Confidentiality Policy

Last update: May 2018

I. General information

Insaro Energy S.R.L., owner of “ghilotina.com”, has the notification number 29426 from September 9th, 2013 from the personal data processing registry of The National Supervisory Authority for Personal Data Processing. Insaro Energy S.R.L. complies with applicable privacy laws (Law no. 677/2001 for the protection of individuals with regard to the processing of personal data and the free movement of such data, as amended and supplemented, and Law no. 506/2004 concerning the processing of personal data and the protection of privacy in the electronic communications sector).

The privacy of your personal data is one of the main concerns of  Insaro Energy S.R.L., with headquarters in Blanari street, no. 18, sector 3, Bucharest, postal code 030062, Romania.

This document is intended to inform you about the processing of your personal data in the context of using the website ghilotina.com.

II. Categories of processed personal data

II.1. If you are client of ghilotina.com, Insaro Energy S.R.L. will process your personal data such as name and surname, telephone, e-mail address, billing address, delivery address, data on how you use ghilotina.com, for example the behavior/preferences/your habits in ghilotina.com, as well as any other categories of data you provide directly in the context of creating your user account, in the context of placing an order via ghilotina.com or in any other way resulting from using ghilotina.com.

If, in order to create a user account on ghilotina.com, you use your Facebook or Google account, Insaro Energy S.R.L. will process the following public profile data displayed by the respective applications: username, email address.

If you choose to create a user account just before completing the ordering of a product available on ghilotina.com, your e-mail address will be required to automatically create an account. If you do not complete the order, the email address and other data provided will not be stored by Insaro Energy S.R.L. and the created account will be automatically deleted.

II.2. If you are a visitor of ghilotina.com, Insaro Energy S.R.L. will process your personal data that you provide directly in the context of using ghilotina.com, such as the data you provide in the question or complaint form, to the extent that you fill it out.

II.3. Applying for a job within Insaro Energy S.R.L. as a candidate, by accessing the Careers section available on ghilotina.com, Insaro Energy S.R.L. will process the personal data you provide in this context such as your name, surname, email address, phone number, experience, and any other data included in the documents you choose to upload in this section.

II.4. If you are a contact person of Partners or Potential Partners, Insaro Energy S.R.L. will process your contact details such as your first and last name, e-mail address, and the phone number you provide in the context of initiating or developing a contractual relationship with Partners or prospective Partners.

III. Purposes and basis of processing

III.1. If you are a customer of ghilotina.com, Insaro Energy S.R.L. will process your personal data as follows:

  • to carry out the contractual relationship between you and ghilotina.com, respectively for taking over, validating, sending and billing the order placed on ghilotina.com, informing you about the order status, organising the return of ordered products, etc.

Basis: Processing your data for this purpose is based on the contract between you and Insaro Energy S.R.L.. The provision of your personal data is required. Refusing to provide data may result in the contractual relationship between you and Insaro Energy S.R.L..

  • to meet the legal obligations incumbent on Insaro Energy S.R.L. in the context of the services provided through ghilotina.com, including the obligations in the field of taxation, as well as in the field of archiving.

Basis: Processing of your data for this purpose is required on the basis of legal obligations. Providing your data for this purpose is required. Refusal to provide data may result in the impossibility of Insaro Energy S.R.L. to comply with its legal obligations and therefore unable to provide you services through ghilotina.com.

For unsubscribing from receiving such commercial communications, you can use the option at the end of each email containing commercial communications. In addition, you can unsubscribe by visiting the My Account Information section.

Providing your data for this purpose is voluntary. Refusing to provide consent to process your data for this purpose will not have negative consequences for you.

  • for the purpose of performing various analyses, reports on the functioning of ghilotina.com, the development of consumer preferences profiles, mainly in order to improve the experience offered on ghilotina.com.

Basis: The processing of your data for this purpose is based on the legitimate interest of Insaro Energy S.R.L. to permanently improve customer experience on ghilotina.com. Providing your data for this purpose is voluntary. Refusing to provide data for this purpose will not have negative consequences for you.

III.2. If you are a visitor to ghilotina.com, Insaro Energy S.R.L. will process your personal data as follows:

  • for marketing activities, respectively for the transmission of commercial communications on the products and services offered by Insaro Energy S.R.L., by means of remote communication (via e-mail) through ghilotina.com.

You can express your consent on the data processing for this purpose by filling in and ticking the appropriate box in the newsletter subscription form available on ghilotina.com. For unsubscribing from receiving such commercial communications, you can use the option at the end of each email containing commercial communications.

Providing your data for this purpose is voluntary. Refusing to provide consent to process your data for this purpose will not have negative consequences for you.

  • to resolve claims, complaints and to monitor traffic and improve your experience on ghilotina.com.

Basis: The processing of your data for this purpose is based on the legitimate interest of Insaro Energy S.R.L. to ensure the correct functioning of ghilotina.com, as well as to permanently improve the experience of ghilotina.com visitors, including by solving various questions or complaints.

Providing your data for this purpose is voluntary. Refusing to provide data for this purpose will not have negative consequences for you.

III.3. If you choose to apply to a ghilotina.com job as a candidate, Insaro Energy S.R.L. will process your personal data as follows:

  • to carry out specific recruitment activities for certain vacancies within Insaro Energy S.R.L.

Basis: Processing your data for this purpose is based on your request for a contract. Providing your data for this purpose is voluntary. Refusal to provide data may result in the impossibility of Insaro Energy S.R.L. to consider you in the recruitment process for different posts.

  • for the other purposes and grounds listed in Section III.2. above.

III.4. If you are a contact person of Partners or Potential Partners, Insaro Energy S.R.L. will process your personal data as follows:

  • to initiate or conduct the contractual relationship between Insaro Energy S.R.L. and Partners or potential Partners

Basis: The processing of your data for this purpose is based on the legitimate interest of Insaro Energy S.R.L. to initiate and conduct contractual relations in the context of providing services on ghilotina.com. Refusal to provide data for this purpose may result in the impossibility of Insaro Energy S.R.L. to carry out their activity.

  • for the other purposes and grounds listed in Section III.2. above.

IV. The length of time we are processing your data

As an idea, Insaro Energy S.R.L. will process your personal data as long as is necessary to achieve the above mentioned processing purposes.

If you are a customer, we will process your data for the duration of the contractual relationship and subsequently, according to the internal policies of Insaro Energy S.R.L., respectively for the time required to fulfil the legal obligations under Insaro Energy S.R.L. (for example, in the case of financial accounting documents for which the statutory retention period is 10 years from the end of the financial year in which they were drawn up).

If you are a customer and you are exercising the user account deletion option by clicking the Delete Account button in the My Account Information section, Insaro Energy S.R.L. will interpret this action as your option to unsubscribe from receiving commercial communications through which we keep you informed about the products and services offered by ghilotina.com. In this regard, if you choose to delete your user account, we will not send you anymore such emails. However, we want to inform you that deleting your account will not automatically erase your personal data. If you do not want your personal data to be processed or you want to delete the data, you can exercise the rights detailed in Section VI below. If you request to delete the account, but there is at least one active order on that account, the request to delete the account will only be recorded after the products have been delivered and the last active order is completed.

If you withdraw your consent to data processing for marketing purposes, Insaro Energy S.R.L. will cease processing your personal data for this purpose, without affecting the processing of Insaro Energy S.R.L. on the basis of your consent before withdrawing it.

If you choose to apply to ghilotina.com, as a candidate, Insaro Energy S.R.L. will keep personal data as long as it is necessary for the recruitment process. If you are not selected for the position you applied for, Insaro Energy S.R.L. will process your data that you have provided for your consideration for other recruitment processes.

If you are a contact person of Insaro Energy S.R.L. Partners or Potential Partners, your personal data will be processed for as long as necessary for the conclusion/performance of the contract, and then subject to internal policies and legal obligations, including archiving.

IV.1. Disclosure of personal data

For the purposes of processing, Insaro Energy S.R.L. may disclose your data to the Partners, affiliated companies of Insaro Energy S.R.L., to third parties or entities that support Insaro Energy S.R.L. in providing services through ghilotina.com (eg courier companies, IT service providers) or to central/local public authorities in the following exemplified cases listed below:

  • for managing ghilotina.com, including for mediating the relationship between you and our partners selling products through this website insofar as you order products sold by them;
  • in situations where this communication would be necessary to award prizes or other facilities to customers as a result of their participation in various promotional campaigns organised by Insaro Energy S.R.L. through ghilotina.com;
  • for the maintenance, personalisation and improvement of ghilotina.com and the services performed through it;
  • to perform data analysis, testing and research, monitoring usage and activity trends, developing security features, and authenticating users;
  • for the transmission of commercial marketing communications under the conditions and limits stipulated by the law;
  • when the disclosure of personal data is provided by law, etc.

For the processing of data done by partners with whom you enter into a relationship, through ghilotina.com and who process your data in their own name, as data operators, please consider the privacy policies offered by those partners. Insaro Energy S.R.L. has no control over how your data is processed by them.

IV.2. Transferring personal data

Personal data provided to Insaro Energy S.R.L. may be transferred outside Romania.

V. Your rights

In connection with the data processing, you have the right to request access to your personal data, rectification or erasure thereof or restriction of processing, the right to oppose your processing within the limits and conditions provided by law, as well as the right to portability of data. Also, if you choose to give your consent, you have the right to withdraw it at any time without affecting the processing of Insaro Energy S.R.L. on the basis of your consent before withdrawing it. In addition, you have the right to file complaints with the National Supervisory Authority for Personal Data Processing.

In accordance with the provisions of Regulation 2016/679 / EU, as the data subject, you will have the following rights:

-the right to access your data: you may request to be notified of the categories of personal data being processed, the purpose of the processing, the recipients to whom they have been or will be communicated, the period for which they are expected to be stored or, if that is not possible, the criteria used to determine that period; the existence of an automated decision making process including the creation of profiles;

-the right to request data rectification: if there are errors with regard to the data being processed, you can ask for them to be corrected; if the data is incomplete, you can request completion. Correction shall be communicated to each recipient to whom the data was transmitted, unless this proves impossible or involves disproportionate efforts;

-the right to request restriction of data processing: you have the right to request restriction of data processing in the following situations: if you have questioned the accuracy of the data for a period that allows us to verify the accuracy of the data; if the processing is illegal, and you will oppose the deletion of your personal data, requesting instead the restriction of their use; if the operator no longer requires personal data for processing, but requires them to find, exercise or defend a right in court; if you have opposed the processing for the length of time that it is verified that the legitimate rights of the operator are prevailing over your rights;

-the right to request data deletion: you may request the deletion of the processed data if the data are no longer required for the purposes for which they were collected or processed, if you have withdrawn your consent and there is no other legal basis for the processing; if you oppose the processing and there are no legitimate reasons to prevail in terms of processing; personal data has been processed illegally; personal data must be deleted for compliance with a legal obligation; personal data was collected in connection with the provision of information society services;

-the right to request data transfer (for data portability): you may request the transfer of your data to another operator if the processing is based on your consent and the processing is automatic;

-the right to oppose processing: you have the right to oppose the processing of your data if it concerns direct marketing. At the same time, you may object to processing, unless the operator demonstrates that he has legitimate reasons for processing and has priority over your interests, rights and freedoms, or that the purpose is to establish, exercise or defend a right in court;

–the right not to be the subject of a decision based solely on automated data processing: you will not be the subject of a decision based solely on automated data processing.

VI. Collected Data

The collection of personal data by ghilotina.com is done in three ways:

– directly from the user: When subscribing to the services offered by Insaro Energy S.R.L. In order to keep track of the use of the site, we may need to ask for personal information (email address, name, surname, address, etc.)

– of the server traffic report: When you visit the site ghilotina.com, you will provide some information about yourself, such as your IP address, visit time, where you came from, visit duration, as Insaro Energy S.R.L. will be recording these data.

– via cookies: When you visit ghilotina.com, you may be sent a cookie to facilitate the storage and tracking of your preferences.

For any additional questions about how your personal data is processed and to exercise your rights above, please refer to: head@ghilotina.com