Data Processing Agreement
While ensuring your protection on data processing is an extremely important goal to us, we used our best endeavours to comply with the standards imposed in the UE Regulation 2016/679 (https://eur-lex.europa.eu/legal-content/ro/TXT/PDF/?uri=CELEX:32016R0679) and in any other legal act in force on the Romanian territory
An important step towards achieving this goal is the information on how your data will be processed (processing means any operation or set of operations performed on the personal data or set of personal data, with or without the use of automated means, such as collection, registration, organisation, structuring, storage, adaptation or alteration, extraction, consultation, use, disclosure or otherwise rendering available, alignment or combination, restricting, deletion or destruction).
1. Who we are and how can you reach us:
Cohn and Jansen Advertising SRL,
Address: Str Speranței nr 21, 020992, 3rd Floor
2. Collection of data / types of data
- Gathered automatically as a result of access (by type)
- IP Address
- Date and time of access<
- Timezone difference to Meridian Greenwich (GMT)
- Content of request (website specific)
- Access status / HTTP status code
- The volume of data transferred
- Required access to the website
- Browser, language settings, browser version, operating system and surface
Collected after completing contact form:
- First and last name;
- Email address;
- Phone number;
- Collected after sending an email:
- First and last name;
- Email address;
- Cookie files. Click here to modify cookies settings
- This Website uses the so called “cookies”. Cookies are small text files that are stored by your device through the browser. They store certain information (such as the preferred language or the website settings) that your browser may send to us (according to the cookie lifetime) at your next visit on our Website.
- Within our Website, we use Google Analytics, a Google Inc. analysis service, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (hereinafter referred to as “Google”).
- Google will analyse the use of our Website on our behalf. The cookies will be used for this purpose. The information collected by Google regarding your use of our Website (such as the related URL, our web sites you visit, your type of browser, your language settings, your operating system, screen resolution etc.) will be sent to a Google server in the USA, where they will be stored and analysed. The results will be further rendered available to us in pseudonymised form. Moreover, Google complies with EU–US Privacy Shield, that ensures an adequate level of protection regarding the data processing by Google in the USA.
- You can withdraw your consent regarding the use of the web analysis at any time, by downloading and installing Google browser plugin provided.
- Within our Website, we use Facebook Pixel provided by Facebook Inc. (“Facebook”).
- We use the Facebook Pixel to track user behavior, which enables us to send you relevant, targeted advertising on Facebook. It’s a tracking pixel that collects information about you, which is used to build and optimize target audiences for Facebook ads. For example, it collects and sends data, which is connected to an identifier such as your name or IP-address, to Facebook regarding that you have visited our site and what you clicked on.The pixel sends this data to Facebook where it’s matched with your user profile if you have one. So, when we create an ad on Facebook, we can ask Facebook to target the ad to people who have visited our site and then it might pop up in your feed.
- We do not collect or store any personal data about you through the Pixel, but Facebook does. If you would like to opt out of this data processing, you can use the settings and opt out options provided by Facebook under: https://www.facebook.com/ads/preferences/edit
4. Purpose of data processing
- To communicate with you
- If you initiate a communication with us, your data will be stored for the period necessary to achieve the purpose for which you contacted us or until you request us to erase the data, whichever of those moments arises first;
- To enable us to provide you with services customised to your needs
- For marketing purposes
- We can use the relevant information to improve the products and services we are offering you.
- To safeguard our legitimate interests
- To safeguard our legitimate interests (in exceptional circumstances such as cyber attacks that can endanger the safety of our platform or in case the information are requested by our competent public institutions aiming at solving ongoing investigations, we reserve our right to process the information concerned)
5. For how long we keep your personal data
The length of time for which your data will be kept is limited and will be subject to the period required for fulfilling the purposes for which the data are processed, this period non exceeding 2 years.
- In case we are bound by the law or we are required to safeguard a legitimate interest, we may disclose certain personal data to public authorities.
- We make sure that the access to your data by the third parties private law legal entities is in compliance with the legal provisions on data protection and information privacy, based on agreements concluded with them.
The data will be processed exclusively on the territory of Romania. Except for the pseudonymised data used in the site analytics function described at point 3. 1 “Third parties cookies” which is done in the USA according to the procedure described and is regulated by EU–US Privacy Shield
8. Your rights
8.1. The Supplier commits to assist the Beneficiary to carry out the obligations that the latter has in relation to the data subject;
8.2. The Supplier commits to observe the data subject’s right as contemplated in the GDPR;
Right of access by the data subject
(1) The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
Right to rectification
(1) The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure (‘right to be forgotten’)
(1) The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
(c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
(d) the personal data have been unlawfully processed;
(e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
(f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).
(2) Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
(3) Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
(a) for exercising the right of freedom of expression and information;
(b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
(e) for the establishment, exercise or defence of legal claims.
Right to restriction of processing
(1) The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
(a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
(b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
(c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims
(d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
(2) Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
(3) A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.
Right to data portability
(1) The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
(a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
(b) the processing is carried out by automated means.
(2) In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
(3) The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
(4) The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.
9. INFORMATION NOTE WITH REGARD TO THE PROCESSING OF PERSONAL DATA IN THE RECRUITMENT PROCESS
As a personal data operator, hereinafter referred to as “Cohn & Jansen”, “the operator” or “us”,
Understands the importance of the processing of personal data and in this regard undertakes to protect the personal data processed in the current activities it carries out, including in the recruitment of its personnel, in accordance with the applicable legal provisions (including Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data) (“GDPR Regulation”).
Through this note, we would like to inform you about (i) the purposes for which we collect and process your personal data, (ii) the legal basis for the processing of these data, (iii) the categories of data we collect from you. and (iv) the length of time that you process these data, (v) the rights you receive as the person concerned and the way you can exercise them, (vi) whose disclosure we share with your personal data.
The purpose for which data is collected and processed
The personal data of candidates submitted to us via CVs and / or available on specialized platforms (e.g., LinkedIn) are processed to evaluate your candidacy for positions available in Cohn & Jansen, or to launch a potential contractual employment relationships, as appropriate.
The legal basis of data processing
The processing of personal data is required for the conclusion and performance of a contract (ie the individual employment contract); in this respect, the legal basis for processing is Article 6 (1) (b) of the GDPR Regulation.
Data categories collected and processed
The personal data we process are those that you provide to us in your resume and / or which are available on specialized platforms and include, among others: first and last name, photo, home address and / or address, personal address, personal telephone number, date of birth, sex, marital status, nationality, professional experience, studies, skills and knowledge, as well as any other personal data included in the resume on which you forward it.
To the extent that the documents you submit also contain the personal data of other individuals (for example, contact persons to check the references), please inform those persons prior to transmitting to Cohn & Jansen their personal data on how their personal data will be processed by the company.
The length of such data processing
The personal data that you make available to us within the CV and / or available on the specialized platforms will be stored and processed during the recruitment process for the available position within the company, and at the end of the process recruiting them to be deleted.
Recipients of personal data. Transfer of personal data
Cohn & Jansen does not transfer the personal data you provide to it in the recruitment processes to other third parties.
Security of processing
Cohn & Jansen will assure the security of your data processing from the time they are conceived by implementing appropriate technical and organizational measures.
Cohn & Jansen will also inform you without undue delay if any breach of your data security is likely to create a high risk to your rights and freedoms, except as provided in Art. 34 of the Regulation.
The rights you receive as a person concerned:
- Taking into account your personality status, you have the following rights:
- The right to be informed about all essential aspects of data processing;
- The right of access to the processed data and to a series of information, in accordance with the law, allows you to be informed whether your personal data is being processed by us as well as the details available in this respect (including but not limited to the scope of processing, the categories of personal data concerned, the recipients or categories of recipients to whom personal data has been or will be disclosed etc.),
- The right to obtain the rectification and / or completion of personal data without undue delay;
- The right to obtain the deletion of personal data without undue delay in the cases provided for by law (for example, when personal data are no longer required for the purposes for which they were collected or processed);
- The right to obtain restriction of processing in the cases provided by law (for example, when challenging the accuracy of data for a period that allows the operator to verify the accuracy of the data).
- The right to data portability You have the right to obtain personally processed data in a structured manner, which is currently used and can be read automatically for the purpose of transmitting this data to another operator, without any obstacle from the operator, in the cases provided by art. 20 of the Regulation.
- Right of objection You have the right to oppose, for reasons related to your particular situation, the processing under the public interest or the legitimate interest of the operator or for direct marketing purposes, including the creation of profiles based on such justifications, except as provided in art. 21 of the Regulation.
- The right not to be the subject of a decision based solely on automatic processing, except for the exceptions provided by art. 22 of the Regulation.
- The right to lodge a complaint with the National Authority for the Supervision of Personal Data Processing (ANSPDCP).
- The right to a remedy before the courts in Romania.
How you can exercise your rights
In order to exercise any of the above rights, please make a written or verbal request, indicating your quality of person and object of the request, which you can address to Cohn & Jansen using the contact details below:
To the attention of: HR Department
Address: Aleea Dealul Mitropoliei nr. 11
As long as you request a copy of the personal data processed by Cohn & Jansen, it will be provided to you in a material or electronic format as your option. Any subsequent copies of the same data will be provided for a fee.
Cohn & Jansen will analyze the merits of your requests and will provide you with an unreasonable delay and in any event within one month of receipt of the request. This period may be extended by two months when the complexity and number of applications require it. For requests submitted by you in electronic format, replies will also be sent electronically, unless expressly requested to provide them in another format.
As a person, we want to let you know that you have the following obligations:
- Providing accurate data
- To inform Cohn & Jansen, without undue delay, of any changes in the data processed.
Notification obligation regarding rectification or erasure of personal data or restriction of processing
(1) The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.
Without prejudice to your right to contact the supervisory authority at any time, you may preliminarily contact the e-mail email@example.com and we will do our utmost to solve any issue.
You are entitled to file a complaint to the supervisory authority with regard to your personal data processing. In Romania, the contact details of the supervisory authority for personal data processing are:
National Supervisory Authority For Personal Data Processing
28-30 G-ral. Gheorghe Magheru Blvd., 1st district, postal code 010336, Bucharest, Romania