Privacy policy

All HR Needs In One Place

This Privacy Policy (the “Privacy Policy”) is intended to inform you about the personal data we process when you use the One2One mobile
application (the “Application”).

The Application is part of a project developed to improve the relationship and collaboration between the employer and HR staff on the one hand and
employees, on the other hand, by creating an interactive link between them, including through online interactions and providing feedback in various
campaigns organized by the employer ( the “Project”).

The purpose of the Application is to facilitate employee access to the employers communication campaigns and to mediate and stimulate
communication between the employee and the employer in order to improve working relationships, including employee involvement in day-to-day
activities for the benefit of the Company, by providing incentives and the possibility of generating feedback from employees, so that, through the
delivery of dedicated reports, the Company has visibility on relevant aspects of work performance (the “Services”).

In order to use the Application, the Company will process personal data as a data controller, and in this capacity we wish to inform you about our
contact details, what data we process and the purposes for which we process it, the legal grounds for processing, the period of data storage, the
entities to whom we disclose certain data, and the rights you have in relation to your personal data.

We are committed to respecting your right to privacy of your personal data by complying with all applicable data protection laws and regulations,
including the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

In this Privacy Policy, the term “personal data” refers to any information relating to an identified or identifiable natural person; an identifiable
person is one who can be identified directly or indirectly, in particular, by reference to an identifier or to one or more factors specific to his or her
physical, physiological, mental, economic, cultural or social identity (the “Data”).

Who are we?

The data controller is ELITE SEARCHERS SRL, with its registered office in Bucharest, District 1, 20 – 22 Av. George Valentin Bibescu St., Building
XI/1, Entrance 1, Foor 1, Apt. 6, registered with the Trade Register under no. J40/7182/2018, Fiscal Identification Code RO 39387680, having the e-mail address sorina.faier@elitesearchers.ro and telephone no. +40722460696, duly represented by Sorina Faier, in capacity as General Manager (the “Company” or the “Employer”). The Company may be mentioned in this Privacy Policy as “we”, “us” or “our”.

The company has not appointed a data protection officer. However, if you have any questions about the content of the Privacy Policy and the use of
your personal data, please use the contact details above and our legal representatives will respond to you.

How do we use personal data?

Your personal data will be processed in order to provide the Services in the various campaigns carried out through the Application in order to facilitate interactions between the Company and its employees.

The Company makes available to users of the Application certain questionnaires that they can fill in and send to the Employer together with the related answers. Based on the options selected in the questionnaire, users can benefit from a dynamic reward. The conditions for running campaigns will be displayed within the Application, in a dedicated section.

What data we process and for which purposes

Providing any Data is purely optional, failure to do so will result in the impossibility to benefit from the Services provided by the Company and implicitly, the impossibility to participate in campaigns.

Categories of Data and the purpose of the processing of such Data

Categories of Data: first and last name, e-mail address, date of birth, demographic information such as residence, habits, interests, answers to questionnaire questions, credit earned related to the relevant campaign, history of credits earned. The purpose of processing the Data is to provide the Services.

Categories of Data: Name and surname, e-mail address, telephone number, question/request asked and any other Data provided in the request. Purpose of Data Processing: To provide answers to your questions or requests, sent by post, e-mail, fax or telephone.

Categories of Data: name and surname, e-mail address, telephone number. Purpose of Data processing: to provide information on campaigns, promotions, various regular information (newsletter).

Legal basis for the processing of the Data

The performance of the contract concluded between you and the Company for the provision of the Services (Article 6 (1) (b) GDPR).

The processing is based on the performance of the contract concluded between you and the Company, in particular your request to receive answers to your questions (Article 6 (1) (b) of the GDPR).

The processing is based on users' consent (Article 6(1)(a) of the GDPR).

Duration of the processing of the Data

For the entire duration of the contractual relationship between you and the Company and for a period of 3 years from the date of termination of the contractual relationship for any reason.

3 years from the date your request was dealt with.

Until the date of withdrawal of the consent given.

Data Recipients

Your data will be processed by designated persons within the Company.

Your data will be processed by designated persons within the Company to answer to your requests.

Your data will be processed by designated persons within the Company for the provisions of regular information.

Other categories of data recipients

We use the services of contractual partners to fulfil the purposes mentioned above.

Some of these contractual partners are persons empowered by the controller: e.g. the IT service provider [*]. The database is structured in such a
way that the data cannot be accidentally accessed outside the limits configured in the system.

Some of the Data indicated above will be made available or transmitted to third parties (e.g. public or judicial institutions, etc.). In these cases, third
parties will have access to the Data in the performance of their duties, e.g. (i) public authorities, auditors or legal or institutions with powers to carry
out inspections and controls on the Company's activity and assets, e.g. ANSPDCP, ANAF, etc.; (ii) to comply with a legal requirement or to protect our
rights, such as courts, bailiffs etc.

Transfer of Data to third countries (outside the EU and EEA)

Data processed through the Application is stored on internal or external servers located within the EU/EEA. The Company may transfer your Data to countries located outside the European Economic Area (EEA). In such cases, the Company will ensure that such transfer is based on appropriate safeguards listed in the GDPR, including (a) standard contractual clauses developed by the European Commission; (b) suitability decisions of the European Commission with respect to the countries in which the recipients are located; (c) binding corporate rules adopted by the Company and approved by the competent authorities or which are part of agreements with the Company in this regard. Copies of appropriate safeguards implemented in cases of transfer are available upon request.

Automated decision-making and profiling

Personal Data referred to in this Privacy Policy is not subject to automated decision-making processes, including profiling.

Your rights as a data subject

Under the provisions of the GDPR, you have the following rights:

1. Right of access to Data – the right to obtain confirmation as to whether or not personal data is being processed by us and, if so, to be informed of the relevant details of such processing activities;
2. Right to rectification of Data – the right to obtain rectification of inaccurate personal data or completion of incomplete data;
3. Right to erasure of Data – the right to obtain the erasure of personal data, if one of the following reasons applies: (i) the data is no longer necessary for the fulfilment of the original purpose (and there is no other lawful purpose), (ii) when the legal basis for processing the Data by us is your consent, and you withdraw your consent and there is no other lawful purpose, (iii) you exercise your right to object to the processing of the Data and the Company has no overriding legitimate grounds for continuing the processing, (iv) the Data has been unlawfully processed, (v) erasure is necessary for compliance with EU or Romanian law or (vi) the Data has been collected in connection with information society services offered to children, where specific consent requirements apply;
4. Right to restriction of processing – the right to obtain the restriction of further processing of Data relating to you, in cases where: (i) you consider that the Data processed is inaccurate, for a period that allows us to verify the accuracy of the personal data; (ii) you consider that the processing is unlawful, but you do not want us to erase your Data, but only to restrict the use of such Data; (iii) where the Company no longer needs your Data for the purposes mentioned above, but you need it to establish, exercise or defend a right in court; or (iv) you have objected to the processing, for the period of time within which we verify whether the Company’s legitimate grounds outweigh your rights;

5. The right to data portability – the right to receive Data in a structured, commonly used and readable format and the right to have such Data transferred by the Company to another data controller, to the extent that the processing is based on your consent or the performance of contract and is carried out by automated means;
6. The right to object – the right to object at any time, on legitimate grounds relating to your particular situation, to the processing of Personal Data concerning you, insofar as such processing is legally based on the legitimate interest of the Company;
7. The right not to be subject to an automated decision or additional profiling related to automated decisions – the right to request and obtain the withdrawal, cancellation or review of any decision based solely on processing by automated means (including profiling) that produces legal effects concerning you or similarly affects you to a significant extent;
8. If your consent was required for the processing of certain personal data, you have the right to withdraw your consent at any time, which will not affect the lawfulness of the processing prior to the withdrawal of consent ;
9. Right to lodge a complaint – you have the right to lodge a complaint with the National Authority for the Supervision of Personal Data Processing (ANSPDCP), as well as the right to apply to the competent courts.

You may exercise any of the above rights at any time by sending a written, dated and signed request or an electronic request to e-mail address
sorina.faier@elitesearchers.ro.

Privacy Policy Updates

This Privacy Policy is updated at the date appearing at the top of the document.

The Company has the right to change, when necessary, its Data processing practices and to update and amend this Privacy Policy at any time. For this reason, in order to keep up to date on how we process your Data, we encourage you to check this document periodically.

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