Given the nature of INPERSPECTIVE's business activity (consultancy) and the purpose of these activities, no personal data of natural persons are processed, but only personal data of representatives of legal entities, companies we conclude contracts with and other commercial partnerships. Thus, the data you transmit to us have the quality of "information" and not the quality of "personal data" according to the definition provided by the GDPR, but we admit that, in relation to us, we may be in a position to process personal data transmitted by a natural person, if you would like to send us information such as your personal phone instead of your service phone, your personal email address and other similar personal data.
As a result, we provide you with transparent information about the personal data and, if applicable, about the information you provide to us and how we use this data and at the same time inform you about your rights and how we understand to respect these rights, including how you can exercise your rights in relation to us.
By continuing to use our website, you understand that the interaction with the services of the company implies the request of certain personal data directly from you and the refusal to provide this data may result in our inability to provide the consultancy services requested.
To the extent that you have requests or questions regarding the processing activities of the information transmitted to us and, if applicable, of your personal data within our company, please contact us using the contact information below mentioned at point 1.
If you send INPERSPECTIVE a request to access information about the personal data processing activities of the company you represent or, as the case may be, your company’s information within the commercial or legal relationship you have at a given time with our company, please consider that, due to the continuous processing of your personal data and taking into account the established routine for deleting the information processed under the conditions of the Data Retention Policy, we undertake to make reasonable efforts to keep this data updated and accurate at all times. Thus, this routine processing may involve altering or deleting the personal information we process, after you have sent a request to us. In this case, we will provide you with the information held at the time we send you the answer, even if they differ from the information that was stored at the time of sending the request. Please note that deleting your personal data is a procedure we would have performed even if you hadn’t submitted the request.
1. Contact information of the entity that performs the described processing activities:
Trading Company S.C. INPERSPECTIVE BUSINESS S.R.L.-D
Registered office address:: Bucharest, România, Str. Avionului, nr. 26, etaj 1, Biroul A, postal code 014333;
You can contact us by sending an email using the form in the Contact. section
2. Collection, storage and processing of personal data
We only store and process personal data in cases where you have voluntarily and directly provided us with such data, such as by telephone in direct contact with the company representative or by e-mail in case of our customers, legal entities or our collaborators. If we collect any other personal data or if we change the purpose or legal basis of the processing, you will be informed of the intended purpose of using this data in the present Policy, separately and punctually by e-mail, or at our next meeting. If it is mandatory in accordance with the General Data Protection Regulation, we will ask for your consent for the processing of personal data prior to any processing activity.
3. INPERSPECTIVE collects personal data, …
of representatives of partner companies and collaborators, in accordance with the contract concluded with these legal persons, for the following purposes:
- each time you access our services, we process your personal data to conclude and execute the framework contract under which we provide the contracted services;
- we process your personal data when we have obtained your consent for processing, such as the use of third-party cookies - such as Google Analytics, to verify the traffic generated when you access our website;
- keeping touch with our partners (via SMS, e-mail, telephone or various messaging applications) regarding the execution of the contract we concluded;
- to respond to any requests regarding the services provided or in relation to data processing activities;
- for the purpose of executing a contract we signed remotely with you, to deliver the requested consultancy services;
- the transmission of information to our contractual partners in order to provide the contracted services or as a result of providing these services;
- ensuring the customer's access to the platforms through which various ways of accessing our services are offered, such as online scheduling (reservation) of the fast consultancy appointment;
- the submission of offers for the purpose of concluding a contract with INPERSPECTIVE;
- the transmission of the information requested by different public authorities according to the legal requirements, to internal or external auditing companies if necessary, or to consultants;
- carrying out internal administrative operations of INPERSPECTIVE (for example: drawing up lists, generating reports, etc.).
4. The personal data we process and the legal basis of the processing
Identification and contact details of the representatives of our customers - depending on how you contact us: first and last name, service or personal email, telephone number (mobile, landline or both), the postal address of the company you work for, illegible signature. The legal basis on which we carry out the processing activities of these personal data is provided in art. 6 paragraph (1) letter b), respectively the processing is necessary for the execution of a contract to which you are a party (as a representative of the company you represent) or to carry out certain processing activities following your request before the conclusion of a contract;
Identification and contact details of our collaborators in capacity of our partners (consultants, non-profit organizations and other partnerships) - first and last name, telephone number, e-mail address, as well as any information needed to conclude and perform the contract concluded by INPERSPECTIVE with them or any information is required from you (our customer), if you ask us to recommend you to an INPERSPECTIVE collaborator for a certain project.
If you don’t provide to us the requested information, we may be unable to optimally perform the requested services.
5. Principles of personal data processing
We respect the principles of data processing and protection so that your personal data will be:
- processed legally, correctly and transparently;
- collected only for a valid purpose which we have clearly explained, and which are not used in a manner considered to be incompatible with such purpose;
- relevant to the purpose we communicated to you and limited only to that specific purpose;
- correct and updated;
- will not be kept longer than necessary in relation to the described purposes;
- safely stored.
6. How we obtain these data:Automatically:
- By using cookies on our website in order to obtain information according to article 11 below.
- Via the website, after you have booked a fast consultancy appointment;
- Via the website, after you have sent a message by filling in the predefined fields in the «Contact» section;
- After you interact with us by telephone or by e-mail) in order to send requests, recommendations or suggestions;
- Through your direct contact with the INPERSPECTIVE consultant during an organized business meeting.
7. To whom we transmit your personal data and the results of our processing activities (reports, lists, etc.)?
a. Our partners (legal persons in relation to which we provide consultancy services and/or provide various functionalities within our website);
The relationship with these providers is transparent within the website, your interaction with our website being possible through the software solutions offered by these partners, for you to access our available services.
INPERSPECTIVE's partner providers are:
CALENDLY LLC, an American company, with headquarters in Atlanta, Georgia. The Calendly platform is hosted on the Amazon server and the back-up of information stored on this platform is provided at the Google Inc. level. Thus, your personal data is transferred to the United States of America and, where appropriate, Ireland where Google has its EU operational headquarters. Calendly has implemented high internationally recognized security standards (ISO 27001, PCI Level 1, FISMA Moderate, etc.) and ensures an encrypted connection with its data transfer partners. For more details on the GDPR compliance of Calendly, please read the information in this link.
HUBSPOT Inc. is an American company, with headquarters in Cambridge Massachusetts, registered with operational headquarters at European Union level in Ireland, under the name HUBSPOT LIMITED IRELAND. We use HUBSPOT to provide you with the opportunity to get in touch with us through the form on the Contact page on our website.
The retention period of these data is established in relation to the duration of the partnership between HUBSPOT and INPERSPECTIVE. In other words, as long as we are in a relationship with HUBSPOT they will process your data through us.
PAYPAL is an American company, with headquarters in San Jose, California. PAYPAL is one of the most popular worldwide online payment systems (payment processor). In the event of carrying out an online transaction (initiating the payment, authenticating the card user, communicating or confirming the status of the payment you made, preventing the risks of fraud and cyber-attack, etc.), respectively when you make a payment of an hourly consultancy session booked through our website, or when we return an amount to you in accordance with the return conditions provided in chapter 4 of the Terms and Conditions, information regarding the used card is entered in the predefined fields on the PAYPAL platform integrated in our website, PAYPAL processes information entered on the credit or debit card used to carry out the transaction. INPERSPECTIVE does not in any way process information about the card that was used to make the online payment. PAYPAL processes personal data and information on transactions carried out in relation to INPERSPECTIVE, in order to comply with the legal obligations of payment processors but also for the purposes of their own business activity. PAYPAL processes data and information in accordance with the retention policies established in accordance with the legal provisions that regulate PAYPAL’s activity. For details about the processing of personal data at the PAYPAL level, please access this link.
Also, PAYPAL hosts the personal data through a network of computers having servers interconnected in cloud as well as other technological infrastructures developed internally or through sub-contractors. These sub-contractors are located at European Economic Area and Switzerland level but also outside this territory. In order to guarantee the security of the transfer of your personal data in different jurisdictions, PAYPAL has implemented according to the GDPR, Binding Corporate Rules that were approved by the data protection authorities in each country. Details on these measures and in general, on the PAYPAL transfer of personal data and information, please access this link.
GOOGLE Inc. When you access the website, send us an email, or set up a video conference, we use services owned and managed by Google Inc. Google is an American company headquartered in Mountain View, California and with an operational EU headquarter in Dublin, Ireland.
By interacting with our website, Google processes the information and personal data you submit to access our services. Thus, the host of the e-mail service used by INPERSPECTIVE is Gmail. We also use the Hangouts video service to access fast consultancy services and after accessing the website we use Google Analytics cookies to generate exclusively statistical and general reports on your activity on our website. We also use Google Drive to store information. For details on how Google uses personal data, please visit this link.
Professionals such as the company's accountant, representatives of the bank we work with, insurers, based in Romania, respectively legal entities that provide certain services to our company.
State authorities in the field of taxation - A.N.A.F. - the National Administration of Public Finance - or, as the case may be, the National Authority for the Supervision of Personal Data Processing (A.N.S.P.D.C.P.), as well as in relation to other state authorities, which is or may be required to send certain reports on the company's activity, in certain circumstances provided by law.
We also process information and personal data belonging to our customers, in order to perform the contracted services, to the extent that you authorize us on the signing date of the contract or after this date, before obtaining this data from you (by granting access to certain platforms or the provision of data of employees or collaborators we need to interact with, data and information that we receive by e-mail or by other means, directly from you).
The updated list of contractual partners, in relation to which we process your personal data, can be consulted upon request, by sending an e-mail to us using the form in the Contact section.
b. Mandatory disclosure
To the extent necessary and INPERSPECTIVE still holds the personal data and information requested, we will make them available to third parties to comply with any laws, regulations, legal proceedings or requests received from public authorities (for example, in accordance with certain law enforcement measures as a result of controls or inspections, summonses or judgments) or when we act in good faith to implement our internal policies and rules, including to investigate possible breaches or detect, prevent or take measures in relation to illegal activities or other deviations, suspicions of fraud or as a result of security incidents. In addition, we will only share your data to the extent that we are required to exercise our legal rights, to defend ourselves against claims with legal implications, or to prevent injury to our rights, property or safety or the company as a legal entity, our partners, you or any third party, either for the purpose of working with law enforcement bodies or if we consider it necessary to ensure the intellectual property of INPERSPECTIVE or other rights are complied with.
c. Business transfers
It is possible to share information that includes personal data of the customers' representatives with whom we have concluded contracts or in relation to which we carry out certain commercial activities, in case of a corporate transaction (purchases of the majority or entirely owned shares of the company such as a merger). In case of the aforementioned, the affiliated companies or the acquiring company, will undertake the rights and obligations described in the present policy.
e. Non-personal information
It is possible to share aggregate information or data that cannot be considered as personal data (statistics, data generated automatically through our internal systems, platforms for generating data for market research - or commercial information) with our business partners and other third parties in accordance with the terms of this policy.
8. Legal basis of personal data processing
INPERSPECTIVE is responsible for the processing of personal data you own, for the entire duration such data is stored by INPERSPECTIVE. We comply with the personal data processing principles established under the General Data Protection Regulation (GDPR) and integrate these principles into the company's internal processes and our commercial practices.
9. Where do we process your data?
For the duration your personal data is processed by INPERSPECTIVE, these data are processed in relation to the partners mentioned in art. 7 letter a). The data and information are mainly processed in Romania, but the INPERSPECTIVE company is characterized by the mobility and flexibility of the consultancy offered, so we can deliver your services from countries inside or outside the European Union, where we can find ourselves at a given time.
If our providers process your personal data in countries that do not provide a sufficient level of protection of your rights, we carefully evaluate all the circumstances and ensure that adequate security and confidentiality guarantees have been enforced and applied so that your rights are in no way hindered. We also make sure that you have the means to exercise your rights.
10. The rights you have
- You have the right to receive information at any time, regarding the purposes of the processing of your personal data, the categories and sources, the recipients, the periods of storage of your personal data and your rights.
- Your requests for the processing of personal data by INPERSPECTIVE will be dealt with as soon as possible. With regard to our internal processes, we will endeavour to deliver any response regarding the personal data processing activities belonging to you, within a maximum of one month (30 days), if you send us an email using the form in the Contact section.
- You have the right not to be subject to an automated decision making, having the opportunity to oppose an automatic decision process. INPERSPECTIVE does not realize automated decision processes at this time.
- You have the right to access your personal data, including the right to obtain a copy of the personal data we process.
- Regarding the right of portability (transfer) of the data you provided to us in relation to the specific purpose for which you provided us with this data, we believe that the exercise of this right is not applicable in relation to our company. The transfer of your data under GDPR conditions to another entity is not possible.
- We update your personal data, asking you to review them from time to time and whenever the need to update them is provided by law. However, if you find that some of the data provided or obtained from you in the manner presented in this policy is incorrect or inaccurate, you may request that we rectify and/or update the incorrect data and for us to correct any incomplete data.
- You may rectify or correct your personal data by contacting us and providing us with the correct or additional data. You can request a restriction on the processing of your data, if the accuracy of the data is challenged for a period that allows us to verify this aspect.
- You have the right to restrict certain processing activities, which means we store your personal data, but do not use it for any other purpose. If you have obtained processing restriction, you will be informed before lifting the data processing restriction, if applicable.
- You have the right to request the deletion of personal data. We will evaluate your deletion request from the point of view of our internal laws and procedures, taking into account, if applicable, the existence of any instructions in place with our contractual partners and we will provide you with a written response within the up mentioned term, which will not exceed the one month (30 days term) from the receival date of the deletion request.
- You have the right to contact us at any time, if you believe that your legal rights on the protection of personal data have been breached.
- You have the right to call the Data Supervisory Authority, respectively the National Supervisory Authority for the Protection of Personal Data (ANSPDCP), with the address: Bulevardul General Gheorghe Magheru 28-30, 1st District, postal code 010336, Bucharest, Romania, or at a competent court, if you believe that your rights regarding the processing of personal data have been breached.
Cookies are text files placed on your computer, smartphone or tablet, to collect standard internet login information and information about your conduct on our website. This information is used, for example, to analyse your use of the website and to compile statistical reports on the activity performed on the website. You can set your browser not to accept cookies. However, some internal cookies are required to allow you to access our website.
Google Analytics cookies are as follows:
Cookie name Description of purpose Duration of use _ga Used to distinguish users 2 ani _gid Used to distinguish users 24 de ore _gat Used to throttle request rate 1 minut
12. We do not process data about underaged children
13. Data retention. How long we process your personal data?
We process your personal data and confidential information transmitted, as much as necessary to achieve the purpose for which we collected these data, including for the purpose of fulfilling any legal, accounting or reporting obligations to the authorities or, where appropriate, to audit institutions.
To determine the appropriate retention period, we consider the quantity of data processed, the type and sensitivity of the data, the potential risk of injury caused by the unauthorized use or disclosure of your personal data, the purposes for which we process, your personal data and if we can achieve these purposes through other applicable legal means and requirements.
The periods for storing personal data are specified in the table below and apply to all mediums, i.e. both paper and electronic format, unless otherwise specified in this Policy.
DEPARTMENT PROCESSING ACTIVITY RETENTION PERIOD NOTIFICATIONS TRANSMITTED BY INPERSPECTIVE Notifications sent by INPERSPECTIVE directly or through its contractual partners (invoices, non-payment notices, etc.) 3 years as of the sending date of each notification; RELATIONSHIPS WITH PROVIDERS Framework contracts for the provision of services concluded by the company with its customers (legal persons) 10 years termination date of the contract; RELATIONSHIPS WITH CONTRACTUAL PARTNERS Service contracts concluded by the company with contractual partners (legal persons) 10 years as of the termination date of the contract; RELATIONSHIPS WITH THE REPRESENTATIVES OF THE CONTRACTUAL PARTNERS Telephone calls We do not record/store evidence of any telephone calls; RELATIONSHIPS WITH THE REPRESENTATIVES OF THE CONTRACTUAL PARTNERS The business cards collected during the organized events we attend 1 year from the receival date of the business card, if the contract is no longer valid or the information has not been used; BUSINESS RELATIONSHIPS (B2B) Personal data, such as: name, position and contact details of the representatives of the companies we work with Until the deletion request date to delete the data or until we have knowledge that the data has become inactive; ACCOUNTING DOCUMENTS Invoices, bank statements, accounting notes, balance sheet, verification balance sheet, as well as any other financial documents - accounting 10 years according to the accounting law; ALL THE DOCUMENTS 6 years, or
if a transaction, an act or an operation is the subject of an investigation, control, complaint, evaluation, audit or legal expertise, as well as other legal proceedings and actions (mediation, litigation in court) that are on-going during within the term of 6 years, then the relevant documents resulting (such as the minutes, the court decisions or the transaction in a mediation procedure) will be stored until the end of the above procedures.
For information regarding the retention (storage) terms of some personal data processing activities within the company that are not specified in this Policy, please send your requests using the form existing in the Contact section.
14. How do we protect your data?
To ensure that your rights and liberties are not hindered and that compliance with relevant laws and regulations is complied with in respect of the data protection legal frame, we implement appropriate technical and organizational measures to ensure a sufficient level of security for processing personal data. These measures consist of contacting partners responsible for the processing of personal data and making sure they implement appropriate technical solutions to guarantee the personal data safety, we introduce policies and processes that are regularly reviewed and updated in accordance with the latest recognized practices in the field.
We also make sure that we carefully evaluate our partners to provide an appropriate level of protection of your personal data and conclude personal data processing agreements with our partners, to ensure that every subcontractor that comes in contact under our authority and with your personal data, it performs the contracted processing activities in under safe conditions and that it complies with the provisions of the personal data processing legislation in force.
© INPERSPECTIVE BUSINESS - Version: April 2020