Last Updated: June 2021
Your privacy is one of our fundamental commitments at NNDKP Societate Civila de Avocati, NNDKP Consultanta Fiscala SRL, NNDKP IP SRL and Legal Play SRL (together referred to as “NNDKP” or “we”).
Therefore, we take outmost care to process your personal data in accordance with the principles set forth in the data protection legislation applicable in Romania, including (EU) Regulation 2016/679 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 (“GDPR”). Personal data represents any information relating to an identified or identifiable natural person, and an identifiable person is that person that may be identified directly or indirectly, particularly by reference to an identification number or to one or more factors specific to its physical, psychological, mental, economic, cultural or social identity.
This privacy policy regards the personal data of our clients, business partners, other persons contacting and visiting us and of the representatives thereof, potential employees, interns, associates or persons attending events organized by or with the involvement of NNDKP and it applies to data collected through our website, www.nndkp.com, as well as to all other personal data we collect through e-mail or other off-line contacts or in the context of events organized by or with the involvement of NNDKP. The privacy policy describes:
- the purposes for which we collect and use your personal data
- the processing grounds for such purposes
- the categories of personal data we collect from you and process
- the duration of processing of such data
- your rights as data subjects and the manner in which you may exercise them
- to whom we may disclose your personal data.
In the context of your interaction with NNDKP, you, as a natural person, may be subject to the data processing activities that we perform. Thus, we use your personal data in the following cases:
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1. If you are a client or potential client of NNDKP
Activity Purposes Categories of personal data Grounds for processing Providing the legal, fiscal and IP-related services requested from us We use your relevant personal data in order to prepare and provide the services requested from us. For instance, in preparing materials required during the course of litigation and arbitration proceedings, we may have to rely on your personal data of relevance for your case. We rely in this case on the performance of our agreement as grounds for processing. Communicating with you We use your contact details in order to communicate with you with respect to your requests and any other relevant business-related matters. Contact details We also rely in this case on the performance of our agreement as grounds for processing. Data processing as obligation imposed by the law and by the statute governing the legal profession We may process some of your data in the context of providing the services based on legal obligations or obligations imposed upon NNDKP by the statute governing the legal profession (e.g., a know-your-client obligation). The categories of data processed in the context of our relationship with you are your name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill these purposes. In such case, the grounds for processing is the legal obligation. Sending legal, fiscal and IP-related newsletters We may also use your contact details in order to provide to you in electronic form our specialized newsletters on relevant developments in the legislation, case law, and authorities’ practice, but only if you have subscribed and, hence, given your express consent to such processing. The categories of data processed in the context of our relationship with you are your name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us. In this case, the grounds for processing is the express consent to such processing. You can always withdraw your consent expressing thereby your option of not receiving our newsletters in the future by clicking “Unsubscribe” when you receive the respective e-mail or by writing at privacy@nndkp.ro.
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2. If you are a representative or contact person of a NNDKP’s client or potential client
Activity Purposes Categories of personal data Grounds for processing Providing the legal, fiscal and IP-related services requested from us We use your relevant personal data in order to prepare and provide the services requested from us. For instance, in preparing materials required during the course of litigation and arbitration proceedings, we may have to rely on your personal data of relevance for your case. We rely in this case on the legitimate interest in providing our services according to our area of activity and managing the relationship with our clients. Communicating with you We use your contact details in order to communicate with you with respect to your requests and any other relevant business-related matters. Contact details We also rely in this case on the legitimate interest in providing our services according to our area of activity. Data processing as obligation imposed by the law and by the statute governing the legal profession We may process some of your data in the context of providing the services based on legal obligations or obligations imposed upon NNDKP by the statute governing the legal profession (e.g., a know-your-client obligation). The categories of data processed in the context of our relationship with you are your name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill these purposes. In such case, the grounds for processing is the legal obligation. Sending legal, fiscal and IP-related newsletters We may also use your contact details in order to provide to you in electronic form our specialized newsletters on relevant developments in the legislation, case law, and authorities’ practice, but only if you have subscribed and, hence, given your express consent to such processing. In all cases, the data are provided either directly by you or by the client. The categories of data processed in this context are generally your name, position, e-mail, phone, fax, address, identification data, as well as other personal data provided to NNDKP, usually by you, as needed to fulfill the purposes. In this case, the grounds for processing is the express consent to such processing. You can always withdraw your consent expressing thereby your option of not receiving our newsletters in the future by clicking “Unsubscribe” when you receive the respective e-mail or by writing at privacy@nndkp.ro.
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3. If you are an employee or other collaborator of a NNDKP client or potential client
Activity Purposes Categories of personal data Grounds for processing Providing the legal, fiscal and IP-related services requested from us We use your relevant personal data in order to prepare and provide the services requested from us. For instance, in preparing materials required during the course of litigation and arbitration proceedings, we may have to rely on your personal data of relevance for your case. We rely in this case on the legitimate interest in providing our services according to our area of activity. Communicating with you We use your contact details in order to communicate with you with respect to your requests and any other relevant business-related matters. Contact details We also rely in this case on the legitimate interest in providing our services according to our area of activity. Data processing as obligation imposed by the law and by the statute governing the legal profession We may process some of your data in the context of providing the services based on legal obligations or obligations imposed upon NNDKP by the statute governing the legal profession (e.g., a know-your-client obligation). The categories of data processed in the context of our relationship with you are your name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill these purposes. In such case, the grounds for processing is the legal obligation. Sending legal, fiscal and IP-related newsletters We may also use your contact details in order to provide to you in electronic form our specialized newsletters on relevant developments in the legislation, case law, and authorities’ practice, but only if you have subscribed and, hence, given your express consent to such processing. In all cases, the data are provided either directly by you or by the client. The categories of data processed in this context are generally your name, position, e-mail, phone, fax, address, identification data, as well as other personal data provided to NNDKP, usually by you, as needed to fulfill the purposes. In this case, the grounds for processing is the express consent to such processing. You can always withdraw your consent expressing thereby your option of not receiving our newsletters in the future by clicking “Unsubscribe” when you receive the respective e-mail or by writing at privacy@nndkp.ro.
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4. If you are a business partner of NNDKP
Activity Purposes Categories of personal data Grounds for processing Maintaining our contractual relationship with you We use your relevant personal data in order to maintain our contractual relationship with you. Contact details We rely in this case on the performance of our agreement as grounds for processing. Communicating with you We use your contact details in order to communicate with you with respect to your requests and any other relevant business-related matters. Contact details We also rely in this case on the performance of our agreement as grounds for processing. Data processing as obligation imposed by the law and by the statute governing the legal profession We may process some of your data in the context of providing the services based on legal obligations or obligations imposed upon NNDKP by the statute governing the legal profession. The categories of data processed in the context of our relationship with you are your name, e-mail, phone, fax, address, as well as other personal data you may provide directly to us, as needed to fulfill the purposes. In such case, the grounds for processing is the legal obligation. -
5. If you are a representative, contact person, employee or other collaborator of a NNDKP’s business partner
Activity Purposes Categories of personal data Grounds for processing Maintaining our contractual relationship with your business partner We use your relevant personal data in order to maintain our contractual relationship with our business partner. Contact details We rely in this case on the legitimate interest in ensuring that the contractual relationship is managed properly. Communicating with you We use your contact details in order to communicate with you with respect to your requests and any other relevant business-related matters. Contact details We also rely in this case on the legitimate interest of ensuring that the contractual relationship is adequately carried out. Data processing as obligation imposed by the law and by the statute governing the legal profession We may process some of your data in the context of providing the services based on legal obligations or obligations imposed upon NNDKP by the statute governing the legal profession. In all cases, the data are provided either directly by you or by the business partner. The categories of data processed in this context are generally your name, position, e-mail, phone, fax, address, identification data, as well as other personal data provided to NNDKP, usually by you, as needed to fulfill the purposes. In such case, the grounds for processing is the legal obligation. -
6. If you are a job/internship applicant
Activity Purposes Categories of personal data Grounds for processing Carrying on the recruitment process to fill a position within NNDKP We use your personal data in order to carry out the recruitment process, to evaluate and manage your application, to determine if your application is suitable for a position within NNDKP, including in relation to our internship program. If you are not selected for the position for which you applied / for which we initially evaluated your application, we will consider your personal data in future recruitment processes, for other positions within NNDKP similar to those for which you have initially applied / for which we initially assessed your application, but only if you do not object to such processing of your personal data, exercising your right to object according to the information in this Privacy Policy.
In all cases, we will also process your personal data to document how we carried out the recruitment process.
This section is supplemented by specific information that may be adopted and communicated by NNDKP to applicants for certain positions within the NNDKP.
The categories of data processed in the context of our relationship with you are or may be: a) categories of data you provide directly to NNDKP: your name, surname, e-mail, phone, fax, address, home address, date and place of birth, , education and training details, professional qualifications, professional experience, previous collaboration with other employers / collaborators, information on involvement in certain professional projects or activities, results of written and practical tests in professional examinations or certifications, recommendations, salary expectations, as well as other personal data you may provide directly to us;
b) categories of data we process about you from third parties, including publicly available sources: name, surname, photos, professional experience, previous collaboration with other employers / collaborators, information on involvement in certain projects or professional activities, data on marital status and family life, data on social and private life, publishing activity, participation in conferences, round tables and other specialized or social events, telephone, e-mail, home address, interactions in the context of previous employment relationships or collaboration. These categories of personal data are or can be processed from the following sources: websites specialized in recruitment services (BestJobs, eJobs, cariere.juridice.ro, bizlawyer.ro), social networks (Facebook, Linkedin, Instagram) , professional networks (bar association, UNBR, INPPA), references, online professional magazines, online press, websites of former or current employers or collaborators, other sources offered by Google search tools.
The volume and nature of the categories of personal data that we will process during the recruitment process may differ, depending on the position within the NNDKP for which you applied / for which we analyzed your application.
In such case, the grounds for the processing is the legitimate interest of NNDKP which consists in taking the necessary steps to fill the available positions within NNDKP and to document how we conducted the recruitment process. If you were selected to hold a position within NNDKP, in order to complete the necessary formalities for initiating the contractual relationship with you, we will process your personal data based on the agreement that will be concluded with you.
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7. If you are a visitor of our premises
Activity Purposes Categories of personal data Grounds for processing Ensuring security We use your personal data in order to ensure the security of our premises, assets and personnel. The categories of data processed in this context are your name as well as other personal data you may provide directly to us. In this case, we base our data processing on the legitimate interest of NNDKP, namely the protection of such premises, assets and personnel. -
8. If you are a user of our Internet website/blog on the protection of personal data
Activity Purposes Categories of personal data Grounds for processing Visiting our internet site, www.nndkp.ro and the site of our data protection blog, www.privacyoutloud.ro We use the personal data we collect from you when you visit our internet site, www.nndkp.ro, and the site of our data protection blog, www.privacyoutloud.ro in order to monitor the traffic and improve the content of the website. For these purposes, we use cookies, as detailed in the Cookies Policy. The categories of data processed in this context are the hour and date of accessing the Internet website and the IP address from which our Internet website was accessed. We base this data processing activity on our legitimate interest in ensuring the proper functioning of our Internet website, as well as its improvement. -
9. If you are a participant to an event organized by or with the involvement of NNDKP
Activity Purposes Categories of personal data Grounds for processing Organizing events by or with the involvement of NNDKP We may process some of your data in the context of events organized by or with the involvement of NNDKP. The categories of data processed in this context are your photo / video image as well as other personal data that may be provided to us by you directly or by the organizer of the event you attended, such as name and surname, company, email, phone number . In this case, we base our data processing on the legitimate interest of NNDKP of raising awareness about the relevant developments in the legislation, case law, and authorities’ practice on juridical, fiscal and intellectual property matters, according to our area of activity. Photographs / video recordings We may process some of your personal data in the context of taking photos / video recordings with the participants at the events organized by or with the involvement of NNDKP. The categories of data processed in this context are your photo / video images as well as other personal data you may provide directly, at your own initiative. In this case, the legal bases are the following: For overview/ panoramic images/ video recordings, we base our processing on our legitimate interest in conducting and promoting the events.
For close-up photos/ video recordings, we base our processing on your consent, expressed including through gestures, behavior (e.g. your posture in the photo / video recordings). If you do not want to appear in such photos/ video recordings, you always have the possibility to address the photographer directly.
Organizing webinars Documenting and improving the quality of the events (webinars) that we organize; promoting NNDKP by means of disseminating the webinars. If you connect to the webinar as a participant: - We process the following categories of personal data: e-mail address in order to send the webinar invitation and to facilitate your connection; the name and surname that you decide to use for connecting to the webinar. If, however, you do not want your name and surname to be captured, you may access the webinar solely by indicating the name of the entity on whose behalf you are connecting.
- In general, we do not record the webinars that we organize. If, however, we will record a webinar, we will inform you in advance. In such a case, if you decide to connect with the audio and/or video functions of your device activated, we will process your voice and/or image.
If you participate as a panelist/presenter:
- We process the following categories of personal data: your e-mail address in order to send the webinar invitation and to facilitate your connection; the name and surname that you decide to use for connecting to the webinar; the function you hold, the name of the entity for which you work, the topic of the presentation.
- If the webinar is recorded, we will inform you in advance. In such a case, we will process your voice and/or image.
In all cases, we may process any other categories of personal data that you decide to provide directly, in the context of the webinar, including by your interventions within the webinar (e.g. data resulting from the presentation you are sustaining or from the questions being posed by e-mail or directly during the webinar).
If you connect to the webinar as a participant: - We process the following categories of personal data in the legitimate interest of NNDKP: name, surname, email address. The legitimate interest results from the necessity to maintain a record with the persons participating in the webinar, to facilitate access thereof and to prevent any potential security issues. If, however, you do not want your name and surname to be captured, you may access the webinar solely by indicating the name of the entity on whose behalf you are connecting.
- If the webinar is recorded, we process the following categories of personal data based on your consent: voice and/or image.
We consider you are expressing consent by connecting to the webinar with the audio and/or video functions activated.
If you do not agree with the recording, please connect with these functions deactivated.
If you connected with the functions activated, you may change your mind at any time and deactivate them – in this scenario we will stop recording you from the moment you withdraw your consent by deactivating the functions.
If you participate as panelist/presenter:
- We process the following categories of personal data for entering into and executing the contractual relationship between you and NNDKP: name, surname, email address, function, the name of the entity for which you work, topic of the presentation. For processing activities which exceed the contractual sphere and for situations when you are not in a contractual relationship with NNDKP, we rely on our legitimate interest for the processing, in order to maintain a record of organizing the webinar and of the persons participating in the webinar, to facilitate access thereof and prevent any potential security issues.
- In case the webinar is recorded, we process your voice and/or image for performing the contractual relationship concluded with NNDKP in order to participate to the webinar as panelist/presenter.
We will inform you with respect to recording the webinar from the moment of initiating the contractual relationship. In such cases the previously mentioned processing is of the essence for participating as panelist/presenter. Refusal to be recorded may make it impossible for NNDKP to fulfill its processing purposes.
If you are not in a contractual relationship with NNDKP, we process your voice and/or image on the basis of the consent you express and communicate to NNDKP. You may withdraw your consent at any time, such withdrawal producing effects for the future.
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10. If your data are provided by our client/potential client
Activity Purposes Categories of personal data Grounds for processing Providing the legal, fiscal and IP-related services requested from us We use your relevant personal data in order to prepare and provide the services requested from us. The categories of data processed in this context are your name, as well as other personal data which may be provided by the client/potential client or accessed from public sources, as required by the client, as the case may be. In addition, in preparing materials required during the course of litigation and arbitration proceedings, we may have to rely on your personal data of relevance for that case. We rely in this case on the legitimate interest in providing our services according to our area of activity. Data processing as obligation imposed by the law and by the statute governing the legal profession We may process some of your data in the context of providing the services based on legal obligations or obligations imposed upon NNDKP by the statute governing the legal profession. The categories of data processed in this context are your name, as well as other personal data which may be provided by the client/potential client, as needed to fulfill these purposes. In such case, the grounds for processing is the legal obligation. -
11. If you exercise the rights provided under GDPR in your capacity as data subject
Activity Purposes Categories of personal data Grounds for processing Managing data subjects rights provided under GDPR We may also process your data in the context of managing requests regarding data subjects rights provided under GDPR. The categories of data processed in the context of our relationship with you are your identification data, as well as other personal data you may provide directly to us, as needed to fulfill these purposes. In such case, the grounds for processing is the legal obligation. -
12. For all above categories of data subjects
Activity Purposes Categories of personal data Grounds for processing Changes in structure or similar transactions involving any NNDKP entity We may also process your data in the context of changes in structure or similar transactions involving any NNDKP entity. The categories of data processed in this context are your identification data, as well as other personal data either you or the parties to such agreement may provide directly to us, as needed to fulfill these purposes. In this case, the grounds for processing may be represented by the legal obligation (in case NNDKP is legally obliged to disclose certain personal data to public authorities), the performance of the agreement concluded by NNDKP in the context of such transaction (if you are a party to such agreement) or the legitimate interest of NNDKP to carry out the transaction in the most effective manner (in the rest of the cases).
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PROVIDING THE PERSONAL DATA
When the data are required directly from you, NNDKP kindly asks you to provide all categories of personal data we request in the aforementioned purposes, as otherwise we shall not be able to carry out our activity (including, among others, to provide you with our services).
If you provide to NNDKP the personal data of other natural persons, we kindly ask you to communicate to them before such disclosure the modality in which NNDKP intends to process their personal data, as described in this Privacy Policy.
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DISCLOSURE OF YOUR PERSONAL DATA
While as a rule we shall not disclose your personal data to any third parties, we may:
- disclose your contact details to our affiliates within NNDKP, to our contractual partners and to our service providers (including data processors);
- if in your interest and necessary, disclose relevant personal data to courts of law and arbitration panels or relevant authorities, in the context of providing the services you have requested from us;
- disclose relevant personal data to the clients who provided your personal data in the context of providing the services requested from us, if it is necessary to fulfill these purposes;
- in the context of organizing events (including webinars) by or with the involvement of NNDKP we may:
- disclose photo / video images by publishing such images on our site, nndkp.ro, or on social platforms like LinkedIn, YouTube or Facebook. In addition, we may transmit photo/video images to the following categories of recipients: persons who participated at the event; persons who registered for the event but were unable to participate; professional organizations; contractual partners or data processors of NNDKP with whom we collaborate in the context of events; our affiliates within NNDKP.
- disclose data regarding persons who participated at the event to the panelists/presenters of the event, as well as to other participants at the event (for example, if you choose to be active during the events without using the option to stay anonymous).
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DURATION OF PROCESSING
We intend to keep your personal data for the duration of the assistance agreement, as well as afterwards, according to our internal policies and the legal obligations incumbent upon us.
In case the data are not collected in the context of an assistance agreement, such data will be kept for as long as necessary in order to attain the purpose of the envisaged data collection (e.g.: 75 years for data included in the personnel file; 10 years for data of unselected applicants who have applied for a lawyer position or for an internship, respectively 1 year for the data of other applicants – during this period the applicants’ data can be taken considered in subsequent recruitment processes, but only in the absence of applicants’ objection to such processing; 3 years for documenting how the recruiting processes were carried out; 3 years for photo / video images recorded in the context of events organized by or with the involvement of NNDKP).
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VERSIONS TO THIS PRIVACY POLICY
This Privacy Policy is in force as of 18 June 2020.
This Privacy Policy may be updated from time to time. Any updates will become applicable within 7 days as of the publication of the new version on NNDKP’s website.
In your capacity as data subjects, the GDPR provides you with a series of rights including:
Right of access | Allows you to obtain confirmation that your personal data are being processed by us and, if affirmative, the relevant details of such processing activities. |
Right to rectification | Allows you to rectify your personal data if inaccurate. |
Right to erasure | Allows you to obtain the erasure of your personal data in certain cases (e.g., if the data are no longer necessary in relation to the purposes for which it was collected).
Important! We will not be able to act on such requests in all cases, such as where the law compels us to keep data for a certain period, or where the data are necessary for a legitimate interest such as the defense of a right in court. |
Right to restriction | Allows you to request us not to use your personal data in any way except to store it until another request from you is resolved, namely: (i) you have requested the rectification of the data; (ii) you have opposed the erasure of the data in the case of unlawful processing; (iii) you have required us to provide you with certain data for the defense of a right; (iv) you have objected to the data processing. |
Right to object | Allows you to object to further processing of your personal data within the conditions and limits set forth by law.
Important! The law compels us to act on such requests only for direct marketing processing (for example, if you receive emails with our informative notes, you can unsubscribe). In the other cases, we will balance our interests and your particular situation in order to make a final decision. Therefore, please explain why you object to the processing when making such a request. |
Right to portability | Allows you to receive the personal data concerning you that you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another data controller.
Important! The law compels us to act on such requests only for the data previously processed based on your consent or on the performance of the contract concluded with us and only if the processing is carried out by automated means. |
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, a written request at 201 Barbu Vacarescu St., Globalworth Tower, 18th Floor, District 2, Bucharest, 020 276, Romania or by e-mailing us at privacy@nndkp.ro.
You also have the right to file a complaint with the data protection authority, having its headquarters at 28-30 G-ral Gheorghe Magheru Bld. District 1, Bucharest, 010336, Romania.
We are committed to always treat your requests with the utmost attention and address any queries you may have in the shortest time possible.