Personal data policy

In accordance with 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 (the General Data Protection Regulation), Law no. 190/2018 on measures implementing Regulation (EU) 2016/679 (the General Data Protection Regulation), Law no. 506/2004 on the processing of personal data and the protection of privacy in the electronic communications sector, and Law no. 365/2002 on electronic commerce, the Administrator will manage the personal data provided by Users securely and only for the purposes specified.

The controller of the personal data is EV SPOTS DRIVE S.A., with its registered office at Str. Gara Veche no. 2, Piatra Neamț, Neamț County, registered with the Trade Register under no. J2021000856277, Sole Registration Code 44564370, hereinafter referred to as “EV SPOTS” or “the Controller”. For any requests regarding data protection, you can contact us at the email address drive@evspots.ro or at the postal address indicated above.

This policy applies to the processing of data through the website evspots.ro, including contact forms, information pages, newsletter functionalities, recruitment pages, cookies and similar technologies. For the use of the EV SPOTS mobile application and the charging services, additional notices or dedicated sections may be applicable.

1. COLLECTION OF INFORMATION THROUGH THE SITE AND THE RELATED FORMS/PAGES

Identification data

Through the site and the available forms, EV SPOTS may process the following categories of data, depending on how you use the site:

• identification and contact data: surname, first name, email, telephone;
• data transmitted through forms: message, request, preferences, attachments, voluntarily entered information;
• data for newsletter/commercial communications: email, telephone, communication preferences, proof of consent;
• recruitment data, if you apply for a position: CV, cover letter, professional data, education, experience;
• technical data: IP, browser, operating system, cookie identifiers, date/time of access, pages visited, traffic source;
• data generated through cookies and similar technologies, in accordance with the Cookie Policy.

Information you provide through the forms, pages or functionalities available on the site

The Administrator collects the content and other information you provide when you use the Service, including when you create an account, when you create or share content, and when you send messages or communicate with other persons.

Your networks and connections

If the site allows the publication of comments, enrolment in a community, or the transmission of content, EV SPOTS may process the data voluntarily entered by the user, such as the display name, the message transmitted, the publication date, and the content of the communication.

Information about the device

The Administrator queries, for statistical purposes, information from or about the computers, telephones or other devices from which you access the Service, depending on the permissions you have granted, such as:

• the operating system, the hardware version, the device settings, the names and types of files and software, the battery and signal strength, and the device identifiers;
• the device locations, including specific geographic locations, such as through GPS, Bluetooth or Wi-Fi signals;
• connection information, such as the name of your mobile telephony operator or the name of the Internet service provider (ISP), the browser type, the language and time zone, the mobile telephone number and the IP address.

Statistical and targeting information and data

The technical data strictly necessary for the operation and security of the site is processed without consent, on the basis of the Controller’s legitimate interest. The data used for non-essential analytics, advertising, remarketing, social media or targeting is processed only on the basis of the consent expressed through the cookie banner/settings panel:

• details about how you used the Site, such as search queries, pages of interest, etc.;
• information recorded in telephony logs, such as the telephone number, the caller’s number, the redirection numbers, the time and date of calls, their duration, the routing information of SMS messages, and the types of calls;
• the IP address;
• information about the events that occurred on the device, the system activity, the hardware settings, the browser type, its language, the date and time of your request, and the referring URL address;
• cookies, as detailed in the Cookie Policy.

2. PURPOSE OF COLLECTION

EV SPOTS processes your data for the following purposes:

• Account administration and provision of services: identification, contact, authentication, account settings data. Legal basis: performance of the contract or pre-contractual steps.
• Response to requests transmitted through forms/contact: name, email, telephone, message content. Legal basis: legitimate interest and/or performance of the contract, as the case may be.
• Newsletter and commercial communications: email, telephone, preferences, proof of consent. Legal basis: consent or, for existing customers and under the conditions of the law, legitimate interest/soft opt-in, with the right to object.
• Recruitment: CV, professional data, education, experience, contact data. Legal basis: pre-contractual steps, consent for retaining the CV for future recruitment.
• Analytics, cookies, marketing and remarketing: online identifiers, IP, usage events. Legal basis: consent, with the exception of strictly necessary cookies.
• Security, fraud prevention and operation of the site: IP, logs, technical events. Legal basis: legitimate interest.
• Invoicing, accounting and legal obligations: fiscal and transactional data, if applicable. Legal basis: legal obligation.

At the moment of creating the user account or of subscribing to the newsletter, you have the possibility to opt to receive information about the products, services, events, promotional offers, and partnerships presented through the Application, by ticking the corresponding box on the account creation page or in the newsletter subscription section.

Personal data will not be used for any other purpose and will not be disclosed or given for use to other parties.

The remaining information collected will be used to ensure a better experience with the Application, including the site, to personalize content and advertisements, to offer social network features, to analyze traffic, or for statistical purposes.

The provision of certain data is necessary for the creation of the account, the provision of services, invoicing, or the response to requests. If you do not provide the necessary data, we may not be able to create the account, provide the requested service, issue fiscal documents, or respond to your request. The data used for marketing, non-essential analytics, or optional cookies is provided/processed only with your consent, where the law requires this.

3. DATA STORAGE

The Administrator stores the data for as long as is necessary to offer you products and services in accordance with your interests and for the entire period of the account’s activity.

Upon the closure of the account through your action or at your request, the personal data will be deleted automatically and instantaneously, with no further possibility of its recovery by the Administrator, and implicitly by the User. Statistical data will remain stored for as long as it is necessary for reporting and analysis activities.

The information associated with the user account will be kept until the account is deleted, under the conditions above, except in the case where the Administrator no longer needs the data to provide the Service.

In the case of a request for the deletion of personal data, it will be removed from all of the Administrator’s systems within a minimum of 10 days but no later than 30 working days from the date of receipt of the request through an official channel – a request by email or post, an unsubscribe mechanism, or account deletion.

If you have applied for a job, all transmitted personal data will be stored until the completion of the recruitment stage and will be deleted within a maximum of 10 working days from completion. In the event that you have given your consent for the CV and the rest of the information to be retained, in order to be considered in other stages of recruitment in the future, then the data will be kept until the withdrawal of consent.

If you have contacted the Administrator with a specific request, the data will be used for managing that request.

4. DATA SECURITY

The data will be stored in a database, on a secure server, in a dedicated data center. The server has a secure connection and can be accessed from anywhere via the internet, but only by accessing the Administrator’s back office and using credentials of the user-password pair type by the Administrator. The database is read only by the automated mechanisms of the Application, and not by persons.

Personal data sent through specific requests, in campaigns, or for recruitment will reach the persons responsible for managing these processes and will be used responsibly. All persons within the company (employees or partners) who could come into contact with your data have undertaken, by signing an NDA, to comply with the requirements of confidentiality, security and responsible use of this data.

The Application is accessible from the internet, through a secure protocol and through installation, on the basis of a username and password. Depending on the manner of registration, namely “Anonymous” or through logging into an account, Users will benefit from different levels of cost of the (charging) Service.

Combinations of username and password for access to the Application are held by the persons with administration rights specially designated by the Administrator. Not all persons who have access to the application also have access to the personal data area.

5. THIRD-PARTY PARTNERS

The Administrator may process and transmit personal data, under the conditions provided by European Regulation 679/2016 (GDPR) and the national legislation in force, to other companies with which it is in partnership relationships, and only on the basis of a confidentiality undertaking from the respective companies, by which they guarantee that this data is kept securely and that the use and provision of this personal information is carried out in accordance with the legislation in force.

The Administrator’s partners are: providers of marketing services, courier services (including Poșta Română), accounting services, payment/banking services, telemarketing, email marketing platforms, SMS marketing platforms, advertising platforms (Google, Facebook, Instagram, LinkedIn, TikTok), other associated platforms, and other companies with which the Administrator may develop joint marketing and communication programs.

6. RIGHTS OF USERS

It is important for you to know that you have the following rights:

• the right of access to data;
• the right to the rectification of data;
• the right to the erasure of data;
• the right to the restriction of processing;
• the right to data portability;
• the right to object, including to processing for direct marketing purposes;
• the right to withdraw consent, when the processing is based on consent;
• the right not to be subject to a decision based solely on automated processing, including profiling, under the conditions provided by the GDPR;
• the right to lodge a complaint with the ANSPDCP (the National Supervisory Authority for the Processing of Personal Data);
• the right to address the competent courts.

7. ACCESSING, UPDATING AND DELETING DATA

Whenever you use the Application, you have access to your personal information. If that information is incorrect, we strive to offer you ways to update it quickly or to delete it, except in cases where we must retain the information for legitimate business or legal purposes.

Our goal is to provide the Service in a manner in which information is protected against accidental or malicious destruction. For this reason, after you delete information from the Application, we may not immediately delete residual copies from our active servers and may not remove the information from our backup systems.

When the processing is based on consent, you have the right to withdraw it at any time, without affecting the lawfulness of the processing carried out prior to the withdrawal. For the processing carried out on the basis of the contract, legal obligations, or legitimate interest, the data will be kept in accordance with the purposes and durations described in this policy.

You will be able to unsubscribe at any time by accessing the unsubscribe option in the newsletter, or through a message to: drive@evspots.ro.

For any request in connection with the protection and processing of your data, you can write to us at the address drive@evspots.ro.

At the same time, you have the right to object to the processing of your personal data and to request the deletion of the data.

The deletion of the user account profile and of your profile can be done in the Application.

In the case of the approval of a deletion request, the data will be deleted, anonymized or restricted, as the case may be, with the exception of data that must be retained for compliance with legal obligations, the defence of rights, fraud prevention, security, audit, litigation, or other purposes permitted by law.

To exercise these rights, you may also make a written request addressed to the Administrator, which you may send to the address Str. Gara Veche No. 2, Piatra Neamț, Neamț County, postal code 610206, or by email to the address: drive@evspots.ro.

For more information in connection with the use of the site and the protection of your data, please access the Terms and Conditions and Cookie Policy sections.