Confidentiality Policy

Revision: October 2020

Your confidentiality is important for us. This Confidentiality Policy explains how the ”Romanian Waters” National Administration (hereinafter also referred to as the „Romanian Waters” or the „Organization”) manages and processes your personal data when visiting our website, www.inundatii.ro („the Site”); or you enter a relation with us in order to use the services provided by our organization („Services”); or you apply for a position with our organization; or you provide us with goods or services or you act as a representative, employee or any kind of agent of a company providing us with goods and services; or we process your data upon receiving the instructions or as a result of actions of third parties.

1. Aim of this policy

This Confidentiality Policy („the Confidentiality Policy ”, the „Policy”) explains our approach to any personal data we are collecting from you or that we have obtained about you from a third party and the purposes for which we are processing your personal data. Also, it specifies your rights on the processing of your personal data.

This Confidentiality Policy will inform you on the nature of your personal data we are processing and on how you may ask for its deletion, update, transfer and/ or granting of access to it.

Under this Policy, we use the term „processing” in order to cover all the activities involving your personal data, including collection, handling, storage, sharing, access, use, transfer and disposal.

This Confidentiality Policy is meant to help you make informed decisions when using our Site and Services, understand how your personal data can be processed by us during or as result of the Services provision or when asking to work for or with our Organization.

2. Who we are and what we do

The ”Romanian Waters” National Administration manages the State public domain assets such as those set forth under art. 136 par. 3 of the Romanian Constitution, republished, publicly-owned assets stipulated by Law no. 213/1998 on the public property and its legal regime, with subsequent amendments and supplementations, as well as own patrimony.

3. How to contact us

Our contact data: 6, Edgar Quinet Street, Sector 1, PO Box 010018, Bucharest,

Tel./Fax: +40 21 312 21 74; Tel.: +40 21 311 03 96;

Mailing address: 11 Ion Campineanu Street, Sector 1, PO Box 010031, Bucharest

If you have any questions on this Confidentiality Policy or if you want to exert the rights set herein, please contact us by sending an e-mail to our person in charge with personal data protection, at the e-mail address: gdpr@inundatii.ro.

4. What personal data we collect

We can collect personal data from you during our activity, including through your use of our website, when you contact us or request information, when you use our services or as a result of your relation with one or several members of our staff or with our beneficiaries.

Both our Site and Services are intended for persons over 18 years old, so that we do not intend to collect and process via our website data of individuals under this age.

Our main purpose in collecting your personal data is to help us:

check the identity;
provide our Services;
improve and develop services;
settle requests, disputes and complaints;
comply with any applicable law, court decision, legal instrument or with the requirements of any authority;
perform our contracts with you;
for recruitment purposes;
use in other cases where required or permitted by law.

In order to achieve such goals, we can process the following personal data:

If you are a visitor of the website:

The information obtained via the cookie files or via similar technologies, such as: display preferences of the website, the agreement on data processing by means of cookies or information that cannot be used for identification with a single profile;
All the information on the cookies used on our site can be found in the ”Cookies Policy”.

We inform you that, by accessing our website, third parties can collect data about you as a result of integrating the plugins of social media, such as the buttons „Like” and „Share”, even if you have not pushed them or you are not a member of the respective social media. Our organization is not involved in any way in operations of data processing by social media, except for collection and retrieval, which are automatically, without us having any access or control over the data collected by social media. For more information, please consult the confidentiality policies of the social media the plugins of which are displayed on our website (Facebook, LinkedIn etc.).

b) If you are a natural entity and have a relation with us, as a beneficiary, in order to use the services provided by our organization (beneficiary or potential beneficiary):

First name and last name
Contact data (e-mail address and phone number)
Any other personal information about you or other third parties that you could provide us in relation to the reception of our services

c) If you are a potential applicant for a job:

Romanian Waters collect information also about applicants in relation with available job or collaboration opportunities. Such information may include CVs, identification documents, academic records, trainings or certifications obtained, work, employment records and credentials.

Romanian Waters use your personal data in order to match your abilities, experience and education with the specific positions provided. Such information is sent to managers in charge with hiring staff and to people involved in the recruitment process in order to decide on your employment. Romanian Waters may collect additional data from you if you are invited to the interview stage (or equivalent) and afterwards.

As to our recruitment activities, we can also collect special categories of personal data from applications for whom we have an obligation stipulated by the labor law in this respect, if the information is relevant for their future work environment within Romanian Waters or the future provision of benefits related to employment or with the respective person’s explicit agreement. For instance, we might need to collect information of the health condition of an applicant, in order to provide an appropriate work environment to that particular applicant, if recruited.

Romanian Waters may collect personal data about you directly from you – for example, the information you provide when applying for a position.

Failure to provide such information shall automatically lead to the impossibility to conclude and/or perform the contract.

As to our recruitment activities, we can also process other special categories of personal data from our applicants when:

the processing is necessary in order to meet our specific employment obligations (data on the health condition, for instance)
the processing refers to personal data which is manifestly made public by you (for example, sexual orientation, philosophical or religious beliefs, etc.)

We can process data on criminal convictions and offences when such processing is authorized by the law of the European Union or by the internal law stipulating appropriate guarantees for the rights and obligations of the persons in scope.

d) If you act as a representative (any member of the staff – employee, manager, agent, collaborator, consultant and other similar) of a company which is our Beneficiary or which provides us with goods and services or of a person empowered by our beneficiaries/ providers.

During our relation with other legal entities, we can be provided with personal data, such as personal data regarding the staff (employees, managers, agents, collaborators, consultants and other similar) of our providers or beneficiaries or of the Persons empowered by the latter.

Data processed about you in this context refers to:

First name and last name
Contact data (e-mail address and phone number)
Position and/or current relation with the Organization – Beneficiary or Supplier or person empowered by the latter, any identification data in a power of attorney granted by you to them
The data necessary for the settlement of complaints, including a complaint identifier
Audio and/ or video recordings, photos

Depending on the needs, one may also process other types of data sent by our contractual partner.

How we use personal data

In order to provide the services and solve your requests

We collect and keep personal data sent by you during the use of our Site and / or of our Services in order to enable us to provide you with the services you require and to solve your requests.

Our site is using different user interfaces in order to enable you to ask for information about our Services. One can ask for contact data in each case and other details on the personal data which are relevant for your request. Such information is used to enable us to respond to your requests.

What is our legal basis?

If you contact us on your own, it is necessary to process your personal data in order to fulfill our obligations as per the legal provisions. If you contact us as a representative of a company, it is our legitimate interest to process your personal data to be able to respond to the request of your Organization made by mean of you. Failure to provide such data shall automatically lead to the impossibility to conclude and/or perform the contract, respectively to the impossibility to solve your request.

We may use your personal data for the following activities:

For the settlement of disputes and complaints
To protect the rights, safety or ownership of your organization or of its staff, employees, providers or other similar
To fulfill the legal obligations and the requests of authorities
For ascertaining, exerting and defending a right in court

What is our legal basis?

In case we use your personal data to fulfill our legal obligations, we do so because it is our legal obligation to use your personal data for this purpose. In the other cases, we process personal data because it is our legitimate interest to do so and the processing is necessary for ascertaining, exerting or defending a right in court.

Analysis

We use cookies to provide you with a tailored experience of navigating and using our Site or services. These are, generally, text files, similar modules or technologies, that your computer, tablet or phone browser can store when visiting our site. Such files have definite durations for keeping and remain passive, they do not include any malware and do not access information on your hard-drive. These types of files can be accessed only by the webserver that has installed them.

Information included in cookie files may refer to the following:

A session ID to track the statistics related to the use of our site
Display and navigation preferences
General demographic data, which cannot identify you in a single manner

By using such information, we can measure the efficacy of our content and how users use our site and services. They enable us to find out what pages of our site are the most attractive for our visitors and which sections of the site are the most interesting.

Consult the Cookies Policies for additional information.

What is our legal basis?

In case your personal data is not in an anonymous form, we use your personal data based on your consent.

What is the legal basis under which we process your personal data

It is necessary to use your personal data based on the following grounds:

In order to meet our obligations in accordance with any contract that we might have with you.
It is our legitimate interest to use personal data so as to ensure that we provide our Services the best way possible
It is our legal obligation to use your personal data to comply with the applicable legal regulations
We have given your consent for processing

We may process special categories of data on the occasion of the provision of our services when:

the processing is necessary in order to fulfill our specific employment obligations (data on the health condition, for example)
the processing is necessary for ascertaining, exerting or defending a right in court
the processing refers to personal data which are manifestly made public by you (for example, sexual orientation, philosophical or religious beliefs, etc.)

With whom we share your personal data

Romanian Waters may share personal data with various categories of third parties, as applicable:

Services providers, IT systems and software, cloud and hosting, IT assistance, storage of documents and information, platforms and/or providers of revision and management of documents and of activities, audit, training, etc.
Human resources and waging platforms, guard firms and facility management bodies, delegates, post or courier services providers
Third-party services providers supporting us in the deployment of processes of the Romanian Waters National Administration;
Public or regulatory authorities.
Please keep in mind that this list is not exhaustive and there may be examples where we have to share personal data with other parties for the provisions of services as effectively as possible or to protect the rights, safety, ownership of the Romanian Waters National Administration or of the of its staff, employees, providers or other similar, to respond to complaints or to prevent fraud and illegal activities.

Use of cookies

Our site is using cookies in order to analyze the trends related to the traffic and preferences of our users. Please consult the Cookies Policy in order to find out all the information about cookie modules we are using, their purpose and duration, respectively how you can use the preferences.

9. Empowered persons, independent operators and associated operators

The confidentiality of your data is important for us, for which reason the delivery of personal data to empowered persons, independent operators and associated operators is made by virtue of a confidentiality agreement with them, guaranteeing that such data is kept safe and that the management of such information is made as per the applicable legislation and policies. In any case, every time, we will send only the information strictly necessary to achieve the respective goal.

We can appoint as empowered persons sub-contractors as required to perform certain activities. We make all endeavors and we use the contractual documentation necessary for any sub-contractor, in order to make sure that the latter processes the personal data in a properly manner and according to the legal and regulatory obligations.

For how long we keep your personal data

We keep our personal data that we are collecting from and about you as long as it is necessary to reach the purpose of collection and in order to meet any legal requirement. In order to determine the appropriate period of time for keeping personal data we are processing, we consider the nature, scope, context and purpose of processing, risks with various degrees of probability and severity for your rights and liberties, applicable legal requirements, as well as if we can achieve the purposes of processing via other means.

We reconsider on a permanent basis the need to keep your personal data and, when the retention deadline is met, we destroy your personal data so as it can no longer be recovered or restored. In case it results in a reasonable manner that this data is no longer necessary, we can destroy them immediately, without any notification.

Confidentiality and security of your personal data

We apply appropriate technical, physical and organizational measures, reasonably designed to protect personal data against destruction, loss, modification, disclosure or unauthorized access and against any other illegal processing forms. The access to personal data is limited to authorized persons based on the need to become aware of it. We keep a comprehensive information security software, proportionally to the processing related risks. The software is permanently adapted to mitigate operational risks and to protect personal data, considering accepted practices in the field. Besides, we use improved security measures when processing any special categories of personal data.

All our partners, employees, suppliers or empowered persons (namely those processing your personal data on our behalf, for the aforementioned purposes), are bound to comply with the confidentiality of such personal data and to grant the same protection level as the one granted by the Romanian Waters National Administration.

Access rights and other rights

You have the following rights over the personal data that we process or hold about you:

Right of access

If you ask so, we will confirm whether we are processing your personal information and, if allowed by law, we will provide a copy of such personal data (together with certain other details). If you need additional copies, we might charge a reasonable fee based on administrative costs.

Right of rectification

If your personal data, that is in our possession, is inaccurate or incomplete, you are entitled to ask for its rectification. If you have the right of rectification and if we have shared your personal data with other persons, we will inform them on the rectification if possible. If you ask, where possible and legal to do so, we will also mention the entities with whom we have shared your personal data, so that you will be able to contact them directly.

Right of deletion

We may ask us to delete or suppress your personal data under certain circumstances, as in the case that we would no longer need it. If you have the right of deletion and we have shared your personal data with other persons, we will inform them about the deletion of such data, where possible. If you ask, where possible and legal to do so, we will also mention the persons with whom we have shared your personal data, so that you will be able to contact them directly.

Your right to restrict the processing

You can ask us to „block” or cease the processing of your personal data under certain circumstances, as if it were the case where you challenge the accuracy of such personal data or you made objections. If you have the right to restriction and if we have shared your personal data with other entities, we will inform them on the restriction where possible to do so. If you ask, where possible and legal to do so, we will also mention the persons with whom we have shared your personal data, so that you will be able to contact them directly.

Right to data portability

Under certain circumstances, you will be entitled to obtain the personal data provided to us, in a structured format, frequently used and which can be automatically read and to use it somewhere else or to ask us to transfer it to a third party, at your choice.

Right of objection

entitiesou can ask us to no longer process your personal data and we will do so if:

We rely on our legitimate interests or on third-party legitimate interests in order to process the personal data, except for the case where we can prove the imperative legitimate reasons justifying the processing

In the context of events organized within the Romanian Waters National Administration, one could make photos /video recordings to help us promote our organization and services. We do not intent to take photos featuring a certain individual. If still your person is identifiable in the photo/video recordings posted by us, you will be entitled to object to the processing for reasons related to your particular situation. In any case, for protecting your right to private life, prior to any photo and/or video session, we will inform you beforehand that we are about to take photos.

Romanian Waters will never use your personal data to subject you to an automatic individual decision.

Right to withdraw your consent

If we rely on your consent as a legal basis for processing your personal data, you shall be entitled to withdraw such a consent at any time.

Your right to submit a complaint with the supervisory authority

If you are concerned about any aspect of our confidentiality practices, including how we have handled your personal data, you can report this to the relevant supervisory authority.

If you want to exert the rights set forth in this confidentiality policy, please contact us by sending an e-mail to: gdpr@inundatii.ro .

Modifications of this Confidentiality Policy

We can operate, from time to time, modifications to this Confidentiality Policy. In order to ensure that you are always informed on how we use your personal data, we will occasionally update this Confidentiality Policy in order to reflect any modification in the use of your personal data. Besides, we can make changes to comply with the amendments of the applicable laws or regulatory requirements. However, we recommend you to consult, on a regular basis, this Confidentiality Policy on our site to be informed about how we use your personal data.