Last update: 03/01/2024

Your privacy is one of our fundamental commitments, and therefore, we take utmost care to process your personal data in accordance with the principles set forth in the applicable legislation, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("GDPR").

We understand the importance of confidentiality, integrity, and security of your personal data ("Personal Data", "Data") and have drafted this information notice ("Privacy Policy") to explain and detail how we process your Personal Data in the context of using the website available at the URL address https://donwasto.com/en (“Website”).

We reserve the right to amend the provisions of this Privacy Policy from time to time. If we make changes to this Privacy Policy, we will publish the updated version on the Website and update the "Last Update" date. Any change to the Privacy Policy will apply from the date it was made, except for changes that require your prior consent, which will apply from the moment you express this consent.

1. CONTROLLER

The Data controller is DON WASTO S.R.L., with registered office in Bucharest, Sector 6, 3A Drajna Street, Room no. 1, Entrance A, Floor 2, Apartment 20, tax identification code (CIF) 47679804, registration number in the Trade Register J40/3451/2023 ("Don Wasto", "we", "us").

2. USE OF THE WEBSITE

When you access and use the Website, your Personal Data will be processed as described in this Policy.

2.1. Website navigation data

Computer systems and software applications used for the operation of the Website generally acquire some Personal Data (so-called "log files"), the transmission of which is implicit in the use of Internet communication protocols.

This information is not collected to be linked to identified individuals, but due to its nature it may allow, through processing and integration with certain data stored by third parties, the identification of users. This information includes IP addresses, time of request, time zone, method used to send the request to the server, size of the file obtained in response, and other parameters relating to the user's operating system.

To the extent that such information leads to the identification of a user, the provisions of this Policy become applicable.

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Purpose of processing	Legal ground
We use this data to obtain anonymous statistical information on the use of the Website and to check its correct functioning	Legitimate interest of the Company (Article 6, para. 1, let. f of GDPR) Details: our legitimate interest in improving the Website, managing server capabilities, and keeping the Website error-free

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2.2. Contacting us

You can contact us through several channels: contact form, e-mail, telephone. In this interaction, we will process your name, surname, e-mail address, phone number and any other Personal Data provided by you.

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Purpose of processing	Legal ground
Communicating with the user on the indicated issues or in relation to solving the indicated problem	Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (art. 6, para. 1, let. b of GDPR)

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2.3. Marketing (newsletters, promotions, offers, commercial messages)

If you have so opted, we will send you marketing messages, in which case we will process the following Personal Data: name, surname, phone number, e-mail address.

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Purpose of processing	Legal ground
Sending commercial messages to promote our services	Data subject consent (art. 6, para. 1, let. a of GDPR)

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2.4. User feedback

Your opinion is important to us, and if you decide to give us feedback, we will process the following Personal Data: name, surname, e-mail address, other information provided by you.

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Purpose of processing	Legal ground
Analysing user feedback to improve services	Data subject consent (art. 6, para. 1, let. a of GDPR)

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3. PROVISION OF PERSONAL DATA

You may refuse to provide certain Personal Data but, in such a case, you may not be able to benefit from certain services related to the provision of the Website.

4. LEGAL GROUNDS

The legal ground for processing differs depending on the specific situation and the Personal Data processed.

Where we process your Personal Data based on your consent, we will seek your free, informed, specific and unequivocal consent to such processing. By expressing your consent, you agree that we may collect, use, disclose, process, and transfer your Personal Data in accordance with this Privacy Policy.

5. AUTOMATED INDIVIDUAL DECISION-MAKING PROCESS

Your Personal Data will not be processed for the purpose of generating decisions based solely on automated processing that are likely to produce legal effects concerning you or significantly affect you within the meaning of Article 22 para. (1) of GDPR.

6. STORAGE DURATIONS

The duration of processing of Personal Data differs depending on the specific processing operation.

As a rule, we will keep Personal Data for as long as necessary to fulfil the purposes listed in this Privacy Policy.

However, in the case of processing based on consent (such as in the case of sending commercial messages), we will process Personal Data until consent is withdrawn.

In certain circumstances, we may retain Personal Data for longer periods of time in order to have an accurate record of your relationship with us in the event of any complaints or if we reasonably believe there is a prospect of litigation.

7. TRANSFER OF PERSONAL DATA

We may transfer Personal Data, to the necessary extent, to the following categories of recipients: IT services suppliers, marketing services suppliers, public authorities.

These recipients can be located in the European Union and/or in the European Economic Area. Where recipients are located outside the European Union and the European Economic Area, including in countries not recognized as ensuring an adequate level of protection, the transfer of Personal Data shall be carried out only if there are appropriate guarantees, in accordance with applicable law (such as the standard contractual clauses issued by the European Commission). You may request a list of recipients from third countries, as well as a copy of the agreed provisions that ensure an adequate level of protection of Personal Data.

8. SECURITY OF PERSONAL DATA

The security of your Personal Data is important for us. Your Personal Data will therefore be processed by applying reasonable technical and organizational measures to protect Personal Data, such as limiting access to Personal Data, encryption or anonymization of Personal Data, storage on secure environments. However, despite our efforts, we cannot always guarantee the effectiveness of the security measures implemented, and therefore we cannot guarantee the security of Personal Data at any time.

9. RIGHTS CONCERNING THE PROCESSING OF PERSONAL DATA

Access right: You have the right to obtain confirmation from us that your Personal Data is processed by us, as well as information on the specific processing, such as: the purposes of processing, categories of processed Personal Data, recipients of Personal Data, the period for which Personal Data is stored, the source of Personal Data, if we transfer the Personal Data abroad and how we protect it, your rights, the right to lodge a complaint before the supervisory authority.

Right to rectification: You have the possibility to request rectification of your Personal Data, provided that the applicable legal requirements are met. In the event of errors, after notification, we will immediately correct your Personal Data.

Right to erasure: In certain cases, you have the possibility to request erasure of Personal Data, namely when: (i) the Personal Data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent on which the processing is based and where there is no other legal ground for the processing; (iii) the Personal Data have been unlawfully processed; (iv) you exercise the right to object to the processing. We are not obliged to comply with your request when the processing is necessary (among others) for compliance with a legal obligation or for the establishment, exercise or defence of legal claims. There are also other circumstances in which we are not obliged to comply with this request for the deletion of Personal Data.

Restriction of processing: You may request us to restrict the processing of your Personal Data in the following circumstances: (i) you contest the accuracy of the Personal Data, for a period enabling us to verify it; (ii) the processing is unlawful and then you oppose to the erasure of the Personal Data and request the restriction of their use instead; (iii) we no longer need the Personal Data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; (iv) you have objected to processing, pending the verification whether our legitimate grounds override yours. However, we can continue to process your Personal Data (i) when you consent; (ii) for the establishment, exercise or defence of legal claims or (iii) for the protection of the rights of another natural or legal person.

Right to data portability: Insofar the Personal Data is processed based on your consent or on the performance of the agreement and the processing is carried out by automated means, you have the right to have your data Personal Data provided to you in a structured format, which is currently used and can be read automatically and you have the right to request us to transfer this Personal Data to another controller. This right shall not adversely affect the rights and freedoms of others.

Right to opposition: In certain situations, such as when we process your Personal Data based on a legitimate interest, you have the right to object to the processing of your Personal Data by us. In the event of unjustified objection, the Company is entitled to continue processing Personal Data. You also have the right to object to the processing of your Personal Data for marketing purposes.

Withdrawal of consent: Insofar you consented to the processing of your Personal Data, you can withdraw your consent at all times, without affecting the lawfulness of processing based on consent before its withdrawal.

Right not to be subject to any automatic individual decisions: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Such right cannot be exercised when the decision: (i) is necessary for entering into, or performance of, a contract between you and us; (ii) is authorized by law which lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (iii) is based on your explicit consent.

Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing ("ANSPDCP") in relation to any breach of your rights regarding the processing of your Personal Data. The contact details of ANSPDCP are: General Gheorghe Magheru Boulevard, Sector 1, postal code 010336 Bucharest, Romania; email: anspdcp@dataprotection.ro.

To learn more about the manner in which you may exercise the aforementioned rights, please contact us at the email below.

10. CONTACT

If you have any questions or concerns about this Privacy Policy or its implementation, you may contact us at office@donwasto.com