This Privacy Notice on the personal data processing applies to all your interactions, in your capacity as user, with our Up Mobil mobile app, as described in this document. The app 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 mobile app:
We collect personal data directly from yourself, either via the mobile app, or in the Company’s capacity as value voucher issuer – as part of the value vouchers’ issuance, management and reimbursement processes.
User Account Setting Up and Management
In order to enable you to set up a user account within the mobile app, 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 mobile app.
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 the mobile app. These data are already processed by ourselves, 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 account user, you can also change your contact data, in which case the new contact data will replace the information you have previously provided (if applicable). 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).
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 your mobile app.
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 your mobile app, the mobile app will forward a request to the e-mail app that you currently use. 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.
Push Notifications
The app generates push notifications regarding your transactions, based on our legitimate interest to keep you updated with regard to the approved transactions and balance available on your cards, in order to improve your user experience. You have the option of turning off the push notifications from your device, by going to the section dedicated to permissions granted to the mobile app.
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 installing the app or subsequently, by going to the Settings → Marketing section within the mobile app. 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 mobile app, 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.
In the event of new functionalities being added to the mobile app subsequently, requiring processing of your personal data, or in the event of any changes in the manner in which our processing activities above being carried out, a new version of these regulations shall be posted. You shall be notified accordingly, via a notification within the mobile app.
Polls
You may occasionally be invited to take part in different polls, via push notifications generated by the app, 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.
Location Data
Your mobile app can access your location, but only provided that you have given your consent to do so, via the appropriate settings. Location data are not stored either in the app or on Up Romania servers. These data are only used to enable you to make a selection of our affiliates or to choose among offers that they may have available, to display results that are most relevant to you, for the purpose of providing a mobile app user experience as good and as easy as possible.
You can choose at any time to withdraw the permission granted to our app to use your location data. Selections operated previously among our affiliates and their available offers shall no longer be possible afterwards.
Your user account shall be valid for as long as you use our mobile app. 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 mobile app.
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. Moreover, deletion of your account shall by no means lead to deletion of your contact data (i.e. e-mail address, phone number), should you have chosen to receive notifications via either of these channels.
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.
Location data used by the app to filter results according to relevance of our partners and their offers for you shall not be stored at all.
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.
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.
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.