Privacy Policy

”Singureni Manor Polo Cup” 2024

The security and privacy of your personal data is a priority for us and we want to be open and transparent about the processing of personal data. Therefore, we have a Policy defining how we process and protect your personal data.

  • CONTROLLER ‘S IDENTIFICATION DATA. CONTACT DATA.

https://singurenimanor-polocup.com is a site belonging to the Romanian legal entity ASOCIAȚIA CLUB SPORTIV POLO SINGURENI.

Under the provisions of Law 129/2018 and Regulation (EU) 679/2016 (applicable in Romania from May 25th, 2018), ASOCIAȚIA CLUB SPORTIV POLO SINGURENI, a Romanian legal entity – association, headquartered in Bucharest Municipality, 333 Calea Giulești, Building C14, semibasement, room 14,  6th District, registered in the National Register of NGOs under no. 83/21.05.2024, Tax reference number 50221156 – is a personal data controller and is responsible for your data in accordance with the applicable data protection legislation.

In carrying out the Event, ASOCIAȚIA CLUB SPORTIV POLO SINGURENI has partners, stand-alone entities, with their own GDPR policy.

POIANA CAILOR S.R.L., a legal entity of Romanian nationality, headquartered in Bucharest 6th District, 333 Calea Giulesti, Building C2, Room 15, 1st Floor, Trade Register Number J40/1605/2021, Tax reference number 43649991, e-mail: contact@singurenimanor.com is the  company that provides access to the Food & Beverage area of the “Singureni Manor Polo Cup” Event and which thus processes the personal data you provide on the website, in the tab https://singurenimanor-polocup.com/acces-la-eveniment/, i.e. the company that has video surveillance on the “Singureni Manor” premises, where the Event takes place and which thus processes your image captured via technical means (video surveillance),  with its own GDPR policy. For detailed information, it is your obligation to  access and https://singurenimanor.com/.

You shall find hereby our Privacy Policy, supplemented by the Cookie Policy available here https://singurenimanor-polocup.com/en/cookie-policy/.

For any requests/ referrals/ complaints regarding your personal data and additional information, you can contact us in writing at our headquarters or via email care of the Data Protection Officer, see section 9.

  • ESSENTIAL NOTIONS ACCORDING TO THE DEFINITIONS OF THE EUROPEAN REGULATION NO. 679/2016

“Personal data” is any information that relates to an identified or identifiable living individual („data subject”); an identifiable living individual is a person who may be directly or indirectly identified, especially by reference to an identifier such as a name, an identification number, location data, an online identifier or one of several special characteristics, which expresses the physical, physiological, genetic, mental, commercial, cultural or social identity of these natural persons; 

“processing” refers to any operation or set of operations performed on personal data or on personal data sets, with or without using automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  • CONTENT AND PURPOSE OF THE POLICY. SCOPE. UPDATES 

This Policy provides, for all users of the https://singurenimanor-polocup.com/  website, information and proof of express/ implicit consent, inferred from the circumstances of browsing the site and the voluntary transmission of data to us/our partners, on the communication routes available/ displayed therein, respectively for all participants in the “Singureni Manor Polo Cup” Event and/ or the “Singureni Manor Polo School”, inferred from access to the “Singureni Manor” premises in Singureni Commune, Giurgiu, 087205, Romania. 

Contacting us using any medium represents your acceptance of the provisions of this document and implicitly of the provisions of the documents referred to herein.

The provisions herein apply both to data processing carried out through the website (and subsequently through the other communication channels), as well as to data processing through third parties/ mediums, in the context of which reference is made to them – for example: data processing through and in the context of online advertising and marketing activities/ through social networks – direct/ indirect processing through external sources that refer to the explicit and/ or implicit political presence.

Please note that when we ask you to fill in your personal data to give you access to the Event/ School/ other functionalities, we will mark some fields as mandatory as this is the information we need to give you access to the respective Event/ School/ functionalities. Please note that if you decide not to provide us with this information, you may not be able to complete your registration, as a user/s you may not be able to become a participant in the Event. 

We reserve the right to amend the Privacy Policy at any time. The latest version of the Privacy Policy is available at all times at our premises and on the website.

  • WHAT DATA DO WE PROCESS? THE PURPOSE AND GROUNDS FOR DATA PROCESSING. RETENTION PERIOD PER EACH CATEGORY OF DATA.

The data processed depend on the section/ functionality accessed on the website, on the download of the Event application – “Singureni Polo Cup”, on the registration to the “Singureni Manor Polo School”, on your physical presence on the premises of “Singureni Manor”, as well as on the way and purpose in which you communicate with us via the site/ through the contact details displayed on the site/via other means of communication: the data collected through cookies, automatically when accessing/ browsing in various sections/ accessing various functionalities – for details, see the  Cookie Policy – related link in section 1.

4.1.1. Last name, first name, email, phone number (possible), gender (if it results from email or last name and first name), QR code/electronic proof of access number, your full address, city, country:

Controller: S.C. Poiana Cailor S.R.L., our partner who ensures the right of access to the Food & Beverage area of the Event. For detailed information, it is your obligation to access its own Privacy Policy – related link in section 1.

Purpose of the processing: to ensure access to the Food & Beverage area; to ensure the registration/enrollment and payment of access to the Food & Beverage area; for invoicing and communication of tax and accounting documents; to ensure the provision of services to which the participant is entitled under the QR code/electronic proof of access; to prevent fraud and misuse; to defend our rights and legitimate interests in case of related disputes/ disputes, to be submitted to controls carried out by state authorities and institutions, to be provided to authorities according to their provisions and for other purposes described in this Policy and the Controller’s own Policy (including marketing).

Grounds for data processing

  • your consent to enter into and perform the contract to which you, as the data subject, are a party (the contract ends when your order and payment will be validated and you will receive, in this regard, an email with the QR code/electronic proof of access); regarding the data you provide to us by filling in the tab on the site, you voluntarily give us the information we process, and the legal basis is Article 6(1)(b) of Regulation (EU) 679/2016) – the processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject before concluding a contract;

According to the GDPR, your consent is not required if the processing is necessary to take steps to conclude a contract, fulfill a legal obligation or legitimate interest.

  • for the purposes of the legitimate interests pursued by the Controller and/ or a third party (including the Event Organizer).

Duration of processing:

For data provided via the tab https://singurenimanor-polocup.com/acces:

  • failure to sign a contract between the Parties, for a period of 1 year from the initiation of the unfinished/ invalidated order;
  • followed by the signing of an agreement between the parties, for a period of 5 years from the termination in any way of the relations between the parties, with the possibility of extension until the settlement of the disputes that would arise in connection with them.
  • for the data contained in the accounting documents – 5 years from the termination in any way of the relations between the Parties/final settlement of the disputes between the Parties or for longer periods, according to the legal tax-financial-accounting obligations (including for data covered by internal controls/ in the audit).

Additional remarks:

The controller does not request or store any bank data, such as card number, expiration date, security code. Bank data processing is done exclusively by/through the payment processor (Stripe).

4.1.2. Last name, first name, email, phone number (possible), gender (if it results from e-mail or surname and first name), QR code/electronic access proof number 

Associated controller: Asociația Club Sportiv Polo Singureni

Purpose of processing: to ensure access to/during the Event; to verify the validity of the QR code/electronic proof and to go through the check-in process; to prevent fraud and misuse; to inform about issues related to access, organization and conduct of the Event; to support your experience at the Event; to respond to a request from the competent authorities; to provide to authorities and courts during controls/ at their request; to ensure the defense of the rights and prevailing legitimate interests of the organizer and its partners, including in case of disputes and differences; for other purposes described in this Policy.

Grounds for data processing

  • your consent. – Article 6(1)(b) of Regulation (EU) 679/2016 – the processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject before concluding a contract.
  • to comply with our legal and contractual obligations as the Event organizer to you and beyond; 
  • for the purposes of the legitimate interests pursued by the controller, our partners or a third party.

Duration of processing:

The data will be anonymized within 4 years from the date of completion of the Event, unless previously requested, circumstantially until the final resolution of the incident for which processing is required as evidence/for the duration required by the authorities.

4.1.3. Last name, first name, email address, gender (if this results from the e-mail or from the first and last name), phone number (possible)

Controller: Asociația Club Sportiv Polo Singureni

Purpose of processing: marketing – advertising of the Event/ upcoming editions of the Event/upcoming Events/adjacent activities. Data processing is necessary to enable data subjects to be informed regarding/about them. The aim is to create a community in which people interested in finding out the latest information join. Data subjects understand (and accept) that by providing their personal data they are signing up to receive recurring marketing information. 

Grounds for data processing: Article 6(a)(f) of Regulation (EU) 679/2016 – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party; the data subject has given his or her consent to the processing of his or her personal data for one or more specific purposes; our legal obligations to prove the compliance of the processing, our prevailing legitimate interest. 

Duration of processing: the data will be anonymized upon withdrawal of consent or at the latest within 4 years if the data subject no longer reacts to any commercial message. 

  • Data resulting from subscribing to the newsletter: email (indirectly last name and first name and gender if it results from the email address) provided voluntarily, associated with a distinct and withdrawable consent – for details, see also the Cookie Policy.

Controller: Asociația Club Sportiv Polo Singureni

Purpose of processing: For the purpose of subscribing to the Event Newsletter with the consent of the data subject. To present and advertise our Event/upcoming editions of the Event/upcoming Events/adjacent activities; to build and maintain a community around common values; to defend our rights and legitimate interests in case of related disputes; to be submitted to/ in case of control/ request of public authorities.

Grounds for data processing: Article 6(1)(a) of Regulation (EU) 679/2016 – your consent – the data subject has given his/her consent to the processing of his/her personal data for one or more specific purposes – by filling in the email address in the newsletter field; our legal obligations to prove the compliance of the processing; our prevailing legitimate interest.

Duration of processing: Until unsubscribe or withdrawal of consent. 

  • Data collected through cookies, automatically when accessing/ browsing in various sections/ accessing various functionalities – for details, see the Cookie Policy – related link in section 1.
  • Data processed on the occasion of access to the Event by persons with disabilities and/ or their attendants such as: last name, first name, address, place of birth, ID card series and number/ passport/birth certificate, date of issue/ expiry of the identification document, personal number, email, age (date of birth), phone number, medical data (for persons with disabilities).

Controller: Asociația Club Sportiv Polo Singureni

Purpose of processing: This personal data is processed in order to grant the rights due to persons with disabilities, in relation to the provisions of Law 448/2006 on the protection and promotion of the rights of persons with disabilities, republished, as amended and supplemented, with the correlative application of the purposes under sections 4.1.2. and 4.1.3.

Grounds for data processing: the consent of the data subject; the mandatory legal rules mentioned above and the correlative grounds under sections 4.1.2. and 4.1.3.

Duration of processing: according to sections 4.1.2. and 4.1.3. The data additional to those in sections 4.1.2. and 4.1.3. shall be kept for 3 years from the time of the conclusion of the Event, circumstantially until the final settlement of the incident for which the processing is required as evidence/for the duration required by the authorities.

Additional remarks: verifying the access to the Event of these persons involves the use of the list of persons (surname and first name). After the event is completed the list will be destroyed.

  •  Data processed on the occasion of the access of minors to the Event on the basis of A DECLARATION REGARDING THE ACCESS OF MINORS AGED 02-18 YEARS, such as: last name, first name, series and ID number/ passport/birth certificate, date of issue of the identification document, age, date of birth, gender (default), email, phone number 

Controller: Asociația Club Sportiv Polo Singureni

Purpose of the processing: to ensure access to the Event; to go through the check-in process; to support your experience at the Event – to ensure the protection of the minor and the accountability of the accompanying adult; to ensure the defense of the rights and prevailing legitimate interests of the minor, the organizer and its partners, including in case of disputes and disputes; to respond to a request from the competent authorities; to provide to authorities and courts in the framework of controls/ at their request; for other purposes described in this Policy, including those under sections 4.1.2. and 4.1.3.

Grounds for data processing: the consent of the data subject; our contractual/ legal obligations, our prevailing legitimate interest, as well as that of the minor, as well as the related grounds under sections 4.1.2. and 4.1.3.

Duration of processing: according to sections 4.1.2. and 4.1.3. Data additional to those under sections  4.1.2. and 4.1.3. – 3 years from the moment of the conclusion of the Event, circumstantial until the final settlement of the incident for which the processing is required as evidence/for the duration required by the authorities.

  • Data processed when downloading the Event application – “Singureni Polo Cup”, such as: last name, surname, email, QR code/electronic proof number/ gender (if it results from email or last name and first name

The “Singureni Polo Cup” application has its own Data Privacy Policy, which you are to access and accept and consent to the processing of your data in accordance with this Policy at the time of downloading the application, creating the user account, respectively at the time of log-in. 

  • Data processed during the media activities within the Event: image of the data subjects

During the Event, technical means are used to capture (live or recorded) images of the data subjects. 

Controller: Asociația Club Sportiv Polo Singureni

Purpose of processing: We capture your images for journalistic, information, artistic, marketing and advertising purposes of the Event and related activities on our own behalf by the Controller or any partner or sponsor of the Event; for the purpose of fulfilling contractual obligations.

Grounds for data processing: your consent, our contractual obligations, our interest or that of a legitimate third party [Article 6 (a) (f) of Regulation (EU) 679/2016] 

Duration of processing: Until the time of the justified request for deletion from the data subject or no more than 15 years from the time of completion of the Event, at which they were carried out.

  • Data processed as a result of access to the video surveillance room “Singureni Manor”: your visual image and the registration number of the cars, correlated with the date and time of the image capture.

Controller: S.C. Poiana Cailor S.R.L..

Remarks: Access to the “Singureni Manor”/ mere presence and transit through the “Singureni Manor” premises is your acceptance of the fact that once you enter the premises, video images of you will be taken via technical means (CCTV closed-circuit video surveillance) owned by the Controller.

As a result, you declare and accept that you have read, understood and mastered the VIDEO SURVEILLANCE POLICY of the Controller, available in the link indicated in section 1.

Associated controller: Asociația Club Sportiv Polo Singureni

Purpose of processing: to ensure the security of goods, premises and persons.

Grounds for data processing:  your consent, legitimate interests pursued by the controller or by a third party.

Processing duration: 30 calendar days from collection, with subsequent automatic deletion. Circumstantially, until the final resolution of the incident for which a registration is required as evidence/for the duration required by the authorities.

  • Data related to the completion of the contact form available on the site such as: last name, first name, email address, phone number, gender (insofar as it is implicit in the first name or email address). Data provided by the data subject voluntarily, without the request of the controller, by filling in the space for the message itself/Data related to the transmission of messages of any type or making phone calls to the contact addresses displayed on the site (other than through the contact form) (e.g.: date of birth/ age/occupation/position/ place of work/marital status/ habits/ preferences, provided explicitly or implicitly in the context of messages/ calls)

Controller: Asociația Club Sportiv Polo Singureni

Purpose of the processing: for the management, settlement, provision of response, investigation/ exploitation of any messages/ calls received from you; to prove compliance in the execution of contracts/in compliance with consumer protection legislation, if the communication received falls within such spheres; to defend our rights and legitimate interests in case of disputes/related disputes; for submission to authorities on request/if necessary.

Grounds for data processing – your consent, our legal or contractual obligation, our prevailing  legitimate interest, as well as those of third parties.

Duration of processing: 

For data collected involuntarily/not requested by the controller and for which it has no legal basis for processing, they shall be deleted as soon as the collection is found, without informing the data subject in this regard.

For the data provided through the contact form/communication routes displayed on the site:

  • not followed by the signing of a contract between the Parties, for a period of 1 year from the provision of a response to the communication/ within one month from the receipt of the request to which no response was provided;
  • followed by the signing of a contract between the Parties, for 5 years from the termination in any way of the relations between the Parties, with the possibility of extension until the settlement of the disputes that would arise in connection with them.
  • Data resulting from visiting and interacting with/ publishing testimonials on social networks managed by the Controller (Facebook, Instagram, LinkedIn) such as: own username on the page, public data associated with the personal page, implicitly accessible by interacting with the site, data contained in the message itself/ images/ video released voluntarily publicly on these pages, which fall under the consent and responsibility of the launcher.

Controller: Asociația Club Sportiv Polo Singureni

Purpose of processing: to advertise our Event through your positive feedback, to adjust our marketing approaches, to improve our business, security and privacy measures and policies, to defend our rights and legitimate interests in case of related disputes/ litigations, to be submitted to/ in case of control/ request of public authorities.

Grounds for data processing: your consent, our legal obligations to prove the compliance of the processing, our prevailing legitimate interest, as well as that of third parties.

Duration of processing: until the consent of the data subject is withdrawn/ until the data deletion request is resolved within the legal term/ until the related Cookies are deactivated, as the case may be.

Remarks: These data will be left in public display/ deleted from the page, at our disposal. You can delete/request us to delete the information associated with/ published on our pages at any time. We do not accept liability in relation to third party takeovers from our own pages. We do not create separate databases from the data published on these pages, but we may implicitly use the data collected directly by these third party pages in audience and marketing analyses (except for email addresses provided by newsletter subscribers).

  • Data resulting from the transmission of requests/ complaints/ referrals  regarding personal data such as: last name, first name, gender (insofar as it can be inferred from the first name or email), contact details related to the chosen means of communication or other contact details (if desired to receive the response by another means) and another identifying attribute (only under the conditions described below, in the section Requests/ complaints/ referrals regarding personal data).  

Controller: Asociația Club Sportiv Polo Singureni

Purpose of the processing: to solve the requests addressed to us; to ensure the effective exercise of your rights and legitimate interests regarding the processing, security and privacy of data and to fulfill our obligations and to ensure our prevailing legitimate interest; to defend our rights and legitimate interests in case of related disputes/ litigations; to be submitted to/ in case of control of public authorities/ at their request.

Grounds for data processing: our legal obligation to respond and take appropriate action; our legal obligation to produce and maintain evidence of compliance with the processing; our prevailing  legitimate interest.

Duration of processing

For the data related to the documents by which the controller can prove the compliance of the processing before ANSPDCP (referrals/ complaints/ requests of the data subject made in person or by proxy, proof of the manner of settlement, obtaining the consent etc.) –  3 years from their production/ completion of the respective procedures, regardless of the duration established for the processing for the basic purposes, strictly in order for the controller to be able to prove, if necessary, before ANSPDCP the conduct of a compliant processing and the observance of the rights of the data subject/ for the application of sanctions to those who are guilty of non-compliance with the rights of the data subject.

  1.  Data resulting from the courses offered by the “Singureni Manor Polo School”by (i) registering on the website in the tab https://singurenimanor-polocup.com/en/polo-school/, such as: last name, first name, age, phone number, email, gender (if it results from last name, first name and/ or email address) (ii) by filling in the Acknowledgement and Risk and Liability Statement, additional data such as: series and ID number/ passport/birth certificate.

Controller: Asociația Club Sportiv Polo Singureni

Purpose of the processing: to enroll in the course; to validate access to the course; to inform about the matters related to the organization and conduct of the course/ School; to ensure the execution and proof of the conformity of the activity carried out in the course/ School; to fulfill our legal and/ or contractual obligations given by the specifics of the activity carried out; to ensure the defense of the rights and prevailing legitimate interests of the organizer; to prepare and deliver the diplomas; for marketing purposes to promote our School/ courses/subsequent activities/ events; to prove the conformity of the processing carried out in these contexts; to defend our rights and legitimate interests in case of correlative disputes/ litigations, to be submitted to the controls carried out by the state authorities and institutions, to be provided to the authorities according to their provisions; to ensure the defense of the prevailing legitimate rights and interests of the controller, including in case of disputes and differences.

The purposes under sections 4.1.2., 4.1.3 shall remain applicable correlatively.

Grounds for data processing: your consent, our legal or contractual obligation, our prevailing  legitimate interest and that of third parties, with the correlative application of the grounds in sections 4.1.2., 4.1.3.

Duration of processing: according to sections 4.1.2. and 4.1.3. Data additional to those under sections 4.1.2. and 4.1.3. – 3 years from the end of the course, circumstantial until the final settlement of the incident for which the processing is required as evidence/for the duration required by the authorities.

Additional remarks: all sections of this material, including sections 4.7. and 4.8., shall remain valid for the data subjects who register and participate in the courses within the “Singureni Manor” premises, organized by the School.

In addition to the aforementioned purposes (4.1. – 4.12.), the controller processes the personal data collected also considering the following purpose:

  • For the fulfillment of the obligations incumbent on us, as a result of the activities carried out (e.g. accounting, tax, audit obligations etc.) they are always compatible with the main purposes for which the data were collected.
  • the data subject has given consent to the processing of their personal data for one or more specific purposes;
  • For any other purpose ancillary to the above, or for any other purpose for which the personal data have been provided to us, in compliance with the relevant legislation.
  • In order to protect our legitimate interests, with a prevalence of the interests or fundamental rights and freedoms of the data subject, taking into account their reasonable expectations based on the relationship with the controller, such as:
    • For direct marketing purposes, to send notifications of general interest or messages by which we ask you to evaluate the quality of our activity and not only;
    • To prevent or detect misuse of our intellectual property, fraud or other offences;
    • In order to ensure security within the Event/ School, to resolve complaints related to fraud, criminal or contravention complaints, complaints related to the acquisition of access, to preserve and defend our rights in court, cases in which the Organizer needs to identify a person based on the data provided.

In cases where we will use your data for purposes other than those expressly/ implicitly mentioned in this Policy, we undertake to obtain your consent, unless we are under a legal obligation or have another legal basis for processing the data.

The Controller does not create individual profiles of the Event participants.

  • HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect your personal data, either directly from you, for example, when you access the tabs on the website, create an account for the Event application, contact us through the contact form, email at info@singurenimanor-polocup.com or any other means  of communication, consent to the communication of commercial messages, fill in the statements of risk and liability etc., or indirectly, for example, when you send this information on our partners’ platforms, in the process of acquiring the right of access for example or when you enter the premises of “Singureni Manor” video monitored. 

We also collect your personal data automatically. When you use the Event website or app, we collect information through cookies and logging your activity. 

If you choose to provide us with the personal data of other persons, such as when you acquire the right of access to the Event/ ensure enrollment in the courses of the School on behalf of others, you assume responsibility for how you obtained this data and that you have a legal basis for processing it, we/our partners cannot be held responsible for the violation of the rights of those persons.

  • HOW DO WE USE YOUR PERSONAL DATA? Information Security

Data storage media are located in secure premises and access to databases is computer-secured.

We make every effort to protect our website, application and users, as well as all personal data collected under this Policy, from any unauthorized access or alteration, unauthorized disclosure or destruction of the information we hold.

To this end:

  • We certify that we meet the minimum security requirements for personal data, the data being processed in a way that ensures protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, by taking appropriate technical and/ or organizational measures;
  • We apply internal policies and procedures based on prior risk assessment;
  • We train the staff involved in the processing and hold accountable the external recipients of your data through specific contractual clauses;
  • We perform the physical/ IT transfer of data according to specific security rules;
  • We secure the data storage spaces both physically and IT, by their type;
  • We periodically ensure the specialized review of the workstations and the security programs used;
  • We regularly review security measures and sanction misconduct;
  • We treat security breaches promptly and in accordance with the law.
  • To whom do we disclose personal data?

In order to fulfill the processing purposes, the controllers may disclose your personal data to partners, third parties or entities that support the controllers in carrying out their activity, or to central/ local public authorities, in the following illustrative cases listed:

  • Our suppliers and contractual partners, for example: marketing and advertising service providers, IT services; persons in charge of providing access to the Event premises etc. These data will be provided on a kneed-to-know basis and only under a confidentiality commitment from the contractual partners, guaranteeing that these data are kept secure and that their processing is carried out in accordance with the legislation in force.
  • To the accountants, auditors, lawyers, insurers or other such external advisors of the Controllers. These data will be provided on a need-to-know basis and only under a confidentiality commitment from the contractual partners, guaranteeing that these data are kept secure and that their processing is carried out in accordance with the legislation in force.
  • Authorities, institutions and public bodies, where there is a legal request from them or to the extent that there is a legal obligation from us. The Controller may disclose these data whenever the law requires it, or if this is necessary to allow the exercise of the rights provided by law and/ or to be able to take legal action against any illegal activity.

Exceptionally, your personal data may be transferred to third countries (EU/ non-EU), based on the contractual relationships we have with our partners (both affiliates and other entities). For example, the data collected during the media activities within the Event (section 4.7) and data resulting from visiting and interacting with/ publishing testimonials on social networks managed by the Controller (Facebook, Instagram, LinkedIn) (section 4, 10). Also, the data provided for marketing communications (section 4.1.) are managed at the level of the contractual partner in a third country of the European Union. For transfers to third countries, which are not assimilated to those within the EU by the GDPR, higher risks may occur for your rights and legitimate interests (e.g. risk in the context of the transfer, difficulties in exercising the rights and for compelling the controller/processor to comply with the rights or to pay compensation in case of breaches). We are constantly working to limit these risks. Your consent to marketing notifications also involves your consent to the data transfer carried out in the manner described.

  • Your rights RELATED to the processing of personal data

As a data subject, you benefit from a number of specific rights guaranteed by the General Data Protection Regulation no. 679/2016 (GDPR) and the legislation in force in Romania on the protection of personal data.

  • Right of information

Data subjects whose personal data is processed in the course of our specific activities have the right to receive from us information about the processing operations carried out in our capacity as data controller.

  • Right of access

You have the right to obtain from us confirmation as to whether or not we process personal data concerning you.

If we confirm that we hold your personal data, you have the right to access it and obtain some relevant additional information.

  • Right to rectification

You have the possibility to obtain from the data controller, the rectification of inaccurate data concerning you or the completion of personal data that is incompletely recorded in our internal records.

  • Right to erasure (right to be forgotten) 

You have the right to request that we erase the personal data we process about you. We must comply with this request if: 

  • personal data is no longer necessary for the purposes for which they were collected or processed;
  • you object to the processing for reasons related to your particular situation;
  • personal data has been processed unlawfully,
  • personal data must be erased for compliance with a legal obligation incumbent on us, unless the data is necessary:
  • for the exercise of the right to free expression and information;
  • to comply with a legal obligation we have;
  • for archiving purposes in the public interest, scientific or for historical studies or for statistical purposes; or
  • for the establishment, exercise or defense of a right.
  •  Right of restriction of processing

You can ask us to restrict the processing of your personal data when:

  • you contest the accuracy of the personal data we process, as long as we verify the accuracy of the data;
  • the processing of data is unlawful, but instead of requesting the deletion of personal data you want the restriction of their processing;
  • the personal data are no longer necessary for us to achieve the purpose for which they were processed, but you request those data for the establishment, exercise or defense of a right in court;
  • you have objected to the processing and you request restriction while we verify that our legitimate interest in the processing prevails.
  • Right to data portability 

You have the right to obtain your data from us in a structured, commonly used and machine-readable format.

  • Right to object

At any time, the data subject has the right to object, on grounds relating to his or her particular situation, to processing. The controller shall no longer process personal data unless the controller demonstrates legitimate and compelling grounds for the processing prevailing the interests, rights and freedoms of the data subject or the establishment, exercise or defense of legal claims.

You may object at any time to the processing of your personal data for direct marketing purposes, for whatever reason.

  • The right not to be subject to a decision based solely on automated processing, including profiling.

This right is applicable if the automated individual decision-making process produces legal effects that concern you or affect you to a significant extent.

  • The right to submit a complaint 

If you have a complaint about how we process your personal data, please contact us so that we can resolve your issue using the following contact details:

Asociația Club Sportiv Polo Singureni 

For the data collected by our partner, please contact them according to their own Policy – see link indicated in section 1.

  • REQUESTS/ COMPLAINTS/ REFERRALS REGARDING PERSONAL DATA

Any requests/ complaints/ referrals regarding personal data shall be addressed in writing, and with the provision of a contact address to which the response/ information related thereto may also be communicated in writing. The same shall apply in the case of requests/ communications related to previous requests/ complaints/ referrals.

When addressing any request/ complaint/ referral, the applicant shall properly identify himself/herself, in order to prevent compromising the data privacy, adopting measures at the request of unjustified/ unauthorized persons or endangering/ violating in any way the rights and legitimate interests of the data subjects in relation to the data to which the request is made.

In the case of requests made by proxy, the proxy shall also be properly identified and its quality checked (including directly from the data subject).

Requests sent by phone or requests in which the only available contact data is the phone number of the data subject will not be considered until they are sent in writing, under the conditions specified above.

If the request is made under conditions that raise a suspicion of the controller as to the identity of the applicant or as to the legality of the request, the controller may suspend the settlement until reasonable additional information/ data is provided in order to confirm the identity and/ or capacity of the applicant.

We subject these requirements to our legal obligation and our legitimate interest in proving compliance with your rights under the GDPR and all legal data protection rules.

The settlement of any request/ referral/ complaint shall be carried out within a reasonable time, but maximum within 30 days of its receipt.

This time limit may be extended by two months when necessary, taking into account the complexity and number of requests, with the reasoned notification of the data subject of the reason for the extension within the 30-day time limit.

The response and/ or any communications required by the specifics of the request shall be sent in writing to the data subject or the processor, in the manner in which the controller has received the request or by other written, express and reasonable way requested, by the data subject/proxy.

The most recent update to this Policy was made in August 2024.

The Privacy Policy is supplemented by the Terms and Conditions and the Cookie Policy.

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