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.
| Purpose/Activity | Type of data: | Legal basis for processing, including basis of legitimate interest |
|---|---|---|
| To register you as a new client | (a) Identity (b) Contact |
Performance of a contract with you |
| To process and deliver your order, including:
(a) managing payments, fees, and charges (b) collecting and recovering money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transactions |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts owed to us) |
| To manage our relationship with you, which will include:
(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (without personal ID number) (b) Contact (c) Profile | (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to participate in a prize draw, competition, or complete a survey | (a) Identity (the personal ID number will be used only to fulfill tax obligations and only for winners of prize draws or contests) (b) Contact (c) Profile (d) Usage |
(a) Performance of a contract with you
(c) Necessary for our legitimate interests (to study how our customers use our products/services, to develop them, and grow our business) |
| To administer and protect our business and this site (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and data hosting) | (a) Identity (without personal ID number) (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, providing administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring)
(b) Necessary to comply with a legal obligation |
| To deliver relevant site content and advertisements to you and to measure or understand the effectiveness of the advertising we serve to you | (a) Identity (without personal ID number) (b) Contact (c) Profile (d) Usage (e) Technical |
(c) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, grow our business, and inform our marketing strategy) |
| To use data analytics to improve our site, products/services, marketing, experiences, and customer relationships | (a) Technical (b) Usage |
Necessary for our legitimate interests (to define customer types for our products and services, to keep our site updated and relevant, to develop our business, and to inform our marketing strategy) |
| To make suggestions and recommendations to you about products or services that may be of interest to you | (a) Identity (without personal ID number) (b) Contact (c) Technical (d) Usage (c) Profile |
(c) Necessary for our legitimate interests (to develop our products/services and grow our business) |
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.