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Personal data protection processing policy – Bucharest Stock Exchage S.A.
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Introduction
Bucharest Stock Exchange S.A. (hereinafter referred to as the "Stock Exchange") pays special attention to the collection, use, processing and storage of personal data with which it comes into contact in its day-to-day activity. Compliance with the legislation and alignment with the new provisions in the field of data protection has always been a priority for the company.
Starting with May 25, 2018, Regulation no. 679/2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (hereinafter referred to as „GDPR”) enters into force and it shall be applicable in all Member States of the European Union. In this respect, we adopt the Personal data protection processing policy to align with the new Community legislation.
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Who can you contact if you have any questions or requests regarding the processing of your personal data?
If you have any questions or requests regarding the processing of personal data, you can contact us by sending us an email at gdpr@bvb.ro. You can also contact us by phone at (+40)(21) 307 95 00.
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How do we collect personal data?
Direct: We obtain personal data directly from individuals in different modalities, including the following situations when individuals provide such data: filling in online forms, subscribing to the newsletter of the Stock Exchange, registering for the events organized by the Stock Exchange, visiting the headquarters of the Stock Exchange or sending CVs for employment on the available positions.
Indirect: We obtain personal data of individuals indirectly in different ways, including recruitment services and contractual relationships with Stock Exchange participants. We can also obtain personal data from the following sources:
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Public sources: Personal data can be obtained from public registers, such as the Trade Register, news, articles, public lists of sanctions;
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Social and/or professional networking sites: If you log in or register with our social media accounts (Facebook, Google, LinkedIn, etc.) on our official website to authenticate and connect to the network, we will collect information regarding your account. These categories of information can include your name, e-mail address, additional information about you;
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Recruitment Services: We can obtain personal data of certain candidates for available positions within the company.
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What categories of personal data do we collect?
We may collect the following categories of personal data with regard to individuals either directly or indirectly according to paragraph 3 above:
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Personal data: contact information such as your first and last name, the name of the company you are working for, the position, the mobile phone number, the e-mail address. The Company's video surveillance system can collect visitors' images;
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Special Data: Normally, we do not process such categories of personal data, but in cases where we process such data, we do so only with the consent of the data subject unless the processing is performed for legitimate purposes. Examples of personal data that we can process: personal documents that can reveal racial or ethnic origin or even biometric data, religious orientation, or physical and/or mental health data;
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Childs’ Data: While we do not normally process personal data of children, we can occasionally receive information about children who attend, along with their parents, events organized by the Stock Exchange (eg conferences, parties, etc.);
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Geolocation data: We can process personal geolocation data (geographic locations) if you are searching for the contact address of the company.
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What are the legitimate grounds for data processing?
We can base our processing of personal data on the following legitimate grounds:
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Contract: We may process personal data to fulfill our contractual obligations;
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Consent: We may process personal data on the basis of the free and untimely consent given by the data subject. Such consent may be given concurrently with the provision of the personal data;
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Legitimate interest: We may process personal data based on legitimate interest when, according to our assessment, we consider that the processing is fair, reasonable and proportionate to the purpose of the processing. Legitimate interest may include providing services to the participants on the Stock Exchange;
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Legal Obligation and Public Interest: We may process personal data in order to fulfill the legal obligations of the Stock Exchange.
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Why do we need personal data?
We desire to offer transparency when collecting personal data and we specify to you the purpose of the processing. The purpose can be, among others:
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Sending invitations and registering guests at events organized by the Stock Exchange;
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Managing, maintaining and securing the information systems and the Stock Exchange website;
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Authentication of users of the Stock Exchange site;
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Searching for qualified candidates, capable of occupying vacant positions within the company;
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Processing the requests received online, including formulating responses to individuals' requests;
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Compliance with the existing legal provisions on money laundering, terrorism financing or other forms of financial crime;
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The fulfillment of the obligations occurring from the conclusion of different contracts.
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Do we share personal data with third parties?
We occasionally transmit personal data to third parties in order to improve the quality of our services. Their obligations are similar to Stock Exchanges’, with respect to the protection of personal data. For instance, we can communicate personal data to the following entities:
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Parties that support us as we provide our services (providers of telecommunication systems, IT systems support, archiving services, cloud-based software services);
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Our advisers, including lawyers, auditors or insurers;
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Marketing services providers;
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Recruitment services providers;
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Public authorities or third parties, in accordance with the applicable legal provisions.
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Do we transfer personal data outside the European Economic Area?
We store personal data on servers in Romania. We may transfer personal data outside the European Economic Area when one or more of the Stock Exchange’s contractual partners are located outside the European Economic Area.
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What are the rights of the data subjects?
As a data subject, you have the following rights:
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the right to request a copy of the personal data that are possessed by the Stock Exchange;
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the right to request the rectification of any inexact or out of date personal data;
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the right to request the erase of the personal data when they are no longer relevant for the Stock Exchange;
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if the processing is based on the consent, a contract or automatic means of decision making, the right to request to the Stock Exchange to provide for the personal data that were directly obtained from the data subject and, if applicable, to transmit these data directly to another controller (the right of data portability);
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the right to retreat the processing consent at any time;
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in the case of a dispute over the correctness of the processing of personal data, the right to restrict the processing;
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if processing is based on legitimate interests, the right to object to the processing of personal data (where applicable);
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the right to file a complaint with the supervisory authority (the National Supervisory Authority for Personal Data Processing).
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Security of personal data
We have adopted technical security policies and procedures to protect personal data against loss, unauthorized use, destruction or alteration. We ensure that access to personal data is limited and authorized only to persons legally entitled to use them. These individuals have the obligation to ensure the confidentiality of the data. We can also use pseudonymisation and data anonymization techniques to protect the personal data.
When the data subjects log in into the account that has been created on our website (https://www.bvb.ro/LoginPage), the data subjects have the obligation to protect the confidentiality of the username and of the password.
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How long do we retain personal data?
We will store the personal data necessary to provide services according to Stock Exchanges’ object of activity, to keep in touch with the data subjects and to comply with our legal obligations. The Stock Exchange will store your personal data for a period of 10 years, unless legal or contractual requirements provide for a different period.
We will dispose of personal data in a secure manner when we no longer need it.
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Revision of the present Personal data protection processing policy
We will review this Privacy Policy and we will publish the revised version of the document on our website.
For information regarding the Personal data protection processing policy - Data Protection Officer email: dpo@bvb.ro