Creative Space is fully compliant with the EU 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)
You can contact our Data Protection Officer by e-mail: dataprotection@cspace.ro.

In this regard, we guarantee to take all technical feasible measures to ensure your Personal Data protection.  All data processing is lawful and fair.

Duration of data processing:

We process your data for as long as the consent is validly given, according to the duration specifically expressed in your consent form, for each particular type of processing and each particular case.

Your consent is given by a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of your agreement to the processing of personal data such as by a written statement, including by electronic means, or an oral statement. This could include ticking a box when visiting an internet website, choosing technical settings for information society services or another statement or conduct which clearly indicates in this context your acceptance of the proposed processing of his or her personal data.

Processing of personal data belonging to third-parties limits to storage, transfer and back-up activities.  Our operators do not perform other activities such as access, view, redistribute, modify, or process in any other way data stored for third-parties.  The entire liability for obtaining consent belongs to the third-party.

For software development and testing, we use pseundnymised data (‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;)

Personal data in Creative Space is

  • (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; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);
  • (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; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘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 only process your personal data if

  • you have given consent to the processing
  • processing is necessary for performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which we are subject;
  • processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
  • For children under 16 years old, consent is given or authorised by the holder of parental responsibility over the child.

Special categories of data (personal data revealing 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) shall only be performed if the data subject has given explicit consent to the processing of those personal data for one or more specified purposes.

 

We try our best to ensure Transparent information, communication and modalities for the exercise of the rights of the data subject (you).

You have the right to request the following information:

  • (a) the identity and the contact details of the controller and, where applicable, of the controller’s representative;
  • (b) the contact details of the data protection officer, where applicable; (dataprotection [@] cspace.ro)
  • (c) the purposes of the processing for which the personal data are intended as well as the legal basis for the processing;
  • (d) where the processing is based on point (f) of Article 6(1), the legitimate interests pursued by the controller or by a third party;
  • (e) the recipients or categories of recipients of the personal data, if any;
  • (f) where applicable, the fact that the controller intends to transfer personal data to a third country or international organisation and the existence or absence of an adequacy decision by the Commission, or in the case of transfers referred to in Article 46 or 47, or the second subparagraph of Article 49(1), reference to the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available.

Also, you may request being informed about:

  • (a) the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
  • (b) the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability;
  • (c) where the processing is based on point (a) of Article 6(1) or point (a) of Article 9(2), the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
  • (d) the right to lodge a complaint with a supervisory authority;
  • (e) whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data;
  • (f) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

If we get your personal data from third parties, you may ask us :

  • (a) the identity and the contact details of the controller and, where applicable, of the controller’s representative;
  • (b) the contact details of the data protection officer, where applicable;
  • (c) the purposes of the processing for which the personal data are intended as well as the legal basis for the processing;
  • (d) the categories of personal data concerned;
  • (e) the recipients or categories of recipients of the personal data, if any;
  • (f)where applicable, that the controller intends to transfer personal data to a recipient in a third country or international organisation and the existence or absence of an adequacy decision by the Commission, or in the case of transfers referred to in Article 46 or 47, or the second subparagraph of Article 49(1), reference to the appropriate or suitable safeguards and the means to obtain a copy of them or where they have been made available.

As well as:

  • (a) the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
  • (b) where the processing is based on point (f) of Article 6(1), the legitimate interests pursued by the controller or by a third party;
  • (c) the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability;
  • (d) where processing is based on point (a) of Article 6(1) or point (a) of Article 9(2), the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
  • (e) the right to lodge a complaint with a supervisory authority;
  • (f) from which source the personal data originate, and if applicable, whether it came from publicly accessible sources;
  • (g) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

We will provide all the information required within a reasonable period after obtaining the personal data, but at the latest within one month, having regard to the specific circumstances in which the personal data are processed.  If the personal data are to be used for communication with the data subject, at the latest at the time of the first communication to that data subject. If a disclosure to another recipient is envisaged, at the latest when the personal data are first disclosed.

You have the right to access your data:

You can obtain from Creative Space a confirmation as to whether or not personal data concerning yourself are being processed, and, where that is the case, access to the personal data and the following information: (a) the purposes of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; (f) the right to lodge a complaint with a supervisory authority; (g) where the personal data are not collected from the data subject, any available information as to their source; (h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

You have the right to rectification

You have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning yourself. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to erasure (‘right to be forgotten’)

You have the right to obtain from Creative Space the erasure of personal data concerning yourself without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; 4.5.2016 L 119/43 Official Journal of the European Union EN; (b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing; (c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2); (d) the personal data have been unlawfully processed; (e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).

You have the Right to restriction of processing

You have the right to obtain from the controller restriction of processing where one of the following applies: (a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; (b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; (c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; (d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

 

You have the Right to data portability

You have the right to receive the personal data concerning your person, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where: (a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and (b) the processing is carried out by automated means. 2.In exercising his or her right to data portability pursuant to paragraph 1, you have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

 

Right to object and automated individual decision-making

You have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning yourself, which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

 

All of our products and services provide Data protection by design and by default

Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the processing, the controller shall, both at the time of the determination of the means for processing and at the time of the processing itself, implement appropriate technical and organisational measures, such as pseudonymisation, which are designed to implement data-protection principles, such as data minimisation, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of this Regulation and protect the rights of data subjects. We implement appropriate technical and organisational measures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed. That obligation applies to the amount of personal data collected, the extent of their processing, the period of their storage and their accessibility. In particular, such measures shall ensure that by default personal data are not made accessible without the individual’s intervention to an indefinite number of natural persons.

When we act as processors, Creative Space and our employees acting under the authority of a controller will not process those data except on instructions from the controller, unless required to do so by Union or Member State law.

We DO NOT transfer your personal data outside the European Economic Space.

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