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GDPR Policy

 

POLICY REGARDING THE PROCESSING OF PERSONAL DATA

CÂMPULUNG FILM FEST - CÂMPULUNG MOLDOVAN INTERNATIONAL FILM FESTIVAL

 

The policy on the processing of personal data describes the categories of data we process, the manner and purposes for which we collect them, the situations in which we transfer personal data and the various rights and options you have in this regard. Our policy on the processing of personal data details how we process personal data in the exercise of specific activity on the organization, conduct and promotion of Câmpulung Film Fest - Câmpulung Moldovenesc International Film Festival (“CFF”) and most often to keeps you up to date with CFF events and products marketed in connection with SBB.

 

  • YOUR PERSONAL DATA OPERATOR

ASOCIATIA HASMAȚUCHI, Romanian legal entity, based in Câmpulung Moldovenesc, str. Nicolae Filimon, no. 6, Suceava county, as organizer of CFF is the operator of your personal data.

  • PERSONAL DATA CATEGORIES PROCESSED

The personal data we process may include:

  • Contact information such as your name, job title, mailing address, including your home address, if you provided it to us, business address, telephone number, mobile phone number, fax number and mailing address e-mail;

  • Additional information that must be processed for the purpose of concluding or exercising a contractual relationship or communicated voluntarily by you, such as instructions given, payments made, requests and projects;

  • Information collected from public sources;

  • Other personal data necessary for the purpose of informing you if they prove relevant to the activity we carry out that falls within the legitimate interest of the operator;

 

In limited situations, in which to carry out our activity, we must collect special categories of personal data as they are found in art. 9 of the Regulation on the protection of individuals with regard to the processing of personal data and on the free movement of such data (“GDPR”), respectively the personal numerical code, your images, data on your membership of a professional or trade association or a union, personal health data, data on your political opinions and criminal record data, processing will be done only:

i. on the basis of your express prior consent or on the basis of fair evidence of your consent provided by a third party who communicates this information to us;

ii. based on a legal obligation to process these categories of data;

iii. on the basis of an obligation to defend a legitimate right;

  • IP addresses. Sites collect IP (Internet Protocol) addresses. An IP address is a number assigned to your computer by your ISP that allows you to access the Internet. An IP address can be a personal date. We use IP addresses to diagnose server problems, report information in aggregate form, determine the most efficient connection to our site, and to administer and improve the site.

  • Cookies. Sites use "cookies". A cookie is a small text file, stored on your computer, tablet, or phone when you open a website, that helps the site recognize you, including your preferences. Some cookies are deleted when you close your browser. These are called session cookies. Others remain on your device until they expire or clear them from your cache. These are persistently called cookies, which allow us to retain information about recurring visitors. The cookies we use allow us to recognize and count the visitors present, and to see where visitors are going to the site. Thus, we can improve the functioning of sites, for example by organizing them so that users can easily find what they are looking for. Our cookies also allow us to personalize the content you view, based on your preferences.

  • Email adress. If you subscribe to the alerts sent by e-mail or confirm the maintenance of the subscription before May 25, 2018, we collect your e-mail address. This address is used only for the information you have requested / confirmed. If you wish to unsubscribe, you can do so at any time by using the instructions in each email you receive, or by sending an email to home@campulungfilmfest.com.

  • HOW WE COLLECT YOUR PERSONAL DATA

 

We may collect personal data about you in certain circumstances, including:

  • When you or your organization engages in contractual relationships with us;

  • When you voluntarily communicate to us or your organization, for any reason, your personal data;

  • When you browse, request information or interact, or your organization browses, requests information or interacts on our website or using CFF online applications;

  • When you participate in an event organized by us that involves the provision of personal data on your part;

 

In certain circumstances, we collect personal data about you from a third party source. For example, we may collect personal data from your organization, other organizations you have links with, government agencies, credit bureaus, information or service providers or from public archives or partners / collaborators with whom we have established contractual relationships that I assume, for others, the sharing of our databases.

 

  • LEGAL GROUNDS ON THE BASIS OF WHICH PERSONAL DATA PROCESSING

Any operation that amounts to a processing (collection, storage, registration, structuring, adaptation or modification, extraction, consultation, use, disclosure by transmission, destruction) of your personal data will be carried out on one of the following legal grounds. :

  • Processing is required to perform a contract to which you are a party or your organization is a party, or such processing is necessary to enter into a contract with you or your organization;

  • Processing is necessary in order to comply with a legal obligation;

  • The processing is carried out with your prior and explicit consent;

  • Processing is necessary to protect the vital interests of you or another individual;

  • Processing is necessary for the purpose of our legitimate interests or those of a third party, unless your interests or fundamental rights and freedoms prevail over those interests.

 

In cases where the applicable legal provisions require your prior and explicit consent for the processing of certain categories of data, we will process such data only on the basis of your prior and explicit consent. At the same time, we will take additional assurances that any natural person or entity who discloses your special personal data to us has obtained your prior consent.

You can choose to withdraw your consent to the marketing materials at any time by simply accessing the 'unsubscribe' link at the bottom of each newsletter or event invitation.

You have the right to withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of the processing based on the consent prior to its withdrawal. In order to withdraw your consent for any processing on which you have previously consented, please send us an e-mail to home@campulungfilmfest.com, contact us at +40 768 220 100 or send us an explicit letter to Str . Nicolae Filimon, Nr. 6, Câmpulung Moldovenesc, Suceava County, Romania. In all cases, consent may be withdrawn in the same manner as it was given.

 

As a general rule, in cases where you withdraw your consent, we will no longer allow the processing of your data and will take appropriate measures to delete any records with your personal data. However, if the processing is strictly necessary in order to carry out the activity and the processing could be based on other legitimate grounds provided by the applicable legal provisions, we will proceed with that processing and inform you accordingly.

 

  • COLLECTION OF PERSONAL DATA OF MINORS

CFF does not allow the processing of personal data of customers under the age of 18.

With regard to the provision of information society services directly to a child, the processing of a child's personal data is legal if the child is at least 16 years old. SBB shall make all reasonable efforts to verify in such cases that the holder of parental responsibility has given or authorized consent, taking into account available technologies. Thus, the processing of personal data of minors by CFF will be done only with the explicit consent of parents or other legal representatives.

 

In the process of creating an account or placing an order in the CFF Shop,

customers must confirm that they have reached the age of 18.

 

  • PURPOSES FOR WHICH YOUR PERSONAL DATA WILL BE PROCESSED

We may use your personal data only for the following purposes ("Allowed Purposes"):

  1. Compliance with our legal obligations (such as record keeping obligations), compliance verification or registration obligations which may include automatic verification of your contact details or other information you provide to us regarding your identity with applicable lists of the sanctioned persons and contacting you to confirm your identity in the event of a possible positive outcome, or recording the interaction with you that may be relevant for compliance purposes;

  2. Purposes such as advertising, marketing and publicity, statistics exclusively in the interest of the operator or his proxies, the organization of courses, seminars, other events (including delegations, conferences and fairs), for educational purposes for the organization of training programs, for the issuance of any financial documents. accounting, concluding contracts or other documents necessary in the activity of SBB;

  3. Analyzing and improving our services and communications to you;

  4. Protecting security and managing access to our headquarters, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities;

  5. For insurance purposes;

  6. For the purpose of monitoring and evaluating compliance with our policies and standards;

  7. For any purpose related to and / or ancillary to any of the above or any other purpose for which your personal data has been provided to us.

 

If you have given us your consent, we may also process your personal data for the following purposes:

  • Communicating with you through the channels you have approved to keep you informed regarding events / information regarding services, products as well as SBB events and projects;

  • Surveys among customers / partners / collaborators, marketing campaigns, market analysis, raffles, contests or other promotional activities or events.

With regard to communications related to marketing / information about events, we will make available to you - if legally required - that information only after you have selected this option to participate and we will give you the opportunity to no longer participate. at any time, in cases where you do not wish to receive marketing / information communications regarding events from us.

We will not use your personal data in making automated decisions that affect you or create profiles other than those described above.

 

  • TRANSMISSION OF YOUR PERSONAL DATA

We may share your personal data obtained from you in the following circumstances:

  1. We may provide you with confidential contact information to third parties for the purpose of obtaining feedback from you on the provision of services by the company, to help us measure our performance and improve and promote our services;

  2. We may share your personal data with companies that provide services for controls against money laundering, credit risk reduction and other fraud and crime prevention purposes, and companies that provide similar services, including financial institutions, credit bureaus and regulators. with whom the respective data are shared;

  3. We may share your personal data with any third party to whom we assign or renew any rights or obligations;

  4. We may also use agreed personal data and statistics in order to monitor the use of the website to assist us in developing our website and services.

 

We may also share your personal data with our authorized persons - mainly service providers within or outside SBB, domestically or internationally, e.g. common service centers, for the processing of personal data in the Permitted Purposes, on our behalf and only in accordance with our instructions. We will retain control of your personal data and use appropriate safeguards, in accordance with applicable law, to ensure the integrity and security of your personal data at the request of those service providers;

Except as above, we will disclose your personal data only when you instruct or grant us permission, when required by applicable law or regulations or requests of judicial or official bodies to do so, or as required to do so. investigation of fraudulent or criminal activities, actual or suspected.

 

  • PERSONAL DATA THAT YOU PROVIDE US WITH OTHER INDIVIDUALS

If you provide us with personal data about another person (such as one of your administrators or employees, or a person with whom you have a professional relationship), you must ensure that you have the right to disclose this data to us. and that, without further action, we may collect, use and disclose such personal data as described in this Personal Data Processing Policy.

In particular, you must ensure that the individual concerned is aware of the various aspects dealt with in this Personal Data Processing Policy, as they relate to that individual, including our identity, how he or she can contact us, the purposes for which we collect, our personal data disclosure practices (including disclosure to recipients abroad), the individual's right to access personal data and to file complaints regarding the management of personal data, and the consequences of non-provision personal data (such as our inability to provide services).

 

  • KEEPING YOUR PERSONAL DATA SECURITY

We have implemented technical and organizational measures to maintain the confidentiality and security of your personal data, in accordance with our internal procedures regarding the storage, disclosure and access to personal data. Personal data may be stored on our personal data technology systems, those of our contractors or in hard copy.

 

  • TRANSFER OF YOUR PERSONAL DATA ABROAD

In exceptional circumstances, under the Permitted Purposes, we may transfer your personal data to countries that have not been recognized by the European Commission as providing an appropriate level of protection.

We will ensure that these international transfers are made subject to appropriate or appropriate safeguards, as required by the General Data Protection Regulation (EU) 2016/679 or other applicable laws. This includes the conclusion of EU Standard Contract Terms. You can contact us at any time, using the contact details below, for further information on these safeguards.

 

  • UPDATING YOUR PERSONAL DATA ABOUT YOU

If any of the personal data you have provided to us changes, for example if you change your first name, last name or email address or if you wish to cancel any request to us, or if you become aware of it. that we have any incorrect personal data about you, please let us know by sending an e-mail to home@campulungfilmfest.com. We will not be liable for any loss resulting from incorrect, inauthentic, insufficient or incomplete Personal Data you provide to us.

At the same time, we will take fair steps to periodically update our records regarding your personal data, but we will not be liable for any unforeseen changes to your personal data.

 

  • PERIOD OF STORING YOUR PERSONAL DATA

Your personal data will be deleted or deleted when it is no longer reasonably necessary in the Permitted Purposes or when you withdraw your consent (if it has been granted) and there is no legal obligation to continue the storage operation. of personal data.

Unless you expressly request us to store your personal data for a longer period of time, personal data will be deleted within a maximum of 5 years from the date on which it was collected.

 

  • YOUR RIGHTS IN CONNECTION WITH THE PROCESSING OF PERSONAL DATA

Subject to applicable legal provisions and subject to certain legal conditions, you have the following rights in connection with the processing of your personal data:

  1. The right of access, which includes the right to know if we process data about you and the right to know who they are, to whom they are transferred, how long they will be kept, where we obtained them and whether they are used for automated profiling / decisions.

  2. The right to rectification. If the data we have is incorrect, we need to correct it (unless we are processing it for someone else. In this case, we will let you know who to send your request to.).

  3. Right of deletion ("right to be forgotten") upon request, we will delete your personal data as soon as possible if 1) they are no longer necessary for the purpose for which they were obtained or 2) if you withdraw your consent for the processing of this data / if you have objections to the processing (unless we need them for a dispute, performance of a contract or legal obligations). Also, if we find that we have a legal obligation to delete or if the processing is illegal, we will delete them. If the data is also processed by third parties, we will take reasonable steps to inform them of the deletion request.

  4. The right to restrict processing if they are illegal, allegedly incorrect, contested, or no longer required.

  5. The right to information. We inform you as clearly as possible about your rights in the field of personal data, and about what data we process about you. or (if applicable) we share with third parties.

  6. The right to behave. If we process your personal data automatically, based on consent or contract, you can ask us to give it to you in a format and we will respond to your request within a reasonable time.

  7. The right to object. You can tell us if you want us to stop processing your personal data. We will grant your request if we cannot demonstrate sufficient legitimate interests. In any case, the data processed for direct marketing will be deleted on request.

  8. The right not to be subject to a decision based solely on automatic processing, including the creation of profiles, unless you have given explicit consent or are required to perform a contract.

  9. The right to submit a complaint to a supervisory authority, in Romania it is about ANSPDCP (National Authority for the Supervision of Personal Data Processing), web: www.dataprotection.ro , e-mail: anspdcp@dataprotection.ro.

 

You also have the following rights:

  • the right to request a copy of the personal data about you that we hold; if you exercise this right in a manner that is manifestly abusive or unfounded, we reserve the right to reimburse the necessary costs incurred for processing those children and for remitting the children within a reasonable period of time;

  • the right to rectify any incorrect personal data and the right to oppose or restrict our use of your personal data;

  • you can also make a complaint if you are concerned about how we handle your personal data;

  • the right to the deletion of your personal data, in situations where you have withdrawn your consent, the processing is no longer necessary or the processing is contrary to law.

 

If you wish to proceed in accordance with the above, please send us an e-mail to home@campulungfilmfest.com. We may ask you to prove your identity by providing us with a copy of a valid means of identification to comply with our security obligations and to prevent the unauthorized disclosure of data.

We will consider any requests or complaints we receive and send you a timely response. If you are not satisfied with our answer, you can submit the complaint to the National Authority for the Supervision of Personal Data Processing - based in Bd. Gheorghe Magheru no. 28-30, Bucharest, Romania.

 

  • UPDATES TO THIS PERSONAL DATA PROCESSING POLICY

The most recent update of this Personal Data Processing Policy was made in May 2018. We reserve the right to periodically update and modify this Data Processing Policy to reflect any changes in the way we process your data. personal or any changes to legal requirements. In the event of any such changes, we will display on our website the amended version of the Personal Data Policy and / or make it available in another way.

 

  • CONTACTS

If you wish to contact us with any questions, comments or requests regarding the Personal Data Processing Policy, please send us an e-mail to home@campulungfilmfest.com, to contact us at tel. +40 768 220 100 or send us a letter to Str. Nicolae Filimon, Nr. 6, Câmpulung Moldovenesc, Suceava County, Romania.

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