Personal data protection policy
The protection of your personal data is important to us, therefore, we pay special attention to the protection of privacy of visitors who access the site https://aviation.adservio.eu/, hereinafter referred to as the Site, as well as persons who use the educational platform ADSERVIO called hereinafter ADSERVIO PLATFORM.
From 25 May 2018, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, hereinafter referred to as “GDPR”.
Personal data is data that directly identifies an individual such as name, surname, home address, e-mail address or telephone number, but also any other data that allows its indirect identification, such as, in certain cases, enrollment number of students.
GDPR is applicable to any legal entity that processes personal data in their activity.
Please pay special attention to reading the following Policy in order to understand how your personal data will be treated.
Through this Policy, we inform you about our practices regarding the application of the provisions of the GDPR but also about the nature of the personal data we process on the Site and on the ADSERVIO PLATFORM, the purposes and grounds of processing, the rights enjoyed by data subjects.
- DEFINITIONS:
- ANSPDCP represents the National Authority for the Supervision of Personal Data Processing;
- “personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifying element, such as a name, an identification number, location data, an online identifier, or one or more many specific elements of his physical, physiological, genetic, mental, economic, cultural or social identity;
- “processing” means any operation or set of operations performed on personal data or personal data sets, with or without the use of automated means such as collecting, recording, organizing, structuring, storing, adapting or modifying , extracting, consulting, using, disclosing by transmission, dissemination or otherwise making available, aligning or combining, restricting, deleting or destroying;
- “restriction of processing” means the marking of stored personal data in order to limit their further processing;
- “controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of processing are determined by Union or national law, the operator or the specific criteria for its designation may be laid down in Union or national law;
- “authorized person” means the natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
- “recipient” means the natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not it is a third party. However, public authorities to which personal data may be disclosed in the course of a particular investigation in accordance with Union or national law shall not be considered as recipients; the processing of such data by the public authorities concerned shall comply with the applicable data protection rules in accordance with the purposes of the processing;
- “consent” of the data subject means any manifestation of the free, specific, informed and unambiguous will of the data subject by which he or she consents, by an unequivocal statement or action, that personal data concerning him or her be processed.
2 . WHO WE ARE
We are Adservio Social Innovation S.R.L. with its registered office in the Municipality of Iași, Bulevardul Socola Street, Number 3, Block D2, Staircase B, 4th floor, Apartment 19, Iași County, registered at the Trade Register Office under no. J22 / 1482/2009, having Unique Registration Code RO 26033834, hereinafter referred to as ADSERVIO.
ADSERVIO is the author, owner and administrator of the https://aviation.adservio.eu/ Site and of the ADSERVIO FOR AVIATION PLATFORM so that all the information contained in this Policy is related and valid in relation to the activity on the Site and on the ADSERVIO PLATFORM.
- IDENTITY AND CONTACT DETAILS OF THE PERSON RESPONSIBLE FOR DATA PROTECTION (DPO)
ADSERVIO has appointed a Data Protection Officer (“DPO”), who has the obligation to verify compliance with the provisions of the GDPR in the data processing operations performed by ADSERVIO and to represent ADSERVIO in relation to data subjects and ANSPDCP.
The persons concerned have the possibility to address at any time, directly, RPD to the following email address: dpo@adservio.education.
- PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA
ADSERVIO undertakes to comply with the principles of personal data protection set out in the GDPR, in order to ensure that all data are:
- Processed correctly, legally and transparently;
- Collected for specified, explicit and legitimate purposes;
- Adequate, relevant and limited in relation to the purposes for which they are processed;
- Correct and updated;
- Kept in a form which does not allow the identification of the persons concerned for longer than is necessary in relation to the purpose of the processing;
- Processed in accordance with the rights of the data subject, in a way that ensures adequate security of processing, so that the data is complete, confidential and available.
- WHAT TYPES OF PERSONAL DATA WE COLLECT
We inform you that we process the following personal data through the existing forms on the Site:
- In the “Request presentation” form: first name, e-mail address, telephone number, the organization you represent, the role in the organization, the locality and the county. We need the data to be able to register for this event and we process it if you give your consent.
- In the “Add a comment” section: name, email address you entered with the desired comment. We need the data to receive your comment and we process it if you give us your consent.
- In the section “Find out all the news Adservio”: the e-mail address that you provide us and that we process if you give us your consent in this regard.
- In the “CONTACT US” section: name, surname, school, telephone, e-mail address. We need your data to contact you as soon as possible (maximum 24 hours) following your request.
- We post on the Site your testimonials about the ADSERVIO PLATFORM that may contain personal information, such as the name, photo, position and / or video of the person in the testimony. We obtain the person’s prior consent to ensure that we have permission to post this content publicly. To request the removal of your personal information from the testimonials, please contact us at dpo@adservio.education
ADSERVIO may also receive and record on its servers the information regarding the IP address and cookie information of the requested site. You have the option to set your internet browser to reject certain cookies. However, this will have a negative impact on your browsing of the Site. Adservio’s cookie policy can be found here.
We collect personal data from users of the ADSERVIO PLATFORM for the creation of user accounts and for the data subjects to have access to the information provided by the ADSERVIO PLATFORM.
- Name, surname, specialization, e-mail address, telephone number, image
- Name, surname, group in which the user is enrolled, e-mail address, telephone number, image;
- Name, surname, e-mail address, telephone number belonging to the Directors and administrators of the educational units with which ADSERVIO has a contractual relationship.
ADSERVIO may access the data when necessary to provide support and assistance in using the ADSERVIO PLATFORM. All data about our users is entered in the ADSERVIO PLATFORM by persons appointed by the Client (educational unit) with which ADSERVIO has a contractual relationship.
- PURPOSE FOR WHICH WE PROCESS PERSONAL DATA
We request and process personal data in order to:
- Make it possible to register for a demo presentation, once you have given your consent through the “Request a presentation” form;
- Receive and analyze your comment once you have given your consent using the form provided in the “Add a comment” section:
- To send you newsletters, invitations, materials related to our services and information related to the events or programs that we organize or promote once you have given your consent through the form “Find out all the news Adservio”;
- To contact you once you have given your consent through the form sent in the section “CONTACT US;
- Make it possible to create your account on the ADSERVIO PLATFORM;
- Ensure the proper functioning of the ADSERVIO PLATFORM;
- To prevent spam, fraud and abuse and to help recover the account, the username of the account via SMS;
7.Grounds for processing personal data
ADSERVIO processes personal data on Site and on the ADSERVIO PLATFORM:
- on the basis of the consent given by the persons entrusting the data to us (art. 6 paragraph 1 sentence 1 letter of the GDPR
- for the execution of a contract to which you are a party (art. 6 paragraph 1 sentence 1 letter b GDPR)
- in order to fulfill a legal obligation incumbent on us (art. 6 para. 1 thesis 1 letter c GDPR)
- according to the legitimate interest of ADSERVIO (art. 6 paragraph 1 thesis 1 letter f GDPR).
- PERSONAL DATA TRANSFERS
We will disclose your personal data where necessary, for example by law or if we believe that such action is necessary to comply with the law or to protect the security or integrity of the Site and the ADSERVIO PLATFORM.
There are also situations in which data is sent to the competent authorities and institutions, lawyers.
Whenever we use subcontractors, acting either as a data controller or as a proxy, we ensure that the requirements set out in the GDPR are met and that your personal data is processed appropriately.
In principle, your personal data will not be transmitted to a third country or to an international organization.
- DURATION OF KEEPING PERSONAL DATA
We retain the personal data you provide for a reasonable period of time, as long as is necessary to fulfill the purposes described above and to fulfill our legal obligations to which we are subject. If our personal data is no longer needed and useful, we will delete it.
The reasons for which we keep personal data are based on compliance with legal obligations under the GDPR and to protect our rights and interests in any actions before the competent courts.
- DATA DISCLOSURE
In the event that we are required to disclose your personal data by court order or to comply with other legal requirements, we will notify you by prior notice before providing such data unless such disclosure is prohibited. We will not sell, disclose, share your personal data without your consent and permission.
- HOW WE ENSURE THE SECURITY OF PERSONAL DATA
We are committed to adopting appropriate technical and organizational measures in line with industry standards. The ADSERVIO PLATFORM is aligned with GDPR requirements and uses encryption and personal data security technology.
ADSERVIO will not disclose personal data collected through the ADSERVIO PLATFORM except for authorized ADSERVIO employees and ADSERVIO contractors / partners who have the capacity of authorized persons.
ADSERVIO, together with its collaborators, has assumed the responsibility of implementing appropriate technical and organizational measures regarding the protection of personal data, respectively for the protection against unauthorized access, use, alteration or destruction of personal data according to the provisions of GDPR, as follows:
- Users who have access to the database of personal information are only those who have created an account on the ADSERVIO PLATFORM, each of them benefiting from the functions of the ADSERVIO PLATFORM with their own account name and password.
- All employees, collaborators and service providers of ADSERVIO who come into contact with personal data must act in accordance with the principles of policies and procedures for the protection and security of personal data by signing declarations and confidentiality agreements with regarding these data.
- The computers from which the database is accessed are password protected, they have implemented up-to-date antivirus, antispam and firewall protection solutions.
- LOCATION OF PERSONAL DATA
Personal data is stored in the cloud, and in physical format, in Romania, in full compliance with legal requirements and in conditions of maximum security and protection.
- WHAT RIGHTS DO YOU HAVE IN RELATION TO PERSONAL DATA?
We assure you that we respect your rights as established by applicable law.
- Right of accessmeans the data subject’s right to obtain confirmation from the controller that he or she is processing or not processing personal data concerning him or her and, if so, access to that data and information on how the data is processed.
- The right to data portabilityrefers to the right to receive personal data in a structured, commonly used and automatically readable format and to the right to have this data transmitted directly to another controller, if this is feasible from the point of view of from a technical point of view.
- Right to object“refers to the data subject’s right to object to the processing of personal data where the processing is necessary for the performance of a task in the public interest or where he considers a legitimate interest of the controller. Where the processing of personal data is entitled For the purpose of direct marketing, the data subject has the right to object to the processing at any time.
- The right to rectificationrefers to the correction, without undue delay, of inaccurate personal data stored. The rectification must be communicated to each of the recipients to whom the data were transmitted, unless this proves impossible or involves disproportionate (demonstrable) efforts.
- Right to erasure of data(“right to be forgotten”) means the right of the data subject to request that his / her personal data be deleted, without undue delay, if one of the following reasons applies: they are no longer necessary for the fulfillment of the purposes for which they were collected or processed; withdraws its consent and there is no other legal basis for processing; opposes the processing and there are no legitimate reasons to prevail; personal data has been processed illegally; personal data must be deleted in order to comply with a legal obligation; personal data have been collected in connection with the provision of information society services.
- The right to restrict processingmay be exercised if the person disputes the accuracy of the data, for a period which allows the accuracy of the data to be verified; the processing is illegal and the person objects to the deletion of personal data, requesting a restriction instead; if the controller no longer needs the personal data for the purpose of processing, but the person requests it in order to establish, exercise or defend a right in court; if the person objected to the processing for the period of time in which it is verified whether the legitimate rights of the controller prevail over those of that person.
- UPDATING THE PROTECTION POLICY AND PROCESSING OF PERSONAL DATA
We reserve the right to change, complete the Personal Data Protection Policy at any time by posting the amended Data Protection Policy.
- CONTACT DETAILS OF THE NATIONAL AUTHORITY FOR THE SUPERVISION OF THE PROCESSING OF PERSONAL DATA
Address: B-dul G-ral Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, România
Mail:anspdcp@dataprotection.ro
Tel: +40318.059.211;+40318.059.212