Policy on the processing of personal data
The policy regarding the processing of personal data describes the categories of data that we process, the way and purposes for which we collect them, the situations in which we transfer personal data, and the various rights and options that you have in this regard. Our policy on the processing of personal data details how we process personal data in carrying out specific activities related to the organization, conduct, and promotion of the librafilm.net website, and most often to keep you up to date with the events organized by librafilm.net and related events.
Your personal data operator
Libra SRL, a Romanian legal entity, with its headquarters in Bucharest, Popa Soare Street 52, Bucharest 2, as the holder of the website librafilm.net, is the operator of your personal data.
In the event that two or more operators jointly establish the purposes and means of processing, they are associated operators. They transparently establish each one’s responsibilities regarding the fulfillment of the obligations incumbent upon them under this regulation, especially concerning the exercise of the rights of the data subjects and each one’s duty to provide legal information.
As of May 15, 2018, the following entities have the quality of associated operators within the meaning of Article 26 of the Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, thus processing your data under the same conditions as those set out below:
- Asociația pentru Promovarea Filmului Românesc
- Asociația Festivalul de Film Transilvania
- Asociația Film și Cultură Urbană
- LIBRA SRL
- TIFF Events SRL
- Transilvania Film SRL
Categories of personal data processed
The personal data we process may include:
- Contact information, such as your name, job title, postal address, including your home address, if you have communicated it to us, work address, phone number, mobile phone number, fax number, and email address;
- Additional information compulsorily processed for the conclusion or exercise of a contractual relationship or voluntarily communicated by you, such as instructions given, payments made, requests, and projects;
Information collected from public sources;
- Other personal data necessary for informing you if they prove relevant to the activity we carry out, which falls within the legitimate interest of the operator;
- In limited situations, where for our activity, we must collect special categories of personal data as found within art. 9 of the Regulation on the protection of natural persons regarding the processing of personal data and the free movement of this data (“GDPR”), such as the personal identification number, your images, data concerning your membership of a professional or trade association or union, personal health data, data on your political opinions and data on your criminal record, processing will only be done:
- based on your prior express consent or based on fair proof of your consent provided by a third party who communicates this data to us;
- based on a legal obligation to process these categories of data;
- based on an obligation that defends a legitimate right;
- IP addresses. The sites collect IP (Internet Protocol) addresses. An IP address is a number, assigned to your computer by your internet provider, that allows you to access the internet. An IP address can be personal data. We use IP addresses to diagnose server problems, report aggregated information, determine the most effective connection to our site, and for the administration and improvement of the site.
- Cookies. The sites use “cookies”. A cookie is a small text file, stored on your computer, tablet, or phone when you open a website, that helps the site recognize you, including your preferences. Some cookies are deleted when you close your browser. These are called session cookies. Others remain on your device until they expire or until you delete them from your cache. These are called persistent cookies, allowing us to retain information about recurring visitors. The cookies we use allow us to recognize and count present visitors and see where visitors go on the site. Thus, we can improve the functioning of the sites, for example by organizing them so that users easily find what they are looking for. Our cookies also allow us to personalize the content you view, according to the preferences you indicate.
- Email address. If you subscribe to email alerts or confirm the maintenance of a previous subscription dated before May 25, 2018, we collect your email address. This address is only used for the information you have requested/confirmed. If you wish to unsubscribe, you can do so at any time by following the instructions in each email you receive or by sending an email to email@example.com.
How we collect your personal data
We may collect personal data about you in certain circumstances, including:
- When you or your organization engage in contractual relationships with us;
- When you or your organization voluntarily communicate your personal data to us, for any reason;
- When you browse, request information, or interact, or when your organization browses, requests information, or interacts on our website;
- When you participate in an event organized by us that requires you to provide personal data;
- In certain circumstances, we collect personal data about you from a third party. For example, we may collect personal data from your organization, other organizations with which you have connections, government agencies, credit bureaus, information or service providers, or from public archives or partners/collaborators with whom we have contractual relationships that include, among other things, sharing our databases.
Legal bases on which personal data is processed
Any operation that equates to processing (collection, storage, recording, structuring, adaptation or modification, extraction, consultation, use, disclosure by transmission, destruction) of your personal data will be carried out based on one of the following legal bases:
- The processing is necessary for the execution of a contract to which you or your organization are a party, or the respective processing is necessary for the conclusion of a contract with you or your organization;
- The processing is necessary to comply with a legal obligation;
- The processing is carried out based on your prior and explicit consent;
- The processing is necessary to protect your vital interests or those of another natural person;
- The processing is necessary for our legitimate interests or those of a third party, except where your interests or fundamental rights and freedoms override these interests.
In cases where applicable legal provisions require your prior and explicit consent for the processing of special categories of data, we will process such data only on the basis of your prior and explicit consent. At the same time, we will take additional guarantees that any natural or legal person who communicates to us your special personal data has previously obtained your consent.
You can choose to withdraw your consent for marketing materials at any time by simply accessing the ‘unsubscribe’ link at the bottom of each newsletter or event invitation.
At any time, you have the right to withdraw your consent. Withdrawing your consent will not affect the legality of the processing based on consent before its withdrawal. To withdraw your consent for any processing to which you previously consented, please send us an email at firstname.lastname@example.org, contact us at +40 213 266 480, or send us an explicit letter at Str. Popa Soare, Nr. 52, Sector 2, Bucharest, Romania. In all cases, consent may be withdrawn in the same way it was given.
As a general rule, if you withdraw your consent, we will not allow the processing of your data and will take appropriate measures to delete any records with your personal data. However, if processing is strictly necessary for the conduct of the activity, and the processing could be based on other legitimate grounds provided by applicable legal provisions, we will proceed with the respective processing and inform you accordingly.
Collection of Personal Data of Minors
Librafilm.net does not allow the processing of personal data of customers who have not reached the age of 18.
Regarding the provision of information society services directly to a child, the processing of personal data of a child is legal if the child is at least 16 years old. librafilm.net makes all reasonable efforts to verify in such cases that the holder of parental responsibility has given or authorized consent, taking into account available technology. Thus, the processing of personal data of minors by librafilm.net will only be carried out with the explicit agreement of parents or other legal representatives.
The purposes for which your personal data will be processed:
We may use your personal data only for the following purposes (“Permitted Purposes”):
- Complying with our legal obligations (such as record-keeping obligations), compliance verification or registration obligations that may include automatic checks of your contact details or other information that you provide us concerning your identity with applicable lists of sanctioned persons and contacting you to confirm your identity in the event of a possible positive result, or recording interaction with you that might be relevant for compliance purposes;
- Purposes such as advertising, marketing, and advertising, statistics exclusively in the interest of the operator or his authorized persons, organizing courses, seminars, other events (including delegations, conferences, and fairs), for educational purposes in organizing professional training programs, issuing any financial-accounting documents, concluding contracts or other necessary acts in our activity;
- Analyzing and improving our services and communications to you;
- Protecting the security and managing access to our premises, IT and communication systems, online platforms, websites, and other systems, preventing and detecting security threats, fraud, or other criminal or malicious activities;
- For insurance purposes;
- For the purpose of monitoring and evaluating compliance with our policies and standards;
- For any purpose related and/or auxiliary to any of the above or any other purpose for which your personal data has been provided to us.
- In case you have given us your consent, we may process your personal data for the following purposes as well:
- Communicating with you through the channels you have approved to keep you updated on events/information regarding services, products as well as Full Moon events and projects;
- Surveys among customers/partners/collaborators, marketing campaigns, market analysis, raffles, competitions, or other activities or promotional events.
- Regarding communications related to marketing/information about events, we will provide – if legally required – that information only after you have selected this participation option, and we will offer you the opportunity to opt-out at any time, in cases where you no longer wish to receive communications related to marketing/information about events from us.
We will not use your personal data in making automated decisions that may affect you or create other profiles other than those described above.
The transmission of your personal data:
We may share your personal data obtained from you in the following circumstances:
- We may communicate your contact details confidentially to third parties for the purpose of obtaining feedback from you regarding the provision of services by the company, to help us measure our performance and improve and promote our services;
- We may share your personal data with companies that provide services for anti-money laundering controls, reducing credit risk, and other fraud and crime prevention purposes, and companies that provide similar services, including financial institutions, credit bureaus, and regulatory authorities with which such data are shared;
- We may share your personal data with any third party to whom we assign or novate any rights or obligations;
- Additionally, we may use agreed and statistical personal data for the purpose of monitoring the use of the website to help us develop the website and our services.
Additionally, we may share your personal data with our authorized persons – mainly service providers within or outside Lună Plină, domestically or internationally, e.g., shared service centers, for processing personal data for the Permitted Purposes, on our behalf and only in accordance with our instructions. We will retain control over your personal data and will use appropriate protection measures, in accordance with applicable law, to ensure the integrity and security of your personal data when requesting such service providers;
Except as stated above, we will disclose your personal data only when you instruct us or give us permission, when required by applicable law or regulations, or requests from judicial or official bodies to do so, or as necessary to investigate fraudulent or criminal activities, actual or suspected.
Personal data you provide us regarding other individuals
In the event that you provide us with personal data concerning another person (such as one of your administrators or employees, or a person with whom you have professional relationships), you must ensure that you have the right to disclose that personal data to us and that, without taking further action, we can collect, use, and disclose that personal data as described in this Personal Data Processing Policy.
In particular, you must ensure that the individual in question is aware of the various aspects dealt with in this Personal Data Processing Policy, as they relate to that individual, including our identity, how they can contact us, the purposes for which we collect data, our practices for disclosing personal data (including disclosure to recipients abroad), the individual’s right to access personal data and file complaints regarding the management of personal data, and the consequences of not providing personal data (such as our inability to provide services).
Maintaining the security of your personal data
We have implemented technical and organizational measures to maintain the confidentiality and security of your personal data, in accordance with our internal procedures concerning the storage, disclosure, and access to personal data. Personal data may be stored on our technological data systems, those of our contractors, or in printed format.
Transferring your personal data abroad
In exceptional situations, under the Permitted Purposes, we may transfer your personal data to countries that have not been recognized by the European Commission as providing an adequate level of protection.
We will ensure that these international transfers are carried out subject to appropriate or suitable protective measures, as required by the General Data Protection Regulation (EU) 2016/679 or other applicable laws. This includes entering into EU Standard Contractual Clauses. You can contact us at any time, using the contact details below, if you want further information concerning these protective measures.
Updating your personal data
In the event that any of the personal data you have provided to us changes, for example, if you change your first name, surname, or email address, or if you wish to cancel any request to us, or if you become aware that we hold any incorrect personal data regarding you, please notify us by sending an email to email@example.com. We will not be responsible for any loss arising from incorrect, unauthentic, insufficient, or incomplete Personal Data that you provide to us.
At the same time, we will take reasonable steps to periodically update our records regarding your personal data, but we will not be responsible for any unforeseen changes to your personal data.
Personal data retention period
Your personal data will be deleted or removed when they are no longer reasonably necessary for the Permitted Purposes or when you withdraw your consent (if it has been given) and there is no legal obligation to continue the personal data storage operation.
Except when you expressly request us to store your personal data for a longer term, personal data will be deleted within a maximum of 5 years from the date on which they were collected.
Your rights regarding the processing of personal data
According to applicable legal provisions and subject to certain legal conditions, you have the following rights regarding the processing of your personal data:
- The right of access, which includes the right to know if we are processing data about you and the right to find out what they are, to whom they are transferred, how long they will be kept, where we got them from, and if they are used for profiling/automated decisions.
- The right to rectification. If the data we have is incorrect, we must correct it (except if we process it for someone else. In this case, we will inform you to whom you should send your request.).
- The right to deletion (“right to be forgotten”). Upon request, we will delete your personal data as soon as possible if 1) they are no longer needed for the purpose for which they were obtained or 2) if you withdraw your consent to the processing of this data/if you object to the processing (unless we need them for a dispute, the execution of a contract, or legal obligations). Also, if we find that we have a legal obligation to delete or if the processing would be illegal, we will delete them. If the data is also processed by third parties, we will take reasonable measures to inform them about the deletion request.
- The right to restrict processing if they are illegal, presumably incorrect, disputed, or no longer needed.
- The right to be informed. We inform you as clearly as possible about your rights in the field of personal data and what data we process about you or (if applicable) share with third parties.
- The right to portability. If we process your personal data automatically, based on consent or contract, you can ask us to give it to you in a certain format and we will respond to your request within a reasonable time.
- The right to object. You can tell us if you want us to stop processing your personal data. We will comply with your request unless we can show sufficient legitimate interests. In any case, data processed for direct marketing will be deleted upon request.
- The right not to be subject to a decision based solely on automated processing, including profiling, except when you have given explicit consent or if they are necessary for the execution of a contract.
- The right to file a complaint with a supervisory authority. In Romania, this is the ANSPDCP (National Authority for the Supervision of Personal Data Processing), website: www.dataprotection.ro, e-mail: firstname.lastname@example.org.
You also have the following rights:
- The right to request a copy of the personal data relating to you that we hold; if you exercise this right in a way that is clearly abusive or unfounded, we reserve the right to refund the necessary costs incurred for processing the respective copies and for sending the copies within a reasonable time;
- The right to rectify any incorrect personal data and the right to object or restrict our use of your personal data; You can also file a complaint if you are concerned about how we manage your personal data;
- The right to delete your personal data, in situations where you have withdrawn your consent, processing is no longer necessary or the respective processing is against the law.
If you wish to proceed as mentioned above, please send us an email at email@example.com. We may ask you to prove your identity by sending us a copy of a valid means of identification to comply with our security obligations and prevent unauthorized disclosure of data.
We will consider any requests or complaints we receive and will respond to you in a timely manner. If you are not satisfied with our response, you can forward the complaint to the National Authority for the Supervision of Personal Data Processing – located at Bd. Gheorghe Magheru no. 28-30, Bucharest, Romania.
Updates to this personal data processing policy The most recent update of this personal data processing policy was made in May 2018. We reserve the right to periodically update and modify this data processing policy to reflect any changes in the way we process your personal data or any changes in legal requirements. In case of any such changes, we will display on our website the modified version of the personal data policy and/or make it available in another way.
Contact details If you wish to contact us regarding any questions, comments, or requests related to the data processing policy, please send us an email at firstname.lastname@example.org, contact us at tel. +40 213 266 480, or send us a letter to Popa Soare 52, Bucharest 2, Romania.
Updates to this policy for processing personal data
The most recent update to this policy for processing personal data was made in May 2018. We reserve the right to update and periodically modify this data processing policy, to reflect any changes in the way we process your personal data or any changes in legal requirements. In the event of any such changes, we will display the modified version of the policy regarding personal data on our website and/or make it available in another way.
If you wish to contact us with any questions, comments, or requests related to the policy for processing personal data, please send us an email at email@example.com, contact us at tel. +40 213 266 480, or send us a letter to Popa Soare 52, Bucharest 2, Romania.