Societatea International Cooling Systems SRL, registered office Str. Aristide Pascal, No. 29-31, Et. 4, Sect. 3, Bucharest, having unique registration code no. RO34600018, and order number in the trade register J40/6704/2015 as a data operator, as the case may be, (hereinafter referred to as "we" or "ICS") we communicate this Privacy Policy of ICS (hereinafter referred to as "Policy privacy"), to provide you with an overview of our practices regarding the collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, disclosure by transmission, dissemination or making available in any otherwise, alignment or combination, restriction, erasure or destruction of personal data (hereinafter referred to as "Processing").

CATEGORIES OF PERSONAL DATA
For the Processing purposes mentioned in point III below, we process your personal data, hereinafter referred to as "Personal Data". Personal Data will include, as appropriate, both your Personal Information and Special Categories of Personal Data, as defined below. "Personal information" refers to: name and surname, name of the company/entity you belong to, postal address, professional address, telephone number, mobile phone number, e-mail address and IP address, other personal data personal information about your preferences that may prove relevant for any purposes regarding the provision of our services, details and information about your visits to our offices, and other data relating to your interaction with us.
We collect your Personal Data directly from you in certain circumstances, including:
When you browse, request information or interact on our website;
When you perform or offer to perform services for us;
When you voluntarily communicate your Personal Data to us for any reason.
In certain circumstances, we collect Personal Data about you from a third party source. For example, we may collect Personal Data from your employer, other companies or individuals with whom you have connections, government agencies, credit bureaus, information or service providers, or from public records.

PURPOSES OF PROCESSING
We process your Personal Data to the extent permitted or required by applicable law for the following purposes:
Communicating with you to continuously inform you about the evolution of the requested service, analyzing and improving our services and communications to you
Managing and administering the business relationship between you and ICS, including payment processing, accounting, auditing, invoicing and collection services, support;
Compliance with our legal obligations (such as record keeping obligations), compliance or registration obligations (such as under trade sanctions and embargo laws, antitrust laws, for anti-money laundering purposes, verification and compliance financial, for the purposes of fraud and crime prevention and detection), which may include automatic checks of your Personal Data against applicable lists of sanctioned persons and contacting you to confirm your identity in the event of a possible positive result, or recording the interaction with you that may be relevant for compliance purposes;
Protecting the security and managing access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal activities;
For purposes of ensuring, monitoring and assessing compliance with our policies and standards, in order to identify persons authorized to transact on behalf of our customers, beneficiaries, suppliers and/or service providers;
For any purpose related and/or ancillary to any of the above.
With respect to marketing-related communications, we will, if legally required, make that information available to you only after you have selected this option to receive such communications, and we will give you the opportunity to unsubscribe at any time, in if you no longer wish to receive marketing-related communications from us. We will not use your Personal Data to make automated decisions that affect you or create profiles other than those described above.

BASIS OF PROCESSING YOUR PERSONAL DATA
Any operation that amounts to a Processing of your Personal Data will be carried out on the basis of one or more of the legal bases below:
Processing is based on your consent as the legal basis for the collection, storage and use of your Personal Data as permitted by applicable law;
The Processing is necessary for the execution of a contract to which you are a party, or the said Processing is necessary for the conclusion of a contract with you;
The processing is necessary in order to comply with a legal obligation;
The processing is necessary in order to protect the vital interests of you or another natural person;
Processing is necessary for the purposes of the legitimate interests of ICS or a third party, except where your interests or fundamental rights and freedoms prevail over these interests. We use your Personal Data for our legitimate interests, respectively for the exercise of our obligations and rights deriving from a contract concluded with the company/entity of which you are a part, to improve our performance and way of working and for administrative and detection purposes fraud.
In cases where the applicable legal provisions require your prior and explicit consent for the Processing of Special Categories of Personal Data, we will process that data only on the basis of your prior and explicit consent.
You can choose to withdraw your consent to marketing materials at any time by simply accessing the "unsubscribe" link at the footer of each newsletter.

SECURITY OF YOUR PERSONAL DATA
ICS has implemented appropriate technical and organizational measures to preserve the confidentiality and security of your Personal Data, in accordance with internal procedures regarding the storage, transmission and access of Personal Data. Personal Data may be stored on our Personal Data technology systems or in hard copy.

RETENTION PERIODS
Personal data processed for the purposes stated herein will be kept only as long as necessary, for the duration of your established relationship with ICS and subsequently for the retention periods required by applicable law. If a legal action is initiated, the Personal Data may be kept until the end of this action, including any appeal or appeal periods, and then it will be deleted or archived, according to the provisions of the applicable legislation.
In principle, we will retain your Personal Data for as long as required or permitted by applicable law. Subsequently, upon expiry of these periods or upon the exercise of one of your rights in accordance with the law, we will remove/delete your Personal Data from our systems and records and/or take steps to anonymise it so that you can no longer be identified based on them.

YOUR LEGAL RIGHTS
If you have declared your consent to Processing activities, you can withdraw this consent at any time with future effect. Such withdrawal will not affect the lawfulness of the Processing prior to the withdrawal of consent. As a general rule, in cases where you withdraw your consent, ICS will no longer allow the Processing of your Personal Data and will take appropriate steps to delete any records of your Personal Data. However, if the Processing is strictly necessary for the provision of ICS services, and the Processing could be based on other legitimate grounds provided by the applicable legal provisions, ICS will proceed with that Processing and inform you accordingly.
Under the terms of applicable law, you have the following rights:
The right of access: You have the right to be informed, upon request, if your Personal Data is being processed, and if so, you have the right to request access to it. The information includes, among other things, the purposes of the Processing, the categories of Personal Data affected and the recipients or categories of recipients to whom your Personal Data has been or will be transmitted.
You have the right to obtain a copy of the Personal Data processed. For additional copies, we may charge you a reasonable fee based on administrative costs.
Right to rectification: You have the right to obtain from us the rectification of your incorrect Personal Data. Depending on the purpose of the Processing, you have the right to complete incomplete Personal Data, including by means of an additional statement.
Right to erasure ("right to be forgotten"): You have the right to ask us to erase your Personal Data.
The right to restriction: You have the right to request the restriction of the Processing of your Personal Data. In this case, the respective data will be marked and can be processed by us only for certain purposes.
The right to data portability: You have the right to receive your Personal Data that you have provided to us in a structured, common and machine-readable format, and you have the right to transmit this data to another entity without objection from our side.
Right to object: You have the right to object, on grounds related to your situation, at any time to our Processing of your Personal Data, and we may be asked to stop processing your Personal Data. If you have the right to object and you exercise it, we will no longer process your Personal Data for that purpose. Exercising this right is free of charge. This right may be invalidated in particular if the Processing of your Personal Data is necessary for the formalities related to the conclusion of a contract or for the fulfillment of a contract already concluded.

You can exercise your aforementioned rights and learn more about these rights by submitting a written request to us, as a data controller, at ICS, Str. Aristide Pascal no. 29-31, et. 4, sector 3, 031443, Bucharest, Romania or by e-mail at info@cooling.ro
You also have the right to file a complaint with the National Supervisory Authority for the Processing of Personal Data.

VERSIONS OF THIS PRIVACY POLICY
This Privacy Policy is effective on May 25, 2018.
This Privacy Policy may be updated from time to time. Any update will become applicable from the moment the new version is published on the ICS website or from the moment it is communicated in any other way.