GDPR Policy

PRIVACY POLICY

Respecting your privacy is one of our fundamental commitments, and we give the highest attention to the processing of your personal data in accordance with applicable legislation.

SC ADVANCED GEMOLOGICAL LABORATORY SRL, with its registered office at 26 MENDELEEV STREET, building A, Bucharest, Sector 1, fiscal identification code 47242221, registered with the Trade Register Office under no. J40/23618/24.11.2022 (“ADVANCED GEMOLOGICAL LABORATORY SRL”, “we”) processes your personal data as the data controller (“Personal Data”). The purpose of this information note (“Policy”) is to detail how ADVANCED GEMOLOGICAL LABORATORY SRL processes your Personal Data.

I. PROCESSED PERSONAL DATA, PROCESSING PURPOSES, AND LEGAL GROUNDS

1. Online client contact

Processed personal data: name, surname, phone number, email address.

2. Marketing (Newsletter, news, articles)

A. Commercial Messages

Processed personal data: name, surname, phone number, email address.

3. Dispute resolution

A. Litigious Issues

Processed personal data: name, surname, home address.

II. PROVIDING PERSONAL DATA

You may refuse to provide certain Personal Data, but in such a case, you may not be able to benefit from certain services specific to the relationship described in this Policy.

III. ABOUT LEGAL GROUNDS

The legal basis for processing differs depending on the specific situation and the Personal Data processed.

In situations where we process your Personal Data on the basis of your consent, we will request your consent for the specific processing. By giving your consent, you agree that we may collect, use, disclose, process, and transfer Personal Data in accordance with this Policy.

IV. SOURCE OF PERSONAL DATA

The source of Personal Data is the online client.

V. AUTOMATED PROCESSING OF PERSONAL DATA

Your Personal Data will not be processed for the purpose of making decisions based solely on automated processing that would produce legal effects concerning you or significantly affect you, in the sense provided by Article 22, paragraph (1) of the GDPR.

VI. DATA PROCESSING DURATION

The duration of processing Personal Data varies depending on the specific processing operation:

In certain circumstances, we may retain Personal Data for longer periods to maintain an accurate record of your relationship with us in the event of any complaints or if we reasonably believe that litigation is imminent.

VII. TRANSFER OF PERSONAL DATA

We may transfer Personal Data, to the extent necessary, to the following categories of recipients: IT service providers, marketing service providers, state authorities.

These recipients may be located within the European Union and/or the European Economic Area, as well as outside these areas, including countries not recognized as providing an adequate level of protection, in which case the transfer of Personal Data is carried out only if there are adequate safeguards in accordance with applicable law (such as the standard contractual clauses issued by the European Commission). You can request a list of recipients from third countries, as well as a copy of the agreed provisions that ensure an adequate level of protection of Personal Data.

VIII. SECURITY OF PERSONAL DATA

The security of your Personal Data is important to us. Therefore, your Personal Data will be processed by applying reasonable technical and organizational measures to protect them, such as restricting access to Personal Data, encrypting or anonymizing Personal Data, and storing them on secure media. However, despite the efforts made, we cannot always guarantee the effectiveness of the security measures implemented, and therefore, we cannot guarantee the security of Personal Data at all times.

IX. RIGHTS REGARDING PERSONAL DATA PROCESSING

Right of access: You have the right to obtain confirmation from us that your Personal Data are processed by us, as well as information regarding the specific processing, such as the purpose, categories of Personal Data processed, recipients, retention period, source, whether they are transferred abroad, and how they are protected, your rights, the right to lodge a complaint with the supervisory authority.

Right to rectification: You have the opportunity to request the rectification of your Personal Data, provided that the applicable legal requirements are met. In the event of errors, upon notification, we will immediately correct your Personal Data.

Right to erasure: In certain cases, you have the opportunity to request the erasure of Personal Data, such as when:

• they are no longer necessary for the purposes for which they were collected and processed;
• you have withdrawn your consent for the processing of Personal Data, and we can no longer process Personal Data on other legal grounds;
• Personal Data are processed unlawfully;
• you exercise a legal right to object.

We are not obliged to comply with your request for erasure if the processing of Personal Data is necessary to fulfill a legal obligation or to establish, exercise, or defend a right in court. There are also other circumstances in which we are not required to comply with this request for erasure of Personal Data.

Restriction of processing: You can request the restriction of the processing of your Personal Data in the following situations:

• when you contest the accuracy of Personal Data, for a period that allows us to verify the accuracy of the Personal Data in question;
• if the processing is unlawful, and you oppose the erasure of Personal Data, requesting instead the restriction of their use;
• when we no longer need Personal Data for processing, but you request them for legal action;
• if you object to the processing, for the period during which it is checked whether our legitimate rights as a data controller prevail over those of the data subject.

We may continue to use Personal Data following a request for restriction if:

• we have your consent;
• to establish, exercise, or ensure the defense of a right in court; or
• to protect the rights of another natural or legal person.

Right to data portability: To the extent that Personal Data are processed on the basis of your consent or for the performance of a contract and the processing is carried out by automated means, you have the right to have your Personal Data provided to you in a structured, commonly used, and machine-readable format and you have the right to transmit this Personal Data to another controller. This right does not adversely affect the rights and freedoms of others.

Right to object: In certain situations, such as when we process your Personal Data on the basis of a legitimate interest, you have the right to object to the processing of your Personal Data by us. In the case of unjustified objection, SC ADVANCED GEMOLOGICAL LABORATORY SRL is entitled to continue processing Personal Data. You can also object to the processing of your Personal Data for sending commercial messages.

Withdrawal of consent: To the extent that we process your Personal Data based on your consent, you may withdraw your consent at any time without affecting the legality of the processing based on consent before its withdrawal.

Automated individual decision-making process: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you in a similarly significant way. This right is not applicable in cases where the decision: (i) is necessary for the conclusion or execution of a contract between you and us; (ii) is authorized by law and provides adequate guarantees for your rights and freedoms; (iii) is based on your explicit consent.

Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with the National Authority for the Supervision of Personal Data Processing (ANSPDCP) regarding any violation of your rights related to the processing of your Personal Data. The contact details of ANSPDCP are: 28-30 G-ral. Gheorghe Magheru Blvd., Sector 1, Postal Code 010336 Bucharest, Romania; email: anspdcp@dataprotection.ro.

To exercise the above-mentioned rights, please contact us at the email address: contact@aglgems.ro.

X. CONTACT

If you have any questions or concerns about this Policy or its implementation, you can contact us at the email address: contact@aglgems.ro.