Privacy Statement (EU)

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ABOUT US

Nicoleta Cherciu Cabinet de Avocat organized under the laws of Romania, with its headquarters at Bucharest, Romania (“Cherciu&Co”, “we”, “us” or “our”) is the controller with respect to your personal data. This means that we decide the purpose and the way your personal data is processed, as specified in this Policy.

ABOUT THIS POLICY

This Policy describes how we collect and use the personal information you provide to us when you use our Website (as defined in the Terms), when you access any tools to submit any applications or requests to us and go through any of our application processes (including, but not limited to jobs applications) (collectively referred to as the “Services”).

From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any material change to the way we collect or process your personal data we will provide you with more information or additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.

Our Cookie Policy provides more information on how we use cookies. You will also find information about how you can manage your cookie preferences and opt-out of certain types of tracking.

WHAT DO WE UNDERSTAND BY PERSONAL DATA?

Personal data is the information related to a natural person and which can be used to identify that person such as name, email address, telephone number, social media usernames, location data or business titles.

This means that when you use our Services, we will collect certain information about you (“personal data”) which can identify you directly (name, email) or indirectly (IP address or another online identifier).

WHAT PERSONAL DATA WE PROCESS?

When you use or interact with our Services, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the categories of personal data we process:

Categories of personal data	Description of category
User Data	This is the personal data that is provided by you to Cherciu&Co, including, but not limited to, by subscribing to our email communications or newsletters, by submitting any application or request to us, by using our Website (as defined in the Terms), or by any other means. Such data may include your first and last name, email address, phone number, mailing address, IP, as well as other personal data you may provide directly to us, and/or if requested by Cherciu&Co in order to fulfill the purposes described below.
Usage Data	This is the personal data that is collected about you when you’re accessing and/or using and visiting our website. Such data may include URL information, IP addresses, online identifiers including cookies, browsing or search history, non-identifiable request IDs, statistics associated with the interaction between device or browser and the services, which are subject to our Cookie Policy and to this Privacy Policy.
Job Applicant Data	We use the personal data contained in the CVs and/or job applications we receive in order to assess the applicants’ qualifications for a position within Cherciu&Co and/or any of its Affiliates. The categories of data processed in the context of our relationship with you are the personal data included in the provided CV and/or job applications, which can contain your name, e-mail, phone, fax, address, education and training details, professional qualifications, job title, job history, as well as other personal data you may provide directly to us, as per our additional request.
Professional Data	This is the personal data that is provided by you as a Cherciu&Co partner or as company’s representative, contact person, employee or other collaborator of said company. Such data may include your name, title/position, email address, phone, fax, business address IP, professional qualification as well as other personal data you may provide directly to us (for example when you seek our investment or promotion as a company founder), and/or when requested by Cherciu&Co in order to fulfill the purposes described below.

We do not and will never collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, health, genetic or biometric data).

HOW IS YOUR DATA USED AND ON WHAT GROUNDS

We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified above under ‘WHAT PERSONAL DATA WE PROCESS’) used for these purposes:

Processing purpose	Legal basis for the processing purpose	Categories of personal data used for the processing purpose
To provide and perform the Services you requested from us	Performance of a contract Legitimate Interest	User Data Professional Data Usage Data
To communicate with you with respect to any relevant matters in connection to your requests	Performance of a contract Legitimate Interest	User Data Professional Data Usage Data Job Applicant Data
To ensure a good contractual relationship with you	Performance of a contract Legitimate Interest	User Data Professional Data
For marketing, promotion, and advertising purposes and for sending you related email communications and/or newsletters	Consent Legitimate Interest	User Data Professional Data Usage Data
To comply with legal obligations and law enforcement requests	Compliance with legal obligations Legitimate interest	User Data Professional Data Job Applicant Data Usage Data
To fulfill contractual obligations with third parties and to take appropriate action with respect to reports of intellectual property infringement and inappropriate content	Legitimate Interest	User Data Professional Data Usage Data
To establish, exercise, or defend legal claims	Legitimate Interest	User Data Professional Data Usage Data Job Applicant Data
To conduct business planning, reporting, and forecasting	Legitimate Interest	User Data Professional Data Usage Data
To process job applications	Legitimate Interest Compliance with a legal obligations	Job Applicant Data

TO WHOM WE DISCLOSE YOUR PERSONAL DATA?

Your Data may be shared with the recipients listed below:

we may provide access to or share your information with selected third parties, such as service providers, intermediaries or external advisors who perform services on our behalf, including without limitation communications, market research, payment, emailing and computer services, and legal services;
we may further disclose your information to any third parties based on your consent to do so.

We may also provide personal data to third parties in the following situations:

to public authorities, auditors, or institutions competent to exercise inspections on Cherciu&Co, which may ask us to provide information, based on their legal obligations.
to comply with a legal requirement or to protect the rights and assets of Cherciu&Co or other entities or people
to third party acquirers, if Cherciu&Co’s business would be subject to a change of control or other similar procedure or acquisition and your personal data would be part of the transaction.

You can always reach out to us at nicoleta@cherciuandco.com find out more details on the third parties we may share your data with.

IS YOUR DATA TRANSFERRED ABROAD?

Some of our external third-party service providers may be based outside the European Union (“EU”). Their processing of your personal data will involve a transfer of data outside the EU. Whenever we transfer your personal data out of the EU, we endeavour to ensure one of the following safeguards is implemented:

we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy decisions;

where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe and which cannot be changed by the parties;

where such data cannot be afforded one of the safeguards above, we shall only transfer such data outside the EU where it is necessary for performing our contract with you or we have your fully informed, active, clear and specific consent. We shall take all steps necessary to ensure that your personal data is protected when we transfer it outside the EU.

DO WE PROCESS PERSONAL DATA FROM CHILDREN?

Our Services are not designed or intended for use by children. If you are under the age of eighteen (18), please do not submit any personal data through the Services. If you have reason to believe that a child under the age of 18 has provided personal data to us through the Services, please contact us at nicoleta@cherciuandco.com and we will endeavour to delete that information from our databases.

WHAT ARE YOUR RIGHTS?

When we process your personal data, it is important to know that you have the following rights:

The right of access to the personal data we process about you: you have the right to obtain a confirmation whether or not we process your personal data, and, if so, to have access to the type of personal data and to the conditions of processing, by sending us a request in this regard
The right to request the rectification or deletion of personal data: you have the right to request, the rectification of inaccurate or incomplete personal data which we have about you, or the erasure of your personal data in case (i) the data are no longer necessary for their original purpose (and no new lawful purpose exists), (ii) we initially process your data based on your consent and you withdraw your consent and therefore no lawful ground exists anymore, (iii) you object and we have no overriding grounds for continuing the processing, (iv) the data have been processed unlawfully, (v) erasure is necessary for compliance with EU law or other applicable law;
The right to request the restriction of processing: you have the right to ask for the restriction of processing in cases where: (i) you consider that the personal data processed is inaccurate, for a period enabling us to verify the accuracy of the personal data; (ii) the processing is unlawful, however you don’t want us to erase your personal data, but to restrict the use of data; (iii) in case we no longer need your personal data for the purposes we described in this Policy, but you are requiring the data for establishing, exercising or defending a legal claim or (iv) you have objected to processing pending the verification whether our legitimate grounds prevail;
The right to withdraw your consent for processing, when the processing is based on your consent, without affecting the lawfulness of processing undertaken until that moment
The right to object to the data processing on grounds related to your particular situation, when the processing is based on legitimate interest and to object at any moment to the data processing for direct marketing purposes, including profiling
The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects for your similarly affect you in a significant manner
The right to data portability, meaning the right to receive your personal data, which you provided us in a structured, commonly used and machine-readable format and the right to transfer those data to another controller, if the processing is based on your consent or the performance of a contract and is undertaken by using automatic means
The right to object to direct marketing – from time to time, Cherciu&Co may send emails containing information about our people, organization and application process, topics relevant to startups, and profiles of founders and companies and other news about us. This is considered direct marketing. Where personal data are processed for direct marketing purposes, you have the right to object at any time and free of charge to the processing of your personal data for direct marketing purposes by clicking “Unsubscribe” when you receive the respective e-mail or by writing at nicoleta@cherciuandco.com. If you object to the processing for direct marketing purposes, the your personal data shall no longer be processed for such purposes. These options, however, do not apply to other communications where the main purpose of such communications is not of promotion.
The right to file a complaint with the with your national Data Protection Authority and the right to address to the competent courts of law.

No fee is usually required for the exercise of the above rights

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond and contact details

We are happy to ensure your exercise of these rights. You may exercise your aforementioned rights and find out more about such rights by filing with us, as data controller by e-mailing us at nicoleta@cherciuandco.com. We shall review your request and reply within a 30 days term. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

We are committed to always treat your requests with the utmost attention and address any queries you may have in the shortest time possible.

UPDATES TO THIS POLICY

This Privacy Policy may be changed and updated by us from time to time as it could become necessary. We will notify you of any substantial changes to this Privacy Policy and will ensure that the notification is made in a way which ensures that you acknowledge them, for example by using the email address that you have provided to us, or by displaying a prominent notice within the Service. If you do not agree with the changes, you may always stop using the Services.

Thank you for reading our Policy. You can always reach out to us at nicoleta@cherciuandco.com if you have any questions regarding the processing of your data by Cherciu&Co.

This privacy statement was last updated on February 17, 2024 and applies to citizens and legal permanent residents of the European Economic Area and Switzerland.

In this privacy statement, we explain what we do with the data we obtain about you via https://cherciuandco.com. We recommend you carefully read this statement. In our processing we comply with the requirements of privacy legislation. That means, among other things, that:

we clearly state the purposes for which we process personal data. We do this by means of this privacy statement;
we aim to limit our collection of personal data to only the personal data required for legitimate purposes;
we first request your explicit consent to process your personal data in cases requiring your consent;
we take appropriate security measures to protect your personal data and also require this from parties that process personal data on our behalf;
we respect your right to access your personal data or have it corrected or deleted, at your request.

If you have any questions, or want to know exactly what data we keep of you, please contact us.

1. Purpose, data and retention period

We may collect or receive personal information for a number of purposes connected with our business operations which may include the following: (click to expand)

2. Sharing with other parties

We only share or disclose this data to processors for the following purposes:

3. Cookies

Our website uses cookies. For more information about cookies, please refer to our Cookie Policy.

4. Disclosure practices

We disclose personal information if we are required by law or by a court order, in response to a law enforcement agency, to the extent permitted under other provisions of law, to provide information, or for an investigation on a matter related to public safety.

If our website or organisation is taken over, sold, or involved in a merger or acquisition, your details may be disclosed to our advisers and any prospective purchasers and will be passed on to the new owners.

We have concluded a data Processing Agreement with Google.

5. Security

We are committed to the security of personal data. We take appropriate security measures to limit abuse of and unauthorized access to personal data. This ensures that only the necessary persons have access to your data, that access to the data is protected, and that our security measures are regularly reviewed.

6. Third-party websites

This privacy statement does not apply to third-party websites connected by links on our website. We cannot guarantee that these third parties handle your personal data in a reliable or secure manner. We recommend you read the privacy statements of these websites prior to making use of these websites.

7. Amendments to this privacy statement

We reserve the right to make amendments to this privacy statement. It is recommended that you consult this privacy statement regularly in order to be aware of any changes. In addition, we will actively inform you wherever possible.

8. Accessing and modifying your data

If you have any questions or want to know which personal data we have about you, please contact us. You can contact us by using the information below. You have the following rights:

You have the right to know why your personal data is needed, what will happen to it, and how long it will be retained for.
Right of access: You have the right to access your personal data that is known to us.
Right to rectification: you have the right to supplement, correct, have deleted or blocked your personal data whenever you wish.
If you give us your consent to process your data, you have the right to revoke that consent and to have your personal data deleted.
Right to transfer your data: you have the right to request all your personal data from the controller and transfer it in its entirety to another controller.
Right to object: you may object to the processing of your data. We comply with this, unless there are justified grounds for processing.

Please make sure to always clearly state who you are, so that we can be certain that we do not modify or delete any data of the wrong person.

9. Submitting a complaint

If you are not satisfied with the way in which we handle (a complaint about) the processing of your personal data, you have the right to submit a complaint to the Data Protection Authority.

10. Contact details

Nicoleta Cherciu
Bucharest
Romania
Website: https://cherciuandco.com
Email: nicoleta@cherciuandco.com
Phone number: 0785663897

11. Data Requests

For the most frequently submitted requests, we also offer you the possibility to use our data request form