1. Who does this Information Notice apply to?

This Information Notice applies to the processing of personal data of:

• visitors and users of our website www.omega-trust.ro („Users”);

2. What data do we collect about you?

We collect and process your personal data as follows:

• from the information you provide to us by completing the forms on our website;
• through correspondence with us by phone, email or any other means.

The information you provide may include your name, email address and telephone number, as well as other information, as applicable.

Through your use of the website, we will not collect or process sensitive personal data relating to you (i.e. information regarding racial or ethnic origin, political opinions, religious beliefs or philosophical beliefs, health, sexual life or sexual orientation).
If you voluntarily provide us with personal data (including sensitive personal data) through your interaction with the website www.omega-trust.ro or through correspondence with us by phone, email or any other means, on your own initiative and not at our request, we will delete such personal data from our systems if we do not consider that their processing is necessary for a legitimate purpose of Omega Trust, unless you have made such data public (for example, in a message forum visible to the public), in which case we will delete such data from the website www.omega-trust.ro only if the law requires it or if we do not wish to retain them.

Each time you visit the website www.omega-trust.ro, we automatically collect the following data:

• technical data, for example this may include the Internet Protocol (IP) address used to connect your computer to the internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device type and mobile device brand;
• data about your visit, which may include URL data, clickstream to, through and from the website www.omega-trust.ro, information you viewed or searched for on the website.

3. What are the purposes of processing personal data and what is the legal basis of processing?

We may process your personal data in the following cases:

• when we need to take steps necessary to conclude a contract with you;
• when we need to fulfil a contract concluded with you;
• when we need to comply with a legal obligation (i.e. applicable legislation in the fiscal, financial, accounting, audit fields,
• applicable legislation in employment relations);
• when it is necessary for our legitimate interests (or those of a third party) and for your interests (i.e. for detecting and preventing fraud or for ensuring IT and network security), except where your fundamental rights prevail over such interests;
• where it is necessary for public interest or for official purposes.

We process your personal data for various technical, administrative and operational reasons, such as:

• to ensure that content is presented in the most effective manner for you;
• to improve the website www.omega-trust.ro, including its functionality;
• to administer the website www.omega-trust.ro;
• for internal operations, including troubleshooting, data analysis, testing, statistics and research purposes;
• to keep the website www.omega-trust.ro secure;
• for advertising and marketing, including targeted marketing purposes, so that we can provide content, including personalized content, that may be of greater interest to you.

In some cases, we will process your personal data only with your consent (i.e. in advertising and marketing cases). In such cases, we will request your consent separately, in a transparent manner, when you provide your personal data. Subsequently, you may withdraw your consent at any time by sending a request to the email address dpo@omega-trust.ro. Withdrawal of consent will not affect the lawfulness of processing carried out before its withdrawal.

When we request personal data to comply with legal or contractual obligations, providing such personal data is mandatory. This means that if such personal data is not provided, we will not be able to manage contractual relationships or comply with legal obligations imposed on us. In all other cases, providing personal data is optional and you are not obliged to provide it.

4. To whom do we disclose personal data?

Omega Trust does not transfer (by sale or rental) your personal data to third parties.

Within Omega Trust, only a limited number of staff members, such as those in the Sales and IT departments, have access to your personal data on a need-to-know basis. These staff members are subject to confidentiality obligations regarding the processing of personal data. Omega Trus tstaff members are entitled to manage personal data only based on the instructions communicated by Omega Trust, in connection with their job responsibilities.

Appropriate technical and organizational measures are being taken to protect personal data. This website uses security measures against the loss, alteration or misuse of information under our control.

However, Omega Trust does not assume responsibility for information losses caused by errors in the software used to design and host the website. We are also not responsible for security errors with the server hosting the website.

Personal data may be disclosed to governmental authorities, tax authorities and/or law enforcement bodies if required by applicable laws or if necessary for the exercise of our rights, including the terms of use, or for the protection of our legitimate interests (including the legitimate interests of third parties) in accordance with applicable laws.

Your personal data may also be disclosed to third parties as follows:

• to service providers that offer administrative, professional and technical support to the Company for IT support;
• to external consultants (i.e. lawyers, accountants, auditors), for specific purposes, when necessary.

Omega Trust carries out an appropriate prior assessment when selecting third-party service providers and requires these providers to maintain appropriate technical and organizational security measures to protect personal data and to process personal data only in accordance with the instructions specified by Omega Trust. Service providers will have the right to use subcontractors in providing services to Omega Trust, provided that each subcontractor complies with the same data protection obligations as the service providers.

5. What is the retention period of personal data?

We will retain your personal data for the period necessary to fulfill the purposes listed in this Policy or for the period required by applicable national legislation, in accordance with the applicable minimum legal retention periods and/or as long as necessary to exercise our legitimate rights (and the legitimate rights of others).

If we have an ongoing commercial relationship with you, we will continue to retain such personal data until the termination of our commercial relationship, as well as for an additional period of 10 years from the end of the financial year, in accordance with Law no. 82/1991 on Accounting, republished, as subsequently amended and supplemented.

If we process your personal data based on your consent, such personal data will be processed only for the period provided by your consent, unless you withdraw or limit your consent before the expiry of this period. In such cases, we will cease processing the respective personal data for the relevant purposes, subject to any legal obligation to process such personal data and/or our need to process such personal data for the purpose of exercising our legitimate rights (including the legitimate rights of others).

6. Storage of personal data and transfer of personal data outside the country

The website www.omega-trust.ro is administered and maintained by Omega Trust SRL and hosted on the servers of Omega Trust SRL, located in Romania.

We do not intend to transfer your personal data outside the EEA unless adequate safeguards are in place, including:

• an adequacy decision issued by the European Commission regarding the destination country or countries;
• appropriate binding corporate rules;
• an approved code of conduct, together with binding and enforceable commitments of the data controller or processor in a country outside the EU and EEA;
• an approved certification mechanism, together with binding and enforceable commitments of the data controller or processor in a country outside the EU and EEA to apply appropriate safeguards; or
• EU standard contractual clauses approved by the European Commission.

7. What rights do you have?

You have the following rights regarding your personal data, in accordance with EU Regulation no. 679/2016:

• the right to obtain confirmation as to whether or not your personal data is being processed and to receive a copy of your personal data;
• the right to request rectification of personal data;
• the right to request erasure of personal data;
• the right to request restriction of processing of personal data;
• the right to object to the processing of personal data by the website www.omega-trust.ro (for example, the use of processing for direct marketing purposes);
• the right to request data portability;
• the right to withdraw your consent at any time, without affecting the lawfulness of processing carried out on the basis of consent before its withdrawal;
• the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing.

Please note that the rights described above may be limited in certain situations and are subject to applicable data protection laws and regulations. For example, the right to object to the processing of your personal data may be limited where we can demonstrate compelling legitimate grounds for processing your personal data that override your interests.

When requesting one or more of these rights, you will need to prove your identity and provide other details that help us respond to your request.

We will not charge a fee to respond to your request, unless permitted by law. If such a fee is charged, it will be reasonable and proportionate to your request.

To exercise one or more of these rights, please contact us at the email address dpo@omega-trust.ro

8. Security of personal data

We use appropriate technical and organizational measures to protect personal data and prevent unauthorized access.

All payment transactions will be encrypted (for example, using the TLS protocol).

Transmission of data over the internet is not completely secure and may involve risks. Although we do our best to protect your data, we cannot guarantee 100% the security of your data transmitted to our website; any transmission of personal data is at your own risk.

Once we receive your data, we will use strict security procedures to try to prevent unauthorized access.

9. Confidentiality of minors’ data

The website www.omega-trust.ro does not knowingly collect personal data from persons under the age of 16. If a parent or legal guardian becomes aware that a minor under their custody has provided personal data to the website www.omega-trust.ro, they must immediately inform Omega Trust at the email address dpo@omega-trust.ro. If we discover that a person under the age of 16 has provided personal data through the website www.omega-trust.ro, we will delete such information from our servers immediately, unless the parent or guardian gives explicit consent for the processing of the child’s personal data for the specified purposes.

10. Cookies

The website www.omega-trust.ro uses cookies to provide you with a better experience when browsing our website. This processing is based on your consent expressed on the website or through your browser settings. You can find more information about cookies on the Cookie Policy page.

11. Contact

If you have questions or concerns regarding the processing of your personal data by the website www.omega-trust.ro or if you wish to exercise one or more of your rights, you can contact us at the email address dpo@omega-trust.ro

Please do not disclose sensitive personal data (for example, information regarding racial or ethnic origin, political opinions, religious beliefs or other beliefs, health or trade union membership) when contacting us.

Note: We may periodically update this Policy and will notify you of any changes by posting the new version on the website www.omega-trust.ro.

Please periodically check the Privacy Policy page to stay informed about any updates.