Privacy Policy
What is the purpose of this Policy?
The following information is provided to inform you about the categories of personal data that are the subject of collection and processing when you use our websites, portals, applications, and platforms ("our Site" or "Sites"), how we (that is, Tukio) use these personal data, and with whom it may be possible to share them. This policy also describes your rights and how you can contact us to exercise these rights or to ask any questions you may have regarding the protection of your personal data.
Tukio builds strong and lasting relationships with its customers, partners, and beneficiaries, based on mutual trust, ensuring that their personal data is safe and remains confidential, being an absolute priority for Tukio.
Tukio is committed to respecting all applicable legal provisions that regulate the protection of personal data.
Tukio applies a very strict privacy policy to ensure the protection of personal data of those who use its Sites:
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Users retain control over their own data. Data is processed in a transparent, confidential, and secure manner.
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Tukio is committed to continuing to protect the personal data of its users in accordance with the General Data Protection Regulation of April 27, 2016 (GDPR).
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Tukio has a Data Protection Officer, whom you can contact in case of doubts at the dedicated address: privacy.ro@tukio.eu.
This policy may be amended, supplemented, or updated, especially to comply with any legislative, regulatory, case law, or technical developments that may arise. However, your personal data will always be processed in accordance with the policy in force at the time of data collection, except in cases where a mandatory legal provision requires otherwise and must be applied retroactively.
Who is the "controller" and how can you contact us?
Controller:
Tukio is a registered trademark of Synnexo Pax S.R.L.
Synnexo Pax S.R.L.,
A Romanian legal entity with headquarters at: Drumul Guliei no. 189i1, Samurcasi, Romania.
Registration Number with the Trade Register: J15/1309/2020
Legal representative: Motiu Alin in his capacity as Administrator
Data Protection Officer: privacy.ro@tukio.eu
Definitions
- "Controller" - Means the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of your personal data on sites. In this Policy, Controller means Tukio represented by Synnexo Pax S.R.L..
- "Personal data" - Means any information relating to an identified or identifiable natural person by reference to an identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- "Processing" - Any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- "Authorized person" - The natural or legal person, public authority, agency, or other body that processes personal data on behalf of the data controller.
- "we", "us" or "our" - Tukio acting as a controller.
- "you" or "Users" - Any user/visitor of the Site or beneficiary of the Services.
How will your personal data be collected? Is it mandatory for you or other persons to provide your personal data?
We may collect your personal data in the following ways:
- Collecting your personal data directly from you, such as when you complete forms on our sites; and
- Collecting your personal data indirectly during navigation on Site or through our service providers and/or technologies on our Sites.
- Indirectly from other partners, based on your prior consent to share personal data with them.
We will collect your personal data in a mandatory manner, in cases where this is imposed by applicable local laws or where this is necessary to provide the services on the site.
If we cannot collect these mandatory elements that represent personal data, we will not be able to manage your access to the Site.
What personal data does Tukio hold? For what purposes and on what legal basis will your personal data be collected and processed?
We may process, use and disclose your personal data for certain purposes, as detailed below, related to your use of the site and the services we provide or based on your relationship with Tukio.
We will collect and process your personal data as detailed below (without this list being exhaustive) when necessary to provide you access to the Site or when necessary to fulfill a legal obligation to which we are subject. Also, we will collect and process your personal data for Tukio's legitimate interests, except in cases where these interests are overridden by your interests or fundamental rights and freedoms. In cases where legitimate interests do not apply as a legal basis for processing personal data in accordance with applicable data protection laws, explicit prior consent will be collected alternatively, if this is required by law.
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Data Processing Activities |
Purposes |
Categories of Personal Data |
Legal Basis |
|---|---|---|---|
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Cookie modules |
Customizing the Website and enhancing the experience. A more detailed description of how and why cookies might be used on Sites is available on our web page |
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Consent The legitimate interest in implementing the necessary technical measures for the operation of our website |
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Site navigation |
Legitimate Interest |
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Legitimate Interest |
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Communication with users |
Collecting and processing requests from Users contacting Tukio |
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The legitimate interest in communicating with users and customers of our site |
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Investor webcast |
Allowing investors to access the platform and enabling Tukio to compile statistics to monitor the audience and contact investors |
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The legitimate interest in interacting with investors |
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Marketing communications |
Collecting and processing personal data in accordance with the consent given for sharing with marketing partners or providers of marketing platforms, including social media promotion services, advertising networks, third-party data providers, and other service providers, in order to attract or better understand users and send more relevant communications. |
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Consent |
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Physical persons acting as representatives of contractual partners or potential customers |
Execution of the value ticket contract. Organizing the value ticket system. Receiving orders for value tickets. Promoting the operator's services and products. Communicating information regarding contract execution, maintaining the contractual relationship (operational), the mechanisms for operating contracted services from the client. Market research and evaluating our services. Recruiting new customers, legal entities, for the purpose of extending the operator's commercial activity. |
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Legal obligation for organizing the value ticket system The legitimate interest in interacting with potential customers or partners for commercial purposes The legitimate interest in interacting with potential customers or partners for commercial purposes |
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Others |
Any other purpose that we will specify at the time of collection and described in the specific privacy policy | Determined at the time of collection and described in a specific privacy policy |
Determined at the time of collection and described in a specific privacy policy |
Who Will Have Access to Your Personal Data?
- Within Tukio
Your personal data security and confidentiality are of great importance to us. This is why we restrict access to your personal data only to designated members of our staff and only to the extent strictly necessary to process your personal data or to provide the necessary services on the site. We ensure that the individuals authorized to process personal data will respect confidentiality and comply with the legal obligation of confidentiality.
European data protection laws do not allow the transfer of personal data to third countries outside the European Economic Area ("EEA") that do not ensure an adequate level of data protection. If you have questions or want details regarding these guarantees, you can contact the group's data protection officer by sending an e-mail to privacy.ro@tukio.eu
- Outside of Tukio
We will not disclose your personal data to any unauthorized third parties. However, we may share your personal data with authorized service providers (for example, technical service providers [hosting, maintenance], consultants, etc.) that we may call upon for the purpose outlined above, in accordance with applicable data protection laws.
All third-party service providers to whom we have disclosed and transferred your personal data have been engaged on the basis of a mandatory confidentiality agreement and data processing with Tukio, through which the respective third party may act only on the instructions of Tukio entities.
This third-party service provider and/or other contractors, as the case may be, may be located in countries (for example, the United States, the United Kingdom), where data protection laws may not provide an equivalent level of protection to European legislation (we mention the fact that the European Commission has recognized the United States and the United Kingdom as providing adequate protection). If Tukio entities or the Tukio group disclose your personal data to such recipients, which will be only for purposes of recovery in extreme cases or for the purpose of providing assistance at our request, we will establish and / or confirm that, before receiving any of your personal data, they will provide an adequate level of protection for your personal data, including appropriate technical and organizational security measures. In particular, if the recipients in question are in a country that does not provide an adequate level of protection, Tukio entities will also implement other appropriate measures, including standard contractual clauses, to ensure such a transfer in accordance with applicable legislation. If you have questions or want details regarding these guarantees, you can contact the data protection officer in Romania, sending an e-mail to privacy.ro@tukio.eu.
In addition, we may share your personal data (i) if the law or a legal procedure imposes us to do so, (ii) in response to a request from public authorities or other officers or (iii) if we believe that transferring this data may be necessary or appropriate to prevent any physical harm or financial loss, or in connection with an investigation into suspected or proven illegal activity.
How Long Will Your Personal Data Be Stored?
We will store your personal data for as long as necessary to fulfill the purposes for which they were collected and processed. This period may be extended, if the case, for any period of time provided for by any applicable legal or regulatory provisions.
Specific retention periods associated with each purpose are listed in the table above.
| Categories of Personal Data; | Purposes | Retention Period |
|---|---|---|
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Customizing the Website and enhancing the experience. | Data related to your use of the Website will be stored for the period necessary for Processing. |
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Up to 13 months (depending on the category the cookie belongs to). For more details, please refer to our Cookie Policy. | |
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Compliance with legal obligations | The period necessary for processing. |
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Collection and processing of requests from Users contacting Tukio Allowing investors to access the platform and enabling Tukio to compile statistics to monitor the audience and contact investors |
The period necessary for processing your request. The period necessary for processing. |
| Any other category of personal data determined at the time of collection and described in the privacy policy | Any other specific purpose specified at the time of collection and described in the privacy policy | The period necessary for processing. |
Subsequently, we would like to remind you that we can anonymize your personal data in such a way that you cannot be identified and can continue to use them for statistical purposes. Data processed for statistical purposes are no longer classified as personal data once they have been properly anonymized.
Will my sensitive personal data be processed?
As a general rule, we do not collect sensitive personal data through our website or for providing our services. We would like to remind you that our contact forms are not intended for collecting sensitive personal data. Therefore, you should limit your contribution to what is strictly necessary regarding your request. When you send us an email, contact us through a contact form, or by any other means.
Sensitive personal data refers to any information about a person's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health data, or data relating to a person's sex life or sexual orientation. This definition also includes personal data relating to criminal convictions and offenses.
In the exceptional case where it is strictly necessary to collect such data in order to achieve the purpose of processing or if you provide us with such data, for example when you send us an email), we will process this data in accordance with local legal requirements for the protection of personal data and, in particular, with your prior explicit consent and under the conditions described in this policy.
What are your rights regarding your personal data and how can you exercise these rights?
It is important that the personal data we hold about you is correct and up to date. Please inform us if your personal data changes by updating your account on our site.
Tukio is committed to ensuring the protection of your privacy rights in accordance with applicable laws. Below you will find a table summarizing your privacy rights in accordance with applicable data protection law, which applies to all personal data processed on our Site.
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Rights |
Description of Your Rights |
|---|---|
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Right of Access and Rectification |
You can obtain all the information listed in Article 15 GDPR and / or you can request a copy of the personal data we hold about you. Also, you can request the rectification of inaccurate or incomplete personal data. |
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Right to Erasure |
Your right to be forgotten gives you the right to request the erasure of your personal data in cases where:
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Right to Restriction of Processing |
You can request the restriction of processing of your personal data in cases where:
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Right to Data Portability |
You can request, if applicable, the portability of your personal data that you have provided to us, in a structured, commonly used, and machine-readable format.
Additionally, you can request that your personal data be transmitted to a third party of your choice (where technically feasible). |
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Right to Object to Processing |
You can object (that is, exercise your right to "opt-out") to the processing of your personal data, especially in relation to profiling or marketing communications. When we process your personal data based on your consent, you can withdraw consent at any time. |
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Right Not To Be Subjected to Automated Decisions |
You have the right not to be subject to a decision based solely on automated processing, including the creation of profiles, which has a legal effect concerning you or significantly affects you. |
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Right to Lodge a Complaint |
You can choose to lodge a complaint with the Romanian Supervisory Authority (ANSPDCP: http.://www.dataprotection.ro) Also, you have the right to lodge a complaint with Romanian courts. |
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Right to Withdraw Consent |
In situations where it is possible to give your specific consent for the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. When you give consent, it is usually provided how to withdraw it. Once we receive the notification that you have withdrawn consent, we will no longer process your information for the purpose or purposes you initially agreed to, except in cases where we have another legal basis to do so under law. Please note that the withdrawal will be implemented within a maximum of 72 hours from the time of registration of this. |
How to exercise these rights, you can:
- use the online request form: This electronic system allows you to connect and see the progress of your request, to see and send messages and to review documents securely. This system is provided by One Trust and after making the request, details will be sent on how to connect.
- Also, you can address questions or complaints to the Group's Data Protection Officer by email at privacy.ro@tukio.eu or by mail to the address Drumul Guliei no. 189i1, Samurcasi, Romania.
Usually, no fee is required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, it is possible that we will charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to proceed with the request in such cases.
What we may need from you
It may be necessary for us to request specific information from you to help us confirm your identity and ensure your right to access information (or to exercise any of the other rights). This is another appropriate security measure to ensure that personal data is not disclosed to anyone who does not have the right to receive it.
How will your personal data be protected?
We implement all possible technical and organizational security measures to ensure the security and confidentiality of processing your personal data.
For this purpose, we take all necessary precautions, considering the nature of the personal data and the risks associated with processing them, to maintain the security of the data and, in particular, to prevent alteration, deterioration or unauthorized access by third parties (physical protection of spaces, authentication procedures with personal access, secured by identifiers and confidential passwords, a login journal, encryption of certain data, etc.)
In addition, if we enter into a contract with authorized persons for the full or partial processing of your personal data, we need a contractual agreement from our service providers to ensure the security and confidentiality of the personal data that we transmit to them or that they collect on our behalf, in accordance with applicable data protection regulations.
However, you also have the responsibility to ensure the security and confidentiality of your personal data, so we invite you to remain vigilant, especially when using an open system, such as the Internet.
Links to Other Websites / Platforms
Occasionally, we provide links to other platforms for practical and informative purposes. These platforms operate independently of our Sites and are not under our control. These platforms have their own privacy policies or terms of use, which we strongly advise you to read. We do not assume any responsibility for the content on these platforms, for the products and services that may be offered there or for any other use of them.
How will you be notified if the uses of your personal data change?
We may update or modify this policy as necessary. In this case, the changes will become applicable only after a period of 30 working days from the date of modification. Please check this page occasionally if you want to be informed of any possible changes.
If you have questions or comments regarding this policy, please do not hesitate to contact us at the following address: privacy.ro@tukio.eu.
Applicable starting from the date of 02.09.2023