ADSONB Privacy Policy

We are concerned about your privacy and are committed to protecting your personal data. This Privacy Policy will inform you of how we handle your personal data, what rights you have in relation to data privacy and how you are protected by law. Please read this Privacy Policy carefully before using our Services.

Contents

1. Who are we?
2. What data do we collect about you?
3. Do we collect data on minors?
4. What are the reasons why we process your personal data?
5. How we inform you about changes to our Privacy Policy
6. Your rights
7. Communication and marketing
8. To whom do we disclose your data?
9. International transfers
10. Where do we store your data and for how long?
11. Technical and organisational measures and security of processing
12. Links to third party websites
13. Contact details
14. Data Protection Authority

This Privacy Policy applies to your use of any products, services, content, features, technologies or functions and any websites, mobile applications, mobile sites or other online products or applications offered to you by us (collectively the “Services”).

1. Who are we?

The primary controller of your data for the purposes of our international services is ADSONB, a limited liability company based in Nicolae Caramfil 49, Bucharest which provides our Services to you in accordance with our Terms and Conditions of Use (hereinafter collectively referred to as “ADSONB”, “we”, “us” or “our/us” in this Privacy Policy). This ADSONB entity is also considered the data controller for the local services it provides. Relevant contact details are set out in Section 15.
The local data controller processing your personal data is: RCC MEDIA DEVELOPMENT SRL, Romanian legal entity with its main office in Bucharest, sector 1, Nicolae Caramfil 49, Bucharest, no. J40/12041/2018, CUI 39782913.

2. What data do we collect about you?

Data obtained from direct interactions
Registration and other account information
When you register to use our Services, we may collect the following information about you:
if you register directly on our platform, you will be asked to provide your email address;
if you register using your Google account: your first and last name, email address and the URL to your Google profile photo;
if you register using your Facebook account: the first and last name that appears on your Facebook account, the email address associated with your Facebook account, your Facebook ID and the URL to your Facebook profile photo. If you have granted Facebook permission through its privacy option within the application (which appears just prior to registering on our Services), we may collect data regarding your gender, age or email address, depending on the permissions you have granted; and
if you register using your ID. Apple: your first and last name and email address; you can decide if you want to share your email address with us when you log in to your account. Apple account.

Depending on the choices you make during your login for our Services or during the process of contracting for our Services, you may choose to provide us with the following additional personal data:

* your name;
* your home address;
* mobile phone number;
* your payment details if you wish to use our paid services as defined by our Terms and Conditions of Use, which, depending on the payment method used, include
* your credit and/or debit card details (cardholder name, card expiry date, credit card type, the first and last four digits of your credit card number, and the CVV/CVC code, which is transmitted to the payment processor and is not stored by ADSONB);
* mobile phone number;
* email address.
* data relating to your education, professional experience, skills, photos, preferences related to the job you want, as well as any other information included in your CV or submitted directly to your employers via our Services, when you opt to provide us with this data via the “My CV” function within your ADSONB Account settings to apply for one of the jobs advertised in the “Jobs” section.

The validity of your account ADSONB

We validate ADSONB user accounts using SMS verification to ensure that each account is associated with a real and unique user. This validation process is started when you first post your ad listing to our Services. To validate your account. ADSONB, prior to the publication of the ad listing, we will send you an SMS from a valid mobile phone number provided by you. This process is completely free of charge.
If you do not agree to the validation of your account, your account will remain active and you will be able to use our Services with limited functionality. This limited account functionality means that you cannot publish new ad listings and you cannot edit, update, promote, expand, reactivate, deactivate or delete existing ad listings until your account is verified by SMS. You will also not be able to receive or reply to any messages from other users.
If you create multiple ADSONB accounts using the same mobile phone number and validate all those accounts via SMS verification, all those accounts will have limited functionality and you will be prompted to choose one of them. Your chosen account will return to full functionality and the other accounts will still have limited functionality.
Any user can request a maximum of 5 SMS messages with verification codes within 24 hours. Account validation is done once per account until the account is successfully verified by SMS by the user.
Once you have validated your ADSONB account, it will remain associated with the mobile phone number used for SMS verification. If you wish to change the mobile phone number associated with your account. ADSONB, you will need to contact our Customer Support team using the Contact Form.

Evaluation and feedback

We collect information about the evaluation and feedback you provide to other users as a result of your interaction with them, as well as the evaluation and feedback you receive from other users, in accordance with the Terms of Use. We do this in order to measure user satisfaction with the transactional experience and to ensure an optimal and effective level of communication between users, as well as to verify and prevent inappropriate actions and behaviors in the context of the activity carried out in connection with our Services, this information allowing us to take necessary and appropriate measures to maintain high standards in the provision of our Services.

Data we automatically collect when you use our Services
When you use our Services, we automatically collect the following information about you:
Information about the devices used
We collect specific information about the devices you use, such as operating system version or unique identifiers. For example, the name of the mobile network you are using, your address. IP address, language settings on your device, device brand and type, operating system and device version, browser type and version, and specific software information such as fonts, system and browser time zone, or available video and audio formats. If you are logged in, we associate your device identifiers with your account on ADSONB.

Location information
Depending on the permissions granted through your device, if you post any ad through our Services, we automatically collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS, Wi-Fi hotspots, and cell towers. Your location data gives us the ability to see articles from users near you and helps you post ads in the area of your location. If we need your location data, we will first present you with a “pop-up” asking you to decide whether or not to allow us to access your location data from your mobile device. If you do not allow us to access your location data, you will still be able to use our Services but with limited functionality. If you do allow us to access your location data, you can change this option at any time thereafter by going to the settings on our website or our mobile app and disabling the permissions granted in connection with location sharing. To learn more about the purposes for which we use your location data and how this data is processed, please see section 4.2 (ii) of this Privacy Policy.
Customer and login data
Technical details, including device Internet Protocol (IP) address, time zone and operating system. We will also store your login information (date of registration, date of last password change, date of last successful login), browser type and version.
Clickstream data
We collect information about your activity on our Services which includes the sites from which you accessed our Services, the date and time stamp of each visit, the searches you performed, the ad listings or banner ads you clicked on, your interaction with such ads or ad listings, the duration of your visit, and the order in which you visited content on our Services.
Cookies and similar technologies
We use cookies for the purposes of administering our users’ sessions, storing your language selection preferences and delivering relevant ads to you. Cookies are small text files transferred by a web server to your computer’s hard drive. Cookies may be used to collect the date and time of your visit, your search history, your preferences and your user name. You can set your browser to refuse all or some cookies or to warn you when websites set or access cookies. If you disable or reject cookies, please be aware that parts of our Services may become inaccessible or may not function properly. For more information about the cookies we use, please see our Policy on Cookies and Similar Technologies. Under Section 9, you will find more information on how we share this information with our analytics providers and advertising partners.
We receive your personal data from various third parties and publicly available sources, which we may combine with or link to the personal data we collect from you through our Services. Specifically, this includes the following information:

3. Do we collect data from minors?

Our Services are not directed to children under the age of 16 and we do not knowingly collect data from anyone under the age of 16. If we become aware that a person under the age of 16 has provided us with personal data, we will delete such data without delay.

4. What are the reasons why we process your personal data?

We will only use your personal data where we are legally permitted to do so. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to conclude or have concluded with you;

when it is necessary in accordance with our legitimate interests and when we consider that our legitimate interests are not overridden by your or other data subjects’ interests or your fundamental rights and freedoms, for example, to improve our Services and to enhance the safety and security of our Services;
when we need to comply with a legal or regulatory obligation.
In certain circumstances, we may also process your personal data based on your consent. In this case, we will inform you of the purpose and category of personal data to be processed at the time we ask for your consent.
We describe below why we use your personal data and the legal grounds we invoke when we do so. We have also identified our legitimate interests where applicable.

To ensure access to and provision of the Services
If you log in using your mobile phone number or email ID, we use your first and last name, mobile phone number and/or email address to identify you as a user and to grant you access to our Services.
If you sign in using your Facebook account or Google account or your ID. Apple account, we use your first and last name and the email address associated with that account, as well as the URL to your profile picture (excluding your Apple account) to identify you as a user of our Services and to grant you access to our Services. The above login information is also used by us to provide our Services to you in accordance with our Terms of Use.
We use third party payment service providers to process any payment you make in connection with our Services. Depending on the payment method, you may be required to provide us with your payment and credit/debit card details, which we will then pass on to the payment service provider for the purpose of processing your payment. We do not store your credit card information unless you choose the option to save this information for easier recurring payments without having to re-enter your details each time. In such cases, we only store the cardholder’s name, card expiry date, card type and the first and last four digits of your card number. We do not store any credit card verification code values and only transmit such values and your credit card number in an encrypted manner for the purpose of processing your payments by the payment service provider.
We store your education data, work experience, skills, photos, preferences related to the desired job, and any other information included in your resume or submitted directly to employers through the Services for the purpose of facilitating your direct communication and transmission of such data to employers who post job advertisements under the “Jobs” category. The legal basis for this processing is the conclusion and performance of the contract between ADSONB and you, under which ADSONB may provide you with services related to the “Jobs” category.

5. How we inform you of changes to our Privacy Policy

We process the above information based on our legitimate interest in conducting marketing activities to provide you with Services that may be of interest to you. Specifically, you may receive certain marketing communications from us:

* by any preferred means of communication, if you have requested such information from us;
* by email, regarding similar products and services, if you already use our Services or have purchased some of our products;
* by telephone or email, if you provided us with your details when you entered the competition; or
* by phone or email if you have registered for a particular promotion.

You can ask us to stop sending such marketing communications at any time by clicking on the unsubscribe link within the email message sent to you or by changing the notification settings in your account.
In situations other than those mentioned above, we will use your email address and mobile phone number to send you direct marketing communications (by email, automated notifications, SMS or phone calls) if you have given us consent to do so by ticking the relevant box at the time of registration.

If you have any problems changing your notification settings, please contact us using our Contact Form.

• To provide you with quality customer service
• we record your telephone conversations with members of the customer relations team or members of the sales team only with your explicit consent;
• if you agree to participate in our customer interaction surveys organised from time to time by ADSONB, we will video record your interaction with our team for the purpose of improving our Services.
• We process the personal data mentioned above for the purpose of in-depth analysis of your interaction with members of our customer relationship team or sales team (as applicable) and to improve the way our team members serve customers.
• You may withdraw your consent at any time and free of charge using our Contact Form.

6. Your rights

In certain circumstances, you have rights under personal data protection legislation. If you wish to exercise any of the rights listed below, please go to your account settings/privacy settings or contact us via our Contact Form:

The right to request access to your personal data (commonly referred to as “data subject access request”). It gives you the opportunity to receive a copy of the personal data held by us relating to your person and to check whether the processing is carried out by us lawfully.
The right to request the rectification of data we hold about you. This gives you the opportunity to have any incomplete or inaccurate data held by us about you rectified, although it may be necessary to check the accuracy of new data you provide to us.
The right to request restriction of the processing of your personal data. This gives you the right to request us to suspend the processing of your personal data in the following situations: (a) if you wish to establish the accuracy of the data; (b) if you believe that our use of the data is unlawful; (c) if you ask us to retain the data even if we no longer need it to establish, exercise or defend a legal claim; or (d) if you have objected to our use of your data. but we have to check whether we have overriding legitimate grounds for using it.
The right to request the deletion of your personal data.This gives you the opportunity to request us to delete or erase your personal data if there are no legitimate grounds for further processing by us. You also benefit from the right to request us to erase or delete your personal data where you have successfully exercised your right to object to the processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Please be aware that for certain purposes we may be required by law to retain your data. See also section 12.
The right to object to the processing of your personal data where we are relying on a legitimate interest (or legitimate interests of a third party) and there are certain elements relating to your particular situation that lead you to want to object to the processing on this ground because you consider that it has an impact on your fundamental rights and freedoms. In some cases, we may be able to demonstrate that we have compelling legal grounds for processing your personal information that override your rights and freedoms. You also benefit from the right to object if the processing of your personal data is carried out for direct marketing purposes. You can exercise your right to object in the following ways, depending on the processing activity you want us to stop:

• regarding marketing emails, click on the unsubscribe link within our emails;
• with respect to SMS marketing messages, automated notifications or phone calls, changing your settings, notifying your account to opt-out;
• with respect to cookie files, clicking on the “opt-out” function on our consent management platform, and;
• regarding any objection raised against the processing of your data in general, you can contact us via the Contact Form.
• The right to request the transfer of your personal data to you or to a third party. We will make your personal data available to you or to the third party of your choice in a structured, commonly used, machine-processable and interoperable format. Please note that this right only applies to automated information in respect of which you have initially given us consent to use it or, by using the information, to perform a contract with you.
• The right to withdraw your consent at any time to the processing of your personal data. It does not affect the lawfulness of any processing already carried out by us on the basis of your consent given above.

7. Communication

We will communicate with you by email, SMS or via the notification app in relation to our Services, with the validation of your account opened with us, to inform you if your ad listings have become active/expired and in relation to other messages regarding transactions in relation to our Services. As it is imperative for us to send you such transaction-related messages, you may not be able to opt-out of such messages.

8. With whom do we share your data?

We may need to share your personal data with the parties listed below for the purposes specified in section 4 above.
Third Party Service Providers: We use third party service providers to help us secure certain aspects of our Services and to maintain and monitor our Services. In this context, your personal data may be shared with the following recipients or categories of recipients:

• payment service providers, such as PayU S.A., may receive your personal data for the purpose of processing payments you wish to make through our Services; for making payments on the ADSONB platform, whether card-based or payment order payments, we use the services of PayU S.A., a company established and operating in accordance with Polish law, with its registered office in Grunwaldzka no.186, Poznan, 60-166, Poland (“PayU”), the payment processor authorised by ADSONB to carry out these operations in accordance with Romanian law. You can find out more about our working relationship with PayU in relation to payment processing under section 11 of the Terms and Conditions of Use.
• Cloud service providers, such as Amazon Web Services, Inc. (AWS), Google Ireland Limited (Google Cloud), Microsoft
• Corporation (Microsoft Azure), who may receive certain of your personal data for cloud storage purposes;
  third party providers of integrated tools, such as Google Ireland Limited (Google Maps), which may receive your location data for the purpose of improving the performance of our Services and customising the content we deliver to you;
• customer support tool providers, such as Zendesk, Inc. which may receive certain data from you such as user account details, customer service requests, message content, for the purpose of communicating with and supporting customers;
• providers of customer relationship management tools, such as ADSONB (sales team), who may receive certain data about you such as user account details or contact details relating to your sales prospect for processing by sales teams;
  Marketing communications service providers.

These third-party service providers may be located inside or outside the EEA.
We carry out checks on our third party service providers and require them to respect the security of your personal data and treat it in accordance with the law. We do not allow them to use your personal data for their own purposes and allow them to process your personal data only for the specified purposes and in accordance with our instructions.
Advertising and analytics service providers: In order to improve our Services, we will occasionally share information about you with analytics service providers, such as Google Analytics 360, who (i) help us analyze how people use our Services in order to improve our Services, and (ii) assist us with online marketing and interest-based advertising activity. For the most part, we share information about you with them in a non-identifiable form for purposes of monitoring and reporting on the effectiveness of campaign performance for our business partners and for internal business analysis. Typically, such information will include a cookie ID, an (abbreviated) IP address, referring URL, and browser and hardware information. By analyzing your browsing behavior on our Services based on cookie files with the help of analytics service providers, we are able to better understand your use of our Services and can improve our product and will be able to present you with more relevant ADSONB-related advertisements when you visit other websites. For advertising purposes, we partner with advertising service providers that are organized under the Interactive Advertising Bureau (IAB) and are listed here: https://iabeurope.eu/vendor-list/. We may share with our advertising partners your ID in relation to first and third party “cookie files” which enable us to serve you more relevant third party advertisements relating to our Services based on your browsing behaviour outside of our Services. To control and manage your ad settings, you can access your settings via a link mentioned in the footnote of our website. For further details on advertising and analytics service providers, please see our Policy on Cookies and Similar Technologies.
ADSONB Group Companies: We will occasionally share information about you with other “ADSONB Group Companies”, meaning entities or subsidiaries directly or indirectly controlled by ADSONB in which ADSONB owns more than 50% of the voting rights or has the right to control such entity (collectively, the “ADSONB Group”). The ADSONB Group is comprised of entities and subsidiaries located throughout the world. Many of these subsidiaries provide a wide variety of Small Advertising Services in numerous countries. You can view all of our classified advertising brands under which we provide our Services at https://www.ADSONBgroup.com/brands. With respect to certain business operations, we leverage our global expertise by using the shared resources of our various subsidiaries to provide you with the best possible Services, including product enhancements, customer support, security and safety, and business intelligence gathering activities. This means that we may need to share your personal data within ADSONB Group Companies, which are located both inside and outside the European Economic Area (“EEA”).
Any sharing of personal data between ADSONB Group Companies will always be subject to the safeguards set out in Section 11, which we have expressly stated in an internal data transfer agreement between all ADSONB Group Companies. This agreement clearly defines the rights and obligations of all ADSONB Group Companies to ensure appropriate technical and organisational measures to protect your personal data.

Mergers and Acquisitions: If our business or assets (or part of them) are reorganised, sold, transferred or merged with another business, your personal data will be disclosed and transferred to the new owners of the business. In such situations, we will take all steps required by law, which may include notifying you and allowing you to decide whether or not you want to continue using our Services.
Law enforcement, regulatory and other authorities: We may disclose your personal data to law enforcement, regulatory authorities, governmental public bodies and other relevant third parties in order to comply with any legal or regulatory requirements.
Publicly Available Information: When you post an item for sale using our Services, you may want to ensure that certain personal information is visible to other ADSONB users. This may include your first and last name, email address, location and contact number. Some information, such as your rating and feedback received from other users, may be publicly disclosed when you post an ad automatically. We also make your rating and feedback available to users you have rated, along with your username. Please be aware that any information you provide to other users may at any time be shared by them with others, so please exercise caution in this regard.
Publicly available information on other ADSONB websites: If your ad is relevant to other platforms managed and developed by ADSONB, such as our website www.autovit.com (“Autovit”) or our website www.storia.ro (“Storia”) and you decide to make your personal data visible to other ADSONB users, this personal data, such as your name, will be made available to other ADSONB users. or your account number (depending on your privacy settings), the content of your ad and your mobile phone number (if you decide to make it public) will be automatically displayed on these platforms, including on Autovit or Storia.
Legal entity customers acting on our Services as employers: for the provision of our Services related to the “Jobs” category and to facilitate the submission of your CV directly through our Services. When you want to apply for a job posted on ADSONB Jobs, we will transmit to employers your education, work experience, skills, photos, preferences related to the desired job, and any other information included in your CV or submitted directly by you to employers through the use of our Services.

9. International transfers

Whenever we transfer your personal data outside the EEA, we ensure that it is afforded a similar level of protection by implementing at least one of the following safeguards:
we will only transfer personal data to those countries that have been deemed to offer an adequate level of protection of personal data by the European Commission. For further details, see European Commission: Adequacy of the level of protection of personal data in third countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission, which ensure the same level of protection for personal data as in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
You can receive a copy of the relevant safeguards that have been implemented by contacting us via the Contact Form.

10. Where do we store your data and for how long?

The data we collect about you will be stored and processed within and outside the EEA on secure servers to provide you with the best possible user experience, for example, for the rapid creation of a website or mobile application. ADSONB user data in the EEA is stored on cloud servers provided by Amazon Web Services, Inc. located in Dublin, Ireland.
We will only retain your personal data for as long as necessary to fulfil the purposes for which we have collected it, including for the purposes of meeting any legal, tax, accounting or reporting requirements.
In determining the appropriate period of retention of personal data, we take into account the volume, nature and sensitivity of your personal data, the potential risk of harm to your personal data caused by unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes by other means, and applicable legal requirements.
We retain your personal data relating to your account for as long as you are registered as a user or until you delete your account, in which case we will ensure that your data is deleted without undue delay and as soon as technically feasible. Depending on the Service you use and the systems where your data is stored, deletion of data may take up to 3 months from the date of your request. During this period, any access to your data will be restricted or blocked immediately.
If there is no activity in your account for more than 24 months, we will close your account in accordance with our Terms of Use and delete all personal data stored in your account, meaning that you will no longer be able to access and use this account. However, we will not close your account and delete your data if you have any open transactions pending or are entitled to a refund of funds credited to your account by you or us. Before we close your account, we will notify you to give you the opportunity to keep your account active, for example, by logging into that account.
When closing your account, we may retain certain data to the extent that this is necessary to (i) fulfil our legal obligations, such as for tax, accounting or auditing purposes, or (ii) to resolve a complaint or dispute in court or to comply with a request from an authority (e.g. in relation to law enforcement). We will retain only that data which is relevant for such purposes and we will delete such data upon expiry of the applicable or statutory retention period or upon fulfilment of the lawful purpose.
In order to ensure customer safety and security and to prevent fraud, we may retain certain data relating to your closed account, such as your ad listings, IP address, moderation and user experience information, for up to 14 months from the date of account closure.
Personal data related to cookie files is stored for the life cycle of the cookie file or until it is deleted by you. You can find out more about this by reading our Policy on Cookies and Similar Technologies.
If you have any questions regarding the retention period of your data, please contact us via the Contact Form.

11.Technical and organisational measures and security of processing

All information received by us about you is stored on secure servers and we have implemented technical and organisational measures that are appropriate and necessary to protect your personal data. ADSONB continually assesses the security of its network and the adequacy of its internal information security program, which is designed to (a) help us secure your data against any accidental or unlawful loss, access or disclosure, (b) identify reasonably foreseeable risks related to the security of the ADSONB network, and (c) minimize security risks, including through periodic risk assessment and testing. In addition, we ensure that all payment data is encrypted using SSL technology.
Please be aware that despite the measures we implement to protect your data, data transfers over the internet or other open networks are never completely secure and there is a risk that your personal data may be accessed by unauthorised third parties.

12. Links to third party websites

Our Services may contain links to third party websites or applications. If you click on one of these links, please note that each will have its own privacy policy. We do not control these websites/apps and are not responsible for those policies. When you leave our Services, we encourage you to review the privacy notice on each website you visit.

13. Contact Details

For any further information or to exercise your rights, please check your account / privacy settings or contact our Data Protection Office using the Contact Form or via the Help Center.
If you wish to contact us to request information regarding the processing of your personal data, you can send a letter to RCC MEDIA DEVELOPMENT SRL, Nicolae Caramfil 49, Bucharest.

14. Data Protection Authority

For data protection complaints, you can contact the Data Protection Authority. You can exercise this right by contacting the authority at your place of residence or place of work or at the address of the data controller.
For Romania, the competent Data Protection Authority is: The National Data Protection Authority, located at: b-dul. Magheru, nr. 28-30, sector 1, Bucharest, website: http://www.dataprotection.ro/