Terms & conditions

 

WHAT TYPES OF PERSONAL DATA DO WE PROCESS, FOR WHAT PURPOSES, AND ON WHAT LEGAL BASES?

In the process of managing this website, the Company will collect certain information („personal data”) related to identified or identifiable individuals, provided either directly by users of this website (e.g., name, surname, email address, phone number) or indirectly (e.g., IP address).

Predominantly, the Company’s portfolio consists of corporate clients, and any personal data processed for the conduct of business pertains, where applicable, to the data of the company representative, their authorized agent, and the personnel within these entities tasked with improving promotional strategies and processes for these clients. The processing of this data is based on contractual grounds, and according to the Regulation, no explicit consent is necessary for this purpose. There may also be instances where the data subjects are individuals with no connection to any corporate client of our services.

The processing of personal data will be carried out for the following purposes, based on the legal grounds indicated for each of them, as follows:

Browsing the website www.gun.ro/en and the use of cookies

When visiting our website, cookies are used to automatically collect technical information that can identify the user, such as the operating system, IP address, type of internet browser used for navigating our website, and the name of the domain or the host domain through which the user navigates our website.

The main purpose of using cookies is to help you have an improved browsing experience and for advertising purposes, to provide you with customized content tailored to your interests and preferences. Thus, to the extent that you have given your consent to the use of cookies, we will use them to offer you a personalized and relevant browsing experience on our website and to understand how you interact with our advertising content.

For more information about the use of cookies on this website and the purposes for which they are used, as well as the possibilities to control and/or disable cookies, please consult our Cookie Policy.

Response to contact form or your questions, requests, or complaints

We will process your personal data, such as name, surname, email address, phone number, and any other information or details you provide in the correspondence, to resolve and respond to your questions, complaints, or requests, depending on the communication channel through which you contact us.

Purpose: The ability to provide responses to: requests for quotes, complaints, questions, or correspondence requests.

Legal basis: The processing is based on a legitimate interest, allowing us to provide answers to your questions, complaints, or requests.

Direct marketing communications/email marketing

We may process personal data to inform you about our products and services, promotional offers, and for subscribing to newsletters. These personal data will be processed for direct marketing purposes only with your prior consent and using the communication channels (e.g., email, SMS, etc.) that you have agreed to.

We will process personal data to establish contractual relationships following your voluntary expression of interest to receive an offer or details about Gun Media products.

The contractual services consist of the Company’s provision of administration and management of your internet marketing accounts and campaigns. For this purpose, we will use the data you fill out on the aforementioned page, according to the existing form at this address, namely, Name, Surname, Email, Phone.

TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?

To achieve the purposes described above, the Company uses the services of external partners. Some of them act as processors, such as IT and Web Hosting Services, companies contracted for outsourcing legal services, accounting, programming and repairing our PCs, billing and accounting, legal consultancy, assistance, and representation services. These partners are active in the IT, accounting, and legal industries and operate commercially in Romania. Your personal data may be provided to these partners to be used within the limits of the obligations they have assumed towards the Company. The personal data we disclose to our processors is limited to the minimum personal information necessary for the provision of those services, and we require them not to use the personal data for any other purpose.

Some of these are third parties who do not intend to process the data but may have access to it in the course of performing their duties or in their interactions with the Company, such as companies providing technical maintenance, financial or legal auditors.

The personal data mentioned above may also be made available or transmitted to third parties in the following situations: (i) public authorities, auditors, or institutions with competencies in carrying out inspections and controls over the Company’s activities and assets, who request the Company to provide information based on its legal obligations. These public authorities or institutions may include the National Agency for Fiscal Administration; (ii) to comply with a legal requirement or to protect the rights and assets of our Company or other entities or individuals, such as courts of law, law firms; (iii) third-party acquirers, to the extent that the Company’s business is transferred (in whole or in part), and the data subjects’ personal data would be part of the assets subject to such a transaction.

The individuals and entities to whom we may distribute your personal data are as follows:

• For the purpose of browsing the website and for purposes related to the use of cookies, we may transmit personal data to providers of analytics services and search engines to provide maintenance services for our website;
• To respond to your inquiries, requests, or complaints, we may distribute your personal data to our call center service providers;
• For organizing and managing promotional campaigns, as well as analyzing their effectiveness, we may distribute your personal data to advertising and marketing agencies or digital media agencies or social media agencies;
• For direct marketing communications, we may transmit personal data to advertising and marketing agencies that conduct communication on our behalf;
• For conducting surveys or market research, customer satisfaction surveys, or obtaining feedback from our customers about our products and services, we may distribute personal data to survey service providers or market research/customer satisfaction survey providers.

TRANSFER OF PERSONAL DATA ABROAD

In the context of the operations described above, your personal data may be transferred abroad to states within the European Union („EU”) or the European Economic Area („EEA”).

We hereby inform you that any transfer made by the Company to a member state of the EU or EEA will comply with the legal requirements provided for in the GDPR.

Some of the personal data listed in this privacy policy are transferred to states that do not provide adequate protection for the processing of personal data, namely, the United States of America. These data are those over which Google has control, within its Google Analytics services.

HOW LONG WE STORE YOUR PERSONAL DATA?

We will store your personal data only for the period necessary to achieve the processing purposes outlined above, while also complying with the applicable legal requirements. If the Company determines that it has a legitimate interest or a legal obligation to further process your personal data for other purposes, you will be duly informed in this regard.

We estimate that the processing activities outlined above will require storing personal data for the following periods:

	Purpose	Storage Duration
1	Browsing the website and using cookies	As determined by Google
2	Responding to your inquiries, requests, or complaints	During the contractual relationship, plus an additional period of 3 years
3	Organizing and managing promotional campaigns and related personal data	During the contractual relationship, plus an additional period of 3 years
4	Direct marketing communications	During the contractual relationship, plus an additional period of 3 years
5	Conducting surveys, market research, customer satisfaction surveys, or obtaining feedback from our customers about our products and services	During the contractual relationship, plus an additional period of 3 years
6	Presenting offers for our own services; Initiating contractual relationships	During the contractual relationship, plus an additional period of 4 years

Once the processing period indicated above expires, and the Company no longer has legal or legitimate reasons to process your personal data, the data will be deleted in accordance with its procedures, which may involve archiving, anonymizing, or destroying them.

PROCESSING DATA OF CHILDREN UNDER THE AGE OF 16

All activities involving the processing of personal data outlined in this Policy exclusively apply to individuals who are at least 16 years old. The use of systems, as well as the results of processing, is prohibited concerning children who have not reached this age without the consent of their parents/legal guardians. In the event that, despite our reasonable efforts to prevent it, such processing occurs, we will cease it once we notice that users have not reached the legal age to initiate commercial relationships.

REFUSAL TO PROCESS AND ITS CONSEQUENCES

As a private entity, there is no legal obligation under which we could demand that you provide us with personal data. Your refusal to communicate your data does not, in principle, have any consequences for you or your experience on our website. However, to the extent that you decide to benefit from our services, providing the requested data, as described above, is inevitably necessary. Since contractual relationships have been established between the Company and you, our legitimate interest concerning the reciprocal execution of contractual obligations will prevail over your refusal to process until the obligations have been fully executed, and there is no prospect of concluding new contractual relationships.

RIGHTS OF DATA SUBJECTS

In the context of processing your personal data, you have the following rights:

1. The right to access processed personal data: you have the right to obtain confirmation of whether your personal data is being processed and, if so, to access the type of personal data and the conditions under which they are processed, by submitting a request to the data controller.
2. The right to request rectification or erasure of personal data: you have the possibility to request, by submitting a request to the data controller, the rectification of inaccurate personal data, completion of incomplete data, or deletion of your personal data if (i) the data are no longer necessary for the initial purpose (and there is no new legal purpose), (ii) the legal basis for processing is the data subject’s consent, the data subject withdraws their consent, and there is no other legal basis, (iii) the data subject exercises the right to object, and the controller has no legitimate grounds overriding the data subject’s rights, (iv) the data have been processed unlawfully, (v) erasure is necessary for compliance with EU or Romanian law, or (vi) the data have been collected in connection with information society services offered to children (if applicable), when specific consent requirements apply.
3. The right to request restriction of processing: you have the right to obtain restriction of processing where: (i) you contest the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data; (ii) the processing is unlawful, but you oppose the erasure of the personal data and request the restriction of their use instead; (iii) the controller no longer needs the personal data for the purposes outlined above, but you require them to establish, exercise, or defend a legal claim; or (iv) you have objected to processing, pending the verification of whether the legitimate grounds of the controller override those of the data subject.
4. The right to withdraw consent to processing when processing is based on consent, without affecting the lawfulness of processing carried out prior to such withdrawal.
5. The right to object to processing for reasons related to your particular situation when processing is based on legitimate interest, as well as the right to object, at any time, to processing for direct marketing purposes, including profiling.
6. The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you in a significant way.
7. The right to data portability, meaning the right to receive the personal data you provided to the data controller in a structured, commonly used, and machine-readable format and the right to transmit those data to another controller where the processing is based on your consent or the performance of a contract and is carried out by automated means.
8. The right to lodge a complaint with the National Supervisory Authority For Personal Data Processing (ANSPDCP) and the right to address competent courts.

These rights can be exercised at any time. To exercise these rights, we encourage you to use the forms available on the ANSPDCP website or to send a written, dated, and signed request or electronic request to the following address: B-dul G-ral. Gheorghe Magheru 28-30 Sector 1, postal code 010336 Bucharest, Romania, or by email to anspdcp@dataprotection.ro. Additionally, if you wish to withdraw your consent for direct marketing purposes, you can use the „unsubscribe” option included in each marketing communication.