This Privacy Notice on the personal data processing applies to all your interactions, in your capacity as user, with our Up Online platform, as described in this document. The platform is meant to be used by holders of at least one of the Up Romania products, in electronic format.
Your personal data are processed by UP ROMANIA SRL, a Romanian company having its registered offices at 42, Soseaua Dudești-Pantelimon, district 3, 033094 Bucharest, registered with the Trade Register under registration no. J40/6468/2002, fiscal identification number RO14774435 (hereinafter referred to as „The Company” or „Up Romania”).
The safety and confidentiality of your personal data is of the utmost importance to us, Up Romania. Therefore, we shall take all necessary and reasonable measures in order to make sure that your personal data remain secure and confidential and that their processing is carried out according to the applicable legal provisions, exclusively for the purposes mentioned below.
Please note that we process the following data as part of your interactions with the platform:
We collect personal data directly from yourself, either via the platform, or in the Company’s capacity as value voucher issuer – as part of the value vouchers’ issuance, management and reimbursement processes; in the latter case, we kindly remind you that your name, surname and your PIN are transmitted to us by your employer, for the purpose of issuing the value vouchers for you, in accordance with the applicable legal provisions.
User Account Setting Up and Management
In order to enable you to set up a user account within the platform, we process your e-mail address, your first name and surname and the password you define, as part of you having entered into an agreement with us. In this context, agreeing to the Terms and Conditions means that you have also accepted the conditions regulating use of the platform.
Account setting up also means that you will have to type in the number of your card (of one of the Up Romania products that you are the holder of), as well as the last 6 figures of your personal account number (in Romanian, CNP). This is construed to be, in fact, a security measure to ensure that you are the only person having access to your personal data. These data are already processed by us, given the Company’s legal duty to do so, given its core business and its main scope of activity and in accordance with the special legislation applicable in the case of issue of value vouchers, in paper format and respectively electronic format.
From the section dedicated to your user account, you can also change your contact data, in which case the new contact data will replace the information you have previously provided (if applicable) – i.e. filling out or, as the case may be, editing your phone number in the app shall lead to overwriting your old phone number and produce effects for the future as regards sending commercial communications by Up Romania (when you have previously consented to such), sending transactional notifications and also obtaining your card PIN by IVR (in the latter two cases, when your employer had contracted for you such additional services). Your contact data are processed in order to enable us to send you e-mails regarding the setting up of your account and, as the case may be, to send you notifications by sms with regard to the topping up of your cards and to the transactions carried out (provided that your Employer has requested us to provide this additional service).
When you create a user account by means of the Up Online platform, such account may be accessed either via the platform or via Up Mobil app. Expressing your preferences as regards the communications sent by Up Romania may be done using any of the two means, and the deletion of the account will imply the impossibility of accessing your account both via Up Online platform and via Up Mobil app.Data on the Transactions Carried Out and Available Balance
In our capacity as value voucher issuer, we have access to the transactions carried out and to your available balance, which we process based on the requirements enforced upon us by the applicable legislation in force (i.e. legal obligations), in order to carry out the complete circuit of value vouchers, from issue to reimbursement. These data are also placed at your disposal via the platform.
Recommend a Partner
When you fill out the form available at the Recommend a Partner section, we ask for your name and surname, your phone number and your e-mail address in order to contact you as regards your recommendation. We are processing these data based on our legitimate interest to verify and keep you updated with the status of your recommendation, for the purpose of keeping in touch with you and to prove to you our real interest in concluding a contract with the potential partner recommended by you.
Feedback
Should you wish to make a request or send us your feedback, by accessing the Feedback section of the platform, we will process your e-mail address, the message itself, as well as any other personal data that you thus entrust to us shall be processed based on your consent, for the purpose of recording your message.
Notifications
Up Romania may send you information regarding amendments of Terms & Conditions or of the present Privacy Notice or information regarding technical issues of the app or of our systems, based on our legitimate interest to keep you informed and to better preserve your rights as conferred by the law.
Commercial and Marketing Communications
Moreover, we also process your contact data in order to send commercial and marketing communications, once you have given your consent to do so, either when creating your user account or subsequently, by going to the Settings → Marketing Notifications section within the platform. You can choose to receive such notifications on any of the three available channels: push notifications, sms or e-mail. You have the right to withdraw your consent either by accessing the same section within the platform, or by sending a request using our contact data below. Furthermore, all messages received by e-mail include a quick link that you can use to unsubscribe.
Polls
You may occasionally be invited to take part in different polls, via notifications in the platform, these being prompted based on our legitimate interest in finding out how pleased you are with the services we provide. Participation to polls is carried out free of charge, voluntarily and anonymously.
Your user account shall be valid for as long as you use it. Should we find out that your account has been inactive for at least 12 consecutive months, it shall be deactivated. Moreover, you can also delete your user account at any time using the platform. The deletion of the user account implies the impossibility to access it both my means of the mobile app and the Up Online platform.
However, deletion of your account shall engender no consequences with regard to the processing of your data needed in order to issue value vouchers for you or data that might be required in order to provide additional notification services, according to your Employer’s option. Otherwise, deletion of your account shall lead to deletion of your e-log-in data from our database and to unsubscribing you from all the commercial communications sent by Up Romania should you have previously chosen to receive such communications.
Your phone number shall be retained by Up Romania for the entire period in which you benefit from the value tickets issued by us, followed by a reasonable period considered as such by Up Romania.
Your personal data communicated by your feedback messages, as well as through the Recommend a Partner form shall be stored for the duration required for the registration of your message, plus an additional period that cannot exceed 6 months. Your e-mail address or other personal data placed at our disposal may be stored for a longer period of time, provided that these are processed by the Company for other stated purposes.
For marketing purposes, we shall process your contact data for a two-year period or, should you have no longer agree to receive commercial messages, until withdrawal of the consent given previously. Upon expiry of the two-year period, we may request you to renew your consent, in order to be able to further send you such messages.
The Company is currently not transferring any of your personal data to legal entities or individuals outside the company. Should this happen, you shall be informed with regard to any transfer of your personal data, unless such transfer or disclosure occurrences are explicitly provided by the European Union laws or by the national legislation and result from our duty to comply with the legal provisions in force.F. Personal
The security, integrity and confidentiality of your personal data are of the utmost importance for us. The Company shall therefore take all the organizational and technical in this respect.
Should we discover any personal data security breach that may result in risks to your rights and liberties, we shall notify the National Authority for the Personal Data Processing („ANSPDCP”) within 72 hours. You shall also be informed about the respective security incident, should it be likely to result in high risks to your personal rights and liberties.
You have the following rights related to the processing of your personal data:
Should you have any queries with regard to processing of your personal data or should you have any requests or wish to exert any of your rights related to the processing of your personal data, please feel free to contact us at our offices, 42, Șoseaua Dudești-Pantelimon, district 3, 033094 Bucharest or using ourthe phone number 021.402.82.23. Alternatively, you can also get in touch with our personal Data Processing Officer at the following e-mail address: gdpr.upromania@upromania.ro. Each request shall be analyzed as soon as possible, but no later than one month.
Should you consider that we haven’t met all your requests or should you be unsatisfied with our answers, you can file a complaint with the ANSPDCP. Furthermore, you can also bring the matter before the competent legal courts.
General information about cookies
Cookies are small text files that your browser stores when accessing the Up Online platform, for the platform to remember your preferences and certain information (such as the language displayed and the options set on the platform), so you can have a personalized and optimized experience as what concerns the display and the content. Cookies contain information on your IP, your type of browser, your device, certain navigation preferences that you have set on the platform. Cookies cannot identify you in a direct way but your IP can be associated with a country, a city and an internet service provider. Cookies may be stored in your browser by the platform or by other traffic or advertising services (partners).
What are the cookies we use?
Up Romania uses session cookies, cookies with a limited validity period and permanent cookies. The session cookies are temporary files that access certain data about yourself or your device until the session had ended, when they shall be permanently deleted. Cookies with a limited validity period shall be deleted when the validity period shall expire, and permanent cookies shall remain active for an unlimited period of time. In the case of the latter two, you have the possibility to manually delete them, in which case the organization managing the cookie shall no longer receive data from you or your devise, as the case may be. If you scroll down you may find more details about how to manually delete cookies.
Necessary cookies are functional cookies, which are essential for the functioning of the platform and cannot be deactivated. These cookies allow you to securely access different sections of the platform. They do not contain any personal data that may directly lead to your identification.
|
Name |
Organization |
Purpose |
Type |
Expiry |
|
SESSION |
upromania.ro |
Preserves users states across page requests. |
HTTP |
session |
|
necessary |
upromania.ro |
Preserves users preferences on accepting or not cookies. |
HTTP |
1 year |
These cookies are necessary to understand the way users interact with the platform. We only receive anonymous information via statistics on how the platform is being used, favorites pages or your behavior. Thus, we can improve the users experience.
These cookies activate useful features of the platform, allowing you to express your preferences such as the language of the platform, your type of browser, your geographic area.
We are not currently using such cookies.
Marketing cookies may belong to third-party services or to organizations helping us to perform marketing and advertising actions. These cookies are being used to create marketing profiles and to display you ads on other sites you may visit. The information that we access via these cookies do not represent data that may directly lead to your identification; they can only identify your browser. This process does not imply targeting you for direct marketing purposes. You shall not receive from us, by simply accessing the platform and accepting this type of cookies, any information via e-mail, sms or other direct communication channels.
Deleting cookies
Usually, browser-like apps implicitly allow cookies to be installed in your device. You can change your browser settings as to implicitly decline the installation of any cookie or as to inform you any time a new cookie is being installed in your device.
For more information on how to control and prevent installing cookies on your device, you can consult the links below, depending your browser type. Please consider that limiting the use of cookies may affect some of our platform’s functionalities.
Internet Explorer / Microsoft Edge:
(https://privacy.microsoft.com/en-gb/privacystatement)
Firefox:
(https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences)
Google Chrome:
(https://www.google.com/intl/en_uk/chrome/privacy/)
Safari:
(https://support.apple.com/en-gb/guide/safari/sfri11471/mac;
https://support.apple.com/en-gb/HT201265)
Any changes of the information included in this Privacy Notice shall be brought to your attention forthwith – no modification of the Privacy Notice shall affect in any way whatsoever the rights granted by the law.
[Version from September 2019]