This Privacy Policy explains our approach to any personal data that we collect about you when you use the website www.cabot-tp.ro (the “Website”). Please read this Policy carefully to find out more about how we process your personal data and to know your rights in this respect.

1. THE CONTROLLER OF YOUR PERSONAL DATA

The controller of your personal data is, as applicable, the company CABOT TRANSFER PRICING srl, all of them headquartered in 47 Aviatorilor Boulevard, RO-011853, Bucharest, Romania (each of them hereinafter referred to as “CABOT TRANSFER PRICING”).

2. TYPES OF INFORMATION COLLECTED, PURPOSE AND LEGAL BASIS

• When you access our Website

The Website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system, device type and other usage information about the use of the Website, including a history of the pages you view.

We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

The legal basis for this processing is our legitimate interest to monitor the Website activity and to ensure the Website security. The data is stored for 1 year starting from the date of the visit, with the exception of cookies whose lifespan is listed in our Cookie Policy available at https://cabot-tp.ro/en/cookie-policy/

Our Website also uses cookies and other technologies, and you can read about these in our Cookie Policy. As a rule, the placing of cookies which are not strictly necessary for the functioning of the Website is based on your consent, which is requested when you access the Website. Your options regarding cookies may be changed at any time, following the instructions included in the Cookie Policy.

• When you contact us for any request

You may contact us by using the contact details provided on the Website (by email, telephone, post) or by any other forms or means. In such cases, we will process your contact data, as well as any other information you choose to provide.

We process such personal data based on our legitimate interest, in order to answer your questions and requests. We will retain the data for a maximum period of 5 years from the last interaction with you, from the final answer to the notified problem or until you request to their deletion (to the extent that the right to erasure applies).

3. DISCLOSURE OF PERSONAL DATA

We will not disclose your personal data, except where strictly necessary for the purposes detailed in thie Privacy Policy and to the following categories of third parties:

• organizations which provide us relevant services for maintaining and developing this Website and its tools;
• potentially other entities, where we or they have a prevailing legitimate interest in the disclosure or where we are required by law to make such a disclosure;
• other entities involved in our services, as communications agencies, mail carriers etc.;
• providers of information technology and support system, including email archiving, disaster recovery and cybersecurity and recovery services;
• other entities, such as public authorities and institutions, accountants, auditors and other external professional consultants, when their activity requires knowledge of the data or when the law requires us to disclose them.

While not in our intention to disclose data in this way, we may disclose it:

• where you request or agree to it;
• to persons who demonstrate they are acting on your behalf;
• where we are required to disclose your data in order to comply with a legal obligation or a request from governmental or enforcement agencies;
• for the establishment, exercise or defense of legal claims.

4. TRANSFERS OUTSIDE OF THE EUROPEAN ECONOMIC AREA

We generally process your personal data within the EEA and do not transfer or disclose your personal data to third parties outside the EEA. If we use non-EEA providers who may have access to your data for the provision of services to us, we will take appropriate measures to ensure that they adequately protect your personal data in accordance with this policy. These measures include, in the case of service providers based in countries other than the EEA, the guarantee represented by the adequacy decision issued by the European Commission, or the conclusion of standard contractual clauses approved by the European Commission.

5. DREPTURILE DVS.

As a data subject, you have specific legal rights relating to the personal data we process about you:

• Right to withdraw consent: Where you have given consent for the processing of your personal data, you may withdraw your consent at any moment by clicking the unsubscribe button in any of the e-mail messages you receive from us.
• Right to access: You may ask from us information regarding personal data that we hold about you, including information as to which categories of data we have in our possession or control, what they are being used for, and to whom they have been disclosed, if applicable.

We will provide you with a copy of your personal data upon request. If you request further copies of your personal data, then we can charge you with a reasonable fee that we base on the administrative costs.

• Right to rectification: You have the right to obtain the rectification of your personal data, if inaccurate or incomplete. For this, you can contact us at the contact details provided below.
• Right to restriction: You may obtain from us restriction of processing of your personal data, if:
  – you contest the accuracy of your personal data, for the period we need to verify the accuracy;
  – the processing is unlawful, if you request the restriction of the processing instead of the erasure of your personal data;
  – we do no longer need your personal data, but you request it for the establishment, exercise or defense of legal claims; or
  – you object to the processing while we verify whether our grounded reasons override yours.
• Right to portability:  You have the right to receive your personal data that you have provided to us, and, where technically feasible, request that we transmit your personal data (that you have provided to us) to another organization.
  You have these rights if, on a cumulative basis:
  – we process your personal data by automated means;
  – the processing of your personal data is based on your consent, or our processing of your personal data is necessary for the execution or performance of a contract to which you are a party;
  – the transmission of your personal data does not adversely affect the rights and the freedoms of other persons.
• Right to erasure: You have the right to request that we delete the personal data we process about you. We must comply with this request if we process your personal data, unless the data is necessary:
  – for exercising the right of freedom of expression and information;
  – for compliance with a legal obligation that binds us;
  – for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; or
  – for the establishment, exercise or defense of legal claims.
• Right to object: You may object – at any time – to the processing of your personal data due to your particular situation, provided that the processing is based on our legitimate interests or those of a third party. In this event we shall no longer process your personal data, unless (i) we can demonstrate compelling legitimate grounds which justify the processing and override your interests, rights and freedoms, or (ii) in case the purpose is the establishment, exercise or defense of a right in court.
• Right to lodge a complaint: If you have any complaints about the way in which we process your personal data, we would prefer that you contact us directly in order to address your problem. However, you may contact the Romanian Data Protection Authority (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal) using the information posted on their website www.dataprotection.ro.

Please note:

• Time period: We will try to fulfil your request within one month, a period which may be extended due to specific reasons relating to the context of the situation or the complexity of your request, with a maximum additional period of 2 months. In all cases, if this period is extended, we will inform you about the term of extension and the reasons that led to it.
• Restriction of access: In certain situations, we may not be able to give you access to all or some of your personal data due to legal restrictions. If we deny your request for access, we will inform you of the reason for the refusal.
• No identification: In some cases, we may not be able to identify your personal data due to the identifiers you provide in your request. In such cases, where we cannot identify you as a data subject, we are not able to comply with your request in accordance with this section, unless you provide additional information enabling your identification. We will inform you and give you the opportunity to provide such additional details.
• Exercise your legal rights: In order to exercise your rights, please contact us in writing (including electronically) at the contact details provided below.

6. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify, where we deem appropriate, the privacy practices and update and make changes to this Policy at any time. For this reason, we encourage you to verify this Policy periodically. This Policy is current as of the date which appears at the beginning of the document.

7. CONTACT DETAILS

Please use the contact details below for any questions regarding the protection of your personal data and for exercising your data subject rights.

Email: office@cabot-tp.ro

Address: 47 Aviatorilor Boulevard, RO-011853, Bucharest, Romania.