Personal Data Protection
1. Introduction
The purpose of this information note is to explain what kind of personal data is being processed, why it is processed and the purpose of its processing. We are taking your confidentiality very seriously and we are never going to sell lists or E-Mail addresses. Being fully aware of the fact that the personal data belongs entirely to you, we are doing all of our best to safely storage and process it carefully. We are not going to provide to a third party your personal information without noticing you of our action. This information is very relevant and important. Please read it carefully. This note informs you regarding the information we are processing, that directly concerns you as an employee or client of our organization and, in some cases, even after you are no longer part of our organization. When collecting this information, we act as operators, therefore we are legally obliged to provide you information about us, about our reasons and about the methods we process your personal data and the rights you have upon your personal data.

2. Other Services
This confidentiality policy does not cover a third party`s Apps and Websites you can access by clicking the links on our Website. This action goes beyond our control. Before you provide any kind of personal data, we invite and encourage you to check the confidentiality policy of each Website and/or other Apps.

3. Who are we?
Seaway International CO, with its registered office at Constanta, Blvd. Bratianu, 8th Office, Nr. 28, Constanta County, Business Registration Number: J13/1501/2014, Tax Code: 33415152, data protection officer Ivascu Bogdan - +40 749 109 770, is responsible for the processing of personal data we are either collecting directly from you or from other sources. According to the law, our company, as your employer, is a personal data operator. In order for your personal data to be safely processed, we implemented reasonable measures to protect your personal information.

4. Who are you?
According to the law, you as an employee or client of our company are defined as a "data subject", which means you are a natural person who can either be identified or identifiable. For us to keep a completely transparent regime of processing personal data and for you to be allowed to easily, at any moment assert your rights, we implemented measures of facilitating the communication between you, the subject data, and us, the data operator.

5. Our commitment
The protection of your personal data and information is very important to us. Therefore, we took the commitment of abiding by the national and the European law regarding the personal data protection, and more specifically, by the EU Regulation 679/2016, known as the GDPR, and the following principles:
Legality, fairness and transparency
We are processing your personal data in a legal and fair manner. We are always transparent when it comes to information we are making a use of and you are always informed accordingly.
You have the entire control
Within the boundaries imposed by the law, we are giving you the possibility to examine, to modify and erase the personal data you provided for us and the possibility for you to assert your other rights.
Data integrity and purpose limitation
The data we are processing are within the purposes described at the moment of collecting or within new purposes that are compatible with the initial ones. In each case, our purposes are compatible with the law. We are taking reasonable measures in order to make sure the personal data are complete, valid and updated.
We implemented reasonable measures of security and encryption, thus being able to protect your personal information as best we can. Nevertheless, you need to keep in mind the fact that no Website, no App or internet connection is completely safe.

6. Adjustments
The confidentiality policy can suffer adjustments at any moment. Every policy update or change will become valid as soon as the notification is released, notification which we are going to display either on the website, by E-Mail or on a visible place in our company.

7. Questions and requests
If you have any questions or uncertainties regarding the processing of your personal data, if you want to assert your rights regarding the data we own or if you have any concerns regarding the manner we treat any confidentiality issue we are waiting your request.

8. Your Information
8.1 What kind of information are we collecting about you?
When you establish a commercial or a contractual relationship with us, it is possible for us to receive information either directly from you or from other sources, which include:
- First name
- Surname
- Address
- E-Mail
- Telephone Number
- Signature
- Medical release
- Bank Account
- Diplomas
- Skills
- Studies
- Personal Identification Number
- Birth Date
- Identity Card Number and Serial

8.2 Why are we collecting information?
We are collecting your information under well determined and legitimate purposes which include, but are not limited to the following:
- In order to ensure and conclude a work contract.
- For abiding by the law.
- For salary payment.
- For supervising whether the employees are getting through with their work tasks.
- For fraud prevention.
- For establishing or claiming of a right in the Court Room.
- To draw up a contract, an invoice, a pro-forma invoice.
- To be able to complete an encashment or a payment.
- For a smooth running of the contract.

Also, throughout the work report, information regarding your performance at work and, in some circumstances, regarding disciplinary actions or warnings can be generated. We will keep and process this information based on our own legitimate interest.

8.3 Which is the legal basis regarding the processing?
- The processing is required for the completion or carrying out a contract between you and us.
- The processing is required when in need to fulfill the legal basis.
- We are processing the data we received from you based on your given consent.

8.4 For how long do we store the data?
Your personal data will be stored throughout the required period for accomplishing the given purposes. After the period ends, your personal data will be either destroyed or erased from the computer systems or will be converted into anonymous data that will be used in scientific, historical or statistics researches.

8.5 How do we share your information with others?
By abiding by the applicable law, we can disclose your data to business partners or other third parties, such as companies in search of employees, accountancy firms, human resources firms, public authorities and so on.
We are always making reasonable efforts to make sure of the fact that these third parties have implemented suitable measures of security and protection. Before sharing your personal information, in a reasonable period of time, we will inform you regarding the identity of these companies and we will make sure of the fact that each transfer is legitimate and based on your given consent or on another legal basis.

For instance, we could give your personal data to other companies, such as providers of IT services or communications, accounting, legal services and other third parties with whom we have a contractual relationship. These third parties are carefully selected so that your personal data will only be processed according to the purposes given by us.

Also, we could share your personal data with business partners as a consequence of a common effort to provide a product or a service.

Although unlikely, in the future, the business or a section of the business could be sold, a situation which therefore would mean a transfer of your personal data.

We can share your personal data to other parties by either having your given consent or according to your instructions.

We could also provide your personal information to the State's Attorney, to the Police, the Court or other competent authorities, based and limited by the legal basis and requests which have specifically formulated to fulfill such a purpose.

Within reasonable limits, we will make sure your personal data will not leave the European Economic Area, however, to the extent that we will share your personal data outside the EEA, we will make sure for each case of the fact that the transfers are legitimate and are based on your given consent or on other legal basis.

9. What are your rights?
According to the GDPR, you have the following rights:
- The right to withdraw your consent.
- The right to be informed regarding the processing of your personal data.
- The right to have access to the personal data.
- The right to rectify inaccurate or incomplete data.
- The right to erase ("to be forgotten").
- The right to restriction of the processing.
- Notification obligation regarding rectification or erasure of personal data or restriction of processing.
- The right to object the processing of personal data.
- Automated individual decision making, including profiling.
- The right to appeal Court.
- The right to lodge a complaint with a supervisory authority.

Please, keep in mind:
- You can always withdraw your given consent regarding any aspect.
- When in want of asserting your rights, you can always do that by sending a written, signed and dated request, either in a physical form or via E-Mail.
- The rights counted above are not absolute. There are exceptions, fact which makes each received request to be analyzed, in order for us to decide whether the request is substantiated or not. If the request is not substantiated and will be rejected, we will make sure you have the rejection reasons explained and of the fact that you are fully aware of your rights to lodge a complaint with a supervisory authority or to appeal to the Court of Justice.
- We will try answering the request within 30 days. However, the time limit can be expanded according to different aspects, such as the complexity of the request, the large number of received requests or the possibility for us not being able to identify you in time.
- If we are still unable to identify you, even though we use our best endeavors, and you do not provide us with additional information in order for us to be able to identify you, we are not obliged to act further on your request.

10. Questions, requests and asserting the rights
If you have any questions or uncertainties regarding the processing of your personal data, if you want to assert your rights regarding the data we own or if you have any concerns regarding the manner we treat any confidentiality issue we are waiting your request.

Also, the following rows will provide the contact information of our Data Protection Officer:
Name: Micu Cristina
Telephone Number: +40 744 301 303

Congratulations! You have reached the end! We are glad you spent time from your busy schedule to get informed on what methods we use in order to protect your personal data.

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