Privacy Policy

Privacy in accordance with the EU regulations


Appnor’s Privacy Policy

 

APPNOR MSP S.R.L. (“Appnor”) is committed to protecting user privacy by maintaining the privacy and confidentiality of user personal data. This Privacy Policy complies with (1) the European Union comprehensive privacy legislation, including the EU Directive 95/46/EC on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and with (2) the Romanian applicable legislation including Law no. 677/2001 on the Protection of Individuals with Regard to the Processing of Personal Data and the Free Movement of Such Data.

This Privacy Policy sets forth Appnor’s privacy practices and provides information on the identity of Appnor, on the purpose of Appnor’s data processing, on the categories of data recipients, on the existence of user right of access and right to rectify the personal data, as well as on the user right of intervention and right to object.

By visiting Appnor’s website at: www.appnor.com (“Appnor’s Website”) or otherwise providing your personal data to Appnor via any other means, you are unambiguously accepting and consenting to the practices described in this Privacy Policy. This Privacy Policy applies to Appnor. It does not, however, apply to entities that Appnor does not own or control.

Who is Appnor?

Appnor is a Romanian company having it seat in Bucharest, at 5 Promoroaca street, Floor 2, Room 1, Sector 1, registered with the National Office of the Trade Registry under no. J40/11100/2010, sole identification code 27709080, and registered as a data controller with the Data Protection Authority („ANSPDCP”) under no.18815. You may contact Appnor with inquiries regarding this Provacy Policy at any time at: legal@appnor.com.

What data does Appnor process?

Appnor processes data which generally includes personal information (i.e. name and surname, address, telephone number, e-mail address, financial account information), IP addresses, product and services selections and other orders and/or things that identify users individually.

What is the purpose of data processing?

Appnor processes personal data solely for the purposes of performing the contract to which the user is party and for any other purpose such as to improve the Appnor’s Website experience and services, as detailed below, all of these purposes being explicitly consented to and authorized by the user by accepting and explicitly consenting to this Privacy Policy.

Appnor’s uses of personal data may include (i) providing high-quality and efficient services; (ii) improving services by conducting research and analysis; (iii) making the Appnor’s Website easier for current use; (iv) providing support for customers; (v) customer contact by sending various communications, notifications, bills etc.; (vii) preventing undesired communications (i.e. spam); (viii) sending promotional materials or newsletters upon your prior consent; (ix) creating the opportunity to download various applications that Appnor and Appnor’s partners offer; (x) making suggestions for the improvement of Appnor’s Website and giving opinions on Appnor’s Website’s features and information provided, etc.

Appnor undertakes that personal data shall be:

  1. processed  fairly and lawfully;
  2. collected for the specified, explicit and legitimate purposes detailed above and not further processed in a way incompatible with those purposes;
  3. adequate, relevant and not excessive in relation to the purposes for which they are collected and/or further processed;
  4. accurate and up to date and every reasonable step shall be taken to ensure that data which are inaccurate or incomplete, giving regard for the purposes for which they were collected or for which they are further processed, are erased or rectified;
  5. kept in a form which permits identification of users for no longer than is necessary for the purposes for which the data were collected or for which they are further processed.

Special categories of data

As a general rule, Appnor does not collect or process data about a user medical and health condition, racial or ethnic origin, political opinions, religious and philosophical beliefs, or trade-union memberships. However, in case such information shall be collected or processed by Appnor, the collection and processing shall be made only upon obtaining your prior explicit consent and for the purposes detailed thereto.

How Appnor processes personal data?

(a) Information collected from users

Generally, Appnor asks a user to provide personal data directly, via e-mail, written correspondence, telephone calls, web standard forms or other means.

In order to access the services provided by Appnor, a user is required to create an account on the Appnor’s Website, by providing the following data: name, e-mail, gender, birth date, home or work address, telephone number, interests, demographic information. In some other cases, Appnor may ask the user additional information for security reasons or in order to provide the user with additional services.

In order to facilitate a user’s access to Appnor’s servers, Appnor may store some of that particular user personal data (i.e. e-mail address, password, questions and secret answers etc.). In addition, in case a user is performing payments or transactions via the Appnor’s Website, Appnor may retain the user account details, name and type of transaction performed etc. When a user accesses Appnor’s Website from a computer, mobile phone or other device, Appnor collects additional information provided by the user’s browser such as location, IP address, other visited pages, search engines and keywords that were used to find Appnor’s Website, pages visited within Appnor’s Website, access time, clicked links or other actions performed on the Appnor’s Website and service.

Appnor uses “cookies” for authentication, storing site preferences, identification of server-based session or other operations that can be accomplished through storing text data. Appnor also uses “web beacons” to monitor the behavior of the user visiting the website or sending an e-mail (including “spamming”). Also, in case of receiving newsletters, advertisements or promotional e-mails, Appnor is able to determine whether e-mails have been opened, as well as the most accessed links in order for Appnor to be provided with more information on your interests and preferences. Turning off the browser’s “cookies” by using the browser’s settings will prevent “web beacons” from tracking a user’s activity.

(b) Information collected from third parties

Appnor may collect personal data via third parties, but only for the same purposes as detailed above. Appnor shall not be held liable for the third party non-compliance with the relevant and applicable legal provisions regarding the transfer of personal data from which it acquired the personal data.

Appnor’s sources to collect personal data include, but are not limited to, platforms, programs, advertising partners or other websites that share information with Appnor. In this respect, Appnor shall receive information on a user actions taken on a particular accessed website, on the reaction of users to various advertisements posted on Appnor’s website compared to other advertisements on other websites.

Tranfer of personal data to third countries

Personal data processed by Appnor may be transferred to another state for the purpose of storage and/or processing only if the third country in question ensures an adequate level of protection. Personal data processed by Appnor may be stored and/or processed solely by a US organization/entity which is fully complying with the EU-US Safe Harbor principles and framework.

Rights of access

A user may obtain from Appnor, without constraint, at reasonable intervals and without excessive delay or expense:

  1. Confirmation as to whether or not data relating to the user are being processed and information at least as to the purposes of the processing, the categories of data concerned, and the recipients or categories of recipients to which the data are disclosed;
  2. Communication to the user in an intelligible form of the data undergoing processing and to any available information as to their source;
  3. Knowledge of the logic involved in any automatic processing of data concerning the user.

Appnor shall provide the user with the possibility to rectify, erase or block the data processing especially if it does not comply with the comprehensive privacy legislation because of the incomplete or inaccurate nature of the data and to notify third parties to whom data have been disclosed of any rectification, erasure or blocking carried out unless this proves impossible or involves a disproportionate effort.

To this effect, a user shall be entitled to access his/her data on the Appnor’s Website at any time after processing of a user personal data, by entering his/her e-mail address and password. The user shall be able to view, edit, update, block, delete or convert into anonymous all personal data provided. In case the user wishes to stop using his/her account on the Appnor’s Website, the user is free to deactivate or delete it anytime.

Right to Object

A user may object at any time on compelling legitimate grounds relating to his/her particular situation to the processing of data by Appnor relating to him/her. In addition, a user may freely object at any time on request and free of charge, to the processing of personal data by Appnor which Appnor anticipates being processed for the purposes of direct marketing, or to be informed before personal data are disclosed for the first time to third parties or used on their behalf for the purposes of direct marketing.

Security

Appnor commits to implement adequate technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, disclosure or unauthorized access, notably if the respective processing involves the data’s transmission within a network, as well as against any other form of illegal processing, in compliance with the EU and Romanian applicable legislation.

However, irrespective of the security measures implemented, Appnor urges the user to be careful when sharing his/her computer, mobile phone or other similar device with third parties. Appnor recommends that users log off after entering the Appnor’s Website or accessing the Appnor’s services in order to protect user’s privacy by not allowing subsequent users to log in using identical username and password.

Controlling unsolicited e-mails (“spamming”)

Appnor has a strong anti-spam policy and dynamically fights against unsolicited commercial e-mail (“spam”). Appnor undertakes to prevent third parties to have unauthorized access to personal data it collects. However, Appnor urges users to be careful in providing their e-mail addresses to third parties while navigating online in order to reduce the amount of possible unsolicited e-mails which may be received subsequently.

Changes to the Privacy Policy

Appnor may change this Privacy Policy occasionally pursuant to the suggestions made by users for the improvement of Appnor’s Website and services. Changes to the Privacy Policy shall be highlighted by the amendment of the date at the top of this Policy. In case of material changes, Appnor commits itself to notifyusers in writing about the above in due course.