Privacy Policy

Date of publication:    21.04.2020

Prepared by: Digitax Online Public Services, CUI 37733256, registered with the Trade Register under number J40/8914/2017, headquartered in Bucharest, Sector 1, Frumoasă St., no. 21, 1st floor, apt. 2 (generically referred to as the Company)

1. Introduction

This policy describes what information we collect when you use the ConectX ecosystem website or applications, services, mobile applications, products and content („Services”). It also provides information about how we store, transfer, use and delete that information and what choices you can make about the information.

This policy applies to all ConectX applications, including the website and mobile applications, as well as other interactions (for example, customer support conversations, user surveys and interviews, etc.) that you may have with Company representatives.

This policy applies when the Company acts as a Personal Data Controller with respect to the personal data of users of our services; in other words, where we determine the purposes and means of processing personal data. For the content and data you generate, upload or make available through the ConectX ecosystem services („User Content”), you are responsible for ensuring that this content complies with our Terms and Conditions and that the content does not violate the privacy of other users.

2. How we collect, process and store data

We, the Company, are committed to protecting the privacy of our users. We will only collect and process the information we need to provide you with the services and to continue to maintain and develop them.

The Company may collect, store and process different types of data, with different legal grounds, as follows:

  • User identity information – users who choose to register with ConectX must go through one of the registration procedures available in the ecosystem, which involves providing accurate identification data, as well as a valid email address and a valid phone number. The user can also choose to display a profile photo that will be used to personalize him in conversations with other users in the ecosystem.
  • Usage data – when the user interacts with our services, we collect and process metadata to provide additional context about how ConectX is used. Usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the time, frequency and pattern of use of the services by you. The source of the usage data is our server software and our data analysis processing system.
    • Technical data (logs) – Like most digital services, our servers automatically collect information when sites or services are accessed or used and record it in the log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited within the services, the browser type and settings, the date and time the services were used, information about the browser configuration and plugins, language preferences and cookie data. The purpose of these collections is to be able to supervise your good faith in the use of the services and for the purpose of protecting your Content and that of other users.
    • Device information – The Company may collect and process information about the devices you use to access the ConectX ecosystem, including the device type, what operating system is used, device settings, application IDs, unique device identifiers, and crash data. The collection and processing of some or all of this information depends on the type of device used and its settings.
    • Information resulting from support activities – The Company may process the information you send us if you choose to send a notification to our support email. If you contact us, we may use your information from and about your personal virtual space to provide you with the requested support.
    • Service notifications – The Company may process the information both to inform you about various changes to the Terms and Conditions or other procedures used to ensure the proper functioning of the system, and to notify you when suspicious, potentially fraudulent activities are observed on your account.
    • Integrations with external services – The Company may store data about the use of services provided by ConectX partners and licensors in order to improve the user experience. This data can be deleted with the delete option from the integration settings or by deleting them from the browser's cache. When you use an integration, metadata such as the title, dates, and sharing permissions of the selected content may be fetched and displayed on the web page. We may store non-personal / non-restricted information (e.g., content ID and access date) in a local storage space to display lists of recently opened integrations. Restricted metadata is always stored by the services themselves and requires the explicit consent given by the user.

3. How we process media elements

Occasionally, only with the prior consent of the user, we may record and store for security reasons or to make available in the user's Personal Virtual Space the media content of interactions with other users. One of the cases in which we can do this is when proving/verifying the user's identity. This is necessary to assure us, the Company, and all other users of the ecosystem of the accuracy of each user's identity. As a user, you agree to the storage and processing of this information for the duration of the use of ConectX services and whenever there are suspicions about your identity both from the Company and other users or public or private entities.

4. Security

For the purpose of protecting your personal data, the Company implements technical and organizational measures for protection against unauthorized or illegal processing and against accidental loss, destruction or damage.

Communications between users can be made either through peer-to-peer connections, the content being sent directly from user to user without passing through our servers, or through our dedicated network of servers. Our server network is protected by strict security measures designed to ensure the protection of data and information stored, sent or collected in the ecosystem.

5. Access of other entities to your personal data

The Company may disclose users' personal data in certain clearly identified circumstances, such as:

  • With the user's consent;
  • With our licensors, partners, suppliers and affiliates for the purpose of ensuring the best quality user experience and to ensure compliance with the ConectX Terms and Conditions of Use;
  • At the express request of the authorities when the law imposes it;

Our partners, licensors, suppliers and affiliates are grouped into several categories as follows:

  • Infrastructure, hosting or data storage providers;
  • Payment processors;
  • Trust service providers (electronic signature);
  • Providers of collaborative work tools or media content support platforms, services available within the ecosystem.
  • Providers of tools for analyzing technical operating parameters;
  • Customer support tool providers;
  • Marketing and Email tool providers (for sending notifications regarding the updating of ecosystem usage procedures, the launch of new functionalities) only related to the proper functioning of the ecosystem;
  • Internal communication tool providers;

6. Data transfer

The Company may disclose your personal data to any company in our group of companies (our subsidiaries or the “parent” company) to the extent that this is necessary and justified by a reasonable purpose.

7. International transfer of your personal data

Your personal data may be subject to international transfer only in compliance with the Terms and Conditions and only to our partners, suppliers or affiliates. As a user, you are fully aware that the personal data you publish in the ConectX ecosystem will be available via the internet. The Company cannot prevent the misuse of this personal data by others.

8. Storage and deletion of personal data

Personal data that we process for any purpose will not be kept for longer than is necessary.

We will keep your personal data as follows:

  • Information regarding the use of the ecosystem and personal Content elements will be kept for 5 years from the date of their creation, unless the law provides otherwise. In the event that there are legal provisions that oblige us otherwise, the legal provisions will be respected.

9. Modification of this procedure

The Company may modify the provisions of this procedure at any time at its sole discretion. If the changes are significant, we will notify you of the changes before they take effect. Using the ConectX services after the changes take effect means that you agree with the changes made. If you do not agree with the changes, we recommend that you delete your Personal Virtual Space before the changes take effect, otherwise the use of ConectX services and personal Content will be subject to the new provisions.

10. User rights

As a user, you benefit from all the rights granted by national laws and/or European regulations in force, as follows:

  • The right to access your personal data
  • The right to rectify your personal data
  • The right to oppose and restrict the processing by us of your personal data
  • The right to be forgotten, respectively the right to delete your personal data
  • The right to data portability

To exercise your rights or if you have other questions regarding the processing of your personal data, we encourage you to contact us at the email address [email protected]. Equally, we inform you that you can file complaints with the data protection authorities.