligations 

For the fulfillment of the legal obligations’ incumbent on Softelligence in the context of the services provided through the Website, including the obligations in tax matters, as well as in archiving matters. (e.g., issuing tax invoices related to the services or granting the guarantee associated with such). Any of your personal data above may be processed. 

Legal grounds: The processing of your data for this purpose is necessary based on legal obligations when the law expressly provides for the processing of certain data – e.g. providing the guarantee, the obligation to archive certain documents / information according to the archiving rules or other applicable regulations; the obligation to notify confidentiality / security incidents to the competent authorities, respectively our legitimate interest in complying with legal obligations involving certain processing, where the law does not establish exactly what data will be processed, such as those to comply with the requests of public authorities / courts / other public institutions that have the competence to impose certain processing operations on us; the obligation to notify confidentiality/security incidents to the competent authorities, etc. 

What happens if you do not provide us with the data: In certain situations, refusing to provide us with data may result in your contractual or civil liability in the relationship with us, or may even lead to the termination / non-conclusion of the contract with you if we are talking about mandatory data for our relationship.

M. Mergers and Acquisitions 

If we are involved in a corporate law transaction (for example, merger, spin-off or sale of the business), we will share or, as the case may be, receive your personal data from the entities involved. We transfer/receive your personal data and for the purpose of integrating databases with the clients of the companies involved in the transaction. For this purpose, we transfer certain Contact Details, Account Details or other data related to you to the companies involved in the transaction as a beneficiary for the integration of customer databases in the transfer in which you are already a client of the other entity involved in the transaction. In the transfer of a planned corporate transaction (e.g., in which our Group or we buy or sell a business), we may use (communicate to the party involved in the transaction) your personal data, personal information to identify and plan the best way to realize any commercial opportunities and possible improvements quickly and efficiently in services in the transfer of that corporate transaction. For example, we may communicate or obtain certain Client data, such as Contact Details, Account Details (e.g., the type of offers/benefits used). As a rule, this information will be transmitted/received in pseudonymized or anonymized form. In all cases, we will additionally communicate or process (as the case may be) personal data only based on an appropriate analysis and risk mitigation measures to ensure that they are not prevalent fundamental rights of the data subjects that could be affected. 

Legal grounds: the legitimate interest of us and/or the third-party entity (party to the transaction) to identify, plan and implement the best way to realize any commercial opportunities and database integration when appropriate and possible service improvements, or your consent quickly and efficiently. 

How long we will keep the data: the data extracted for this purpose will not be kept separately longer than during the acquisition process and for 3 years after its conclusion. If they are the subject of formal procedures, disputes, the retention periods specific to these purposes will apply.

5.2. We collect and use your Personal Data as a representative/employee of the Business Client (both legal entities and professionals), including a Prospective Client for all the above-mentioned purposes, as the case may be, strictly to allow the fulfillment of such purposes for the Client you act for/legally represent or for which you are the main contact. As a rule, the following data will be processed: Identification Data, Contact Data, Client Relationship Data (including your voice), Inferred data (e.g., the date and hour of the interaction with you).

Legal Grounds: our legitimate interests as described at the above-mentioned purposes and our specific legal obligations, as the case may be. For all the processing operations connected to the contract performance, the corelative legal ground will be instead of contract conclusion and performance our legitimate interest to conclude and ensure adequate performance of the contracts concluded with our clients. In case of recorded call, your consent shall be the legal ground applicable. All the other details described in the Business Clients section above shall apply accordingly.

5.3. If you are a user of the Website, Softelligence may process your personal data as follows (in addition to the specific purposes of other qualities Client, Partner, Participant to our events):

A. For direct marketing activities, respectively, for the transmission through the e-mail of commercial communications (newsletters) regarding the services offered by Softelligence through the Website. As a general rule, these personal data will only be processed for direct marketing purposes with your consent and through the use of electronic communication channels. 

We will use: Contact Details: your e-mail address, Account data: your permission, date and time of expressing it, withdrawal of your consent, and the corresponding time coordinates.

Legal grounds: The processing of your data for this purpose is based on your consent if you choose to provide it in the section dedicated to newsletters. You can unsubscribe from these communications at any time by: clicking the “unsubscribe” link or button in our messages or by writing to us at privacy@softelligence.net. If you withdraw your consent or do not provide us with contact details for this purpose from the start, you will no longer receive commercial communications from us by e-mail.  

How much we keep your data (depending on the specific situation): we keep your choice. marketing and proof of acknowledgment of this privacy policy for as long as it is not withdrawn, respectively for a period of 3 years from withdrawal, and by exception, for the duration of any procedures / disputes / controls involving this data.

B. Assistance and management of the relationship with website users who are not Clients: management of any questions or requests, including complaints you may have regarding our services and the processing of your data, including to provide you with any information required by law, on any communication channel.

We use the following data: Identification data (such as name, surname); Contact details (such as e-mail address, telephone number, home address, mailing address); User relationship data (such as complaint history, correspondence, and records with you); any other data provided by you by means of requests and documents submitted in support thereof; any other data from the categories listed above under Clients related to the relationship with you necessary to resolve requests. 

Legal grounds: our legitimate interests in ensuring a good relationship with you and to defend our rights and interests in judicial, administrative or similar proceedings, to properly handle any request you submit to us and to improve our services; specific legal obligations in the field (e.g., the processing of certain data mandatory in the form dedicated to the complaint and for resolution, the obligation to keep certain documents according to the law, etc.); your consent in case you contact us by phone and the call is recorded. 

How much we keep your data (depending on the specific situation): for the duration of solving your request and after settlement for a duration of 3 years for settled claims, respectively for the duration of any disputes / procedures and for a duration of 3 years after their final settlement, or for other durations imposed according to our legal obligations. 

What happens if you do not provide us with the data from the standard forms / or requested by our colleagues: the data we request from you is mandatory for the proper handling of your requests. Your refusal to provide that data may prevent or affect the complete resolution of your request. (e.g., refusal due to lack of sufficient information, delays, partial settlement, etc.). If you choose to contact us through another communication channel operated by a third party (e.g. WhatsApp, Facebook) we will share your personal data with the owner of this channel to confirm that you are a user of this service. We recommend that you check the privacy settings and read the privacy policy of the respective operators to obtain more detailed information on how they use the personal data of users of the services they provide. If you do not agree to call recording, you can contact us on our other communication channels.

C. To monitor traffic and improve your experience on the Website

When you visit our Website, we may use cookies and/or similar technologies to collect technical information that can identify the user, such as your I.P. address, the type of internet browser used to browse the Website, your operating system, domain name or host of the domain through which the user navigates the Website. The main purpose of using cookies is to help you have an improved browsing experience and for advertising purposes, to be able to offer you individualized content tailored to your interests and preferences. As a result, to the extent that you have consented to the use of different categories of cookies or other similar technologies, we will use them to provide you with a personalized and relevant browsing experience and to understand how you interact with our advertising content. For more information about the use of cookies on the Website and the purposes for which they are used, as well as on the possibilities to control and / or disable cookies, please consult our Policy on cookies used on the Website, accessible at the following address: https://www.softelligence.net/cookies-policy/.

Legal grounds: the processing of your data for this purpose is based on Softelligence’s legitimate interest in ensuring the proper functioning of the Website as well as to permanently improve the visitor experience, including by solving various questions or complaints for the necessary functionalities (necessary cookies) and your consent for other cookies and technologies that ensure performance, functionality or marketing cookies.

D. Purposes described for Clients: 5.2.1 F. Surveys, market studies and other internal analyses, G. Economic, financial and administrative management, H. Security. Preventing improper use of services and Clients’ data. Fraud and incident prevention and management, I. Trainings and evaluation of our personnel/collaborators’ performance, J. Interacting through Social Media, and M. Mergers and Acquisitions, and the above details from individual Clients may apply accordingly. In particular, in your case it will the legal grounds will not be the performance of the contract but our specific legitimate interests corelative to the pursued purpose and legal obligations, or, as the case may be, your consent.

E. Defending our rights and interests, respectively fulfilling legal requirements / complying with specific legal obligations

We may process any of your personal data. to defend our interests (e.g., e-mail, permission, permission time coordinates) in the context of complaints, official controls, litigation, or to comply with specific legal requirements in terms of data security, processing of personal data, consumer protection, archiving or other obligations depending on the activity you carry out on the Website.

Legal grounds: our legitimate interests to defend our rights and interests in the context of situations in which Softelligence’s image and interests would be exposed or affected, respectively to keep evidence of our rights and interests as well as our compliance with specific legal obligations (for example, solving complaints within the deadline imposed by law or data protection,  manner of settlement, identification and proof of identification of customers / other individuals before making changes in orders / providing customer account data, etc.); our legal obligations, such as those to comply with the requests of public authorities / courts / other public institutions that have the power to impose certain processing operations on us; the obligation to archive certain documents/information according to the archiving rules or other regulations applicable to Softelligence; the obligation to notify confidentiality/security incidents to competent authorities, etc.

Where we can get the above data: directly from you or we can infer them from our own systems.

How long we keep your data (depending on the specific situation): for the duration required by specific legal provisions; where there are no rules, for the duration of the procedure/audit/investigation/litigation, and for a period of 3 years from its termination, respectively, taking into account the limitation period applicable to the specific situation; for the duration required by the competent authority/institution/court, as provided by law; for the duration you request to defend your rights and interests or of a third party having a legitimate interest in doing so.

What happens if you do not provide us with data: in certain situations, refusal to provide us with data may result in your contractual or civil liability in relation to us, other persons whose rights/interests would be affected.

5.4. If you are a Partner / potential partner of Softelligence, we process your personal data as follows:

5.4.1. For our partners acting within a proffesion as individuals:

A. To initiate or carry out the contractual relationship between Softelligence and Partners or potential Partners and / or through contractual partners expressly mandated to do so. 

This purpose also includes any basic checks we carry out – e.g. the capacity of legal representative, public information on partners and their services. 

We Use Your: Identification Data, Contact details, Data regarding your qualification, Partner Data – any data relevant to the contract, including minimum data for your assessment in order to conclude the services contract 

Legal grounds: our legitimate interest in ensuring a good management of contractual relationships in the context of provision of our services, respectively the legitimate interest in performing a minimum analysis and verification of partners and choosing the most suitable partner or, as the case may be, conclusion and performance of the contract with you, for operations closely related to the contract. 

Refusal to provide data for this purpose may result in Softelligence being unable to sign the contract with you. 

How long we keep the data: the data will be kept for the entire duration of the contractual relationship, as a rule, and for 3 years after termination of the contract. If there are open procedures, investigations, disputes, the duration will be extended during them, until the final settlement and for 3 years thereafter.

B. Financial and accounting management. Internal audit/internal/external investigations.

It includes: 1. payment of invoices, purpose which includes: (i) making payments by us for services / products provided / offered; (ii) communicating with you; to ensure correct payment of products/clarify the status of a payment; 2. keeping accounting and tax records, respectively carrying out mandatory internal and external reporting. 3. conducting any internal / external audits / investigations related to payments / invoices, services provided. 4. confirmation of amounts due and fulfilment of performance indicators, if applicable. 

We use the following categories of data: Identification data (such as your first and last name); Contact details (such as home address, e-mail address, telephone number); Partner Data (such as invoices, payment history, services rendered, timesheets, performance indicators); Financial data, as well as any other information you provide to us or the person acting for you. 

Legal grounds: our legitimate interests: to ensure the payment of invoices in good conditions, to verify their correctness and keep proof of payment, respectively to verify the fulfillment of contractual conditions for payment, to be able to investigate potential errors / incidents / unauthorized payments, to be able to ensure financial management in an optimal way, to organize internal audit; conclusion and performance of the contract with you; our legal obligations: to keep track of invoices received and related payments, to report certain accounting / tax aspects mandatorily, etc. 

How much we keep your data (depending on the specific situation): records of payments and documents related to the settlement of payments will be kept for 10 years from the end of the financial year in which they were issued; correspondence with you related to the above purpose will be retained for the duration of the relationship with you (as long as you have an active account with us), for a maximum of 10 years from creation.

What happens if you do not provide us with the necessary clarifications regarding the invoices issued: in the absence of additional data requested, the invoice may be renegotiated or not paid. Without providing payment data in accordance with the contract, we cannot make the payment to you.

C. Partner relationship support and management: handling any questions or requests, including complaints you may have regarding the contract, invoice payment, and the processing of your data, including to provide you with any information required by law, on any communication channel, as well as to check the level of services provided / products offered.

We use the following data: Identification data (such as name, surname); Contact details (such as e-mail address, telephone number, home address, mailing address); Data regarding the relationship with Partners (such as complaint history, correspondence and records with you, agreed performance indicators, documents drawn up, services provided, deliverables including your data); any other data provided by you by means of requests and documents submitted in support thereof; any other data from the categories listed above under Clients related to the relationship with you necessary to resolve requests. 

Legal grounds: our legitimate interests in ensuring a good relationship with you and to defend our rights and interests in judicial, administrative or similar proceedings, respectively to properly manage any request you submit to us and to improve our services as well as to verify and ensure the quality of the services / products you provide; specific legal obligations in the field (e.g., the processing of certain data mandatory in the form dedicated to the complaint and for resolution, the obligation to keep certain documents according to the law, etc.); your consent in case you contact us by phone and the call is recorded.

How much we keep your data (depending on the specific situation): for the duration of solving your request and after settlement for a duration of 3 years for settled claims, respectively for the duration of any disputes / procedures and for a duration of 3 years after their final settlement, or, as the case may be, for other periods imposed according to our legal obligations; during the contractual relationship in the case of quality checks, respectively for 3 years thereafter these durations, if there is no need of extension for reasons of formal proceedings, complaints, litigation.

What happens if you do not provide us with the data from the standard forms / or requested by our colleagues: the data we request from you is mandatory for the proper handling of your requests. Your refusal to provide that data may prevent or affect the complete resolution of your request (e.g., refusal due to lack of sufficient information, delays, partial settlement, etc.). Refusal to provide quality/performance information under the contract may result in termination/suspension of the contract with you.

If you choose to contact us through another communication channel operated by a third party (e.g.  WhatsApp, Facebook) we will share your personal data with the owner of this channel to confirm that you are a user of this service. We recommend that you check the privacy settings and read the privacy policy of the respective operators to obtain more detailed information on how they use the personal data of users of the services they provide.

If you do not agree to call recording, you can contact us on our other communication channels.

D. Security and access control

We continuously review and improve security of our I.T. and other infrastructure (for example buildings). We therefore process data, for example, for monitoring, inspection, analysis and testing of our networks and I.T. infrastructures, for system and error checks, for documentation purposes and in the context of backups. 

Access controls include electronic system access controls (for example logging into user accounts), as well as physical access controls (for example building access). For security purposes (to prevent and investigate incidents), we also keep access protocols and visitor lists and use surveillance systems (for example security cameras). We will inform you about surveillance systems at the relevant locations through appropriate signage, as the case may be.

We may also collect data about who enters certain buildings, and when or who has access rights (including in relation to access controls, based on registration data or lists of visitors, etc.) and who uses our infrastructure and systems and when.

We base such data processing activities on our legitimate interest to ensure security and safety of persons, goods and assets and to ensure compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable laws.

E. Defending our rights and interests and complying with specific legal requirements/obligations

We may process your personal data in the context of official external audits / requests received from public authorities / third parties with legitimate interests, including complaints from Clients / employees, possible litigation or other official procedures, to defend our rights and interests. Also, your personal data may be processed to comply with specific legal standards (e.g., authentication data to secure access to our systems) or legal obligations – mandatory accounting/tax reporting that also includes your data or data included in archiving accounting documents).

The data used may be all data related to you, depending on the context, including Data Inferred by us.

Legal grounds: our legitimate interests to defend our rights and interests, to comply with official requests, the legitimate interests of third parties if justified and do not prejudice your interests, respectively our legitimate interest in complying with legal obligations/legal standards and our specific legal obligations.

5.4.2 For representatives/contact persons of partners who are natural / legal persons:

The purposes of paragraph 5.4.1 above shall apply accordingly. The processed data will be: Identification Data, Qualification Data (including the quality of representative), Contact Data, Data regarding the interaction with you as a representative/contact person, Partner Data, if you provide services and these are valued by name, per natural person within the Partner.

The grounds will be those indicated in point 5.4.1 above, except for the conclusion and execution of the contract. In your case, this ground is replaced by our legitimate interest in ensuring the conclusion and performance of the contract with our Partners.

The rest of the information described in section 5.4.1 above shall apply accordingly.

5.5. If you are a participant/potential participant to our events

A. Registration to our events and communication related to such (including webinars, hackathons, other online of physical-presence events)

We may process some your data in view of registering you to our events and communicating with your all-relevant events related details. Regularly your Identification Data and Contact Data will be used.

Legal grounds: our legitimate interest to organise the events and to communicate with you any relevant event related details.

How much we keep your data (depending on the specific situation): for a period of maximum 6 (six) months since registration. Any communication related to the events shall be kept for a period of 3 years since it occurs. If the relevant data is related to an official procedure/complaint, the period may be extended until the procedure is closed/complaint is solved.

What happens if you do not provide us with the data from the forms for registration / or requested by our colleagues: the data we request from you is mandatory for your registration to our events. Your refusal to provide that data may prevent or affect your attendance to our events – e.g., lack of contact information may affect your information received on the event location, time, agenda, etc.

B. Organising and hosting the events

When you decide to attend to one of our events, we will process your data in view of organising our event, including access granting to the event, preparing relevant documents/materials needed specific to the event (including diplomas for participation), ensuring the security of persons and goods during the event. For such purposes we may process the following data: Identification Data (e.g., name, surname, id related data, photo, video images), Contact Data, Event participants Relationship Data (your specific requests), Inferred Data.

Legal Grounds: our legitimate interest to organise our events, to ensure adequate documents/materials or other resources to be ensured for participants, to ensure the security of persons and goods, our legal obligations if any legal provisions/public authorities request specific conditions to be fulfilled for event organisation.

How much we keep your data (depending on the specific situation): for a period of 3 years since event organization. If the relevant data is related to an official procedure/complaint, the period may be extended until the procedure is closed/complaint is solved.

What happens if you do not provide us with the data requested by our colleagues: some of the data we request from you is mandatory for your attendance to our events (we will let you know what data is mandatory). Your refusal to provide that data may prevent or affect your attendance to our events – e.g., lack of identification information may prevent your access to the event, etc.

C. Internal analyses related to events

To communicate with you in the process of conducting surveys about event participant satisfaction for analysis purposes, for quality improvement, to measure the success of events or to adapt our events to your requirements. 

We use the following data: Identification data: name, surname, contact details: telephone number and e-mail address, city of residence; Event participant relationship Data: type of event, data related to your opinion on our events and your expectations; your feedback about the events we run, communicating with you. 

Legal grounds: our legitimate interests to know the opinion and preferences of events participants regarding our events, as well as to optimize our activity and identify new opportunities for the development and promotion of our services in general.

We will ensure that we only use personal data if such use is necessary to achieve the intended purpose. As a rule, the result of internal analyzes is in an anonymized format. 

Where can we get the above data: in general, we use the data that either: we receive from you. (directly or through our partners – such as marketing, promotion and market research agencies), we either generate or infer them based on the information we hold about you.

How long we keep your data (depending on the specific situation): in the case of the data underlying the analyses with anonymized results – for the time necessary to transform into anonymized statistics, but not more than 6 months after the survey / market study or the internal analysis / study. If they are not anonymized, the results of the analyzes will be kept for 1 year from the date of their generation and will not be made public. 

What happens if you do not provide us with the data: if you do not want to participate in our surveys or, as the case may be, provide us with certain information for this purpose, we may not implement or take into account certain of your suggestions or other matters of interest to you. In any case, your refusal to do so will not in any way affect your relationship with Softelligence. Specific surveys may be conducted through our Website. For data processed through cookies and new technologies in this case see our Cookie Policy.

D. Internal training and evaluation of our personnel

We may use analytics or various analysis related to the events, as well as images (photos, videos, your feedback) to ensure internal training in respect to event organising and evaluate our personnel in the context of the event they manage, organized by, or with the involvement of Softelligence. 

Legal grounds: our legitimate interests to improve our events, promote our image and services, evaluate and train our personnel.

How long we keep your data (depending on the specific situation): in the case of the data underlying the trainings and evaluation, only until the training occurs/evaluation of relevant employees is finalized. In the output, only anonymized data will be included.  

E. Promoting our events

We may use your image (photos/videos), your feedback or other data related to you to promote our events (e.g., the company you represent, your interests, your opinion on the event).

Legal grounds: our legitimate interest to promote our events: for an overview, wide angle, panoramic photos/video recordings and for anonymous feedback posted online/overall articles on events mentioning feedback with no details in respect to the participant; for close-up photos / video recordings, we base our processing on your consent (that you may grant to us in writing or verbally,  including through gestures, behaviour (e.g., your presence in an area dedicated to taking photos, your active participation in a certain activity etc.). Also, for publishing your feedback along with other details on social media, our Website, or similar mediums, we base the processing on your consent.

In case you withdraw your consent, the processing which already occurred remains as such and your withdrawal will produce effects only for the future.

If you do not want to appear in events photos/ video recordings, you have the possibility to address the photographer directly, or, in the case of online events, to connect with the camera and microphone functions deactivated.

F. The purposes described under items A, B and E above under section 5.3. and J. and M. under section 5.2.1 shall apply accordingly. Any references to services shall be understood as reference to events organised by or with the participation of Softelligence. Likewise, consent collection for marketing activities shall occur in the context of the event registration/organisation via dedicated forms/channels, and contract as a legal ground shall be replaced by the corresponding legitimate interest.

6. HOW WE SHARE YOUR DATA 

While as a rule we do not disclose your personal data to any third parties, we may disclose your personal data to third parties, if this is needed to perform our services, to observe a legal obligation or if it is in our legitimate interest to do so.

Concerning transfers or personal data to other recipients located aboard, your data is processed inside the European Economic Area (EEA). In exceptional cases, your data may be processed in countries located outside the EEA. Currently, we undertake such transfers with our affiliates in U.K. (recognised as providing an adequate level of protection by the European Commission) and Macedonia (with which we concluded standard contractual clauses). If other recipients are located in a country without adequate statutory data protection, we require the recipient to undertake and comply with data protection rules, and we implement safeguards as required under GDPR, including, for example, the standard contractual clauses approved by the European Commission.  

In each case, the data strictly necessary for the provision of services or that we are obliged to provide will be disclosed after confirmation of the compliance of the data list by the privacy responsible. 

Recipients common to all data subjects (Clients, Website Users, Partners, events Participants): 

• audit firms; 
• public and regulatory authorities, government bodies, courts – if necessary (including if required by law) or, as the case may be, a third entity or organization – if such disclosure is necessary to comply with any applicable legal provisions, or other legal or regulatory requirements (for example, if we receive such notification and/or address from central or local public authorities or in connection with a dispute in course pending before the Romanian courts, respectively for fulfilling our tax reporting obligations, disclosing data to ANSPDCP / ANPC in the context of a complaint); 
• third-party consultants (e.g., external lawyers, auditors, experts), where we involve them in disputes or disputes relevant to us or other activities requiring their professional experience; 
• software/hardware service providers and I.T. support; 
• providers of equipment / network installation and maintenance services; 
• server maintenance service providers – e.g. for storage, I.T. incident remediation; call center service providers – to respond to your questions, requests or complaints; 
• archiving service providers; 
• our affiliates
• Individuals who complain about certain situations, or incidents concerning you, if there is a justification for receiving access to data and granting access, would not affect your rights. 

Specific recipients for Business Individual Customers: 

• partners or agencies involved in delivering our services (e.g., hosting providers, I.T. security services providers, software providers); 
• print service providers; 
• Call-center / telesales service providers 
• Business customers individuals, for their staff data; 
• financial service providers – in the context in which you decide to make the payment through the direct debit facility of your account. 
• Financial consultants and accountants 
• CRM platforms 
• in the event of a merger or acquisition. Where we undergo a reorganization or sale process, we will provide your personal information to that organisation; 
• Third-party partners we work with to sell our services: We collect and combine information to monitor how you sell our services and other Clients use our services, as well as to help us improve the quality of our services. We provide this information to third parties (for example, content and advertising providers), but any such reporting to a third party will not include information that can identify you as an individual; 
• Our providers of electronic communications services – chat platforms, customer interaction applications, platforms for sending e-mails or automated messages; 
• Marketing Service providers & Social Media account management and platforms (if you have an account on these platforms and access our pages) – e.g. advertising and marketing agencies or digital media agencies – organizing and managing promotional campaigns, as well as analyzing their effectiveness, we may share your personal data. Providers of surveys or market research/Customer surveys – to conduct surveys or market studies, customer satisfaction surveys or to obtain feedback from our Clients on our services.

Specific recipients for Events attendants: 

• In the context of organizing events by or with the involvement of Softelligence we may disclose photo/video images by publishing such images on our Website or on social platforms like LinkedIn, YouTube, Twitter, Instagram, Facebook, etc. In addition, we may transmit photo/video images to the following categories of recipients: persons who participated at the event; persons who registered for the event but were unable to participate; professional organizations; contractual partners with whom we collaborate in the context of events.

Specific recipients for Partners:

• Relevant Partners for data related to their personnel/representatives/provided services/products;

7. DURATION OF PROCESSING 

We intend to keep your personal data for as long as necessary for the purposes detailed in this information notice in accordance with our legal obligations and internal policies. 

If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes.

8. AUTOMATED DECISION MAKING

To the extent that the fulfillment of some of the above processing purposes will be achieved by using computer techniques that do not involve the presence of a human factor, which will lead to legal effects on you or which may similarly significantly affect you, the processing will be based on your express consent for this purpose or another legal basis, as required by law. In this regard, this document will be updated whenever necessary to ensure that you are properly informed. We do not use such processes at this time. For details on automated decision-making processes, please contact the following address: privacy@softelligence.net.

9. HOW WE PROTECT YOUR DATA

We take appropriate security measures to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful use, disclosure or access. 

Technical and organizational security measures may include encryption and pseudonymization of data, logging, access restrictions, keeping backup copies, giving instructions to our employees, entering confidentiality agreements, and monitoring activities. We protect your data that is sent through our Website in transit by appropriate encryption. However, we can only secure areas in our control. We also require our data processors to take appropriate security measures.

10. YOUR RIGHTS CONCERNING PERSONAL DATA AND HOW TO EXERCISE THEM
You have the following rights in relation to our data processing, depending on the applicable data protection law: