updated on 03.03.2021
We consider the insurance of the right to protection of personal data as a fundamental commitment of ASUM, therefore we shall assign all resources and efforts necessary in order to process your data in full compliance with the (EU) Regulation 2016/679 (“The General data protection regulation” or “GDPR”), as well as with any other legislation applicable on the Republic of Moldova territory. Since one of the essential principles of this legal framework is represented by transparency, we have prepared this document by means of which we wish to inform you about the manner in which we collect, use, transfer and protect your personal data when you interact with us in relation to various issues, including by means of our website and the apps available for mobile phones.
We reserve the right to update and modify periodically this GDPR Regulation, in order to reflect any changes in the manner in which we process your personal data or any other changes in legal requirements. In case of any such changes, we will display on our website the amended version of the GDPR Regulation, for this reason, we kindly ask you to check periodically the contents of this Confidentiality Policy.
Who we are and how you can contact us
The Association for Urban Safety and Mediation (Asociația pentru Siguranță Urbană și Mediere- hereinafter “ASUM” or “us/we” In the sense of the legislation regarding data protection, we are an operator when we process your personal data.
Since we are always open to find out your opinions, as well as provide you with any additional information you may require with regard to the processing of your data, we encourage you to contact the ASUM Responsible person for data protection at the email address gdpr@asum.md or via post or courier at the address: mun. Edinet, str-la Uzinei, nr 2, mentioning: to the attention of the ASUM Responsible person for data protection.
What personal data categories we process
Generally, we collect your personal data directly from you, so that you have control over the type of information you offer us. As an example, we receive information from you as follows:
When you subscribe to ASUM, you send us: your email address;
We can also collect and process subsequently certain information with regard to your behaviour during your visit on our website in order to personalize your online experience and provide you with offers customized to your profile. We invite you to find out more details in this regard by consulting the section regarding the purposes of the processing of data given below.
On our website we can collect and store information using cookies and similar technologies, according to the Cookies Policy.
We do not collect, nor process in any other manner sensitive data, included through the General Data Protection Regulation in special categories of personal data.
What are the purposes and grounds for the processing of the personal data
We will use your personal data for the following purposes:
1. For providing the ASUM services to your benefit.
We base these activities on our legitimate interest to carry out activities in legitimate interest, always taking take that your fundamental rights and freedoms are not affected.
2. In order to defend our legitimate interests
There can be situations in which we will use or send information in us to protect our rights and our activity. Such situations may include:
– Protective measures for the ASUM website against cybernetic attacks:
– Measures for prevention and detection of fraud attempts, including sending certain information to competent public authorities;
– Measures for managing various other risks.
The general grounds for these types of processing of personal data is our legitimate interest to protect our activity, understanding that we make sure that all the measures we take guarantee a balance between our interests and your fundamental rights and freedoms.
Likewise, in certain cases we base our processing of data on legal provisions such as the obligation to ensure safeguarding of goods and assets provided by the legislation applicable in this field.
How long do we keep your personal data
As a general rule, we will store your personal data as long as you are subscribed to the ASUM newsletter.
In the event you notify us regarding a case or an infringement of your rights, your personal data will be stored until the settlement of the case and for a duration of 5 years after that.
You can request at any time the deletion of certain information or the closing of the account and we will honour such requests, with the specification that we may keep certain information, even after the account has been closed, in situations in which the applicable legislation or our legitimate interests demands such action.
To whom do we send your personal data
Depending on the case, we can send or grand access to certain personal data belonging to you to the following categories of recipients:
- In case a legal obligation arises or if it is necessary in order to defend a legitimate interest of ours, we can also reveal certain personal data to public authorities.
- We make sure that access to your personal data by third party private legal entities is granted in accordance with the legal provisions regarding the protections of data and the confidentiality of information, on the basis of certain contracts concluded therewith.
In what countries do we transfer your personal data
At present, we store and process your personal data on the territory of the Republic of Moldova.
Nevertheless, it is possible that we may transfer certain personal data belonging to you to certain entities located in the European Union or outside the European Union, including to countries for which the European Commission has not recognized an adequate level of personal data protection.
We will always take measures to ensure that any international personal data transfer is managed carefully for the purpose of protecting your rights and interests. Transfers to service providers from other countries and other third parties shall always be protected through contract commitments and, depending on the case, through other guarantees as well, such as standard contract clauses issued by the European Commission or certification guidelines, as well as the Confidentiality Shield for protection of personal data transferred from inside the EU to the United States of America.
You can contact us at any time, using the contact information listed above, in order to find out more information about the countries in which we transfer your data, as well as the guarantees we have applied with regard to these transfers.
How do we protect the safety of your personal data
We undertake to ensure the safety of your personal data by implementing adequate technical and organizational measures, according to the industry standards.
The transmission of your personal data is done using the latest generation encryption algorithms and we store them on secured servers, ensuring at the same time the redundancy of the data.
Despite all measures taken to protect your personal data, we draw your attention to the fact that sending information via the Internet, in general, or via other public networks, is not completely safe, existing the risk that the data could be seen and used by unauthorized third parties. We cannot be responsible for such vulnerabilities of certain systems that are not under our control.
What rights you have
The general regulation regarding data protection acknowledges a series of your rights in connection with your personal data. You can request access to your data, correction of any errors in our records and/or you can object to the processing of your personal data. Also, you can exercise your right to submit a complaint before the competent supervisory authority or to address a court of law. Depending on the case, you can also benefit from the right to request the deletion of your personal data, the right to restrict processing of your data and the right to portability of your data.
More information about each of these rights can be obtained by consulting the table given below.
In order to be able to exercise your rights, you can contact us using the contact details given above. Please keep in mind the following aspects if you wish to exercise these rights:
Identity. We take seriously the confidentiality of all records that contain personal data. For this reason, we kindly ask that you send us your requests regarding such records by using the email address corresponding to the ASUM account. Otherwise, we reserve the right to verify your identity by requesting additional information with the purpose of confirming your identity.
Fees. We will not request a fee in order for you to exercise any right with regard to your personal data, except in the case in which your request to access the information is unfounded, repetitive or excessive respectively, in which case we will charge a reasonable fee in such circumstances. We will inform you about any fees applied before answering your request.
Response time. We strive to answer any valid requests in within a maximum one-month deadline, except for the case in which such action is specifically complicated or if you have made several requests, in which case we will answer within maximum 30 days. We will inform you if we need more than one month. We may ask you if you can tell us exactly what you wish to receive or what it is exactly that concerns you. This will help us act faster and shorten the response time for your request.
Third party rights. We do not have to honour a request if it will negatively impact the rights and freedoms of other targeted parties.
| Targeted rights | Description |
| Access | You can request us: to confirm if we are processing your personal data; to provide you a copy of such data; to offer you other information about your personal data, such as the what data we have in our possession, what we use them for, who we disclose them to, if we transfer them abroad and how we protect them, how long we keep them, what rights you have, how you can file a complaint, where we obtained your data, to the extent to which such information have not already been provided by means of this notice. |
| Correction | You can ask us to correct or supplement your personal data that are inexact or incomplete. It is possible that we may attempt to verify the accuracy of the data before correcting them. |
| Deletion of the data | You can ask us to delete your personal data, but only in the following cases: they are no longer required for the purposes for which they have been collected; or you have withdrawn your consent (in case the processing of the data was based on your consent); or you are exercising a legal right to opposition; or they have been processed illegally; or a legal obligation in this sense is in our charge. We do not have the obligation to comply with your request to delete your personal data if the processing of your personal data is required: for compliance with a legal obligation; or for acknowledging, exercising or defending a right in court. There are other specific circumstances in which we are not obligated to comply with your request to delete the data, although the two mentioned above are the most probable circumstances in which we could refuse such request. In case you do not make such proceeding before exercising your right to deletion, you will lose all such documents, and ASUM will be in the impossibility of providing them to you, depending on the case, because the process of deleting the data, with all the data and documents related thereto, is an irreversible process. |
| Restriction of the data processing | You can ask us to restrict the processing of your personal data, but only in the following cases: their accuracy is being brought into question (please see the correction section), in order to allow us to verify the accuracy thereof; or the processing is illegal, but you do not wish the data to be deleted; or they are no longer required for the purposes for which they have been collected, but you need them in order to acknowledge, exercise or defend a right in court; or you have exercised your right of opposition and the process of verifying if our rights prevail is undergoing. We can continue to use your personal data following a restriction request, in the following cases: we have your consent to do so; or to acknowledge, exercise or defend a right in court; or to protect the rights of ASUM or of another natural person or legal entity. |
| Portability of the data | You can ask us to provide you the personal data in a structured format, commonly used and that can be read automatically, or you can request that they be “ported” directly to another data operator, but for each case only if: the processing is based on you consent or on the conclusion or the performance of a contract signed with you; and the processing is done via automatic means. |
| Opposition | You can object at any time, for reasons related to the particular situation you find yourself in, to the processing of your personal data on the grounds of our legitimate interest, in case you consider that your fundamental rights and freedoms prevail over such interest. Likewise, you can object at any time to the processing of your personal data for the purpose of direct marketing (including the creation of profiles), without invoking any reason therefor, in which case we will cease such processing as soon as possible. |
| Making automatic decisions | You can request us to not make you the object of a decision based exclusively on automatic processing, nut only when such decision: generates legal effects with regard to yourself; or it affects you in a similar manner and to a significant extent. This right does not apply if the decision reached following automatic decision making: is necessary in order to finalize or perform a contract concluded with you; is authorized by law and there are adequate guarantees for your rights and freedoms; or is based on your explicit consent to do so. |
| Complaints | You have the right to submit a complaint with the National Centre for Personal Data Protection with regard to the processing of your personal data. In the Republic of Moldova, the contact information for the National Centre for Personal Data protection are as follows: the municipality of Chișinău, str. Serghei Lazo no. 48, MD-2004, The Republic of Moldova, Telephone: +373 22 820 801; E-mail: centru@datepersonale.md without any prejudice to your right to contact at any time the National Centre, we kindly ask you to contact us beforehand and we promise that we will make all efforts necessary to resolve any issues amiably. |
