Privacy Policy

General

The confidentiality of your data is one of our fundamental commitments. Consequently, we take great care to process your personal data in accordance with the principles established in European data protection legislation (Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (“GDPR”)).

According to Regulation (EU) 2016/679 on the protection of natural persons, personal data means any information relating to an identified or identifiable natural person, and an identifiable person is one who can be identified, directly or indirectly, particularly by reference to an identifier such as a name, identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. This privacy policy concerns the personal data of our beneficiaries, partners, other people who contact us, and their representatives, potential employees, and applies to the data collected through our website www.facesofcourage.ro , as well as the personal data we collect through email or other offline contacts.

PERSONAL DATA CONTROLLER

Asociația PHONEO, as the data controller, with its registered office at Str. Decebal 22-24, Cluj-Napoca, Romania, contact phone: +40 748 317 277, office@phoneo.ro, processes your personal data in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), Law no. 190/2018 on measures to implement the General Data Protection Regulation and any other applicable legal regulations.

All requests regarding the exercise of data subjects’ rights will be addressed to the Data Protection Officer (DPO) at the following email address: gdpr-phoneo@phoneo.ro. Additional information regarding the processing of personal data by Asociația PHONEO can be requested by contacting the Data Protection Officer at the same email address.

HOW WE COLLECT PERSONAL DATA

In general, our intention is to collect only personal data that is provided voluntarily by you through accessing the website www.facesofcourage.ro . We obtain personal data by you completing online forms, subscribing to newsletters. The collected data is the minimum necessary to provide you with information about our activities and projects or the ways in which you can get involved.

FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA

We may use your personal data for the following purposes (“Permitted Purposes”):

• Receiving donations – legal basis: conclusion or execution of the contract. The collected data are those that you register on the site: name, surname, email address, bank account, phone, city, county, street, number, postal code.
• Managing and administering the contractual relationship with our donors – legal basis: conclusion or execution of the contract. The collected data are those that you register on the site: name, surname, email address, bank account, phone, city, county, street, number, postal code.
• Periodically sending the newsletter – we may send you various communications through the channels provided by you (email) to keep you informed about the projects you are involved in or the activities and events of the association – legal basis: your consent. The collected data are those that you register on the site: email address.

LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

Any operation of processing your personal data will be carried out based on one of the legal grounds below:

1. Conclusion or execution of the contract – art. 6, para.1, letter b GDPR.
2. Your consent – art. 6, para.1, letter a GDPR.

DISCLOSURE OF YOUR DATA TO RECIPIENTS OR CATEGORIES OF RECIPIENTS

We may disclose your personal data only to those employees of Asociația PHONEO who effectively manage the marketing projects in which you are involved, to those entities contracted by the Association for outsourcing services within which it will be necessary to process personal data (email management/sending services: MailChimp, Mail Agent), respectively to providers who manage the Association’s websites with access to data only in case of website malfunction, providers do not have access to the bank account), Libra Bank, online payment platform EuPlătesc (data required according to banking regulations in case of payment).

TRANSFERS TO THIRD COUNTRIES

The personal data recorded by individuals on the Association’s website are not and will not be transferred to third countries.

HOW LONG WE KEEP PERSONAL DATA

All personal data of donors will be kept for a period of up to 3 years from the completion of the program related to the donation contract. When you register to receive the newsletter, the data will be processed until you decide to no longer receive this information, by sending a request to the email address: gdpr-phoneo@phoneo.ro. Also, you can unsubscribe from receiving communications from us at any time, using the unsubscribe link in the emails you receive.

RIGHTS OF DATA SUBJECTS REGARDING THE PROCESSING OF PERSONAL DATA

The Association ensures the exercise of these rights and provides a complete information on these rights below:

• Right of access to data – you have the right to obtain from Asociația PHONEO a confirmation whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and information about the processing; you can also obtain a copy of the personal data undergoing processing. For any other copies requested by you, the Association may charge a reasonable fee based on administrative costs; if the request is made electronically, and unless you request otherwise, the information will be provided in a commonly used electronic form.
• Right to rectification – you have the right to obtain from Asociația PHONEO the rectification of inaccurate personal data concerning you, as well as the right to have incomplete personal data completed.
• Right to erasure of data – you have the right to obtain from the Association the erasure of personal data concerning you without undue delay, and the Association has the obligation to erase personal data where one of the following grounds applies: (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw your consent on which the processing is based and there is no other legal ground for the processing; (iii) you object to the processing and there are no overriding legitimate grounds for the processing; (iv) the personal data have been unlawfully processed.
• Right to restriction of processing – you have the right to obtain from Asociația PHONEO the restriction of processing where one of the following applies: (i) you contest the accuracy of the personal data, for a period enabling Asociația PHONEO to verify the accuracy of the personal data; (ii) the processing is unlawful, and you oppose the erasure of the personal data and request the restriction of their use instead; (iii) you have objected to processing pending the verification whether the legitimate grounds of Asociația PHONEO override your rights; Asociația PHONEO will communicate any restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort and will inform you about those recipients if you request it.
• Right to data portability – you have the right to receive the personal data concerning you, which you have provided to Asociația PHONEO, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller, where technically feasible; in exercising this right, you have the right to have the personal data transmitted directly from Asociația PHONEO to another controller, where technically feasible.
• Right to object – you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, including profiling based on those provisions.
• Right not to be subject to a decision based solely on automated processing, including profiling.
• Right to lodge a complaint with the National Supervisory Authority for Personal Data Processing.
• Right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

The exercise of any of the above-mentioned rights can be realized by submitting a written, dated, and signed request to the Association, at the address: Str. Decebal 22-24, Cluj-Napoca, Romania, or by email at gdpr-phoneo@phoneo.ro. The Data Protection Officer of the Association can be contacted at the address: Str. Decebal 22-24, Cluj-Napoca, Romania, or by email at gdpr-phoneo@phoneo.ro.