Statement on the protection of personal data

1. Our privacy statement International Arcoglass SRL attaches great importance to preserving the privacy of your personal data. That is why we want to offer you a transparent process of collecting and using your personal data. When we say ‘we’, we refer to International Arcoglass SRL headquarters in Str. Barlogeni , Nr . 46-48 Romania BUCURESTI SECTOR 1 .
This Privacy Statement is intended to explain in a simple way our personal data processing processes: what kind of data we process and how we do, the explanation we offer to you – as customer, visitor to our website or in any other quality you contact us.
This statement applies both to individuals and legal entities.

2.   Processing and using your personal data
By personal data, we mean not only data that you can identify directly, but also data that you can identify indirectly:
· Direct identification can be accomplished through data such as your name and address.
personal code, email address, phone number, etc.
· Indirect identification can be made on the basis of more combined information, which together can lead to your identification. For example, your contract number is not necessarily personal. However, it will enter your personal data when it is automatically (automatically) coupled with your name. By processing and using personal data we mean in fact: collecting, saving, keeping, using, consulting, modifying, disclosing, publishing deleting your personal data.

2.1 What personal data do we process?
The different categories of personal data that we usually process are as follows:
· Identity information such as your first and last name, date of birth, place of birth, identity card number (or bulletin, if applicable), email address, and even the IP address of your computer or mobile phone.
· Data about the operations you make through us, such as the bank account number.
· Financial data, such as the value of your real estate or other assets you have.
· Social-demographic data, such as your civil status, your family situation or other relationships you are involved in, your level of training and your knowledge.
· Data about your Internet behavior and preferences we register when browsing our website or when using our mobile apps.
· Data about your interests and desires that you share through personal contact (including via the contact center) on the internet platform (for example when completing an inquiry on our website).
· Audiovisual data, such as surveillance cameras’ images when visiting one of our offices or call records on your mobile phone when you call our office.
In cases provided by law, we can also use data from external sources (for example, information from government authorities in the fight against terrorism and money laundering).   We generally do not use sensitive personal data such as your health, your religious, political or philosophical beliefs, sexual inclinations, or ethnicity.

2.2 To whom do the personal data we process?
We process personal data of the natural or legal persons with whom we have a direct or indirect relationship, or with whom we have had in the past or want to develop such a relationship in the future.
Thus, personal data may relate to:
· Our customers, their representatives or beneficiaries;
· Potential customers who are interested in our products and services
· Anyone has a legal person, such as a representative of a company or a de facto organization.
We process your personal data, for example, when entering into a contract with us, visiting our website or completing an inquiry. These are both personal data you fill in on your own behalf and those that you fill out on behalf of a legal person.   We also use personal data of third parties, people who are not clients but who are in contact with our clients because of a certain function, concluded agreements or due to a certain right they have towards our clients .
Some examples:
· Legal representatives (as well as empowered agents)
· Payees made by our customers
· Creditors of our clients (for example, after declaring bankruptcy)
· Shareholders of commercial companies where they are natural persons
· Statutory representatives
· Administrators or other persons listed as contact persons in the case of a merchant customer.

2.3 For what purpose do we use your personal data?
We use your personal data for the following purposes:
· Managing the client file
If you want to enter into a brokerage agreement with us, we are legally required to retrieve a personal data (such as a copy of your identity card or any other document attesting your identity) to determine whether you we can accept as a customer. In addition, we need your address and phone number to contact you afterwards.
· Delivery and provision of services
If you want to buy a new product or service, we also need some personal data to determine whether we can deliver the product or whether we can deliver the service with the features you want.
· Managing customer relationships
You may receive invitations to participate in customer satisfaction surveys or other types of inquiries. The results of these surveys can be sent to the various members of our staff to improve the quality of our products and services. We can also use notes made during visits to one of our offices to be able to provide you with more appropriate products or services as you need.
· Based on a review of your profile, we determine to what extent a product fits you and is suitable for you. Whenever we offer you a product, we will have to ask you some questions about your educational training, the knowledge you it’s about the products you offer and your wishes and needs.
· In order to continue with the customized approach of each client dossier, as we suggest, for example by sending letters or emails via personalized offers or offering custom mobile or customized applications.
In order to offer you the most relevant products or services, we can proceed to:
• Analyzing the information we collected when, for example, you visited our website, when you had a meeting at one of our offices or when you met with some of our real estate agents
• Analyze your potential need for delivering products or delivering our services (we can, for example, invite you to one of our offices to discuss products and services that fit your profile).
• Identify the key moments that certain of our products or services become relevant to your situation (birthday anniversaries, deaths, marriages, divorces, adoptions).
• Evaluate your interests, for example based on the simulations you make on our website.
· Optimizing the services provided.
• Using data on your operations to better understand how you use our services so that we can improve them.
• Analyze the results of our marketing activities to measure the efficiency and effectiveness of our promotion campaigns.
· Prevent, detect and combat non-compliance with mandatory legal provisions (eg in the fight against money laundering, terrorist financing and tax fraud).
· We can process your personal data and protect you and your property against fraudulent practices. This can happen, for example, when you are the victim of identity theft when your personal data is published without authorization or when you are the victim of a cyber attack.   We can also collect relevant data for a customer (name, account number, age, nationality, IP address, etc.) to create a client profile in order to quickly and efficiently detect criminal activities.
We also use contact data and security data (such as card reader, password, etc.) to allow remote protection of your operations and messages that you exchange through our communication channels .

3. How do we work when we work with your personal data?
3.1 We comply with the legal provisions on the protection of personal data
For us, it is extremely important to keep our own reputation for integrity and respect for the privacy of our customers’ data.
We do our best to comply with the Belgian law on the protection of privacy and privacy and its implementing rules and regulations. In this regard, we are under the jurisdiction of the Commission with regard to the protection of personal data.
According to the legal provisions, we apply appropriate technical procedures and organizational measures (eg IT security procedures and measures, etc.) to guarantee the proper protection of your personal data against loss or theft.
We also conclude contractual arrangements with our suppliers or partners who process personal data or provide us with such data.

We also recommend that you take appropriate personal data protection measures yourself:

· Install anti-virus, anti-spyware, and firewall software. Install these programs with automatic periodic updates at short intervals.
· Do not leave your equipment and communications accessible and unattended.
· Sign out of your account from the luminary app whenever you do not use it.
· Keep passwords strictly secret and use strong passwords – try to avoid combinations of digits and letters easy to guess.
· Be cautious in all unusual situations, such as when you are dealing with a new internet address or bizarre requests, such as when you are asked to send customer data by e-mail.

3.2 How do we collect your personal data?
We are in possession of your personal data when you become a customer or when you register online for our services when completing online forms or when signing contracts with us when you use our products or services or when you contact us through our communications channels.

3.3 How do we deal with “cookies”?
We use “cookies” on our website to improve its functionality, to keep your preferences and to send you certain information when we think it might be of interest to you.
In a simple explanation, “cookies” mean small data files that remain saved on your computer.
They can serve different functions, but they generally retain data about the sites you visit. “Cookies” contain small amounts of information about the views you have made on a specific web page, which can then be used to retain your preferences in the event of a future visit.
“Cookies” can be “functional” and contain data about you (as a user), such as the language or currency you have chosen so that it appears from the beginning to the next view.
“Cookies” may also be “technical” containing data about the user-viewed page on the website of International Arcoglass SRL regarding the fields completed on the forms on the site. Such “cookies” are required to provide you with personalized information and avoid repeating information or advertisements on the views you make successively.
We use cookie data for statistical purposes or for studies on the Luminarc internet site to improve its content and performance.
We can also use “cookies” to identify your online behavior patterns and to adapt our web site to your needs and interests.
No cookies will be placed unless you explicitly declare that you accept their insertion. You may also revoke at any time the agreement you have made to that effect. The agreement once expressed is also valid for accessing the following information at the same session on the site.   You can install your browser to let you know how to manage these cookies. If you refuse to receive cookies from us, our site may operate slower or it may not all services work.

3.4 Automatic Processing of Your Personal Data
In order to deliver products and services efficiently and quickly, it is sometimes possible to perform automatic processing of your personal data. However, no automated decision-making procedures are used.

3.5 During what period do we store your personal data?
We do everything we can to store personal data for longer than is necessary to meet the purpose for which we have collected.
The personal data we have collected for prospective clients is kept for a maximum of one year.
Other data, such as telephone conversations, are kept less, in accordance with the legal provisions in force.
In deciding how long personal data should be retained, we must also take into account the legal data retention obligations imposed by applicable laws (eg anti-money laundering legislation). We may keep your personal data and as evidence in case of any court processes. In this case, personal data will not be used actively.

Therefore, there is no general retention period for personal data – it varies from case to case depending on the circumstances (your data may be retained for up to ten years from the time your contract with us ceased).
4. With whom do we collaborate in the processing of your personal data?
4.1 Using your personal data within Luminarc
We take the best care of your personal data and share it with others only to the extent that it is absolutely necessary to provide you with the best service.
We can transfer personal data to other entities that help us perform certain operational tasks, protect IT, or deliver specific products and services. For certain operational protection activities and screening activities to combat money laundering, we can appeal to entities outside of Belgium. We are responsible for our own products but for distributing them we also work with other merchants with whom we have concluded distribution contracts.

Additional information on the activities of Luminarc not the stars and find the International Arcoglass has taken measures to ensure the security of personal data shared with other entities or transferred to them in accordance with international rules and regulations.

4.2 Use your personal data outside of Luminarc
1. Sometimes we are legally required to make available to your external organizations your personal data .
We are legally required to put the personal data we have at our disposal to these third parties:
· Public authorities, regulators and supervisors when there is a legal obligation
to make available to them personal customer data, as in the case
the Financial Administration or the National Bank of Belgium (NBB);
· Courts or research courts, such as the police, public prosecutors, courts of law,
arbitration courts, mediation bodies at their express request;
· Lawyers, for example in the event of bankruptcy, notaries, court liquidators or curators managing the business of another and auditors.
2. Third parties to whom we are not required to provide personal data,
but we call for many of the services we provide:
· Specialists from various sectors of activity who have the legal obligation to process personal data with responsibility:
· Service providers, ie businesses and individuals who provide support for:
• designing and maintaining our internet tools and applications we use;
• marketing operations for our activities, organization and events, and management
the communication process with our customers
• preparing reports and statistics, printing and designing our products.
· Organizations whose products and services we sell or collaborate with.

In the above cases, we ensure that the third parties concerned have limited access to personal data, that is, to the extent necessary to enable them to perform their specific tasks. We also ensure that the third parties undertake to use the data we provide in a safe and reliable manner, in accordance with our instructions. Under no circumstances do we sell to third parties the personal data we have at our disposal.

When working with entities outside of Romania, we take steps to ensure that personal data is adequately protected in the country to which it is transferred. In these cases, we take action (such as contractual obligations) to ensure that personal data transferred is processed as carefully as in Romania.

5. What are your rights?
We do our utmost to ensure a high degree of transparency in the use of your personal data.
As far as your personal data is concerned, you are legally entitled to be informed about the processing, to have access to this data and to correct it. You also have the right to oppose your use. You have the right to request the deletion of these data, to refuse to transfer them, as well as the right to oppose automatic data processing for making decisions as well as to create a profile for you. We will respond to any requests within one month from the date of receipt of the request.

a. Information

No personal data will be retrieved or retained without explicit authorization and without proof of disclosure of this privacy statement.

b. Access

We will offer you

· A description of the personal data we keep
· An explanation of why your personal data is being collected
· Information about the external partners to whom we will transfer the data
· Information on why any automatic processing of your personal data takes place.

To access your personal information, you can visit us directly at our Bellegem headquarters. Before responding to your request, we may ask you to provide us with an identity document or to answer our questions for identification purposes. Then we’ll give you a copy of the data we use. The first request is completely free. For each copy you request later, we can ask you for an appropriate price to cover administrative costs (€ 0.5 per page + € 50 per project cost).

In some cases, in cases where access to data could reveal commercially or legally sensitive information that we have to keep confidential or where a judicial inquiry is under way, we may be required to restrict / refuse right of access. This provision relates specifically to information on beneficiaries, where only the right holder has the right to make known the identity of those beneficiaries.   You will receive in due time a reasoned response to your request and how you may complain against this refusal through one of our channels of communication. We will do our utmost to ensure that your personal data is accurate, current, complete, relevant and not misleading. We can ask you to confirm that your personal details are up to date.

c. Correction

If you feel that your personal data is incorrect, you can ask us to modify it. We will perform the required operations as soon as possible after we have been informed in advance of how long it will take to process the requested change.   We will make changes to your personal data if it appears to be false, obsolete, incomplete,

Irrelevant or misleading, taking into account the purposes for which they were collected. If we correct your personal information after having previously made it available to third parties, we will make these changes known to third parties if we have a legal obligation to do so.
If we refuse to modify your personal information as requested, we will explain the reasons for our decision and how to complain against this decision. In this case, we may ask you for an additional explanation of why you think the data is wrong.

d. Opposition law

When you become our client, we will ask you if you want a personalized approach, in which case we will use your personal data. You can then at any time decide to stop using this customized merchant offer:
· Accessing the “delete from database” button located at the bottom of each commercial email;
· Through our contact form on www.
· Contacting us by phone;

Please note that even if you opposed a personalized business approach, we may contact you for other purposes, such as in the case of a legal obligation or performance of a contract (for example, with important information about your contract. or administration thereof).

e. The right to be deleted from the database

You have the right to request that your personal data be deleted. This request may be refused if there are legal grounds based on legal provisions (eg legal deadlines for data retention, anti-money laundering obligations), contractual relationships, based on a court order, in an ongoing criminal investigation , or in the case of a court challenge. You will find out in due time why your application has been declined and how you can eventually complain against this refusal through our communications channels.

f. The right to portability of your personal data

You have the right to request the transfer to another data operator of the personal data you have made available to us. Data is transferred free of charge in an accessible and legible structured form. This operation can only be done for the data you have provided to us based on your authorization or an agreement.

g. Respond to oppose automatic data processing to make decisions as well as to create a profile for you.

You may not be automatically processed for your personal data to make decisions or create a profile for you. Luminarc and its suppliers are provided with such procedures.

6. Do you want additional information or do you want to file a complaint?
We are responsible for carefully processing the personal data you entrust to us, such as your bank account name, address, and information.
We are obliged to respond to any complaints you submit to us regarding the confidentiality of your personal data within one month of receiving your request.

If you want additional information on the external partners we provide
your personal data on the basis of a legal obligation or in the performance of a service we have subcontracted with or in case you have complaints about the processing of your personal data, you can contact us:
· on the phone ,
· Sending us an e- mail (office @ luminarc .ro) or
7. With regard to this statement on the protection of personal data

This Privacy Statement enters into force on 1 January 2018 and may be amended to bring it into line with relevant changes in existing legislation or within Perfect Laundry. The most recent version is available on our web site and the changes made to it will be communicated to you either through this page or through the other channels we use.

8. GDPR notifications

On 24 May 2016, the General Data Protection Regulation (GDPR) entered into force.

In the light of this regulation, we provide the following information.

Responsible for data within the meaning of the Regulation is Arcoglass International

Purpose, nature and legal liability of processed data.






The goal Nature of processed data Legal responsibility for data
News brochure, delivery of commercial and promotional content Name, first name, postal address, email address, language Pre-informed and informed consent under the GDPR
Preparation, conclusion and execution of the contract Surname, first name, postal address, email address, fixed and mobile phone numbers, language, insurance contributions , bank account numbers Contract data
Control to combat money laundering Name, first name, postal address, language email address, CNP,   identity card number, CI photocopy, IC printed version Legal obligations or regulation to combat money laundering.
Suitability and relevance test in pre-contractual phase Level of studies, financial knowledge, family composition, civil status, composition of property, desires and needs, risk profile score. Regulations on the “two-point model”.





Original Romanian text:
Dacă doriți să cumpărați un produs sau un serviciu nou, avem nevoie în plus de anumite date cu caracter personal pentru a putea stabili dacă vă putem livra produsul sau dacă putem presta serviciul cu caracteristicile pe care le doriți.
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