GDPR – Confidentiality Policy

Last update: May 2018

I. General Information

The confidentiality of your personal data is one of the main concerns of Q and Q Info Consult SRL (hereinafter referred to as QQinfo), based in Bucharest, Str. Maior Alexandru Câmpeanu nr. 11, ap. 10, sector 1, Romania, registered with the Trade Register under no. J40/10262/2005, as data controller.
The purpose of this document is to inform you about the processing of your personal data in the context of the use of the website https://qqinfo.ro and associated sub-sites (“the Site“).

II. Categories of personal data processed

II.1. If you are a customer of the Site or of QQinfo, QQinfo will process your personal data, such as your first and last name, telephone number, e-mail address, billing address, delivery address, data relating to your use of the Site, e.g. your behavior/ preferences/habits on the QQinfo Site, as well as any other categories of data that you provide directly in the context of creating a user account, in the context of placing a comment or request through the Site or in any other way resulting from your use of the Site or a direct business relationship with QQinfo.

If you use your Facebook or Google account to create your user account on the Site, QQinfo will process the following public profile data displayed by those applications: username, email address.

If you choose to create a user account only before completing an order for a product available on the Site, you will be asked for your e-mail address and an account will automatically be created for you. If you choose to create a user account only before completing an order for a product available on the Site, you will be asked for your e-mail address and an account will automatically be created for you.

II.2. If you are a visitor to the Site, QQinfo will process your personal data that you provide directly in the context of your use of the Site, such as the data you provide in the contact/questions/complaints section, to the extent that you contact us in this way.

III. Purposes and bases for processing

III.1. If you are a customer of the Site or QQinfo, QQinfo processes your personal data as follows:

  • to carry out the contractual relationship between you and QQinfo, i.e. for taking, validating, dispatching and invoicing the order placed on the Site, informing you about the status of the order, organizing the return of ordered products, etc.

Basis: The processing of your data for this purpose is based on the contract between you and QQinfo, as defined in the Terms and Conditions. The provision of your personal data is necessary for the performance of this contract. Refusal to provide your data may result in the impossibility of the contractual relationship between you and QQinfo to continue.

  • for the fulfilment of QQinfo‘s legal obligations in the context of the services provided through the Website, including tax and archiving obligations.

Basis: The processing of your data for this purpose is required by legal obligations. Providing your data for this purpose is necessary. Refusal to provide data may result in QQinfo being unable to comply with its legal obligations and therefore unable to provide you with services through the Site.

  • for marketing activities, i.e. for sending commercial and technical communications on the products and services offered by QQinfo through the Website or directly via remote communication means (e-mail, sms).

Basis: The processing of your data for this purpose is based on your consent, if you choose to provide it. [Note: Separate direct marketing consent (tick) must be collected, which does not pre-ticked or condition the completion of order placement. Proof of agreement must be retained].

You can consent to the processing of your data for this purpose by ticking the appropriate box when you create your account, or after you have created your account in the My Account Information section. To unsubscribe from receiving such commercial communications, you can use the option at the end of each email/sms containing commercial communications. In addition, you can unsubscribe by going to the My Account Information section. Important! Providing your data for this purpose is voluntary. Refusal to provide consent to the processing of your data for this purpose will not have negative consequences for you.

  • for the purpose of carrying out various analyses, reporting on the functioning of the Site, creating consumer preference profiles, mainly in order to improve the experience offered on the Site.

Basis: The processing of your data for this purpose is based on QQinfo‘s legitimate interest in continuously improving the customer experience on the Site. Providing your data for this purpose is voluntary. Refusal to provide data for this purpose will not have any negative consequences for you.

III.2. If you are a visitor to the Site, QQinfo processes your personal data as follows:

  • for marketing activities, i.e. for the transmission, by means of remote communication (e-mail, sms), of commercial communications on products and services offered by QQinfo through the Site.

Basis: The processing of your data for this purpose is based on your consent, if you choose to provide it.

You can express your consent to the processing of data for this purpose by completing and ticking the appropriate box in the newsletter subscription form available on the Site. To unsubscribe from receiving such commercial communications you can use the option at the end of each email/ sms containing commercial communications.

Providing your data for this purpose is voluntary. Refusal to provide consent to the processing of your data for this purpose will not have negative consequences for you.

  • to resolve complaints, grievances and to monitor traffic and improve your experience on the Site.

Basis: The processing of your data for this purpose is based on QQinfo’s legitimate interest in ensuring the proper functioning of the Site, as well as to continuously improve the experience of visitors to the Site, including by addressing various comments, questions or complaints.

Providing your data for this purpose is voluntary. Refusal to provide data for this purpose will have no negative consequences for you.

IV. Duration for which we process your data

As a matter of principle, QQinfo will process your personal data only to the extent necessary to achieve the processing purposes mentioned above.

If you are a customer, we will process your data for the duration of the contractual relationship and thereafter, in accordance with the legal obligations incumbent on us (e.g., If you are a customer and you exercise the option to delete your user account by clicking on the Delete Account button in the My Account Information section, we will interpret this action as your option to unsubscribe from receiving commercial communications informing you about the products and services offered through the website.

In this regard, if you choose to delete your user account, we will no longer send you such emails and/or sms. However, we would like to inform you that deleting your account will not automatically delete your personal data. If you wish to stop the processing of your personal data or if you wish to have your data deleted, you can exercise the rights detailed in point VII below. If you request account deletion, but there is at least one active order on that account, the account deletion request can only be registered after delivery of the products and completion of the last active order.

If you withdraw your consent to the processing of your data for marketing purposes, QQinfo will cease processing your personal data for this purpose, without however affecting the processing carried out by QQinfo on the basis of the consent expressed by you prior to your withdrawal of consent.

If QQinfo‘s contractual arrangements provide for informing the customer of new releases or an active support contract, QQinfo will delete information that falls outside the legal retention obligations (specified above) only after it has once again informed the impact that deletion of such information will have on QQinfo‘s ability to honor its contractual commitments to the customer (or to the contracting legal entity whose employee or representative is the individual in question).

V. Disclosure of personal data

For the fulfillment of the processing purposes, QQinfo may disclose your data to partners, third parties or entities that support QQinfo in carrying out the activity through the Site (e.g. courier companies, IT service providers, software producers, QQinfo‘s suppliers), or to central/local public authorities, in the following cases listed by way of example:

  • for Site administration;
  • in order to register the software license sold or to provide and renew support services for the software sold;
  • where such communication would be necessary to award prizes or other benefits to data subjects obtained as a result of their participation in various promotional campaigns organized by QQinfo through the Site;
  • for maintaining, customising and improving the Site and the services provided through it;
  • for conducting data analysis, testing and research, monitoring usage trends and activity, developing security features and user authentication;
  • for the transmission of commercial marketing communications, under the conditions and within the limits laid down by law;
  • to perform data analysis around the registration of licenses, insurance and renewal of support contracts with customers (natural or legal persons);
  • where disclosure of personal data is required by law, etc.

VI. Transfer of personal data

Personal data provided to QQinfo may be transferred outside Romania, but only to countries in the European Union.

VII. Your rights

Under the conditions laid down in the legislation on the processing of personal data, as data subjects, you have the following rights:

  • the right to information, i.e. the right to receive details of the processing activities carried out by QQinfo as described in this document;
  • the right of access to data, i.e. the right to obtain confirmation from QQinfo about the processing of personal data, as well as details of the processing activities, such as the way in which the data are processed, the purpose of the processing, the recipients or categories of recipients of the data, etc.;
  • the right to rectification, i.e. the right to have inaccurate/ unjustified personal data corrected by QQinfo without undue delay and to have incomplete data completed; rectification/completion will be communicated to each recipient to whom the data was transmitted, unless this proves impossible or involves disproportionate effort;
  • the right to erasure without undue delay (“right to be forgotten”) if one of the following applies:
    • they are no longer necessary for the purposes for which they were collected or processed;
    • where consent is withdrawn and there is no other legal basis for processing;
    • where the data subject objects to the processing and there are no compelling legitimate grounds;
    • where personal data have been unlawfully processed;
    • where personal data must be deleted to comply with a legal obligation;
  • personal data have been collected in connection with the provision of information society services in accordance with Union or national law governing the controller;

It is possible that, following the request for deletion of the data, QQinfo may anonymize these data (thus depriving them of their personal nature) and continue processing for statistical purposes under these conditions;

  • the right to restrict processing insofar as:
    • the person disputes the accuracy of the data for a period that allows us to verify the accuracy of the data;
    • the processing is unlawful and the data subject objects to the erasure of the personal data and requests instead the restriction of their use;
    • the controller no longer needs the personal data for processing purposes, but the data subject requests them for the establishment, exercise or defence of legal claims; or
    • the data subject has objected to the processing (other than direct marketing), for the period of time during which it is verified whether the legitimate rights of the controller prevail over those of the data subject.
  • the right to data portability, i.e. (i) the right to receive personal data in a structured, commonly used and readable format, and (ii) the right to have such data transferred by QQinfo to another data controller, provided that the conditions laid down by law are met;
  • the right to object – in relation to processing activities may be exercised by submitting a request as indicated below:
    • at any time, for reasons relating to the data subject’s particular situation, that data relating to him or her are processed on the basis of the legitimate interest of QQinfo or on the basis of the public interest, except where QQinfo can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of data subjects, or for the establishment, exercise or defence of legal claims;
    • at any time, free of charge and without any justification, that data concerning him/her be processed for direct marketing purposes.
  • the right not to be subject to an automated individual decision, i.e. the right not to be subject to a decision taken solely on the basis of automated processing activities, including profiling, which produces legal effects concerning or significantly affecting the data subject;
  • the right to address the National Supervisory Authority for Personal Data Processing or the competent courts, to the extent you deem necessary.

For any further questions on how personal data are processed and to exercise your rights mentioned above, please contact: or at the phone and fax numbers specified on the contact page.

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