The confidentiality of your personal data represents one of Lugera’s main concerns. This document has the role of informing you about the processing of your personal data, in the context of using the website www.lugera.ro.
Lugera is a group of companies mainly active in the field of human resources (recruitment, temporary workforce, outsourcing services, personnel administration and salary calculations etc.), but also in the field of financial brokerage services, human capital being the main resource we are providing.
The terms ”Lugera” or ”us” refer to any of the companies Lugera & Makler S.R.L., Lugera & Makler Romania S.R.L., Lugera & Makler Payroll S.R.L., Lugera Recruitment Services S.R.L., SSM Outsourcing Services S.R.L., Lugera Executive Search S.R.L., Servicii Profesionale Externalizate S.R.L., Credit Card Broker S.R.L., as well as to any affiliated company registered in Romania. Also, in the cases expressly provided, Lugera may refer to any affiliated company registered in or outside the European Economic Area.
The term ‘you’ refers to the user of our Site.
The term ‘Site’ refers to our website.
In order to provide effective services, Lugera collects personal data depending on the type of service provided and the purpose of collection.
Lugera undertakes to comply with the requirements of General Data Protection Regulation (European Regulation 2016/679/EU).
Lugera has implemented organizational and technical security procedures to ensure the confidentiality, transparency, integrity and availability of personal data and to comply with the requirements of General Data Protection Regulation by:
- Managing all information, electronic or paper, with responsibility and professionalism;
- Ensuring effective communication channels;
- Ensuring, as much as possible, the accuracy and updating of personal data;
- Implementation of organizational and technical measures for limiting the access to personal data, for reducing the risk of disclosure of personal data and for the protection of personal data recorded electronically or on paper;
- Personal data processing, through a transparent process, based on your consent or based on our legitimate interest or to comply with our contractual or legal obligations;
- Respecting your decision to collect, use, restrict, delete and share information that concerns you.
Personal data we may collect from you
We will collect personal data when you visit the Site, including, but not limited to, traffic data, location data, IP address, web logs, the content of online correspondence or discussions and other data relating to your communication and resources you access. Collecting this personal data will make your visit to the Site easier in the future, as we may suggest relevant content to you based on the location you access the Site.
We will collect all the information sent by you when you contact us by e-mail or Chatbox. In particular, this personal data refers to name, surname, e-mail address, telephone number.
In order to respond to your requests, questions, comments or complaints, we may need certain personal data, so it is necessary to provide them to us. Other information or personal data that you send us by e-mail or through Chatbox is at your discretion. If you contact us, we will keep track of that correspondence.
If you register on the Site, by creating an account, we collect the following personal data: name, surname, e-mail address, telephone number. You should know that in order to create an account on Site, the fields marked with “*” are mandatory fields, because we need this information to identify you.
When you apply for a job, no matter which option you have chosen to send us your CV (e.g. apply using the account created on the Site, where you have already uploaded your CV, or apply directly by uploading your CV), we will collect your personal data that you mentioned in your CV. Please note that when you send us your CV, it will be automatically sent to Lugera’s database. You can give up from being involved in a certain time in several recruitment processes or you can withdraw your consent, at any time.
If you log in to the Site using a social account (e.g. Facebook etc.), we will collect your profile data.
We process your personal data in order to send you marketing materials directly by e-mail or SMS when you choose this option from your account created on the Site. You can give up from receiving future marketing communications at any time.
We may also store cookies, as specified in details in the Cookies Policy, which you can access here.
How we use your personal data
Your personal data will be collected and handled by Lugera for the following purposes:
- to best tailor content and resources according to your preferences;
- to develop and improve the Site and its systems to better serve you;
- to improve Lugera services;
- to respond to your request, questions, comments or complaints, when you contact us;
- to be able to communicate with you in a personalized way, e.g. to respond to our feedback requests or to respond to your requests, questions, comments or complaints;
- creating and managing your account on the Site;
- for recruitment for any position corresponding to your qualification and experience, regardless of whether it is open within one of the Lugera companies or to a potential employer, in the country or abroad;
- to keep you up to date with our commercial developments, commercial and job offers through our newsletter.
Our use of your personal data as described above is permitted by applicable data protection law because it is:
- necessary for our legitimate interests in pursuing the purposes set out above;
- in some cases, necessary to meet our legal obligations and responsibilities, such as disclosures to authorities, regulators or government bodies;
- in limited circumstances, processed with your consent which we obtain from you from time to time, such as when you opt for recruitment, respectively for receiving marketing communications.
We do not make any automated decisions solely on automatic processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
The retention periods of your personal data depend on the purpose the data are processed for. The criteria used to determine the applicable retention period are that we will retain the personal data set out in this policy for as long as (i) necessary for the respective purpose, (ii) necessary to carry out our business relationship with you, (iii) you have consented to, and/or (iv) required by applicable laws regarding the retention of personal data.
Registering an account
If you create, use or have an account on the Site, you agree:
- i) to provide real, accurate, current and complete data and information about you, as required by the account registration form and
- ii) to maintain and promptly update the registration data in order to be real, accurate, current and complete.
If you provide any information that is untrue, inaccurate, incomplete or out of date, Lugera reserves the right to suspend or cancel your account and to refuse any present or future use of its services by you.
Account and password confidentiality
You are responsible for maintaining the confidentiality of your account and password and you are fully responsible for all activities that take place under your account or with your password.
You agree to notify Lugera immediately about any unauthorized use of your password or account and to ensure that you log out of the account at the end of each session. Lugera cannot and will not be liable for any loss or damage resulting from your failure to comply with this section.
Lugera reserves the right, at its discretion, to block the password, the use of its services, to remove any material posted on the Site, with or without reason. Also, Lugera may suspend the provision of its service, partially or totally, with or without notice.
You agree that Lugera may close your account immediately, under certain circumstances and without prior notice, interrupting any access to the service. Furthermore, you agree that all closures or locks of your account are made at Lugera’s sole discretion and that Lugera will not be liable to you or any third party for any termination of your account or your access to the service.
Deleting the account at your request
In case you want to delete your account, you can either send us an e-mail to email@example.com to request this, or you can do so directly from your account on the Site. In the latter case, you will need to select the box with this option from your account on the Site.
We remind you that when you upload your CV using your account, it is automatically sent to Lugera database. Deleting the account from the Site has the consequence of deleting all your personal data that can be found on the Site. However, deleting the account from the Site does not lead to the deletion of your personal data from Lugera database. If you want this too, please see the section below.
Processing of your personal data for the purpose of recruitment
Lugera has several ongoing projects in the field of human resources, both internally and for our clients, and has various other partnerships, for which, if you are looking for a job or you are interested in participating In various recruitment projects, you can send us your consent for the processing of personal data for this purpose.
You have the possibility to give your consent by checking the box corresponding to this purpose of processing, namely the one referring to the purpose of recruitment for any position appropriate to your qualification and experience, whether it is open in one of the Lugera companies or in a potential employer, from our country or from abroad. Please note that your personal data may also be transmitted to our affiliates located in the European Economic Area.
When you apply for a job, no matter which option you chose to send us your CV (e.g. apply using the account created on the Site, where you have already uploaded your CV, or apply directly by uploading your CV), we will collect your personal data that you mentioned in your CV.
We inform you that when you upload a CV on the Site, regardless of the transmission of the CV, it will be automatically sent to the Lugera database.
The personal data we collect and process are the data mentioned in your CV, as well as data resulting from the interaction with us in connection with recruitment (eg. following discussions, regardless of the means of communication; in interviews; as a result of feedback etc). The personal data we usually collect includes, but is not limited to:
- name and surname, date and place of birth, nationality, contact details (eg. home / residence address, telephone number, e-mail address etc.), profession, education, qualifications, experience, name and other details regarding former and current employers, skills (eg. PC operation, driving license etc.), knowledge of foreign languages, passions, photo etc.;
- current salary/income, as well as salary expectations;
- your feedback on our services and on certain employers or potential employers;
- feedback from former, current and potential employers;
- details of the adjustments that will have to be made at the workplace, whatever their reason (eg. disabilities, a certain work schedule etc.), if case you request this from us;
- certain personal data considered sensitive (other than those mentioned above), if are required in the recruitment process and the law allows it.
You are not required to provide us your personal data, but for us it would not be possible to work with you or offer our services if you do not provide us the minimum necessary data. It may also limit the services we provide to you if in certain cases you choose to provide us limited personal data.
You can give up from being involved in a certain or in several recruitment processes or you can withdraw your consent, at any time.
In case you do not want to be involved in a certain time or in certain recruitment processes, you can send us an e-mail to firstname.lastname@example.org, requesting this, mentioning the recruitment processes which you no longer want to participate in. Please note that in this situation, your personal data will remain on the Site and in our database, in order to be involved in other further recruitment processes.
In case you want to delete your account from the Site, you can either send us an e-mail to email@example.com to request it, or you can do so directly from your account on the Site. In the latter case, you will need to select from your account on the Site the box corresponding to the deletion of the account. The consequence is the deletion of your personal data from the Site (which includes the deletion of the account, as well as all your other personal data, which are found on the Site). Please note that deleting your account from the Site, as well as your other personal data found on the Site, does not lead to the deletion of your personal data found in Lugera database, namely personal data which were automatically sent to our database when you sent us your CV, respectively those collected further. If you also want your personal data deleted from Lugera database, you will have to withdraw your consent, according to the next paragraph.
In case you want to withdraw your consent, you can either send us an e-mail to firstname.lastname@example.org to request it, or you can do so directly if you have an account on the Site. In the latter case, you will have to select from your account on the Site the box corresponding to the withdrawal of the consent given for the purpose of recruitment. The consequence of withdrawing consent is the deletion of your personal data from the Site (which includes the deletion of the account, as well as all your other personal data, which are found on the Site), as well as personal data that have been transmitted to our database, respectively those collected further. The withdrawal of consent does not affect the lawfulness of the processing made on the basis of the consent before its withdrawal.
Your personal data will be kept and processed for the period of time you are legally active, on the labor market, until reaching the legal retirement age of 65 years. This period may be extended in cases you wish, on the basis of a separate consent.
We will send marketing communications to you via e-mail and/or SMS only if you have consented that we may do so.
In this regard, we offer you a check box on the account registration form, and if you agree to receive marketing communications, you must check the box.
If you have opted for marketing communications, you may opt out of receiving any future marketing communications at any time by unchecking the box or contacting us at email@example.com, providing us with information regarding your name and surname, e-mail address, phone number and telling us that you want to opt out of marketing communications.
Recipients of personal data
We inform you that we disclose your personal data to third parties, but their disclosure takes place only in the situations and conditions mentioned below. The recipients of personal data are:
- providers performing services on the Site (e.g. hosting and/or maintaining and/or developing the Site and its content etc.). These providers are located in Romania or in the European Economic Area and have access only to your personal data requested to perform their contracted services. These recipients will comply with contractual obligations of confidentiality.
- Lugera affiliated companies located in the European Economic Area.
- potential employers, from Romania or from the European Economic Area, in case we involve you in a recruitment process.
- government authorities, to fulfill our legal obligations.
Storage of personal data
We also inform you that your personal data are stored on servers located in the member states of the European Economic Area.
Transfer of personal data outside the European Economic Area
Your personal data can be transferred and processed in one or more other countries, in or outside the European Economic Area. If the case, we shall only transfer your data outside the European Economic Area to countries which the European Commission believes that offers an adequate level of protection to you, or where the Lugera has put in place protection measures to seek to preserve the privacy of your personal data (concluded an agreement with the recipient in accordance with the standard contractual clauses for the transfer of personal data to operators or authorized persons from third countries, as established by the European Commission) or on the basis of your express consent. We shall inform you upon these countries when we will identify the need to transfer your data.
Automatic collection of personal data
In some cases, Lugera automatically collects certain types of information, when you visit our Site and through exchanged emails. Automated technologies may include the use of a web server to collect IP addresses and cookies. Collecting this information will allow us to better understand and improve the performance, usability and efficiency of the Site, as well as to measure the effectiveness of our marketing activities.
We are committed to ensure that in case of collecting personal data online, the information is secure. In order to prevent unauthorized access or their disclosure, we have put in place adequate procedures to protect and secure the information we collect online.
However, although we will do our best to protect your personal data, you should be aware that the transmission of information via internet is not completely secure and we cannot guarantee the security of your personal data transmitted to the Site or any third party. For this reason, any transmission of information is at your own risk.
Your rights regarding your personal data
According to the data protection legislation in force, you have the following rights:
- The right to access and obtain a copy of your personal data: You have the right to request confirmation whether we process any of your personal data. If the case, you can access your personal data and certain information about how it is processed. In some cases, you may ask us to provide you a copy of your personal data, processed by us.
- The right to correct your personal data: If you can prove that personal data we hold about you is incorrect, you may request that this data be updated or corrected.
- The right to delete personal data (the right to be forgotten): You have the right to have your personal data deleted, unless the law provides otherwise. You can make such a request at any time and Lugera will evaluate the possibility of solving your request, taking into account the legal rights and obligations under which it may be necessary to keep such data. For situations where in accordance with the law, Lugera establishes that your request to have your personal data deleted must be granted, Lugera will do the deletion.
- The right to object: If the processing of personal data is based on our legitimate interest or is directly linked to direct marketing, you have the right to object to the processing of your personal data by Lugera, referring to your particular situation you are in.
- The right to restrict: In certain circumstances, you have the right to restrict the processing of your personal data. However, in some cases, such a restriction on processing may limit the services you may receive from us.
- The right to portability: You have the possibility to request us to transmit your personal data to another operator, if you have provided us the data in a structured format, commonly used and “machine-readable”.
- The right to withdraw your consent at any time: If the processing of your personal data is based on your consent, you have the right to withdraw it at any time. The consent withdrawal shall not affect the lawfulness of any processing carried out on the basis of the consent given prior to receipt of such withdrawal.
You can exercise these rights by sending a written request, either in physical format, to Lugera – Lugera & Makler S.R.L., at the address from Bucharest, 3rd district, 98 Vulturilor street, 1st floor, with the mention Data Protection, either in electronic format, at the e-mail address firstname.lastname@example.org. Lugera will respond to your request as soon as possible, but no later than 1 (one) month after receiving it. This period may be extended by 2 (two) months when necessary, taking into account the complexity and number of requests.
Lugera, according to the applicable legislation, offers free access and/or obtaining copies of personal data only for the first 3 (three) requests of the same type regarding the same information, otherwise the access and/or obtaining copies will be made against a cost, which Lugera estimates at 70 Euro / request, this amount can be updated.
You also have the right to file a complaint with the competent supervisory authority, namely the National Authority for the Supervision of Personal Data Processing (www.dataprotection.ro).
Changes to this policy
Questions about the policy and its implementation
If you have any questions or comments regarding this policy or the administration of your personal data by us, please contact us at email@example.com and/or at postal address: Bucharest, 3rd District, 98 Vulturilor, 1st floor, with the mention Data Protection.
Lugera & Makler S.R.L. | RO 13861487 | J 40/4327/2001
98 Vulturilor, 1st, 3rd and 4th floors, 3rd District, Bucharest, Romania
+40 (0)21 318 7120 //+40 (0)21 318 7120 || www.lugera.ro || firstname.lastname@example.org
Lugera & Makler Romania S.R.L. – RO 15619774, J40/10246/2003 || Lugera & Makler Payroll S.R.L. – RO 18838779, J40/11234/2006 || Lugera Recruitment Services S.R.L. – RO J40/2510/2017, CUI 37134222, SSM Outsourcing Services S.R.L. – RO 29319025, J40/13292/2011 || Lugera Executive Search S.R.L. – RO 32833416, J40/2153/2014 || Servicii Profesionale Externalizate S.R.L. – RO 26061346, J40/9877/2009 || Credit Card Broker S.R.L. – 26705927, J40/3209/2010