This policy gives you information about the personal data we collect from you or which you provide us through this website and how they will be processed by us. We undertake to respect your privacy, respecting all data protection laws and regulations, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
Please carefully read the following in order to understand our point of view and practices regarding your personal data and the way we treat them.
1. PERSONAL DATA – WHAT WE COLLECT, HOW WE DO IT & HOW WE USE IT
In the process of administering this website, we collect certain information (“personal
data”) about identified individuals, or that may lead to the identification of individuals, that are provided by users of this website directly (eg: name, surname, username, e-mail address, Steam profile) or indirect (for example, IP address).
We will process your personal data for the following purposes, based on the legal grounds indicated for each of these:
1.1. Navigating the web site. Using cookies
If you disagree with this processing, you will not be able to use our site or, depending on the case, you will not be able to enjoy the full experience of using it.
1.2. Answering to your questions, requests or complaints
We will process your personal data such as your name, surname, e-mail address, telephone number, and any other information or details you may provide to us in the correspondence to resolve and answer your questions, your complaints or requests, depending on the communication channel through which you contact us, as described below.
Purpose: Responding to your questions, complaints, or requests via email or telephone
Legal basis: Processing is based on a legitimate interest, allowing us to provide answers to your questions, complaints, or requests.
If you do not provide us with the data for this purpose, we will not be able to respond to your requests.
1.3. Communicating special offers (through newsletters)
We can process your personal data to inform you about our products and services, promotional offers and subscription to newsletters. As a general rule, this personal data will be processed for direct marketing purposes only with your consent and using the communication channels (eg e-mail, etc.) with which you agreed when you expressed your consent.
However, to the extent that you have communicated your e-mail address when purchasing a product or service from us, we may use your e-mail address, in accordance with the legal provisions in force that allow us to send you commercial communications on similar products or services, based on our legitimate interest in doing so; in this case, to get your email address from you and then, with every marketing message we may send you, we will offer you the option to oppose your use of the email address (unsubscribe)
Purpose: to inform you about the products and services offered by Train Motion S.R.L.
Legal basis: Consent or, if you have purchased our products / services, legitimate interest.
If you do not provide your data or unsubscribe, you will not receive in the future commercial communications (newsletter)
2. DATA RECIPIENTS
For the purposes described above, we use the services of several contractual partners. Some of them are third parties who do not intend to process the data, but can access them in performing their tasks or interacting with them, such as companies that provide technical maintenance, financial or legal auditors. The above-mentioned personal data may be made available or transmitted to third parties and in the following situations: (i) public authorities, auditors or institutions competent to carry out inspections and controls on our activity and assets that require us to provide information (ii) to comply with a legal requirement or to protect our rights and assets, or other entities or persons, such as courts of law; (iii) third party acquirers, to the extent that our business is transferred, and the data of the data subjects would be part of the assets that are the subject of such a transaction. The individuals and entities to whom we may share personal data are as follows:
a) For the purpose of browsing the website and for the purposes of using cookies, we may transmit personal data to analytical service providers and engineers search for them to provide maintenance services to our website, such as Google, Facebook, WordPress, Namebox, MonsterInsights.
b) For direct marketing communications, we may transmit personal data to advertising and marketing agencies that make the communication on our behalf;
3. HOW LONG DO WE STORE YOUR DATA
We will store your personal data only for the period of time required to achieve the above-mentioned processing purposes, while respecting the legal requirements in force. If we determine that we have a legitimate interest or a legal obligation to further process your personal data for other purposes, you will be duly informed accordingly.
We estimate that the above-mentioned processing activities will require the storage of personal data over the following periods:
Web browsing and cookie usage: 3 months
Response to your questions, requests or complaints: 1 year
Direct marketing communications: up to unsubscription
Once the above processing period expires and we no longer have any legal or legitimate reason to process your personal data, the data will be erased in accordance with its procedures, which may involve archiving, anonymization, or destruction.
4. DATA PROCESSING OF CHILDREN AGED UNDER 16 YEARS
All personal data processing activities presented in this Policy refer only to persons who are at least 16 years of age. The use of systems and processing results is forbidden for children who have not reached this age without the consent of their parents / legal representatives. If, despite our reasonable prevention efforts, such processing still takes place, we will end it once we notice that users have not reached the age mentioned above.
5. SECURITY OF DATA PROCESSING
We hereby inform you that we continually evaluate and update the security measures implemented to ensure personal data processing in safe and secure conditions.
6. WHAT ARE YOUR RIGHTS
In the context of processing your personal data, you have the following rights:
a. Right of access to processed personal data: you have the right to obtain confirmation that your personal data is processed or not and, if so, to have access to the personal data type and the conditions in which are processed by requesting the data operator to do so;
b. The right to request restriction of processing: You have the right to obtain restriction of processing in cases where: (i) you consider that processed personal data are inaccurate for a period of time allowing the operator to verify the accuracy of the personal data; (ii) processing is illegal, but you do not want us to delete your personal data, but restrict the use of such data; (iii) if the data controller no longer requires your personal data for the purposes mentioned above, but you need data to establish, exercise or defend a right in court; or (iv) you have opposed to processing, for the time to verify that the legitimate grounds of the data controller override the rights of the data subject;
c. The right to request the rectification or deleting of personal data: You can request, by addressing to the data controller, the rectification of inaccurate personal data, the completion of incomplete data or the deletion of your personal data if (i) the data is not necessary for the original purpose (and there is no new legal purpose), (ii) the legal basis of the processing is the consent of the data subject, the data subject withdraws consent and there is no other legal basis, (iii) the data subject has the right to oppose and the operator has no legitimate reason to prevail in order to continue processing, (iv) the data have been processed unlawfully, (v) the deletion is necessary to comply with EU or Romanian legislation or (vi) the data were collected in relation to the information society services provided to the children (if applicable), when specific requirements apply consensus figures;
d. The right to withdraw your consent to processing, when processing is based on consent, but without affecting the legality of the processing activities performed up to that time;
e. The right not to be the subject of a decision based solely on automated processing, including profile creation, which produces legal effects that affect the data subject or affects it in a similar manner in a significant manner;
f. The right to oppose data processing for reasons related to your particular situation, when processing is based on legitimate interest, and to oppose at any time processing of data for direct marketing purposes, including profile creation;
g. The right to data portability, meaning the right to receive the personal data you have provided to the data controller in a structured, commonly used and readable form, as well as the right to transfer the data to another operator, if the processing is based on your consent or the execution of a contract and is done by automatic means;
h. The right to file a complaint with the Data Protection Authority (ANSPDCP) and the right to appeal to your competent courts.
The above rights may be exercised at any time. In order to exercise these rights, we encourage you to submit a request, signed and dated, electronically, by e-mail to email@example.com. Also, if you want to withdraw your consent to direct marketing purposes, you can use the “unsubscribe” option that is included in each marketing communication.
You may ask us any questions regarding this document using the following contact details: firstname.lastname@example.org
8. MODIFICATIONS TO THIS POLICY