Legal

Terms and Conditions

Any order placed on www.nav.ro implies acceptance of the Terms and Conditions detailed below.

How to enter into a contract

If you wish to use any hosting services offered by NAV Communications, you must first accept the specific terms and conditions for their provision. Acceptance is performed online, through the Client's consent to the application of these clauses. According to ORDINANCE No. 130 of 31 August 2000 on the legal regime of distance contracts: "The consumer has the right to notify the merchant in writing of withdrawal from the purchase, without penalty and without invoking a reason, within 10 working days from receipt of the product or, in the case of services, from the conclusion of the contract."

If you do not accept the terms and conditions set out in this document, do not use the www.nav.ro website or the services offered through it.

Definitions

Acceptable Use Policy: the acceptable use policy (which may be modified periodically) is published on our website www.nav.ro;

Provider: NAV COMMUNICATIONS S.R.L., registered with the Trade Register Office of the Bucharest Tribunal under No. J40/9914/1997, registered office in Bucharest, Strada Tămâioarei, No. 116, Office Building TAM, 1st floor, postal code 023644, tax registration code RO 10019108, account No. RO19 RNCB 0087 1316 4280 0001 opened at BCR — Banca Comercială Română, personal data operator code: 32265.

Client: The natural/legal person placing an Order;

Services: Any services offered by NAV Communications, mentioned in the Order, to be provided by NAV Communications to the Client.

Order: The agreement between NAV Communications and the Client whereby NAV Communications undertakes to deliver the services and the Client to pay the corresponding amount.

Contract: An Order confirmed by the Provider.

Client area: https://client.ro

By processing an order on www.nav.ro, the Client agrees to the website's Terms and Conditions. The order acceptance by NAV Communications is considered completed upon email confirmation. Any order not confirmed by NAV Communications shall have no contractual value.

Placing the order

After selecting the desired services and adding them to the shopping cart, the Client proceeds to payment according to the methods detailed in the Payment Methods section.

The Client undertakes to enter complete, correct, and truthful data in the form. Domain registration is carried out in accordance with applicable law. NAV Communications cannot be held liable for any damages caused by the Client providing incorrect or incomplete information.

The Client agrees to pay the value of our services in advance, for the period during which they are provided: monthly, every 3 (three) months, 6 (six) months, yearly, every 2 (two), or 3 (three) years.

Services offered

• Internet access
• Dedicated server rental services
• VPS Servers (Virtual Private Server)
• Server colocation services
• Internet domain registration
• Web hosting services
• Web hosting reseller
• Internet domain reseller
• SSL Certificates (Secure Sockets Layer)
• IP address allocation
• AS number allocation (Autonomous System Number)
• Cloud backup
• Server administration services
• IT consultancy and support services

Details about the characteristics of each service or product can be found on the site in the respective category.

Tariffs (prices)

The tariffs shown on www.nav.ro and in the client area https://client.ro are expressed in EURO and do not include VAT. Payment is made in RON at the official exchange rate communicated by the National Bank of Romania, valid on the day of payment.

The commission charged by the payment processor will be added to the tariff shown for each service or product:

• PayPal: 2.90% + 0.30 EURO
• MobilPay Card: 2.70% + 0.10 EURO
• Bank transfer: Depending on the bank

NAV Communications has the right to modify the tariffs displayed on www.nav.ro and https://client.ro, as well as to modify the characteristics of the packages offered.

Until an order is placed, NAV Communications reserves the right to modify the prices of services offered via the site at any time, and NAV Communications does not provide price guarantees or refunds in case of a price reduction or promotional offer following the purchase.

Payment method

Online payment by card

Online payment by card may be made via the Netopia MobilPay platform, under fully secure conditions. The cards accepted for payment are those issued under the logos VISA (Classic and Electron) and MASTERCARD (including Maestro, if they have a CVV2/CVC2 code).

For the correct completion of the transaction, you must provide the card code (all digits in the four groups on the front of the card, without spaces), the expiration date, the cardholder's name, and the last three digits on the back of the card printed on the signature strip (depending on the card, some information may be missing).

Card data processing is done exclusively via the Netopia MobilPay platform. www.nav.ro and/or www.client.ro do not request or store any details regarding your card.

Online payment via PayPal

Online payment may also be made via PayPal, using your PayPal account.

Payment by bank transfer

Payment by bank transfer is made only based on the proforma invoice issued by NAV Communications and sent by email to the Client.

Order processing and service delivery will be performed after payment of the issued proforma invoice is confirmed in the account below.

Beneficiary NAV COMMUNICATIONS S.R.L.
Unique registration code RO10019108
IBAN: RO71INGB0000999908931781
SWIFT code INGBROBU
Account with ING Bank N.V. Amsterdam — Colentina Branch

Regardless of the currency of your account, transactions are made in lei, at your bank's exchange rate.

Additional details can be found at: /informatii-bancare

Payment terms, suspension, additional fees, deletion of services and domains

The invoice amount is paid at the beginning of each payment period, within 7 calendar days from the date the proforma invoice is issued.

Activation of services or web (Internet) domains is performed approximately 15 minutes after payment confirmation.

Exceeding the payment due date by 2 (two) days leads to suspension of the service.

Exceeding the payment due date by 10 (ten) days leads to application of the data retention service on NAV Communications servers. The cost for the data retention service is calculated at 10% of the value of the primary service (hosting, servers, colocation, etc.), but not less than 5 EUR + VAT.

Exceeding the payment due date by 30 (thirty) days leads to irreversible deletion of the service.

Domains

NAV Communications will send the following notifications informing of a domain's expiration:

• The first notification will be sent 30 days before the domain expiration date
• The second notification will be sent 20 days before the domain expiration date
• The third notification will be sent 15 days before the domain expiration date
• The fourth notification will be sent 7 days before the domain expiration date — 7 (seven) days in advance NAV Communications automatically sends the invoice for domain renewal
• The fifth notification will be sent 2 days before the domain expiration date

The Client may at any time access the client area (https://client.ro) and generate their domain renewal invoice, or notify NAV Communications via a support ticket that they want the domain renewal invoice.

7 (seven) days before the domain expiration date, NAV Communications automatically sends the renewal invoice.

Exceeding by 30 (thirty) days the first domain renewal notification or by 7 (seven) days the invoice due date leads to domain expiration (the domain enters a 30 (thirty)-day grace period) and the application of the quarantine/grace fee of 50 EURO + VAT.

Exceeding by 60 (sixty) to 90 (ninety) days (depending on the registry) the domain expiration date leads to the Redemption Period and the application of the redemption fee of 50 (fifty) EURO up to 350 (three hundred fifty) EURO depending on the Registry.

Exceeding by 90 (ninety) days leads to irreversible deletion of the web (Internet) domain, or the rules of each Internet Domain Registry will apply.

Right of withdrawal

Each of the web hosting services benefits from a 14-day full refund guarantee. If the Client is not satisfied with our services within the first 14 days, the price paid will be refunded in full once a request is made to the payments department. The withdrawal period expires after 14 days from the day of payment.

To exercise your right of withdrawal, you must inform us of your decision to withdraw from this contract, using an unambiguous statement — for example, a letter sent by post, email, or using the form provided in the client area https://client.ro. To this end, you may use the service cancellation button in the client area.

To comply with the withdrawal deadline, it is sufficient to send the communication regarding the exercise of the right of withdrawal before the withdrawal period expires.

Termination

At the Client's request, a service contract concluded with NAV Communications may be terminated with 30 (thirty) days' prior notice. Termination requests will not be accepted as long as the account has outstanding payments. Termination requests must be communicated in writing by letter sent by post, email, or using the cancellation form provided in the client area https://client.ro.

If the Client requests termination of the contract (except under the right of withdrawal) without fault of the Provider, NAV Communications, the price calculated and paid in advance by the Client for the prepaid services will not be refunded; the difference is retained by NAV Communications as compensation, considering that the Client benefited from free service installations and/or discounts for advance payment.

NAV Communications or the Client may terminate the agreement (without prejudice to other rights) if one of the parties involved materially breaches the agreement (including, but not limited to, a breach of the Acceptable Use Policy by the Client).

Uptime — service availability

The guaranteed level of service availability over the contract duration is 99.9%.

If that level is not met, the following discount scheme applies:

• 99.90% — 99.00% — The Client may request a 10% discount (7.2 hours/month)
• 98.99% — 98.00% — The Client may request a 25% discount (14.4 hours/month)
• 97.99% — 97.00% — The Client may request a 50% discount (21.6 hours/month)
• 97.00% — The Client may request contract termination.

The discount may be requested by contacting the payments department via the ticketing system provided to the Client through https://client.ro (client area), and approval of this request remains at the discretion of our company.

The monthly SLA value (Service Level Agreement = service availability) will be the maximum uptime value reported by at least 3 (three) of the following independent monitoring services:

• www.siteuptime.com
• www.serviceuptime.com
• www.host-tracker.com
• www.uptime.com
• www.uptimerobot.com

Absence of a report from at least 3 (three) of the monitoring services listed above implies 100% availability.

Our servers' uptime is defined by OS reports and our own monitoring system, so it may differ from uptime reported by other monitoring systems.

Scheduled service interruption intervals are not subject to the monthly uptime report. Such intervals will be announced to the CLIENT at least 24 hours in advance and will occur, where possible, between 1:00 AM and 5:00 AM.

The status and uptime of our servers can be checked in real time at: https://client.ro/serverstatus.php

Backup — backup copies

The use of services is strictly the Client's responsibility. NAV Communications keeps backups but recommends keeping your own backups, given that this service is provided additionally and free of charge. Backups are not guaranteed, and they cannot be fully verified to confirm every file or directory. NAV Communications is not responsible for the loss of files and/or information.

For hosting services with cPanel or cPanel/WHM control panel, we make free daily backups with 10 calendar days retention. Additionally, the Client can create backups using their own methods or download/restore a backup using the solution provided by NAV Communications.

NAV Communications assumes no liability for the deletion or modification of files hosted on its own infrastructure. The Client is solely responsible for ensuring the integrity of data hosted on NAV's servers using their own backup methods.

NAV Communications uses internal backup procedures to restore data stored on hosting and VPS servers.

Backups are performed daily with 10-day retention and are used exclusively by NAV Communications in case of failures of its own servers. These backups cannot be restored upon Client request for any reason other than failures of NAV Communications hardware. Client restoration requests following NAV Communications server failures will be investigated through specific methods and, if found justified, will be honored.

Services suspended for any reason are automatically excluded from backup.

NAV Communications reserves the right to exclude VPS or hosting accounts which, due to their size, generate very high load on NAV Communications' backup infrastructure, caused by the large volume of data hosted on a Client's hosting account or VPS server.

NAV Communications reserves the right to exclude from backup hosting accounts and VPS servers occupying more than 10 GB of disk space.

If the service has not been excluded from the backup list and you wish to restore a backup for any reason other than physical failure of one of NAV Communications' servers, the restoration cost is 1 EUR + VAT per 1 GB occupied by the VPS server or hosting account. (For a hosting account or VPS server with 10 GB, the cost will be 10 EUR + VAT.)

NAV Communications does not provide and has not implemented (even internally) a backup solution for dedicated servers, cloud servers, cluster servers, or colocation servers. For these servers, the Client has the option to purchase a backup service from NAV Communications' offering at additional cost.

Use of services

The services offered by NAV Communications shall be used only for lawful and ethical purposes; any activities that may be considered illegal are strictly prohibited. The Client will comply with the Acceptable Use Policy and ensure that any other entity using the services complies with the Acceptable Use Policy as well.

According to legal provisions, sending commercial communications by email is prohibited, except where the recipient has previously given explicit consent to receive such communications.

Sending messages to a large number of email addresses (mass email) may be performed using our servers or via other servers to promote any site hosted on our servers, only in accordance with applicable law. Any complaint received in this regard will be immediately forwarded to the Client to resolve the issue between the two parties involved (Client and complainant); however, NAV Communications may resort directly to suspending or deleting the provided service based on the scale and severity of the complaint.

All services provided by NAV Communications are used and administered by the Client, and use of these services is entirely the Client's responsibility. NAV Communications has no or limited access to the information or activities being conducted and is not liable for non-compliance with applicable laws or infringement of trademark or copyright rights of their holders. NAV Communications complies with legal provisions and will act on any complaint received from prejudiced persons or institutions/authorities/organizations, complaints that create at least a reasonable appearance of legality.

Prohibited uses

NAV Communications servers may only be used for lawful purposes. Transmission, storage, or distribution of any information, data, or materials that violate applicable laws or that may directly facilitate violation of any legal provision is prohibited.

The Client undertakes not to use the provided services in any form or under any circumstances for communicating, referring to, or directing to any of the following:

• materials or informational content that infringes copyrights, trademark rights, or any other intellectual property right belonging to a third party;
• nudity, pornography, any image or text with sexual or obscene content, without compliance with applicable legal conditions;
• child pornography;
• threats, abuse, harassment, defamatory statements;
• any image or text intended to encourage xenophobia;

The following activities are prohibited:

• using NAV Communications services to create or transmit computer viruses, worms, flooding, mail bombing, or engaging in denial of service attacks;
• use of proxy or IRC scripts, or scripts of the FormMail, PhpShell type or similar, including commercial scripts with known security holes, Chat rooms, IRC Egg Drop bots, torrent trackers, etc.;
• on web hosting servers, scripts such as online chat, steam status, game tracker, hostbill, whmcs, Clientexec, blesta are prohibited;
• collection of personal information for use for illegal purposes;
• unauthorized access to data, systems, or networks (phishing, spoofing, proxy, hacking, sniffing, etc.), including any attempt to probe, scan, or test the vulnerability of a system or network or to create security breaches without authorization from the owner of the network or system;
• any interference with the service provided to a user, with a server or network, such as: mail bombing, flooding, deliberate actions to overload the system;
• forgery of TCP-IP packets or any part of an email header;

Any script that presents a potential security risk or may affect server performance or network security will be automatically shut down or removed, without prior notice.

Pursuant to the provisions of E-commerce Law No. 365/2002, as amended, NAV Communications will act promptly to remove or block access to any activity or information which, by its nature, may harm the rights of a third party.

Use of resources

The Client shall consider that web hosting, reseller, and VPS packages are located in a shared space (server); therefore, excessive resource use over a prolonged period by the Client or their clients will not be accepted. Accounts harming our servers will receive a notification to resolve the issue within 12 (twelve) hours, as long as the damages are not significant. Otherwise, those accounts may be suspended until the situation is resolved. If the Client fails to address the issues notified to them within 2 (two) days from the notification date, NAV Communications may, at its sole discretion, terminate the contract and delete the service.

Responsibilities

The Client is responsible for updating the contact and billing information mentioned in their account. NAV Communications bears no responsibility for damages resulting from the Client failing to make necessary updates.

The Client is responsible for maintaining the security conditions of the username, passwords, and other sensitive information. If there is any doubt, the Client must change or request the change of authentication data using the password reset form at https://client.ro/pwreset.php or by contacting the support team.

NAV Communications shall not be liable for damages caused by temporary server unavailability, regardless of the cause. This provision also includes damages resulting from data corruption or loss.

Processing of personal data

NAV Communications S.R.L. is registered under number 32265 in the General Register of the National Supervisory Authority for Personal Data Processing, in accordance with Law 677/2001 for the protection of persons regarding the processing of personal data and the free circulation of such data.

According to the requirements of Law No. 677/2001 for the protection of persons regarding the processing of personal data and the free circulation of such data, as amended and supplemented, NAV Communications is obliged to securely manage the personal data you provide to us about yourself, only for the specified purposes.

The purpose of data collection is: providing services, informing users/clients about their account status on www.client.ro, informing users/clients about order progress and status, evaluation of the services offered, commercial activities, product and service promotion, marketing, advertising, media, administration, development, market research, statistics, sales tracking and monitoring.

By filling in your data in the account creation and/or Order form, you unconditionally declare that you accept that your personal data will be included in the NAV Communications database, a company registered in the personal data processing register under number 32265, and you give your express and unambiguous consent for all this personal data to be stored, used, and processed without territorial and/or temporal limitation by NAV Communications, its affiliates, and collaborators for the conduct and/or carrying out by NAV Communications, its affiliates, and collaborators of activities such as, but not limited to, commercial activities, product and service promotion, marketing, advertising, media, administration, development, market research, statistics, sales tracking and monitoring. You also give your express and unambiguous consent that this personal data may be transferred (assigned) by NAV Communications to its affiliates as well as to other entities.

By reading these Terms and Conditions, the Client acknowledges that they are guaranteed the rights provided by law, namely the right of information, the right of access to data, the right of intervention, the right of objection, the right not to be subject to an individual decision, and the right to bring legal action in case of violation of their rights guaranteed by Law No. 677/2001 for the protection of persons regarding the processing of personal data and the free circulation of such data.

At the same time, the Client has the right to object to the processing of personal data and to request its total or partial deletion.

Based on a written, dated, and signed request sent by email to office@nav.ro or by post to: Strada Tămâioarei, No. 116, Office Building TAM, 1st floor, Bucharest, Sector 2, postal code 023644, you may exercise, free of charge, the following rights:

• once a year, to receive confirmation of whether personal data are processed or not;
• to intervene on the transmitted data;
• to object to the processing of data for justified and legitimate reasons related to your particular situation;
• to request data deletion, except in cases provided by law.

Force majeure

Neither party shall be liable for the non-performance of its contractual obligations if such non-performance is due to an event of force majeure, in accordance with applicable law.

Applicable law — jurisdiction

The contract is subject to Romanian law. Any disputes arising between NAV Communications and the Client will be resolved amicably or, if not possible, the disputes will be settled by the competent Romanian courts in Bucharest.

Intellectual property rights

All materials embedded in this site are the intellectual property of NAV Communications. These materials may not be copied or reproduced.

Final provisions

In addition to the Terms and Conditions displayed above, NAV Communications may, depending on the service purchased by the Client, conclude additional service provision contracts, in which case the conditions thus established will be valid between the parties. Thus, the Terms and Conditions represent a general framework contract that may subsequently be modified by agreement of the parties through the signing of additional contracts or annexes.

NAV Communications reserves the right to modify its policy and service usage conditions without prior notice.

CONSUMER HOTLINE — INFOCONS — 021.9551

Consumer Protection Commissariat of the Municipality of Bucharest

Address: Str. Transilvaniei, No. 2, Bucharest, Sector 1, postal code 010798
\tTel.: 021/310.63.75 — complaints office
\tTel: 021/310.63.79
\tFax: 021/310.63.80

Website: https://www.anpc.gov.ro/

Version: 28 MAY 2018

Privacy Policy

NAV COMMUNICATIONS S.R.L. is registered in the Register for the Processing of Personal Data under number 32265.

Important information and company introduction

The websites www.nav.ro and www.client.ro are owned by NAV Communications S.R.L. ("we").
We are committed to protecting and respecting your privacy and your personal data.

This policy (together with the Terms and Conditions of Use (see our website) and any other documents referenced therein) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will process it.

We have appointed a Data Protection Officer who will respond to your questions regarding this privacy policy. If you have any questions about this privacy policy, including any request to exercise your legal rights, please contact the Officer using the details provided below.

Contact details:
Our full details are:
Full legal entity name: NAV Communications S.R.L.
Email address: legal@nav.ro

If you believe that we have not fulfilled any of our legal obligations regarding your personal data, we inform you that you have the right to file a complaint in this regard with the National Supervisory Authority for Personal Data Processing (ANSPDCP — www.dataprotection.ro, anspdcp@dataprotection.ro). However, we would appreciate the chance to address your concerns before you approach the competent authorities, so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes during your relationship with us.

Links to third parties

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our site, we encourage you to read the Privacy Policy of every site you visit.

Information we may collect from you

Personal data or personal information means any information about an individual that can lead to that person being identified. It does not include data from which the identity has been removed (anonymous data).

We may collect, use, store, and transfer different types of personal data about you, as follows:

• Information you provide to us — You may provide information about yourself by filling in forms on our site https://www.nav.ro (our site) and https://client.ro (our site, client area) or by corresponding with us by phone, email, or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, participate in discussion forums on our site, enter a contest, promotion, or survey, and when you report a problem with our site. The information you provide may include identity information such as name and personal identification number, contact information such as address, email address, and phone number, financial information, and credit card information.
• Information we collect about you — In relation to each of your visits to our site, we may automatically collect the following information:
• technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform;
• information about your visit, including the full Uniform Resource Locator (URL) clickstream to, through, and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), and methods used to browse away from the page, and any phone number used to call our customer service.
• Profile information such as username and password, purchases/orders, interests, preferences, feedback, and survey responses.
• Information about your use of our services, such as information about how you use the website, products, and services.
• Information we receive from other sources — We may receive information about you if you use any of the other websites we operate (if any) or other services we provide. In this case, we will inform you, when we collect those data, that they may be shared internally and combined with data collected on this site. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment, and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

We do not collect any Special Category personal data about you, except where this results from the contract concluded with you (this includes details about race or ethnic origin, religious or philosophical beliefs, sexual life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not collect any information about criminal convictions.

If you do not provide us with personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may cancel a product or service you have ordered, but we will notify you if this is the case.

Cookies

Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve it.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our site.

We use the following cookies:

• Essential cookies — These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site.
• Analytical/performance cookies — They allow us to recognize and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily. These are statistical and do not identify any individual.
• Functionality cookies — These are used to recognize you when you return to our site. This enables us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
• Targeting cookies — These cookies record your visit to our site, the pages you have visited, and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests.

Please note that third parties (including, for example, advertising networks and providers of external services such as web traffic analytics services) may use cookies over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. Any information collected by these third parties will be governed by their own Privacy/Cookies Policy.

How we use your personal data

We will use your personal data only when the law allows us to. Most commonly, we will use your personal data in the following situations:

• Where we need to perform the contract we are about to enter into or have entered into with you
• Where it is necessary for our legitimate interests and your interests, and your fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

In general, since the personal data we process arises from the contract concluded with you for the provision of services or goods, we do not rely on consent as a legal basis for processing your personal data, except for the transmission of third-party marketing communications via email or text messages. You have the right to withdraw your consent to marketing at any time by contacting us.

The purposes for which we will use your personal data

We have set out below, in tabular form, a description of all the ways we plan to use your personal data, and the legal bases we rely on to do so. We have also identified what our legitimate interests are where applicable.

Note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data.

Marketing

We strive to provide you with choices regarding certain uses of personal data, particularly in marketing and advertising.

We may use your identity, contact details, technical data, usage data, and profile data to form a view of what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have purchased goods or services from us or if you provided us with your data when you entered a competition, registered for a promotion, or otherwise gave your consent — and until you opt out of the relevant marketing communications.

Third-party marketing

We will obtain your express consent before we communicate your personal data to any company outside our group of companies for marketing purposes.

Unsubscribe

You can ask us to stop sending you marketing messages at any time by logging into the site (https://client.ro — client area) and ticking or unticking the relevant boxes to adjust your marketing preferences, by following the unsubscribe links in any marketing message sent to you, or by contacting us at any time at the email address: office@nav.ro.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose.

If we need to use your personal data for another purpose, we will notify you and explain the legal basis that allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in accordance with the rules above, when this is required or permitted by law.

Disclosure of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above:

• i) Third parties to whom we may choose to sell, transfer, or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

• ii) If we receive a complaint from a third party that you have used the service in a manner that is unlawful (for example, if there is an alleged copyright infringement). If we receive such a complaint, we may use your IP address to notify you. Except where required by law, we will not disclose your personal information to the complainant.

iii) We may also retain certain information about the use of Internet services to comply with the law. We will disclose this information when we are legally required to do so.

Data security

We have implemented appropriate security measures to prevent the accidental loss, unauthorized use, or unauthorized access to your personal data, alteration, or disclosure. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who need to know it for business purposes. They will process your personal data only on our instructions and are subject to a duty of confidentiality.

We have implemented procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of meeting any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, as well as the applicable legal requirements.

In some circumstances, you may ask us to delete your data: see further information below.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are listed below:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing of your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, you can contact us at any time during normal working hours at NAV Communications S.R.L., address: Strada Tămâioarei, No. 116, Office Building TAM, 1st floor, sector 2, postal code 023644

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Information we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Response deadline

We try to respond to all legitimate requests within 30 (thirty) days. Occasionally, this period may be exceeded if your request is complex or if you have made several requests. In that case, we will notify you and keep you informed.

Third parties

Internal Third Parties — Other companies in our Group acting as joint controllers or processors.

External Third Parties

• Service providers acting as processors who assist us in providing our services to you.
• Professional advisers acting as controllers or processors, including lawyers, bankers, auditors, and insurers providing consultancy, banking, legal, insurance, and accounting services.
• State authorities or other governmental entities that may request personal data, as well as tax authorities, customs, registrars for Internet domain names (.ro zone), and other domain name registries.

Your legal rights

You have the right to:

Request access to your personal data (known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data we hold about you. This enables you to correct any incomplete or inaccurate data we hold about you, although we may need to verify the accuracy of the new data you provide.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following situations:

• (a) if you want to establish the accuracy of the data;
• (b) where our use of the data is unlawful but you do not want us to erase it;
• (c) where you need us to retain the data even if we no longer need it as you require it to establish, exercise, or defend legal claims;
• (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we rely on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you, if this is the case, at the time you withdraw your consent.

Version: 25 MAY 2018

Acceptable Use Policy

1. Introduction

1.1. This Acceptable Use Policy ("AUP") defines the principles governing the use of systems, services, and equipment (as applicable) provided by NAV Communications in connection with the services we offer you.

1.2. "User(s)" or "you" means the clients or any other person who uses or accesses our services.

1.3. We may amend, modify, or replace this AUP at any time. Continued use of the services provided under your contract after any such amendment, modification, or replacement constitutes your acceptance of any new AUP. We recommend visiting our website periodically to check for updates or modifications to this AUP.

2. NAV Communications enforcement actions — our rights to investigate, suspend, restrict, or terminate your services

2.1. We reserve the right to investigate any suspected breach of this AUP. When we find possible breaches, we may initiate an investigation, which may include gathering information from the User involved and the complaining party (as applicable) and examining materials on our servers or networks or other equipment associated with the services we provide under your contract.

2.2. We will take action if you abuse our services and/or breach this AUP. The actions we may take, at our discretion, at any time, include but are not limited to:

(a) a phone call or an informal email requesting your cooperation;

(b) a formal warning to you;

(c) suspension of the service (with or without notice);

(d) restricting your access to all or any part of a service provided under your contract (with or without notice); or

(e) termination of any service under your contract (with or without notice).

2.3. Without prejudice to our right to restrict, suspend, or terminate the service, if you breach this AUP and/or our terms and conditions, we may decide to issue you a formal warning, specifying the unacceptable behavior and informing you that repeated breaches may result in the total or partial withdrawal of our services, temporarily or permanently.

2.4. If, after issuance of a formal warning in accordance with section 2.3 above, your behavior continues to breach this AUP, we will withdraw all or any part of the services until we are satisfied that you have implemented the appropriate steps to ensure that your use of our systems, services, or equipment will comply with this AUP.

2.5. If such suspension is imposed, it may be lifted, at our discretion, upon receipt of a written commitment from you that you will not commit further abuse. Until we receive the written commitment via the contact details provided, services will remain suspended. NAV Communications is in no way responsible for any loss during transmission (post, email).

2.6. Before terminating services, depending on the nature of the AUP breach, we may work with Users to avoid future AUP breaches and to ensure that the breach does not recur. For clarification, the decision to work with you to resolve any AUP breach is entirely at our discretion.

2.7 If you are a reseller of our services and you and/or the end user breach the AUP, it is your responsibility to inform the end user about any action we take in connection with the terms of this AUP.

3. Use of Services

3.1. You must not use our services in any unlawful manner or to the detriment of other users of our services. You must also not allow any person using your connection to use our services in any unlawful manner or to the detriment of other users of our services.

3.2. In addition to and without prejudice to your obligations under our terms and conditions, you agree to comply with (and ensure that others using the services comply with) all applicable laws, rules, and regulations in connection with the services. As a User of the services, you are liable for any use of the services provided to you, regardless of whether they are used without your knowledge and/or consent.

3.3. You are obliged to update the contact details provided to NAV Communications. Keeping these records up to date is important, as we may send you notifications or other information using the contact information you have provided.

3.4. If your use of services is investigated by the competent authorities, we reserve the right to suspend the services for the duration of the investigation.

4. Your responsibilities — security

4.1. The security of the services used by you is your responsibility. We are not liable for the consequences of your failure to comply with adequate security measures (e.g., lost or corrupted files, identity theft, fraud).

<i>Device security</i>

4.2. Users are responsible for the security of their own systems and devices connected directly or indirectly to our systems.

4.3. If we identify that the systems and/or devices at the end of your connection have a significant impact on our service or are part of a "botnet" (machines hijacked by others to distribute malicious software or other forms of abuse), we reserve the right to suspend or disconnect your services without notice.

4.4. You must take all reasonable precautions to protect yourself and your systems and servers from viruses and other forms of malicious intrusion. We will not be liable for any loss or damage suffered as a result of such intrusion.

<i>Account security</i>

4.5. You must keep your password(s) (if any) confidential and secure. If you believe that your password has become known to any unauthorized person or may be used in an unauthorized manner, you must take steps to change your password immediately. If you believe that any of your devices has been used to breach the terms of this AUP, you must inform us immediately.

5. Your responsibilities — NAV Communications systems, services, and equipment

5.1. Users must not take any action that restricts or prevents any person, partnership, company, firm, or organization (client of NAV Communications or another person) from lawfully using or enjoying our systems, services, or products.

5.2. The specific acts prohibited in connection with NAV Communications systems, services, and equipment are:

5.2.1. Selling or reselling our services and products;

5.2.2. Any form of unsolicited, unwanted, or deceptive advertising;

5.2.3. Providing false data, including fraudulent use of credit card numbers (and this behavior is grounds for immediate termination and may subject the offender to civil or criminal liability);

5.2.4. Attempting to circumvent user authentication or the security of any host, network, or account (also known as "cracking" or "hacking"). This includes but is not limited to accessing data not intended for the User, connecting to a server or account that the User is not expressly authorized to access, or probing the security of other networks without the express authorization of the third-party network owner;

5.2.5. Carrying out security breaches or communication interruptions. Security breaches include but are not limited to accessing data of which the User is not a recipient or connecting to a server or account that the User is not expressly authorized to access. For the purposes of this section, "interruptions" include but are not limited to port scans, ping floods, packet spoofing, forged routing information, deliberate attempts to overload a service, any form of Denial of Service (DoS) attack, or attempts to "crash" a host;

5.2.6. Use of any program/script/command or sending of messages of any kind designed to interfere with or negatively affect the use by Users of our network by any means, locally or over the Internet, including violating the confidentiality of other Users; and

5.2.7. Performing, for harmful purposes, any form of network monitoring or interception of any data that does not belong to you.

6. Your responsibilities — content/material

<i>General aspects</i>

6.1. The storage, distribution, transmission, or arrangement for the publication of any "prohibited" material through use of the services is forbidden, including, for example, the use of email services, posting on online forums, and use of social media. What constitutes "prohibited material" will be determined by us (at our sole discretion). Prohibited content includes (without limitation):

6.1.1. Material that threatens, harasses, invades privacy, is discriminatory, defamatory, racist, obscene, indecent, offensive, abusive, harmful, or malicious;

6.1.2. Materials that infringe or violate the intellectual property rights of third parties (including, without limitation, copyrights, trademarks, design rights, trade secrets, patents, moral rights, paternity rights, and performance rights) — including the use, distribution, and/or copying of any materials without the express consent of the owner;

6.1.3. Materials that violate any law or regulation in force in the country where you use and/or receive the services; and

6.1.4. Programs containing viruses, malware (malicious software), forgeries, or any other tools designed to compromise the security of users, web pages, and/or systems. You may, however, transmit malware samples in a secure manner to the appropriate agencies to combat their spread.

6.2. Phishing — material designed to obtain information such as usernames, passwords, credit card details, or other personal information by masquerading as a trustworthy source.

6.3. For the avoidance of doubt, storage and/or distribution through our systems and/or services by any User of "pirated" software or any other materials not expressly licensed to the User will constitute a breach of this AUP.

6.4. At our sole discretion (and without prejudice to any other rights we have under this AUP and under this contract), we reserve the right to remove or block any material from any server under our control. In addition to other actions we may take, we reserve the right to notify the competent authorities, regulators, and/or other third parties of the use, storage, distribution, transmission, retransmission, or publication of prohibited materials (and/or any other materials whose handling or use may constitute unlawful conduct by Users).

Version: 25 MAY 2018