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Personal Data Protection
This Privacy Policy defines how we, TEMPO CONSULT SRL, collect, store, and use your personal data when you access or interact with our website www.moto24.ro, and where we obtain or collect your data.
This Privacy Policy is applicable from May 23, 2018.
Summary
Details about our company
What information we collect when you visit our website
What information we collect when you contact us
What information we collect when you interact with our website
What information we collect when you place an order on our website
Use of automated decision-making systems
How we collect information about you from third parties
Disclosure and additional uses of your data
Retention of your data
Securing your information
Transfer of your data outside the European Economic Area
Your rights regarding personal data
Your right to object to data processing for certain purposes
Sensitive personal data
Changes to our privacy policy
Privacy of minors
Copyright
This section summarizes how we obtain, store, and use your data. This summary aims only to provide a general overview of the privacy policy. It is not a complete description, and reading the additional sections in this document is necessary for full details.
Data Controller: TEMPO CONSULT SRL
How we collect or obtain information about you:
When you provide the data (e.g., by contacting us, accessing, ordering, or purchasing various services and products from Tempo Consult, completing the offer request form, creating an account on the site, subscribing to the company’s database to receive marketing information about our services and products, filling out online or offline forms to register for advertising lotteries and events (e.g., fairs), completing the form to issue a loyalty card);
When you access our site, some data is collected via cookies; and
From third parties: tour operators and resellers.
What information we collect:
Name, surname, phone number, home address, email address, IP, company name (if applicable), VAT registration number (if applicable).
How we use your data:
For business and administrative purposes (especially to contact you and process orders you place on our website), to fulfill our contractual obligations, to promote our goods and services, and in connection with our legal rights and obligations.
Disclosure of user data to third parties:
Minimum necessary to fulfill our contractual obligations to you for business operations, to comply with legal obligations.
Your data is not sold to third parties.
How long your information is stored:
No longer than necessary – depending on our legal obligations (e.g., to maintain accounting records), or based on any other grounds we use the information (e.g., consent, contractual obligations, legitimate interests).
Specific information on the retention periods of user data is in the "Retention of Your Data" section.
How your data is secured:
Using technical and organizational solutions such as:
Storing information on secure servers
Encrypting data transfers using SSL technology
Encrypting payment transactions
Allowing access to your personal data only when necessary
Pseudonymization and/or anonymization
Use of cookies and similar technologies:
We use cookies and similar technologies, such as web beacons, including essential, functional, analytical, and targeting cookies.
More information: Cookie Policy
Transfer of your personal data outside the European Economic Area:
This occurs only when required by law or for contractual obligations.
When this occurs, we ensure protective measures, such as standard contractual clauses for non-EU partners.
Use of automated decision-making processes:
We use such systems via:
Web Analytics
Cookies and web beacons
Targeted advertising (e.g., Google AdSense)
Your rights regarding your personal data:
Right to access your data and receive information
Right to rectification (correction/completion)
Right to erasure ("right to be forgotten")
Right to restrict data use
Right to data portability
Right to object to processing
Right to withdraw consent
Right to lodge a complaint with a supervisory authority
Sensitive personal information:
We may collect "sensitive personal data", such as union membership.
More details: See section "Sensitive Personal Information."
Details about Our Company
Data controller: TEMPO CONSULT SRL,
Address: Str. 13 Decembrie 31, Brașov, Romania
Email: dpo@moto24.ro
What Information We Collect When You Visit Our Website
Web Server Log Information
Hosting provider: DATACORE SOLUTION SRL
Privacy policy: Namebox Privacy
Information collected:
IP address
Pages accessed
Requested information
Date and time
Referring URL
Browser and OS version
Use of Web Server Log Information for IT Security Purposes
Used for:
Network security
Identifying unauthorized access
DDoS prevention
Cyberattack detection
If not investigating, we do not attempt to identify you.
Legal Basis for Processing: Article 6(1)(c) GDPR – Legal obligation
Article 32(1) GDPR – Technical security measure
Cookies and Similar Technologies
Used: Essential, functional, analytical, targeting cookies, web beacons
Manage cookies: browser settings or cookie control tool
More info: Cookie Policy
Guide: www.allaboutcookies.org
Information We Collect When You Contact Us
Collected: Email address, name, phone number, signature info
Legal Basis:
Legitimate interests (Art. 6(1)(f) GDPR)
Contractual necessity (Art. 6(1)(b) GDPR)
Transfer and Storage of Your Information
Provider: Microsoft - Office 365
Privacy: Microsoft Privacy
Stored in: Austria, inside the European Economic Area
Contact Form
Collected: Name, surname, email, phone number, other comments
If required fields are missing, form cannot be submitted.
Legal Basis:
Legitimate interests (Art. 6(1)(f))
Contractual necessity (Art. 6(1)(b))
Storage:
Phone
Collected: Phone number, details from the conversation
Calls are recorded.
Legal Basis:
Legitimate interests (Art. 6(1)(f))
Contractual necessity (Art. 6(1)(b))
Processed by: Orange Romania
We collect all information contained in your postal communication.
Legal Basis:
Legitimate interests (Art. 6(1)(f))
Contractual necessity (Art. 6(1)(b))
Reason Necessary for the Performance of a Contract: If your message concerns the provision of goods or services or taking action upon your request before providing the goods and services to you (e.g., providing information about such goods and services); we will process your information to do so.
Information We Collect When You Interact with Our Website
We collect and use data from individuals who interact with certain features of our website, in accordance with this section and the section titled "Disclosure and Additional Uses of Your Information."
Newsletter
When you sign up for our newsletter to receive information about promotions, events, or contests from us via subscription forms or any other form where you can express consent to be added to our database, we collect your first name, last name, and email.
Legal Basis for Processing: Your consent (Article 6, paragraph 1, letter (a) of the General Data Protection Regulation).
Consent: You give your consent to receive our newsletter by signing up to receive it, following the steps described above.
Transfer and Storage of Your Data
We use a third-party service to send our newsletter and manage our email list, MailChimp. Their privacy policy is available here: https://mailchimp.com/legal/privacy/. The information you submit to subscribe to our newsletter will be stored within the European Economic Area on the servers of our provider.
Use of Web Beacons and Similar Technologies in Emails
We use technologies like web beacons (small graphic files) to measure the performance of our emails, such as delivery rates, open rates, click rates, and unsubscribe rates, and the links with which the client interacted. We will use web beacons to measure interactions in a newsletter.
For more information on how we use web beacons in our newsletters, consult our cookie policy, available here: https://www.moto24.ro/pagini-utile/politica-cookie-uri.html. For more information about our newsletter providers and the use of web beacons, consult their privacy policy here: https://mailchimp.com/legal/privacy/.
Registration on Our Website
When you register and create an account on our website, we collect the following information: first name, last name, email address, phone number. If you do not provide all the required information in the registration form, you will not be able to register or create an account on our website.
Legal Basis for Processing: Our legitimate interests (Article 6, paragraph 1, letter (f) of the General Data Protection Regulation).
Legitimate Interest: To register and manage accounts on our website, allowing you to access your purchase history, invoices, and product preferences list.
Transfer and Storage of Your Data
The information you provide through the registration form on our website will be stored within the European Economic Area on the servers of our web hosting service provider, Datacore Solution SRL from Romania. Their privacy policy is available here: https://www.prologue.ro/servicii/hosting/.
Information We Collect When You Place an Order on Our Website
We collect and use information from individuals who place an order on our website in accordance with this section and the section titled "Disclosure and Additional Uses of Your Information."
Information Collected When You Place an Order
Required Information
When you place an order for goods or services on our website, we collect: first name, last name, email, phone number, billing address, company name (if applicable), tax identification number, and company registration number in the Commercial Register.
If you do not provide this information, you will not be able to purchase our goods or services on our website or enter into a contract with us.
Legal Basis for Processing: Necessary for the performance of a contract (Article 6, paragraph 1, letter (b) of the General Data Protection Regulation).
Reason Necessary for the Performance of a Contract: We need the mandatory information collected through our verification form to establish who the contracting party is and to contact you to fulfill our obligations under the contract, including sending receipts and order confirmations.
Legal Basis for Processing: Compliance with a legal obligation (Article 6, paragraph 1, letter (c) of the General Data Protection Regulation).
Legal Obligation: We have a legal obligation to issue an invoice for the goods and services you have purchased from us, in which you are registered for VAT purposes, and we request the mandatory information collected for this purpose via our payment form.
Optional Information
We also ask for your consent if you wish to receive marketing communications from us. For more information, see the "Marketing Communications" section below.
Legal Basis for Processing: Our legitimate interests (Article 6, paragraph 1, letter (a) of the General Data Protection Regulation).
Legitimate Interest: You agree to process any optional information you provide by submitting it to us, so that you can stay informed about our offers and services.
Marketing Communications
At checkout, you will have the option to receive marketing communications from us.
Transfer and Storage of Your Data
We use a third-party service to manage our email list: MailChimp. The information you submit to subscribe to our newsletter will be stored within the European Economic Area on the email list provider’s servers in Romania.
Use of Web Beacons and Similar Technologies in Emails
We use technologies like web beacons (small graphic files) to evaluate the performance of our emails, such as delivery rates, open rates, and click rates.
For more information on how we use web beacons in our emails, consult our cookie policy, available here: https://www.moto24.ro/pagini-utile/politica-cookie-uri.html.
Our Goods and Services
You can sign up to receive marketing communications from us about our goods and services via email, text message, phone, and mail by completing the form and checking the box indicating that you wish to receive such communications.
We will send you marketing communications about our goods and services only if you sign up to receive them.
Legal Basis for Processing: Consent (Article 6, paragraph 1, letter (a) of the General Data Protection Regulation).
Consent: You give your consent to receive information about our goods and services by signing up to receive such information in accordance with the steps described above.
Information Collected or Obtained from Third Parties
This section outlines how we obtain or collect information about you through third parties.
Information Received from Third Parties
In general, we receive information about you from third parties. These third parties are typically group companies, affiliates, business partners, or individuals purchasing our services (and) on your behalf. It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
The information we receive from third parties usually includes your name and contact details, but it may include any additional information about you that is provided to us.
Legal Basis for Processing: Necessary for the performance of a contract or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason for necessity: If a third party has shared information about you (such as your name and email address) for the purpose of providing you services, we will process that information to take steps at your request to enter into a contract with us.
Legal Basis for Processing: Consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: If you have requested a third party to disclose information about you to us for purposes unrelated to fulfilling a contract or service, we will process the information based on your consent, granted by requesting the third party to provide the information to us.
Legal Basis for Processing: Legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: If a third party discloses information about you to us without your consent, we may process this information under certain circumstances to pursue our legitimate interests.
For instance, we may have a legitimate interest in processing your information to fulfill obligations arising from a subcontract with the third party if that third party has the main contract with you. Our legitimate interest is in fulfilling our obligations under the subcontract.
Similarly, third parties may share information about you with us if you have breached or may breach any of our legal rights. In such cases, we have a legitimate interest in processing this information to investigate and pursue any potential breach.
If We Receive Information About You in Error
If we receive information about you from a third party in error and/or lack a legal basis for processing such information, we will delete your information.
Information Obtained by Us from Third Parties
In certain circumstances (e.g., to verify information we hold about you or to obtain missing information necessary to provide you with a service), we may obtain your data from publicly available sources both within and outside the EU, such as public institutions or authorities.
In some cases, we may also obtain information about you from private sources both within and outside the EU, such as insurance companies. These data will only be processed with your explicit consent.
Legal Basis for Processing: Necessary for the performance of a contract or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason for necessity: If you have entered into a contract with us or requested us to enter into a contract with you, we may obtain information from public sources to understand your business and deliver services to a satisfactory standard. For example, we may obtain and/or verify your email address from your website if you request us to send information via email and we lack or need confirmation of your email address.
Legal Basis for Processing: Legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: In some circumstances, we have a legitimate interest in obtaining information about you from public and private sources. For example, if you have breached or are suspected of breaching any of our legal rights, we have a legitimate interest in obtaining and processing information from these sources to investigate and pursue any suspected or potential breach.
Legal Basis for Processing: Consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: We may obtain information from third parties if you have agreed to have such data shared with us, e.g., by checking a box indicating that you want your information shared with us.
Use of Automated Decision-Making Mechanisms
We use automated decision-making mechanisms on our website. We do not believe this has a legal or similar effect on you.
You have the right to object to our use of automated decision-making and profiling as described in this section. You can do so by opting out of cookies and similar technologies as explained in the relevant section of this privacy policy. If you do not want us to process your actual IP address (usually assigned by your Internet Service Provider), you can use a virtual private network (VPN) or a free service like Tor.
You can learn more about the use of cookies and similar technologies (including the legal basis for their use) and how to opt-out in our cookie policy, available here: Cookie Policy.
Automated Decision-Making Mechanisms
Automated decision-making mechanisms are processes of decision-making through technological means (via a machine) without human involvement.
Disclosure and Additional Use of Your Data
This section outlines the circumstances in which we will disclose your data to third parties and any additional purposes for which we use your data.
For Service Providers
We use a range of third parties to provide services necessary to operate our business or to assist us in conducting our business. These include:
• Telephone service providers
• Email service providers
• IT service providers
• Website developers
• Web hosting service providers
• Marketing service providers
• Email marketing service providers
Your information will be shared with these service providers where necessary to deliver the service you requested, whether accessing our website or ordering goods and services from us.
Independent Contractors
We occasionally engage independent contractors in our business. Your information will only be shared with independent contractors if necessary for them to perform the service we have contracted them to provide in connection with our business.
Insurers
We will disclose your information to our insurers when necessary, for example: if you choose an insurance system when purchasing a product or afterward, in relation to a claim or potential request we receive/make, or to meet our general disclosure obligations under our insurance agreement.
Our insurers are located in Romania.
• Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
• Legitimate interest: effective operation and management of our business.
• Legal basis for processing: necessity for the performance of a contract (or to take steps at your request before entering into a contract) (Article 6(1)(b) of the GDPR).
• Reason for necessity: we need to share information with third parties (partners, insurers, etc.) to fulfill our contractual obligations to you or to take steps at your request before entering into a contract.
We do not disclose the identities of all third parties with whom we may share information for security reasons and to maintain a competitive advantage. If you would like additional information about such third parties, please contact us directly through the contact form at https://www.moto24.ro/agentii/ or via email at secretariat@Tempo Consult.ro. We will provide this information if you have a legitimate reason and only if we have shared your data with such third parties.
We will disclose your information to a potential or actual buyer or seller in the context of a business sale or purchase, merger, or similar actual or potential event.
• Legal basis for processing: legitimate interests (Article 6(1)(f) of the GDPR).
• Legitimate interest: enabling access to information for a potential buyer, seller, or similar entity to facilitate such a transaction.
Disclosure and Use of Your Information for Legal Reasons
• Reporting suspected criminal activity or threats to public safety to competent authorities:
If we suspect criminal or potentially criminal behavior, we may need to contact a competent authority, such as the police. For instance, if we suspect fraud, cybercrime, or receive threats or malicious communications involving us or third parties. Processing your information for this purpose will generally only occur if you have been involved or affected by such an incident in some way.
o Legal basis for processing: our legitimate interests (Article 6(1)(f) of the GDPR).
o Legitimate interest: crime prevention or suspected criminal activity (such as fraud).
• Enforcement or potential enforcement of our legal rights:
We may use your information in connection with enforcing or potentially enforcing our legal rights, including sharing information with debt collection agencies if you fail to pay amounts owed under your contractual obligations. Our legal rights may be contractual (if we have entered into a contract with you) or non-contractual (e.g., copyright or tort law).
o Legal basis for processing: our legitimate interests (Article 6(1)(f) of the GDPR).
o Legitimate interest: enforcing our legal rights and taking steps to ensure such rights.
• Litigation or legal proceedings:
Your information may be used if we are involved in a dispute with you or a third party, such as resolving the dispute, mediation, arbitration, or similar legal processes.
o Legal basis for processing: our legitimate interests (Article 6(1)(f) of the GDPR).
o Legitimate interest: dispute resolution or handling potential disputes.
• Compliance with laws and regulations:
We will use and process your information to comply with legal obligations. For instance, it may be necessary to disclose information under a court order or subpoena.
o Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the GDPR).
o Legal obligation: obligations established by national or international laws (e.g., international agreements signed by Romania).
o Legal basis for processing: our legitimate interests (Article 6(1)(f) of the GDPR).
o Legitimate interest: compliance with obligations that are part of another country's laws not incorporated into Romania's legal framework.
Data Retention Period
This section outlines how long we retain collected data, specifying periods where possible or criteria for determining retention.
• Server logs: retained for 6 months.
• Order information: retained for six years after the financial year in which the order was placed, as required for tax purposes.
• Correspondence: retained as necessary or until you explicitly request deletion, in compliance with our legal obligations.
• Newsletter: retained while you remain subscribed or until we discontinue the service.
Criteria for Retention
Information will be retained only as long as necessary, considering:
• The purpose and use of the information now and in the future.
• Legal obligations to retain records.
• Basis for continued processing (e.g., your consent).
• Legitimate interests for continued processing.
• Risks, costs, and responsibilities involved in retaining the information.
Protecting Your Information
We implement technical and organizational measures to safeguard your information, including:
• Minimizing data sharing and access, with confidentiality restrictions where applicable.
• Using secure servers for storage.
• Identity verification before granting access.
• SSL encryption for website forms.
• Secure systems for data transfer.
Email Information Transmission
Information sent via the internet is not entirely secure. Sending information to us through such means is at your own risk, and we are not liable for any loss or damage resulting from your choice to transmit information.
Data Transfers Outside the European Economic Area
Your data will not be transferred outside the EEA.
• Safeguards: Contractual clauses for transferring personal data from the EU to third countries per GDPR Article 46(2)(c).
Your Rights Regarding Personal Data
Subject to certain restrictions, you have rights regarding your data, including access, correction, deletion, restriction, data portability, and objection to certain processing purposes. You can also withdraw consent for processing based on your prior consent.
For further information or assistance exercising your rights, contact:
https://www.moto24.ro/pagini-utile/panou-control-gdpr.html or email dpo@moto24.ro.
