1. Introduction
When you use the accelerate.gov.ro platform, managed by Unitatea Executivă pentru Finanţarea Învăţământului Superior, a Cercetării, Dezvoltării şi Inovării, (hereinafter referred to as " UEFISCDI"), you entrust us information about yourself, also known as personal data, by virtue of your confidence in us. We thank you for your confidence, that is why we want to clearly and transparently explain what are our practices regarding the privacy of your data.
Through this policy, we point out what type of information we collect, the way in which we use it, as well as the options you have in relation to this data
2. Whom does this Privacy Policy apply to?
Summary: This policy applies to the worldwide users of ACCELERATE.GOV.RO services, including to the users of apps, websites or of any other functions offered by ACCELERATE.GOV.RO (hereinafter, taken as a whole, referred to as "accelerate.gov.ro platform" or "ACCELERATE.GOV.RO").
We operate and function in Romania.
This policy describes the way in which ACCELERATE.GOV.RO and its affiliates collect and use the users' personal data (both customers as well as partners), in order to be able to provide the offered services.
The policy applies to all who use the ACCELERATE.GOV.RO products in one way or another, as defined in the Terms and Conditions (we recommend you read them carefully prior to giving your consent), by means of the apps, websites or any other functions offered by ACCELERATE.GOV.RO.
To better understand how it works, the policy applies especially to:
• Registered users: users that register on ACCELERATE.GOV.RO and who require or benefit from services provided by ACCELERATE.GOV.RO, as defined in the Terms and Conditions;
• guests: users that visit on and do not register an account
ACCELERATE.GOV.RO works with a series of partners/persons in order to provide services (they are not publicly seen, but they help us provide our services to you) and which are connected to the services provided by ACCELERATE.GOV.RO (an example would be the public institutions we maintain direct contact with in order to improve the content and its accuracy).
Given that it would take us too long to list all these persons, as they keep on changing, all the persons indicated above shall be defined in this policy as "users" and these conditions shall apply to them.
3. Personal Data Operator
As you could or will see, ACCELERATE.GOV.RO requires certain personal data, according to the stage you are in on the Accelerate.gov.ro platform. Because we decide on what type of information we request, according to the General Data Protection Regulation, we are a data operator.
You can find our identification data below: Denomination Unitatea Executivă pentru Finanţarea Învăţământului Superior, a Cercetării, Dezvoltării şi Inovării (UEFISCDI) Registered office Str. Mendeleev nr. 21-25, Sector 1, Cod 010362, București Phone no.: +4021 30 23 850 E-mail victor.velter@uefiscdi.ro DPO Contact: Victor Velter
If there are unclear aspects, observations or if you have complaints regarding us or the personal data we process for you, you can send us an e-mail to the above address, as any moment.
4. Information We Collect
Summary: ACCELERATE.GOV.RO collects the following personal data:
• the information you provide to ACCELERATE.GOV.RO, for example, when you create your ACCELERATE.GOV.RO account;
• information obtained from other sources, such as from ACCELERATE.GOV.RO partners and third parties using ACCELERATE.GOV.RO’s API keys or who have access to the platform.
4.1. Information You Provide
4.1.1 Information provided when you create your account:
Information necessary for registration
When you register on ACCELERATE.GOV.RO, the following information is necessary to finalize the registration process and to create an account on our platform:
• last name;
• first name;
• e-mail address;
• password;
Demographic Information
Demographic information: we may collect demographic data about you, including through user surveys, for the improvement of our services.
Content provided by you on various occasions
We may collect information you send when you contact ACCELERATE.GOV.RO customer support, when you rate ACCELERATE.GOV.RO partners/other users or when you contact ACCELERATE.GOV.RO for any other reason (through the contact form on the platform, chat application, by phone etc.)
Agenda or Calendar
There are situations in which we may access the agenda or calendar associated to your e-mail address used for registration, in order to be able to schedule a meeting with one of ACCELERATE.GOV.RO partners for the provision of our services.
4.1.2 Information provided when you use our services:
They may include:
• Usage Information We collect information on the way in which you use our services. It includes information such as the access dates and times, functions of the app or pages viewed, app errors and other system activities, browser type and third party websites or services you use prior to using our services. In some cases, we collect this information by means of cookies, tracking pixels and similar technologies which create and run unique identifiers. In order to find out more about these technologies, please access the Cookies Policy.
• Information about Devices: We may collect information about the devices you use to access our services, including the hardware designs, the device's IP address, operating systems and versions, software, file names and versions, preferred languages, the device's unique identifiers, marketing strategy identifiers, series numbers, information on the device's mechanism and information on the mobile network or internet.
• Location Information: We may collect information regarding your location, through the GPS installed on the device and through the connected functions (such as mobile/Wi-Fi data usage) in order to find your location within the purpose of being able to benefit from our services.
4.2. Information from Other Sources
For you to enjoy our services' experience, we may process information about you from other sources, as well, such as:
• user feedback, such as rating or assessment;
• sources available to the large audience;
• marketing services providers.
5. How do we use the obtained information?
ACCELERATE.GOV.RO collects this information so as to offer services requested by you on the platform, to improve the service provision, as well as for the development of new technologies to meet your needs.
More specific, we use the information:
• to improve our users' and our services' safety and security;
• for support offered to users;
• for research and development;
• to allow communication to or between users;
• in relation to legal procedures.
ACCELERATE.GOV.RO does not sell or share your personal information to third parties within the third parties' direct marketing purposes.
ACCELERATE.GOV.RO uses the information you provide, in order to:
5.1. provide the services and ensure functionality.
ACCELERATE.GOV.RO uses the collected information in order to provide, to customize, to maintain and to improve its products and services. This includes the use of information for the following:
• to create and to update your account;
• to confirm your identity;
• to allow access to the services provided by ACCELERATE.GOV.RO, according to the Terms and Conditions;
5.2. Safety and Security
ACCELERATE.GOV.RO considers that our users' safety and security must come first, in order to deliver a high standard service. Consequently, we will use the information you provide us for the following:
• to verify the users and partners prior to allowing them to use our services and at subsequent intervals, including by analysing the verification of: (a) the eligibility conditions for the profession they belong to or (b) the history when the law allows it, in order to prevent the users or the partners that do not fulfil the legal requirements from using our services;
• our identity confirmation functions when accessing the platform ensure only the fact that the relevant identified user has access to the account attributed to that particular user, this protecting the user information and offering the security of the data which cannot be accessed by foreign persons;
• the use of the assessments provided by other users in order to remove, if the case, another user or partner from the platform. This assessment can be carried out through an automated decision-making process and the concerned persons are entitled to oppose to this process.
5.3. Customer Support
ACCELERATE.GOV.RO uses the information provided by you (such as the browsing history, personal data etc.) in order to improve the support service offered to the users, such as for the following:
• to investigate and solve your problems;
• to monitor and to improve the answers you receive from the customer support;
5.4. Research and Development
ACCELERATE.GOV.RO is continuously improving the services it provides to the users, through continuous research and development of the solutions we want to implement, in order to constantly provide qualitative and competitive services and to facilitate access to information.
That is why your data is very important for us and we will be able to use it for testing, research, analysis and development of products. This allows us to improve our services' safety and security, to develop new functions and products and to facilitate the provision and expansion of our services.
5.5. Legal Procedures
We may use the information you provide to us so as to investigate or to settle disputes regarding the use of ACCELERATE.GOV.RO services or for any other purpose permitted by the applicable law. Likewise, ACCELERATE.GOV.RO could transmit the provided information in accordance with the requirements coming on behalf of the jurisdictional bodies having competence over the access to this information, such as criminal investigations, cases on the dockets of law courts or in preliminary proceedings etc.
6. Transfer of Obtained Information
ACCELERATE.GOV.RO considers that the user must know where the data he/she provides is transferred to. We work with partners and service providers we carefully select, in order to make sure that your data is safe throughout the period you enjoy our services.
6.1. Transfer to Service Providers and ACCELERATE.GOV.RO Partners
ACCELERATE.GOV.RO may transmit information to the service providers and to its partners within research and development, etc., such as:
• cloud storage services providers;
• data analysis service providers;
• research and development partners, including the ones conducting surveys or research projects in collaboration with ACCELERATE.GOV.RO or on behalf of ACCELERATE.GOV.RO;
• providers helping ACCELERATE.GOV.RO to improve the website safety and security;
• specialists, lawyers, accountants and other professional service providers.
If you are a user, we may transfer your personal data to the research and development partners, anonymously or under a pseudonym, in order to contribute to the improvement and expansion of the provided services, according to section 5.4.
6.2. Transfer of Data to Competent Authorities
ACCELERATE.GOV.RO may transfer the data obtained from you to the competent authorities and bodies in the case of a legal proceeding or of a dispute referring to the ACCELERATE.GOV.RO services, when requested in accordance with the applicable legislation, at their request.
7. Data Preservation
According to the regulations in force, we do not want to keep the data more than necessary, as a measure for protecting the private life.
ACCELERATE.GOV.RO keeps the information referring to the user profile and other information throughout the entire period of ACCELERATE.GOV.RO account's activity.
ACCELERATE.GOV.RO keeps the information referring to transactions and usage statistics for 5 years, due to the regulations, tax and insurance requirements, as well as to other requirements in force where it operates . After this period expires, ACCELERATE.GOV.RO deletes or passes under anonymity such information in accordance with the applicable laws.
The users may request the deletion of the account at any moment. Following such a request, ACCELERATE.GOV.RO will delete the information which no longer must be kept and it will restrict the access or the use of any information which still must be kept, in accordance with what was indicated above.
8. Data Storage
The personal data you provided to us and which we process are processed within the EEA ("European Economic Area") and stored in the Amazon Web Services (in Europe). Nevertheless, this data can be processed by the personnel outside EEA working for us or for one of our business partners or service providers. An exhaustive list of the sub-authorised third parties and details about their privacy policies will be found on our website, when they exist. Some countries outside EEA cannot ensure the same adequate protection level for your rights and liberties with reference to the personal data processing; nevertheless, by using our services, you give your consent for ACCELERATE.GOV.RO to present personal data to those third parties.
Please contact us using the data provided under section 3 for more details regarding the specific guarantees applied to the transfer of your personal information outside EEA.
9. Purpose of Processing
ACCELERATE.GOV.RO uses the information you provide to give you access to the services you access through the platform. For the good fulfilment of these services, ACCELERATE.GOV.RO shall use the provided information in other purposes, as well, such as for invoicing, statistics, research & development etc. If ACCELERATE.GOV.RO considers that the provided information could also be used within other purposes than the ones listed above, it will immediately inform the users on the matter.
9.1. Data processing is necessary for the provision of the services you request
ACCELERATE.GOV.RO must collect and use certain information for the provision of services. It includes:
• information on the user profile necessary to create and maintain the account, including to confirm identity;
• information on the verification of the legal conditions fulfilment and on the history, necessary to allow the trade partners to provide the services through Accelerate.gov.ro platform;
• information on the use of ACCELERATE.GOV.RO services, necessary to maintain, optimize and improve ACCELERATE.GOV.RO services.
9.2. Processing is necessary for ACCELERATE.GOV.RO's legitimate interests
ACCELERATE.GOV.RO collects and uses personal information to the extent in which this is necessary for the fulfilment of its legitimate interests. This includes the collection and use of the information:
• to maintain and improve the user safety and security;
• to prevent, detect and to fight the fraud that could be connected to the use of our services;
• to provide user support services;
• to optimize the provided service and to develop new services;
• within research, development and analysis purposes (usage trends analysis included in order to improve user experience and to offer new services);
• to determine the direct marketing strategy (the users' usage trends analysis is included, in order to offer marketing campaigns adapted to needs);
• to meet the ACCELERATE.GOV.RO terms & conditions.
9.3. Processing is necessary to meet ACCELERATE.GOV.RO's legal obligations
ACCELERATE.GOV.RO is subjected to the applicable law having jurisdiction over the territory in which it operates. To this purpose, there will be situations in which ACCELERATE.GOV.RO would transmit your personal data to the competent bodies when asked for such data, for the settlement or prevention of disputes.
10. Grounds for Processing (according to Regulation (EU) 2016/679 General Data Protection Regulation-GDPR)
ACCELERATE.GOV.RO is based on your consent when processing your personal data, according to Regulation (EU) 2016/679 (General Data Protection Regulation-GDPR). We do not want to process the personal data of people aged under 16, that is why we will carry out verifications to this respect and we will ask for the consent of the parental authority holder in the event the concerned person shall be a minor under 16 years old.
You can withdraw your consent at any moment. If you withdraw your consent, you will no longer be able to use the services or functions that require the collection or use of the information we obtained or used based on your consent.
Likewise, ACCELERATE.GOV.RO uses various grounds for processing the data you provide in order to be able to offer the platform services. They are as follows: Data element Grounds for processing Last name, first name, e-mail address, telephone number Article 6 para (1) letter b GDPR – to fulfil the contract you remotely conclude with us when you create an account on the platform and when you access our services Location data Article 6 para (1) letter b GDPR – to fulfil the contract you remotely conclude with us when you create an account on the platform and when you access our services Promotional & marketing activities Article 6 para (1) letter a) GDPR – consent – in case of direct marketing, if you do not want to receive information and newsletters regarding our activity and provided services, you can withdraw your consent at any moment. Article 6 para (1) letter f) GDPR – legitimate interest – to promote the offered services and products, you can withdraw your consent at any moment.
11. Your Rights
Based on GDPR, you have a series of rights regarding your personal data. Also, please take into account the information on Chapter 6.1-Transfer to Service Providers and ACCELERATE.GOV.RO Partners: Access Right You have the right to request information on the personal data we process and which concern you. We will try, to the possible extent, to offer you the information regarding your data in a machine-readable manner as clear, accessible and structured as possible. In order to do so, we must make sure that the relevant data refer to you, therefore we will identify you based on a copy of your ID you provide us. Data Correction Right Your data should be permanently up-to-date and complete. Even though we make all the efforts to make sure your data is always correct, we will also need your help. If you discover that your data is not correct, that changes occurred or if you want to add something, please send us a request for the correction of that data, be it an update, amendment or supplementation. Right to Cancellation/Right ”to be forgotten” You can ask us to delete your personal data in the following cases: • the personal data is no longer necessary for the fulfilment of the purposes for which it was collected or processed; • you withdraw your consent based on which the processing takes place; • You oppose data processing when such personal data processing has direct marketing as purpose; • personal data was illegally processed; • personal data must be deleted so as to comply with a legal obligation. The users may request the deletion of the account at any moment. Following such a request, ACCELERATE.GOV.RO will delete the information which no longer must be kept and it will restrict the access or the use of any information which still must be kept, in accordance with what was indicated under section 7. Right to Limit Processing You can ask us to limit your personal data processing in the following cases: • you challenge the exactness of your personal data, but for a period allowing us to check the exactness of your data; • data processing is illegal and you do not agree with the deletion of your personal data, but you request in exchange to limit its processing; • we no longer need your personal data, but you request it to ascertain, exercise or defend a right in court; • you oppose your personal data processing when the personal data processing has direct marketing as purpose, for the time period in which verifications are carried out to see if our legitimate rights prevail over yours. Right to Data Portability You can ask us to send the personal data concerning you and that you provided to us in a structured form, currently used and automatically-readable and you have the right to transmit such data to a different operator, under the following circumstances: • data processing is based on consent; • data processing is carried out through automated means. Right to Oppose You have the right to oppose processing when: (a) processing is needed to fulfil a task which serves for a public interest, (b) processing is necessary within the legitimate interests followed by us or by a third party, including for the creation of profiles based on the relevant provisions. In such cases, we no longer process your personal data, except for the case when we prove we have legitimate and imperative reasons that justify data processing and which prevail over the interests, rights and liberties of the concerned person or when the purpose is to ascertain, exercise or defend a right in court. The right to oppose an individual automated decision-making process, including the creation of profiles You have the right to not be the object of a decision exclusively based on automated processing, including the creation of profiles who produce legal effects concerning you or which affect you in a similar way, to a significant extent. Such right has certain limitations, i.e.: • the automated decision is necessary to conclude or to carry out a contract between you and us; • the decision is authorised according to the legal provisions; • we have your explicit consent for this matter. In such a case, please send us a request for us to subject your personal data to a manual processing process.
12. Complaints
If you believe that an issue with the personal data processing occurs, please send us first a request to the address gdpr@accelerate.gov.ro – we will make all the efforts to settle amicably your request within the shortest time possible. More details about the GDPR’s policy of UEFISCDI (as owner of ACCELERATE.GOV.RO) are accessible here: https://uefiscdi.gov.ro/protectia-datelor-cu-caracter-personal.
Likewise, you may submit a complaint to the supervisory authority for personal data. For Romania, the contact data can be found below: Name National Supervisory Authority for Personal Data Processing Address B-dul G-ral. Gheorghe Magheru nr. 28-30, Sector 1, zip code 010336, Bucharest, Romania Phone no.: +40.318.059.211 or +40.318.059.212 E-mail anspdcp@dataprotection.ro
13. Changes to This Policy
We may occasionally update this policy and we will notify you through the Accelerate.gov.ro platform or by e-mail regarding the most recent version. Even if you do not get a notification, we encourage you to access and to read periodically this policy in order to be up-to-date with its most recent versions.