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PERSONAL DATA PROCESSING POLICY
AG DIGITAL PEOPLE S.R.L. (the “Company” or “AG DIGITAL PEOPLE” or AG MEDIA SPACE “we”, “us”, “our”) is a limited liability company having its registered seat in Romania, Agigea, 71 Traian Vuia Street, room no. 3, department of Constanta, registered with the Trade Registry under number J13/1571/01.07.2020, sole registration code 42715639. We provide digital marketing services, such as email marketing, content marketing, social media marketing, paid advertising, pay per click (PPC) (the “Services”) to our clients.
This Privacy Policy (the “Policy”) explains how the Company uses the Personal Data we collect.
We are fully committed to processing the personal data of individuals in compliance with the legal norms in force in Romania, as well as with the principles laid out in the 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 (“General Data Protection Regulation” or “GDPR”).
In reaching this objective, we intend to collect, use and maintain the personal data of data subjects in the strictest compliance with the data protection requirements.
This Policy explains how we may collect, use, store and / or disclose personal data or information about data subjects and describes the rights you may have as data subject, in respect of your own personal information.
“Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal data may also include “special categories of personal data” from which we can determine or infer, or which directly refer to an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
We will only collect special category of data if it is strictly necessary for one of the purposes described below.
We may process the following types of Personal Data:
We may receive your Personal Data when:
We may process your Personal Data on the basis of:
The Company acts a data processor, for the Personal Data we process for our customers when providing our services. This means that our customers determine the type of Personal Data they provide for us to process on their behalf. We typically have no direct relationship with the individuals whose Personal Data we receive from our customers.
We process your Personal Data following the principles below:
(a) | processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); |
(b) | collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; (‘purpose limitation’); |
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(c) | adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’); |
(d) | accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’); |
(e) | kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; (‘storage limitation’); |
(f) | processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’). |
We may process your Personal Data for the purposes of:
When the purposes of processing are satisfied, we will delete the related Personal Data within one year.
We may share Personal Data with our service providers, who process Personal Data on our behalf, and who agree to use the Personal Data only to assist us in providing our Services or as required by law. Our service providers may provide:
We may disclose your Personal Data (i) where this is necessary for the purposes described under this Policy; (ii) if required by the applicable law; (iii) in connection with a reorganization or merger of our Company with another company; (iv) if we believe that such disclosure is necessary to enforce or apply terms of engagement or other agreements or otherwise protect or defend the Company’s rights, property or safety; (v) in order to comply with a judicial proceeding, court order or other legal obligation, or regulatory or government inquiry; (vi) with your consent; (vii) if necessary for a task carried out in the public interest. If we have to disclose your Personal Data to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of your Personal Data.
For the avoidance of doubt, we reserve the right to use, transfer, sell, and share aggregated, anonymous data, (which does not include any Personal Data) about individuals whose Personal Data we process in connection with providing our Services, for any legal business purpose. These purposes may include analysing usage trends or seeking compatible advertisers, sponsors, and customers.
The Company is a Romanian entity which may have, on occasion, global connections. As a result, your Personal Data may be transferred outside the country of origin (which includes transfers outside the European Economic Area) and may be accessed by third parties.
We are committed to taking all necessary safety and legal precautions to ensuring the safety and integrity of Personal Data which is being transferred to third entities, outside the EU, EEA or to countries not recognized as having an adequate data protection by the European Commission.
A comprehensive list of States situated outside the EU or EEA which have been deemed by the European Commission as having an adequate level of data protection may be assessed at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.
Our Company would like to make sure that you are fully aware of all your data protection rights. Each user is entitled to the following:
A “cookie” is a small file stored on your device that contains information about your device. We may use cookies to provide basic relevant ads, website functionality, authentication (session management), usage analytics (web analytics), and to remember your settings, and generally improve our websites and Services.
We use session and persistent cookies. Session cookies are deleted when you close your browser. Persistent cookies may remain even after you close your browser, but always have an expiration date. Most of the cookies placed on your device through our website are first-party cookies, since they are placed directly by us. Other parties, such as Google, may also set their own (third-party) cookies through our website/Services. Please refer to the policies of these third parties to learn more about the way in which they collect and process information about you.
If you would prefer not to accept cookies, you can change the setup of your browser to reject all or some cookies. Note, if you reject certain cookies, you may not be able to use all of our website’s features. For more information, please visithttps://www.aboutcookies.org/.
You may also set your browser to send a Do Not Track (DNT) signal. For more information, please visithttps://allaboutdnt.com/. Please note that our website do not have the capability to respond to “Do Not Track” signals received from web browsers.
We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect Personal Data from unauthorized processing. This includes unauthorized access, disclosure, alteration, or destruction.
If we make any material change to this Policy, we will post the revised Policy to this web page. We will also update the effective date. By continuing to use our Services or website after we post any of these changes, you accept the modified Policy.
If you have any questions about this Policy or our processing of your Personal Data, please write by email at adela@ag-digitalpeople.com.
If you wish to report a complaint or you feel that our Company has not addressed your concern in a satisfactory manner, you may contact the National Supervisory Authority for the Processing of Personal Data (e-mail anspdcp@dataprotection.ro, telephone +40.318.059.211).
Welcome to our website. This site is maintained as a service to our customers. By using this site, you agree to comply with and be bound by the following terms and conditions of use.
This Term and Conditions agreement (“the “Agreement”) specifies the Terms and Conditions for access to and use of AG – MEDIA SPACE (AG – DIGITAL PEOPLE) (the “Website” or “Site”) and describe the terms and conditions applicable to your access of and use of the Website. This Agreement may be modified at any time by AG – MEDIA SPACE (AG – DIGITAL PEOPLE) upon posting of the modified Agreement. Any such modifications shall be effective immediately. You can view the most recent version of these terms at any time at the Website. Each use by you shall constitute and be deemed your unconditional acceptance of this Agreement.
Your visit to our site is also governed by our Privacy Policy. Please review our Privacy Policy at the Website.
All content included on this site is and shall continue to be the property of AG – MEDIA SPACE (AG – DIGITAL PEOPLE) or its content suppliers and is protected under applicable copyright, patent, trademark, and other proprietary rights. Any copying, redistribution, use or publication by you of any such content or any part of the Website is prohibited, except as expressly permitted in this Agreement. Under no circumstances will you acquire any ownership rights or other interest in any content by or through your use of this Website.
This site is intended for teenagers and adults only. This site is not intended for any children under the age of 13.
The name AG – MEDIA SPACE (AG – DIGITAL PEOPLE), logos, domain names, service marks, and any other distinctive brand features are either trademarks or registered trademarks of AG – MEDIA SPACE (AG – DIGITAL PEOPLE). Other product and company names mentioned on this Website may be trademarks of their respective owners.
AG – MEDIA SPACE (AG – DIGITAL PEOPLE) grants you a limited, revocable, nonexclusive license to use this site solely for your own personal use and not for republication, distribution, assignment, sublicense, sale, preparation of derivative works, or other use. You agree not to copy materials on the site, reverse engineer or break into the site, or use materials, products or services in violation of any law. The use of the Website is at the discretion of AG – MEDIA SPACE (AG – DIGITAL PEOPLE), and AG – MEDIA SPACE (AG – DIGITAL PEOPLE) may terminate your use of the Website at any time.
You must establish a profile to use many features on AG – MEDIA SPACE (AG – DIGITAL PEOPLE) and may be required to enter information such as a username and password, name, date of birth, gender, email address, zip code, and country. You (“User”) are fully responsible for maintaining the confidentiality of the username and password, and for all activities that occur under that username. All users agree to (a) immediately notify AG – MEDIA SPACE (AG – DIGITAL PEOPLE) of any unauthorized use of their username or password or any other breach of security, and (b) ensure that they exit from their account at the end of each session. AG – MEDIA SPACE (AG – DIGITAL PEOPLE) cannot and will not be liable for any loss or damage arising from failure to comply with this Agreement.
The site contains hyperlinks to other Internet sites and services not under the editorial control of AG – MEDIA SPACE (AG – DIGITAL PEOPLE). These hyperlinks are not expressed or implied endorsements or approvals by AG – MEDIA SPACE (AG – DIGITAL PEOPLE) of any products, services or information available from these third-party sites.
All content from these links or sites is the sole responsibility of those third parties, and AG – MEDIA SPACE (AG – DIGITAL PEOPLE) is not responsible for the accuracy or details of those third-party sites. Any information published by AG – MEDIA SPACE (AG – DIGITAL PEOPLE) pertaining to these sites or services is believed to be accurate at the time of publication but should be verified independent of this Website.
AG – MEDIA SPACE (AG – DIGITAL PEOPLE) may receive a fee and/or other compensation on some clicks or purchases made on or linked through this website, through an arrangement it has with a third party if you (i) click on certain links on our site, emails or newsletters, or (ii) purchase a product or service after clicking a link.
AG – MEDIA SPACE (AG – DIGITAL PEOPLE) does not directly sell or license any of the products related to the third-party websites or links, and AG – MEDIA SPACE (AG – DIGITAL PEOPLE) disclaims any responsibility for or liability related to them. AG – MEDIA SPACE (AG – DIGITAL PEOPLE) does not supervise contact between Users and third parties. Information you share with third party websites should be limited consistent with our Privacy Policy, and AG – MEDIA SPACE (AG – DIGITAL PEOPLE) is not responsible for financial or payment details based on any activity between the User and a third party.
You agree to comply with all applicable laws regarding your use of the Website. You further agreed that the information provided by you is truthful and accurate to the best of your knowledge.
Users agree not to: (a) upload, post, email, transmit or otherwise make available any content that is unlawful, harmful, threatening, abusive, harassing, tortious, defamatory, vulgar, obscene, libelous, invasive of another’s privacy, hateful, or racially, ethnically or otherwise objectionable; (b) harm minors in any way; (c) impersonate any person or entity, guide or host, or falsely state or otherwise misrepresent your affiliation with a person or entity; (d) forge headers or otherwise manipulate identifiers in order to disguise the origin of any content transmitted through the Website; (e) upload, post or otherwise make available any content that you do not have a right to make available under any law or under contractual or fiduciary relationships (such as inside information, proprietary and confidential information learned or disclosed as part of employment relationships or under nondisclosure agreements); (f) upload, post or otherwise make available any content that infringes any patent, trademark, trade secret, copyright or other proprietary rights of any party; (g) upload, post or otherwise make available any material that contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment; (h) interfere with or disrupt the Website or servers or networks connected to the Website.
AG – MEDIA SPACE (AG – DIGITAL PEOPLE) reserves the right to suspend or delete your account if you fail to comply with any of the provisions of this Agreement.
You agree to indemnify, defend and hold AG – MEDIA SPACE (AG – DIGITAL PEOPLE) and our partners, employees, and affiliates, harmless from any liability, loss, claim and expense, including reasonable attorney’s fees, related to your violation of this Agreement or use of the Site.
The information on this site is provided on an “as is,” “as available” basis. You agree that use of this site is at your sole risk. AG – MEDIA SPACE (AG – DIGITAL PEOPLE) disclaims all warranties of any kind, including but not limited to any express warranties, statutory warranties, and any implied warranties of merchantability, fitness for a particular purpose, and non-infringement. To the extent your jurisdiction does not allow limitations on warranties, this limitation may not apply to you. Your sole and exclusive remedy relating to your use of the site shall be to discontinue using the site.
Under no circumstances will AG – MEDIA SPACE (AG – DIGITAL PEOPLE) be liable or responsible for any direct, indirect, incidental, consequential (including damages from loss of business, lost profits, litigation, or the like), special, exemplary, punitive, or other damages, under any legal theory, arising out of or in any way relating to the site, your site use, or the content, even if advised of the possibility of such damages. This includes any potential damages arising from contact with other parties through this site. Your sole remedy for dissatisfaction with the site and/or content is to cease all of your site use.
You may have additional rights under certain laws (including consumer laws) which do not allow the exclusion of implied warranties or the exclusion or limitation of certain damages. If these laws apply to you, the exclusions or limitations in this Agreement that directly conflict with such laws may not apply to you.
AG – MEDIA SPACE (AG – DIGITAL PEOPLE) reserves the right, and you authorize us, to use and assign all information regarding Site uses by you and all information provided by you in any manner consistent with our Privacy Policy.
If you believe your work has been copied in a way that constitutes copyright infringement, or your intellectual property rights have otherwise been violated, please provide a notice containing all of the following information via email to adela@ag-digitalpeople.com
(a) An electronic or physical signature of the person authorized to act on behalf of the owner of the copyright or other intellectual property interest;
(b) A description of the copyrighted work that you claim has been infringed;
(c) A description of where the material that you claim is infringing is located on the Site;
(d) Your address, telephone number, and e-mail address;
(e) A statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law; and
(f) A statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the copyright owner or authorized to act on the copyright owner’s behalf.
You agree to the laws of Romania, without regard to conflicts of laws provisions, will govern these Terms and Condition and any dispute that may arise between you and AG – MEDIA SPACE (AG – DIGITAL PEOPLE) or its affiliates. You also agree that the courts of Constanta will have sole and exclusive jurisdiction to hear or determine any dispute or controversy arising under or concerning this Agreement.
If any provision of this Agreement shall be adjudged by any court of competent jurisdiction to be unenforceable or invalid, that provision shall be limited or eliminated to the minimum extent necessary so that this Agreement will otherwise remain in full force and effect.
The failure of AG – MEDIA SPACE (AG – DIGITAL PEOPLE) to exercise or enforce any right or provision of this Agreement shall not operate as a waiver of such right or provision. Any waiver of this Agreement by AG – MEDIA SPACE (AG – DIGITAL PEOPLE) must be in writing and signed by an authorized representative of AG – MEDIA SPACE (AG – DIGITAL PEOPLE).
AG – MEDIA SPACE (AG – DIGITAL PEOPLE) may terminate this Agreement at any time, with or without notice, for any reason.
Nothing contained in this Agreement or your use of the Site shall be construed to constitute either party as a partner, joint venture, employee or agent of the other party, nor shall either party hold itself out as such. Neither party has any right or authority to incur, assume or create, in writing or otherwise, any warranty, liability or other obligation of any kind, express or implied, in the name of or on behalf of the other party, it is intended by both parties that each shall remain independent contractors responsible for its own actions.
This Terms and Conditions constitute the entire agreement between you and AG – MEDIA SPACE (AG – DIGITAL PEOPLE) and governs your use of the Site and supersedes all prior or contemporaneous communications and proposals, whether electronic, oral or written, between you and AG – MEDIA SPACE (AG – DIGITAL PEOPLE) with respect to this Site. Notwithstanding the foregoing, you may also be subject to additional terms and conditions, posted policies (including but not limited to the Privacy Policy), guidelines, or rules that may apply when you use the Website. AG – MEDIA SPACE (AG – DIGITAL PEOPLE) may revise this Terms and Conditions at any time by updating this Agreement and posting it on the Site. Accordingly, you should visit the Site and review the Terms and Conditions periodically to determine if any changes have been made. Your continued use of the Website after any changes have been made to the Terms and Conditions signifies and confirms your acceptance of any such changes or amendments to the Terms and Conditions.