Your Privacy Is Important to Us

Green Technology Association (GTA) as the management entity of the Green Technology Cluster (GTC) is committed to your privacy and the protection of your personal data. This Privacy Statement is provided to describe our privacy practices as required by the General Data Protection Regulation (“GDPR”) (EU) (2016/679) and other Data Protection Laws. This Privacy Statement applies where GTA is acting as a Data Controller with respect to the personal data of our customers, resellers, suppliers, and website users; in other words, where we determine the purposes and means of the processing of that personal data.

This Privacy Statement outlines how we collect, share, transfer, retain and protect your personal data and what rights you can exercise regarding your information. If you provide us with your personal data, or we obtain information about you from other sources, we treat your information according to this Privacy Statement.

This Privacy Statement applies to GTA websites, apps, mobile apps, social media accounts, etc. (Sites). This Privacy Statement does not apply to third-party applications, products, services, websites, or social media features that may be accessed through links we provide on our Sites that have their own Privacy Policies, Statements, or Notices. Accessing those links will cause you to leave the GTA Sites and may result in the collection or sharing of information about you by a third party. We do not control, endorse or make any representations about those third-party websites or their privacy practices, which may differ from ours. We encourage you to review the Privacy Statement of any site you interact with before allowing the collection and use of your personal data.

What Information Do We Collect About You?

The following describes the general categories of personal data that we may process, the purposes for which we may process personal data, and the legal bases of the processing. In the case of personal data, we did not obtain directly from you, the source and specific categories of that data are also described.

• We may process data related to your (“Account Data”). The Account Data may include your name, title, postal and email address as well as payment information. The source of the Account Data may be you or your employer. The Account Data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases, and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and GTA and/or taking steps, at your request, to enter into such a contract.
• We may process information contained in any inquiry you submit to us regarding goods and services (“Inquiry Data”). The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and GTA and/or taking steps, at your request, to enter into such a contract.
• We may process data about your use of our website and services (“Usage Data”). The Usage Data may include your IP address, geographical location, browser type, and version, operating system, referral source, length of visit, page views, and website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The source of the Usage Data may be Cookies, analytics tracking systems, or other methods. This Usage Data may be processed for the purposes of analysing your use of our website and services. The legal basis for this processing is consent.
• We may process data about you to ensure the security of your personal data and our IT system, on the basis of your and our interest in security. The legal basis for this processing is our legitimate interests, namely the safe and secure: (1) administration of our website, (2) use and storage of business information and, (3) communications with users and customers.
• We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters to keep you up-to-date on GTA events and news (“Notification data”). The legal basis for this processing is your explicit consent, or your implicit consent if you are a customer.
• We may process information contained in or relating to any communication that you send to us (“Correspondence Data”). The Correspondence Data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The Correspondence Data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
• We may process your personal data where necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, an investigation, or other legal matter. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others. We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

Where the processing of your personal data is based on your consent only, you have the right to withdraw this consent at any time. We will then erase your personal data and stop processing it subject to our receipt of a valid Data Subject Access Request from you.

Sources of Information We Collect

GTA receives information about you or your devices from the following sources:

• When you, or someone on your behalf, provides information to us to:

Establish or maintain an account;

Make a purchase or receive a service;

Apply for employment at GTA;

Post comments to online communities;

Participate in a survey, marketing promotion, sweepstakes or contest; or

Connect with us via social media.

Through Business Partners, Resellers and Suppliers;

• Our Sites, apps, and email;
• Through the use of automated means such as cookies and similar technologies, and;
• From other third parties, including, advertisers, data partners, marketing partners, and publicly available sources such as social networks.

GTA, our service providers, and other third parties may collect the following information about you through automated means (such as Cookies):

• IP address;
• Browser type and language, access time, and referring website address;
• The pages you view within our Sites and other actions you take while visiting us;
• We may collect information related to whether you’ve opened an e-mail or clicked on a link contained in an e-mail;
• If you are referred to our Sites from another source (an advertising site, a blog, a social media site, etc.), we may collect data about you. Also, we may provide a referring source with appropriate data (such as the amount of a purchase) to compute referral fees or other similar purposes;
• We may conduct surveys and promotions that collect your information. Our surveys and promotions are voluntary and any information you provide may be collected, used, shared, disclosed, stored, transferred, and processed in accordance with this Privacy Statement. Your participation in our surveys and promotions, and your submission of information, serves as your consent to these practices;
• Some features of our Sites allow users to make data public or engage in other sharing. For example, if you post content or otherwise participate in discussion forums or other social areas of our Sites, your participation (including the content you post, your name, and a link to your profile) may be shared across our Sites and in other public or private areas of the internet.

Collecting information through automated means allows us to collect statistics about the usage and effectiveness of our Sites, personalize your experience on our Sites, and tailor our interactions with you. For details regarding the technologies we employ, see our Cookie Policies, and the section below regarding Cookies.

How Will We Use Your Information?

GTA may use your personal information in the following ways:

• Account Maintenance – We may use your information to identify you, contact you, and for any other actions regarding account maintenance;
• E-mail – If you choose to be contacted by email, we may use your email information to communicate questions, respond to inquiries, and distribute information about GTA and our products and services that may be of interest to you. You may choose not to receive marketing materials from us at any time by following the unsubscribe instructions included in the Email Notifications section below.
• Customer Feedback – We may use your information to provide a mechanism for your feedback.
• Personalizing your Experience on our Sites – We may use the information we collect about you to provide a personalized experience on our Sites, such as providing you with content that you may be interested in and making our Sites easier for you to navigate.
• Aggregate/De-Identified Information – We may aggregate and/or de-identify your information so that such information can no longer be linked to you or your devices (Aggregate/De-Identified Information). We may use Aggregated/De-Identified Information for any purpose, including without limitation, research, and marketing purposes. We may also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.
• Combined Information – You consent that, for the purposes discussed in this Privacy Statement, we may combine the information that we collect with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Statement.
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How We Share Your Information

Your personal data may be shared with others as described below:

• We may disclose your personal data to any member of our group of companies, affiliates, resellers, suppliers, and service providers as reasonably necessary for the purposes, and on the legal basis, set out in this Privacy Statement.
• We may disclose your personal data to our insurers and professional advisers as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defence of legal claims, whether in court proceedings or other legal proceedings.
• In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data; (a) where such disclosure is necessary for compliance with a legal obligation to which we are subject, (b) enforce our Terms of Service, this Privacy Statement, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of GTA, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, or in order to protect your vital interests or the vital interests of another natural person.

We reserve the right to transfer your personal information in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will require that the transferee use the personal information you have provided in a manner consistent with our Privacy Statement and the applicable legal framework.

Third-Party Links

We may collect your information from third parties. This includes you logging in through a third-party site such as a reseller website, a referring site, Facebook, Snapchat, Instagram, LinkedIn, Twitter, etc. We may also disclose information collected from third parties to customize ads and to manage and facilitate messaging on third-party sites. We do not control the privacy practices of third parties. We encourage you to review the privacy policies of third-party sites for more information regarding their applicable privacy practices.

Data Retention

We will keep your personal data while we are providing our products and services to you. Thereafter, we will keep your personal data for one of these reasons: (a) to respond to any questions, complaints, or claims made by you or on your behalf; (b) to show that we treated you fairly; and/or (c) to keep records required by law.

We will not retain your data for longer than necessary for the purposes for which it was collected as set out in this privacy notice. In determining data retention periods, we take into consideration local laws, contractual obligations, our reasonable business requirements, and your expectations and requirements. When it is no longer necessary to retain your personal data, we will securely delete or anonymize it.

Information Submitted by Children

GTA does not knowingly collect personal information from children under the age of 13. If GTA learns that it possesses information from a child under the age of 13, we delete that information from our systems. If you are a parent or guardian and are aware that your child has provided us with personal information, please contact us so that we will be able to take the necessary actions to delete such data.

Cookies, Web Beacons, and Other Technologies

GTA‘s Sites use Cookies. Cookies are text files containing small amounts of information that are downloaded to your device when you visit a website. Cookies are useful because they allow a website to recognize a user’s device. Cookies help with a variety of website functions including allowing users to “log in” to websites (making your navigation of websites more efficient), remembering your preferences (such as language), and generally improving your experience on our Sites. Cookies can also help ensure that the advertisements and content you see online are more relevant to you and your interests. We may also include web beacons in marketing e-mail messages or our newsletters in order to determine whether messages have been opened and links contained within clicked on.

Some of our business partners set web beacons and cookies on our site. In addition, third-party social media buttons may log certain information such as your IP address, browser type and language, access time, and referring website addresses. Further, if you are logged in to those social media sites, they may also link such collected information with your profile information on that site.

If you would like to opt out of cookies, visit www.aboutcookies.org or www.allaboutcookies.org for further information. These websites also tell you how to set your browser not to accept cookies and how to remove cookies from your browser. However, in a few cases, some of the features on our Sites may not function as a result. More information on our use of cookies can be found in our Cookies Policy.

Do Not Track

GTA does not track its customers over time and across third-party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, you may be able to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.

Email Notifications

You may choose not to receive commercial emails from us by following the unsubscribe instructions contained in the commercial emails we send. You may also email us directly at contact@greentechnology.ro at any time if you would like to unsubscribe from our email service. Please note that even if you unsubscribe from commercial email messages, we may still email you regarding your account.

Using Mobile and Other Devices

GTA, or third parties that we have engaged, may collect and store unique identifiers matched to your mobile device in order to deliver customized ads or content while you use our Sites, navigate the internet, or identify you in a unique manner across devices or browsers. In order to customize these ads or content, we, or third parties, may collect your information, e.g., your email address, or data passively collected from you such as your device identifier or IP address.

By adjusting the privacy and security settings on your device, you can manage how your mobile device and mobile browser share information, as well as how your mobile browser handles Cookies and other tracking identifiers. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

Marketing Communications

At GTA we take your privacy seriously and will only use your personal information to administer your account and to provide the products and services you have requested from us. By making contact with GTA and submitting information in the Inquiry Data, you indicate your consent that we may process that information for the purposes of offering, marketing, and selling relevant goods and services to you. GTA may share information with affiliates, resellers, suppliers, and service providers to provide products and services that help the market to customers or provide other requested customer services. You can also request us to send you marketing communications by managing your preferences in your account. If you have consented to receive marketing, you can unsubscribe yourself at any time from services to which you have subscribed by contacting us via email at contact@greentechnology.ro Unsubscribing yourself from our Marketing material will not negatively impact the services you have requested.

Your Access to and Control Over Your Information

You can inquire about your personal information, ask the following questions, or take the following actions by contacting us via email at contact@greentechnology.ro or via the address or phone number on our Sites to:

• See what information we have about you if any,
• Change/correct any information we have about you,
• Have us delete any information we have about you,
• Express any concerns you have about our use of your information.

Under certain conditions, you may have the right to request from GTA, among other things:

• The right to access your personal data;
• The right to rectification of your personal data;
• The right to the erasure of your personal data;
• The right to restrict processing of your personal data;
• The right to object to the processing of your personal data;
• The right to data portability of your personal data;
• The right to unsubscribe from marketing material at any time;
• The right to withdraw consent; and
• The right to complain to a supervisory authority.

For more information on the full extent of your rights or to exercise your rights, please contact our Data Protection Officer by mail to the address below or e-mail at contact@greentechnology.ro

Changes to Our Privacy Statement

Any material changes to this Privacy Statement will be posted on our webpage. It is your responsibility to review our Privacy Statement each time you provide Personal Information to us as the Privacy Statement may have changed since the last time you used our Sites or services.

How To Contact Us

If you have questions about GTA’s privacy policies and practices, please e-mail us at contact@greentechnology.ro

Green Technology Association

Address: 20 Cornelia Street ,4th District, Bucharest, Zip Code 040181

Privacy Questions/Data Subject Requests: contact@greentechnology.ro

Complaints, if they cannot be settled amicably with the GTC, can be addressed to:

National Authority for the Supervision of Personal Data Processing

B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336

Bucharest, Romania

anspdcp@dataprotection.ro

Phone/Fax: +40.318.059.211/+40.318.059.212

Green Technology Cluster

President

Gabriel MUNTEANU