PRIVACY POLICY OF NOVA POSHTA GLOBAL RO SLR

I. GENERAL INFORMATION

1. 1
   This privacy and use of cookies policy is a set of rules for the processing of personal data and collection of cookies (hereinafter: Policy) by NOVA POSHTA GLOBAL RO SLR with its registered office in Romania, Bucharest, District 3, Burniței 24 str.of. A74, floor 1, entered into the Registered at the Trade Register under nr. J40 /18831/2022 tax code RO46883384 (hereinafter: "NOVA POSHTA GLOBAL RO SLR" or "Administrator or Company"), incl. on the www.novapost.com website (hereinafter: the "Service"), defines what data we collect about consumers, who use our services and to other individuals whose personal data we process in the framework of our activities, including candidates for work. This Privacy Policy also applies to personal data processing and communication on social media accounts of the Company (e.g. Facebook, Instagram, Linkedin), via phone, e-mail, or letter. how we use it and who we share it with. This information also describes the measures we take to protect your personal data.
2. 2
   Users can contact the Administrator in the following way:

   • 2.1
     by letter to the following address: Romania, Bucharest, District 3, Burniței 24 str.of. A74, floor 1;
   • 2.2
     via e-mail: dpo@novapost.com;
   • 2.3
     by phone: +40 37 37 85 207.
3. 3
   Personal data is any information relating to an identified or identifiable natural person. The scope of this type of data includes, among others, name, surname, address, telephone number and e-mail address. Information that cannot be traced back to an identified or identifiable person (such as statistical data) is not considered personal data. 
4. 4
   Before you start using the Service and the services of the Company, the User should read this privacy and use of cookies policy. The purpose of the document is, inter alia, fulfillment of the information obligation referred to in art. 13 p. 1 and 2 and also art. 14 p. 1 and 2 of the Regulation of the European Parliament and the Council (EU) 2016/679 of 27 April 2016 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 (General Data Protection Regulation), (hereinafter: "GDPR").
   

II. APPLICABLE LAW ON PERSONAL DATA PROTECTION AND CONFIDENTIALITY OBLIGATION

1. 1
   NOVA POSHTA GLOBAL RO SLR is subject to the provisions of Regulation of the European Parliament and the Council (EU) 2016/679 of 27 April 2016 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 as well as other relevant national data protection legislation.
   

III. INFORMATION PROTECTION

1. 1
   NOVA POSHTA GLOBAL RO SLR, by applying appropriate technical and organizational measures, makes every physical and technical effort to protect personal data against loss, damage, disclosure to not authorized personal, alteration or improper use.
2. 2
   All notifications regarding the protection of personal data are registered and explained in detail and analyzed in accordance with applicable law.
   

IV. RIGHTS OF DATA SUBJECTS

The data subject has the right to:

• 1
  receive the information and have an access to data concerning him/her (the right of access by the data subject under art. 15 GDPR);
• 2
  rectify his/her personal data that are incorrect and update his/her data (the right to rectify data, Article 16 GDPR);
• 3
  request the deletion of his/her personal data (the right to delete data under art. 17 GDPR);
• 4
  requests to cease processing (the right to limit processing under art. 18 GDPR);
• 5
  request the transfer of data to another administrator (the right to transfer data under art. 20 GDPR);
• 6
  objecting to the processing of his/her personal data (the right to object under art. 21 GDPR).

V. WITHDRAWAL OF CONSENT TO THE PROCESSING OF PERSONAL DATA AND MECHANISM OF WITHDRAWAL OF CONSENT

1. 1
   In the case the basis for data processing is the consent of the data subject, we inform you that this person has the right to withdraw consent at any time. The declaration of withdrawal of consent is made by providing the Administrator by e-mail or postal delivery, in accordance with the data provided, a statement in this regard.
2. 2
   Receiving of such a declaration does not affect the lawfulness of the prior processing of personal data.
3. 3
   Withdrawal of consent to the processing of personal data is ineffective to the extent necessary for the proper provision of services or provisions of an ongoing contract, including complaint proceedings. In this case, the withdrawal of the above-mentioned consent becomes effective upon resignation from services, termination of the contract or complaint process.
4. 4
   Despite the effective withdrawal of consent to the processing of data, the Administrator is entitled to process them to the extent necessary for:

   • 4.1
     pursuing claims related to the concluded contract;
   • 4.2
     fulfillment of the legal obligation incumbent on the Administrator;
   • 4.3
     performance of a task realized in the public interest or in the exercise of public authority vested in the administrator;
   • 4.4
     purposes resulting from legitimate interests realized by the Administrator or by a third party, except where these interests are overridden by the interests or fundamental rights and freedoms of the data subject.
     

VI. IMPLEMENTATION OF RIGHTS ARISING FROM GDPR

In connection with the submitted declaration of withdrawal of consent to data processing, for the purpose of identifying the person submitting the declaration and in order to protect against unauthorized access to data, NOVA POSHTA GLOBAL RO SLR is entitled to obtain additional confirmation of the identity of the person submitting such a declaration.

VII. PERSONAL DATA CATEGORIES. PURPOSES OF THEIR PROCESSING AND LEGAL BASIS

1. 1
   In order to provide the Services and fulfill the Agreement with its Clients (Senders, Addressees) [Pursuant to art. 6 p. 1b) GDPR] NOVA POSHTA GLOBAL RO SLR processes as the Administrator the necessary data, such as:

   • 1.1
     Client's data (registration data, data of contact persons on the customer's side, i. e. name, surname, position, telephone number, signature, e-mail address, job position);
   • 1.2
     Sender's data (sending address and necessary contact details, signature, payment information and other data needed to perform the service ordered by the sender);
   • 1.3
     data of the Addressee (name and surname, signature, address, zip code, city, country, and optionally other data necessary for the realization provided to the data Administrator by the sender of the shipment or indicated by himself the Addressee, such as e-mail address, telephone number).
     
2. 2
   Providing personal data is voluntary, but it is necessary for the performance of the Services provided by NOVA POSHTA GLOBAL RO SLR. If the Sender provides additional personal data of the Addressee, in connection with the selection of one of the Additional Services, the Sender is responsible for the correct collection of this data, in particular for having the Addressee's consent for their transfer to NOVA POSHTA GLOBAL RO SLR.
3. 3
   In some cases, the data is also processed:

   • 3.1
     on the basis of consent [Pursuant to Article 6 p. 1 a) and art. 7 GDPR] - in particular for marketing purposes or in relation to data provided voluntarily by the Addressee in connection with the delivery of the parcel.
   • 3.2
     and the legitimate interests of the Administrator [Pursuant to ART. 6 p. 1 f) GDPR] – in particular, such as: solvency control, compliance programs or sanctions, satisfaction surveys with the services provided (as well as to analyze the results of surveys completed as part of this survey and the possibility of return contact with the person providing the answer).
     
4. 4
    Using the NOVA POSHTA GLOBAL RO SLR website may involve the processing of personal data for the following purposes:

   • 4.1
     Placing an order and activities aimed at its implementation.
   • 4.2
     Shipments tracking [Pursuant to art. 6 p. 1b) GDPR] – the Parcel number is required to provide information about the status of the parcel.
   • 4.3
     Contact via the contact form [Pursuant to art. 6 p. 1f) GDPR] - data sent via the contact form, such as: name and surname, address, postal code, city, e-mail address are required to process and answer the inquiry; [Pursuant to art. 6 p. 1a) GDPR] consent to the processing of data such as: e-mail address, telephone number is required for contact in order to present a commercial offer.
   • 4.4
     Contact with a consultant via chat [Pursuant to art. 6 p. 1f) GDPR] - data sent during the conversation with the consultant, such as e-mail address, first and last name, address, postal code, city, are processed in order to verify the question asked and answer the question.
   • 4.5
     Parcel redirection [Pursuant to art. 6 p. 1b) GDPR] – via the NOVA POSHTA GLOBAL RO SLR website, the Addressee has the option to change the delivery address if he or she cannot collect the parcel in person. For this purpose, we collect the following personal data:

     • 4.5.1
       name and surname of the Addressee or company name;
     • 4.5.2
       street / house number; 1.c. zip code / place of residence;
     • 4.5.3
       e-mail address and description of the desired location.
       
5. 5
   Direct marketing and sales promotions:
   
   When you place an order on our sites, we will call or send you occasional direct marketing via e-mail and SMS about similar products and services. We have a legitimate interest in sending you this marketing: to promote our products and services to our customers and to make sure you are aware of the best offers and deals available.
   
   Can I stop receiving direct marketing?
   
   Yes! You are always free to unsubscribe from direct marketing at any time; this will never have an impact on our commitment to provide you with great service and a quality product. To withdraw consent to marketing, please unsubscribe directly following the instructions provided in the e-mail or SMS. We will stop sending you marketing messages as soon as possible but, in any event, will do so no later than 30 days from your request.
   
   How long do you keep me opted in for direct marketing?
   
   If you haven't placed an order in 5 years, then we will automatically opt you out of receiving further direct marketing. If you order from us again and have not previously unsubscribed, or if you place an order and opt-in to direct marketing, we will recommence sending marketing communications to you.
6. 6
   Selection of candidates
   
   During the recruitment process, the following categories of your data will be processed, for the purposes and on the lawful basis.

   • 6.1
     Basic data (name, date of birth) where applicable;
   • 6.2
     Contact information (address, telephone number, email address, etc.), if applicable;
   • 6.3
     Application details (resume, motivation letter, certificates, references, interview notes and any data you provide us or wish to provide during the interview);
   • 6.4
     Photo, video, if possible;
   • 6.5
     Citizenship and work permit, if applicable;
   • 6.6
     Details of health for work, if applicable;
   • 6.7
     Previous convictions, if relevant to the advertised position, for example, for drivers;
   • 6.8
     Data that you have provided through public platforms used for professional purposes, in accordance with the applicable terms of the company responsible for managing the platform;
   • 6.9
     Communication and means of communication (e.g. confirmation of your application or information about a phone/video interview if possible).
     
     In addition to these categories of data, in order to evaluate each job application, we need data that tells us how well suited you are to the position in question.
     
     To manage our relationship with you, including

     • 6.9.1
       to assess your suitability for work (purposes), the legal basis for processing is contract performance
     • 6.9.2
       to set up and conduct (video) interviews (purpose), the legal basis for processing is contract performance
     • 6.9.3
       to check your data for compliance with applicable sanctions lists and laws (purpose), the lawful basis for processing is a.) legal obligation and b.) legitimate interest.
       
       How we collect your data
       
       We collect data directly from you when you provide your details on our careers website or through other communication channels. When you use another channel, for example through public platforms used for professional purposes such as LinkedIn, we will process your data in accordance with the applicable terms of that platform. When we work with recruitment agencies, we receive your data indirectly. In this case, these institutions are responsible for ensuring the accuracy of the data and transferring it to us in accordance with applicable law.
7. 7
   Video cameras We monitor and process your personal data when you visit our postal services, both for your personal safety and for the safety of our employees, customers and property. Video surveillance is carried out in accordance with strict security and confidentiality rules using modern technologies and equipment. Video surveillance recordings are stored in our systems for up to 30 calendar days.

VIII. SHARING OF DATA BY NOVA POSHTA GLOBAL RO SLR

1. 1
   NOVA POSHTA GLOBAL RO SLR may provide personal data:

   • 1.1
     to subsidiaries of NOVA POSHTA GLOBAL RO SLR and subcontractors (e. g. transport partners, operating parcel collection points or parcel lockers) within the European Union or outside it for the purpose of delivering parcels from the sender to the Addressee [Pursuant to art. 49 p. 1b) respectively c) GDPR];
   • 1.2
     entities that are subject to a contract for the provision of services for NOVA POSHTA GLOBAL RO SLR or on behalf of NOVA POSHTA GLOBAL RO SLR (Processors), in particular an IT service providers;
   • 1.3
     other persons or organizations based on applicable law;
   • 1.4
     banks and payment operators in order to perform the transaction (including payments made using the codes);
   • 1.5
     law enforcement officers and authorities to comply with national security requirements or as part of a legal process to protect property, or to pursue an investigation of a violation of NOVA POSHTA GLOBAL RO SLR principles and policies, unauthorized access or use of NOVA POSHTA GLOBAL RO SLR equipment, or any other illegal activity.
     
2. 2
   Only the Sender and the Addressee have the right to receive information about the shipment.
   

IX. STORAGE PERIOD AND DATA DELETION

1. 1
   NOVA POSHTA GLOBAL RO SLR processes personal data only for the time necessary to achieve the purpose for which they were collected. The period of data storage is determined based on the following requirements:

   • 1.1
     operational requirements: the period in which the information is necessary to perform the provided Services.
   • 1.2
     legal requirements: the period in which NOVA POSHTA GLOBAL RO SLR is required to store data for a specified period of time to comply with the law.
   • 1.3
     legitimate interests of NOVA POSHTA GLOBAL RO SLR: the period in which data is processed for the purpose of their implementation, in particular to establish and pursue possible claims in connection with the Services provided.
     
2. 2
   What information about you do we collect and how do we use it
   

• 1
  Archived data is available only to authorized employees. After the expiry of the period authorizing data storage, they are permanently deleted.

X. TRANSMISSION OF PERSONAL DATA TO COUNTRIES WHICH ARE NOT MEMBERS OF THE EUROPEAN ECONOMIC AREA

1. 1
   Personal data is transferred to third countries in the event that the services provided by NOVA POSHTA GLOBAL RO SLR are also to be performed in the territory of a third country. Such a situation occurs in particular when sending a parcel via NOVA POSHTA GLOBAL RO SLR takes place to a country that is not a member of the European Economic Area. Personal data may also be transferred to NOVA POSHTA GLOBAL RO SLR subcontractors (e. g. entities that deliver the parcel in the territory of a third country) and entities providing NOVA POSHTA GLOBAL RO SLR tax, legal, audit and billing consultancy, if they operate in a third country.
2. 2
   NOVA POSHTA GLOBAL RO SLR does not transfer personal data to international organizations.
3. 3
   NOVA POSHTA GLOBAL RO SLR does not transfer personal data to third countries if it is impossible or would be inconsistent with generally applicable law.
4. 4
   The level of protection of Personal Data outside the European Economic Area ("EEA") is not the same as the level provided by European law. Therefore, NOVA POSHTA GLOBAL RO SLR transfers personal data outside the EEA only when it is necessary, while ensuring an adequate level of data protection, mainly through:

   • 4.1
     cooperation with entities processing personal data in countries for which an appropriate decision of the European Commission has been issued regarding the assurance of an adequate level of protection of Personal Data;
   • 4.2
     use of standard contractual clauses issued by the European Commission, provided that an adequate level of personal data protection is ensured;
5. 5
   In the event of a justified intention to transfer personal data outside the EEA, other than the one indicated above, NOVA POSHTA GLOBAL RO SLR will inform about this fact at the appropriate stage of data processing, in accordance with applicable law.

XI. INFORMATION ON DATA COLLECTED THROUGH THE NOVA POSHTA GLOBAL RO SLR WEBSITE

1. 1
   Event log and cookies. Each time a user accesses the NOVA POSHTA GLOBAL RO SLR website, the data is saved in a log file. The scope of temporarily stored data includes:

   • 1.1
     the IP number of the computer from which the query was received;
   • 1.2
     domain name;
   • 1.3
     date and time of access;
   • 1.4
     http response code;
   • 1.5
     visited pages;
   • 1.6
     name and version of the operating system;
   • 1.7
     browser name and version;
   • 1.8
     screen resolution.
2. 2
   Using the NOVA POSHTA GLOBAL RO SLR websites may be associated with the use of cookies by NOVA POSHTA GLOBAL RO SLR servers. These files are used by site administrators. Each user can configure their browser settings so that cookies are not accepted by it. In this case, no data will be saved on the visitor's computer. Information stored in cookies will not be sent to NOVA POSHTA GLOBAL RO SLR.

XII. COOKIE

1. 1
   Cookies are internet data, in particular text files, which are stored on the end device (computer, mobile phone, tablet) of the User. First of all, they contain the name of the website of their origin, their unique number, and the storage time on the end device. Cookies are used to provide the Administrator with statistical information on Users' traffic, Users' activity and the manner of using the Service. They allow the content and services to be adjusted to the User's preferences. 
   
2. 2
   In connection with our use of cookies, we provide the most important information about their use:

   • 2.1
     The cookie mechanism is not used to obtain any information about Users, except for information about their behavior on the Service pages.
   • 2.2
     The Administrator stores cookies on Users' computers in order to:

     • 2.2.1
       proper adjustment of the Service to the needs of Users and optimization of the use of websites;
     • 2.2.2
       remembering the preferences and individual settings of the User, recognizing the User's device and properly displaying the website tailored to his needs (full version, mobile version of the website);
     • 2.2.3
       creating Website viewing statistics that help to understand how Users use websites, which allows improving their structure and content;
     • 2.2.4
       maintaining the User's session (after logging in), thanks to which the User does not have to re-enter the login and password on each subpage of the Website;
     • 2.2.5
       saving the cart data in the online store in order not to lose them after visiting the Service again.
3. 3
   The website uses two main types of cookies : session ( session cookies ) and permanent ( persistent cookies ). Session cookies are temporary files that are stored on the website user's end device until the user logs out, leaves the website, or closes the software (web browser). Persistent cookies are stored on the end device of the Website User for the time specified in the cookie settings or until they are deleted by the Website User.
   
4. 4
   The service uses two main types of cookies :

   • 4.1
     "Necessary" cookies that enable the use of services available on the Website, such as authentication cookies used for services that require authentication on the Website, cookies that are used to ensure security, such as those used to detect authentication fraud on the Website;
   • 4.2
     "Functional and analytical" cookies that allow "remembering" the settings selected by the User and personalize the User interface, for example, regarding the User's selected language or region, font size, appearance of the website and allow collecting information about how use the pages of the Website, etc.;
   • 4.3
     "Advertising" cookies that allow Website Users to provide advertising content that is more relevant to their interests.
     
5. 5
   When you first visit the website, you will be shown information about the use of cookies . The use of the website requires the processing of "necessary" cookies . The processing of other cookies is possible after giving consent to the use of cookies in accordance with the provisions of this Policy. You can always withdraw your consent by changing the cookie settings in your browser. These settings can be changed, in particular, in such a way as to block the automatic processing of cookies in the web browser settings or to inform each time they are placed on the end device of the Website User. Detailed information on the possibilities and methods of processing cookies is available in the software (web browser) settings. "Advertising" and "analytical" cookies placed on the end device of the Website User may also come from the Administrator's partners and be used for analytical and marketing purposes. Detailed information about this can be found in the privacy policy of this partner. The administrator uses the following analytical and marketing tools provided by partners:
   

   • 5.1
     Google Ads – files used by Google to configure ads in its services, for example in the search engine or to display ads on the Internet, more information: https://policies.google.com/technologies/partner-sites
   • 5.2
     Facebook pixels – files used to match advertising on Facebook services to the individual preferences of the recipient, more information: https://www.facebook.com/privacy/policies/cookies/
   • 5.3
     Google Analytics - files used to analyze how users use the website, create statistics and reports, more information: https://policies.google.com/technologies/partner-sites
     

XIII. BLOCKING THE ACTION OF COOKIES

1. 1
   In many cases, web browsers allow cookies to be stored on the User's end device by default. Website Users can change cookie settings at any time, e. g. in such a way as to block the automatic handling of cookies or inform about their every posting on the Website User's device. Detailed information on the possibilities and methods of handling cookies is available in the browser settings or on the following websites:

   • 1.1
     in the Internet Explorer browser;
   • 1.2
     in the Mozilla Firefox browser;
   • 1.3
     in the Chrome browser;
   • 1.4
     in the Safari browser;
   • 1.5
     in the Opera browser;
     
2. 2
   The Administrator informs, however, that limiting the use of cookies may affect some of the functionalities available on the Website's pages.
   

XVIII. COMPLAINTS

1. 1
   If you have a complaint about the manner in which NOVA POSHTA GLOBAL RO SLR have handled your data please submit it in writing, providing as much detail as possible, using the contact details at Section I of this policy above. NOVA POSHTA GLOBAL RO SLR will work with you to resolve any issues without delay.
2. 2
   If you believe that your rights under the General Data Protection Regulation have been infringed you have the right to lodge a complaint with NOVA POSHTA GLOBAL RO SLR supervisory authority. In Romania, the relevant authority is the National Supervisory Authority for Personal Data Processing – information and contact details can be found on its website (http://www.dataprotection.ro/).
   

XIX. CHANGES TO THIS POLICY

Any changes NOVA POSHTA GLOBAL RO SLR may make to this privacy policy in the future will be posted on the website www.novapost.lt. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use any / all of NOVA POSHTA GLOBAL RO SLR Services.