1. Data collected by CTOtech

Personal data or personal information is any information about you from which you can be identified. It does not include data where your identity has been removed (this is called anonymous data.)

We collect and process different kinds of personal information about you and use different methods to collect it, as follows:

· Identity and contact information: this includes your full name, contact details, (including your email address and mobile phone number), job title, physical address and information about the company you work for;

· Financial data: this may your fee details for your services (bank account and payment card details, details about payments to and from you and other details of services you have purchased from us). We obtain this information through our direct interactions with you (either in person, on the phone, by email, by post or when you give this information via our digital services, and indirectly when it is provided to us by our providers of technical and payment services.

· Technical and usage data: if you use our digital services we collect certain information through automated technologies.

The type of information we collect includes details of the device you use, traffic data, location data (including the country and telephonearea code where your computer device is located, and other technology on the devices you use to access it, as well as information about how you use our digital services and the resources that you access (including the pages of our digital services that you view). We collect this personal data by using cookies, server logs and other similar technologies. We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences or any data relating to children. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by sending an email to office@ctotech.io.

2. Data usage by CTOtech

We will only use your personal data when the law allows us to. Most commonly we will use your personal data where it is necessary for our legitimate interests. Our legitimate business interest is in conducting and managing our business to enable us to give you the best services, and to provide you with the best and most secure experience when using our digital services. We make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). We use your personal information in connection with our business activities. In particular, we may use your personal information in the following ways:

· to carry out our obligations arising from any contracts entered into between you and us. For example, we will use your personal data to process and fulfil your requests for services. This may include using your personal data;

· to manage and administer our relationship with you (including registering you as a new customer, contacting you regarding your orders and any services you have requested, responding to queries you submit to us, and notifying you of changes to our terms, our services or our privacy policy);

· to provide, enhance and personalise your experience when using our digital services;

· to identify and prevent fraud and to assess creditworthiness;

· to carry out market research. For example, we may contact you (including by email) to obtain your feedback on our products and services, and we may use details of your purchases to understand market trends and to identify popular products and services;

· to help us review, develop and improve the products and services we offer, including our digital services, and to improve and develop our customer database;

· for internal business and data analysis;

· to ascertain the products and services that are likely to be of particular interest to you in order to send tailored marketing information to you. For instance, if you browse pages of our procurement services in relation to a particular category, we may use this information to send you marketing communications about that category of product;

· and to administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance and support, reporting and hosting of data);

· to comply with any legal or regulatory obligation which is imposed on us.We may share your personal information with the following third parties:

· companies and other persons who provide services to us. For example, we engage other companies to update our databases of customer details (including the removal of repetitive information), analyse data, help us develop, provide and improve our digital services and provide us with marketing assistance. We also use IT subcontractors, hosting services and payroll providers (relevant to employee data only).

· professional advisers (including lawyers, bankers, auditors and insurers in Romania and overseas, who provide us with consultancy, banking, legal, insurance and accounting services);

· government bodies, regulators and other authorities in Romania and overseas, who require reporting of activities in certain circumstances (for example Office for National Statistics etc.);

· other parties as we may be required to by law or regulation, including for the purpose of detecting and preventing fraud and criminal activity, or pursuant to a court order; and

· third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Your personal data will be kept for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the risk of harm from it being used or disclosed without our authority, the purposes for which we process it and whether we can achieve those purposes without it. We also take into account the applicable legal requirements.  

3. Your legal rights

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. You have the right to:

· Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;

· Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;

· Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;

· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;

· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;

· Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

For a detailed information about the new general data protection regulation, please visit the following website : https://www.dataprotection.ro/?page=noua _pagina_regulamentul_GDPR

If you have any questions regarding this Privacy Policy, please feel free to contact us in any of the following ways:

· online via https://www.ctotech.io/

· by email at office@ctotech.io