Information on the processing of personal data

Homplex S.A., with registered office in Voluntari, bd. Pipera nr. 1/VII, Building Nord City Tower, et. 7, jud. Ilfov, registered with the Trade Register under no. J23/290/2017, CUI: 32591037, with IBAN account no. RO26 BREL 0002 0008 7865 0100, opened at LIBRA BANK, tel/fax 0234 547840/0374.49.49.49, e-mail: office@homplex.com, represented by Panainte Tudor Gheorghiță, as administrator, hereinafter referred to as HOMPLEX, collects and processes personal data in accordance with the legal provisions on the processing of personal data and the free movement of such data.

The purpose of this notification is to inform you about the purposes of the processing, the legal basis of the processing, the duration of the processing, the recipients of the personal data collected, the modalities of exercising individual rights as well as providing information about the secondary purpose of the processing, if the data will be processed for a purpose other than the one for which they were collected.

Please read this information carefully!

1. Categories of personal data that may be processed by HOMPLEX in the activity of providing services:

Personal identification data (name, surname, address, age, date of birth, gender, telephone, email, ID, nationality, holographic signature and digital signature).

The data are necessary for the valid conclusion and the execution of the contractual relationship with Homplex.

Information on the location, image and audio-video recordings of individuals (video recordings captured by surveillance cameras installed at Homplex premises, audio recordings of telephone calls from the call-center, IP address captured when using the Homplex website and applications).

The data is necessary to ensure security and protection at Homplex premises, to improve the services offered, to resolve complaints and any requests from customers and to ensure the technical functionality of the online platforms used by Homplex).

2. Purpose for which personal data are used

Homplex collects and processes your personal data for the following purposes:

• Provision of services/supply of goods/products that are related to the business, management of contracts, including contract renewals;
• Marketing, for informing and providing loyalty benefits and for the continuous improvement of the quality of services and products offered (sending news, promotions, new products);
• internal reporting;
• statistical analysis;
• handling complaints and requests from customers;
• communications or reports to the relevant state or government authorities, institutions or agencies;
• ensuring the necessary security measures (audio-video surveillance);
• to carry out the mandate/power of attorney granted by the client/potential client in order to mediate the relationship with installers, individuals or companies, etc.
• to recover debts/collect debts;
• carrying out periodic analysis of the clients’ perception of the work carried out and identifying their needs, i.e. the degree of satisfaction with the services provided

3. The legal grounds for processing your data for the purposes mentioned above are:

• the conclusion and execution of the service contract to which you are a party, as well as the performance at your request of the steps prior to the conclusion of the contract;
• a legal obligation of Homplex;
• Homplex’s legitimate interest, for activities such as: performing statistical analysis and reporting internally or to other entities, verifying the integrity and compliance of data subjects, ensuring necessary security measures, etc.
• your consent;
• establishing an initial communication channel, such as contact and interaction forms on the www.homplex.ro website or within Homplex applications.

Refusal by Customers/Partners to transmit personal data to Homplex and/or to allow Homplex to process personal data shall result in the impossibility to provide services/provide goods that are related to Homplex’s core business, including the use of online applications/services.

For the purposes of fulfilling the purposes, namely the transmission of commercial communications for direct marketing purposes that are related to Homplex’s activities or the transmission by Homplex partners of commercial communications for direct marketing purposes that are NOT related to Homplex’s activities, the transmission of your personal data is voluntary.

The lack of your consent for the latter purposes will have absolutely no consequence on the conclusion of the contract.

The mandatory or optional nature of the expression of consent will be specified at the time of data collection.

You have the right to withdraw your consent to the processing of personal data at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent prior to the withdrawal of consent.

4. Categories of recipients to whom personal data collected may be disclosed:

• state authorities (including tax authorities, consumer protection and insurance authorities, state criminal prosecution authorities) as a result of a legal obligation of Homplex;
• suppliers directly/indirectly involved in the sales process (e.g. IT service developers, call centre providers, etc.);
• providers of marketing, market research, customer satisfaction surveys and other similar services;
• intermediaries involved in contract administration;
• Courts or arbitration tribunals, notaries public, lawyers, bailiffs, translation offices, other authorised services, valuation experts;
• Homplex employees

5. Transfer of personal data to a country outside the European Economic Area

Homplex could not transfer personal data to other companies outside the European Economic Area.

6. Storage of personal data

Personal data will be processed at least for the duration of the service contract and subsequently for the time necessary for the performance of the contractual obligations by either party.

Personal data will be stored for as long as necessary for the above-mentioned purposes or for the period of time provided for by the general legal provisions and those applicable in the matter, in accordance with the Archival Nomenclature applicable at Homplex level.

If you consent to processing for marketing purposes, the personal data collected will be kept until you notify us of the withdrawal of your consent for this purpose.

7. Your rights regarding your personal data

In connection with the processing of personal data under the conditions specified in the EU Data Protection Regulation 679/2016 you may exercise any of the following rights:

(a) the right of information and access to personal data 

Allows you to be informed about the processing of personal data, to obtain confirmation from us whether or not HOMPLEX processes personal data concerning you and what such data is processed. If personal data concerning you is not collected from you, we will inform you of any available information about its source, where we do not have a legal prohibition on disclosure of the source.

b) Right to rectification

This involves the right to request that inaccurate or incomplete personal data relating to you be rectified or updated, or completed where incomplete.

c) Right to erasure of data or “right to be forgotten”.

This involves the right to request the deletion of personal data concerning you in certain circumstances, such as:

(i) the personal data are no longer necessary for the purposes for which they were collected or processed,

(ii) your data has been unlawfully processed,

(iii) the processing of the data has taken place on the basis of your consent and your consent has been withdrawn.

d) Right to withdraw your consent

Consent may be withdrawn at any time where the processing of personal data relating to you has been carried out on the basis of your consent.

e) Right to restrict processing

This involves the right to request and obtain the restriction of the processing of personal data concerning you in certain circumstances, such as:

(i) you dispute the accuracy of the data, for as long as it would allow us to verify the accuracy of that data,

(ii) your data have been unlawfully processed and you object to their deletion by requesting restriction of their use.

f) Right to data portability

It implies that you have the right at any time to object, for reasons relating to your particular situation, to the processing of personal data in certain circumstances, such as:

(i) the processing was carried out in our legitimate interest; or

(ii) the processing is for the purpose of direct marketing, including profiling on the basis of those provisions.

h) The right not to be subject to a decision based solely on automated processing of your data, including profiling that produces legal effects or significantly affects you.

It implies that you have the right to request human intervention by Homplex, to express your point of view and to challenge the decision.

i) The right to lodge a complaint with us and/or the competent data protection authority

j) The right to take legal action

k) The right to be notified by Homplex of security breaches that have/may have an impact on your personal data.

To exercise your rights or for further information you may contact the Homplex Data Protection Officer via:

• e-mail at gdpr@homplex.ro,
• by post, at Bd. Pipera, nr.1 / VII, 7th floor, Nord City Tower, Voluntari. or
• by personally submitting a holographically signed notification at any of Homplex’s offices in Bucharest or in the country.

To submit a complaint to the National Authority for the Supervision of Personal Data Processing, contact details are:

Website: http://www.dataprotection.ro/

Email: anspdcp@dataprotection.ro

Adresa: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, cod poștal 010336, Bucuresti, Romania

Telefon fix: +40.318.059.211,+40.318.059.212

Cabinet Președinte: +40.318.059.220; Fax+40.318.059.60

8.Updating the presence of information on the processing of personal data

This information on the processing of personal data is subject to periodic review. In order to be informed of any important changes that may have an impact on the processing of your personal data, please consult the company’s website www.homplex.ro – section “Protection of personal data” regularly.

The most recent update of this information on the processing of personal data was on 01.07.2022.