Updated version in August 2024
Since we consider ensuring the right to the protection of personal data as a fundamental commitment for HUMANA ROMANIA, we dedicate all the necessary resources and efforts to process your data in full compliance with Regulation (EU) 2016/679 ("General Data Protection Regulation" or " GDPR"), as well as with any other legislation applicable on the territory of Romania. The processing of personal data is carried out by mixed means (manual and automatic), in compliance with legal requirements and under conditions that ensure security, confidentiality, principles and respect for the rights of the persons concerned.
Legal framework and definitions
The basic document to which we refer in terms of ensuring compliance requirements is Regulation (EU) 679/2016 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/CE (General Data Protection Regulation - GDPR), completed with Romanian legislation in force.
According to the definitions in Art.4 GDPR: "Personal information" means information about any person or from any person that can be identified directly or indirectly.
"Personal data" is defined as "Any information regarding an identified or identifiable natural person (the "data subject"); an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more many specific elements, specific to his physical, physiological, genetic, psychological, economic, cultural or social identity".
"Process", "Processing" or "Processed" means any activity involving personal data, including but not limited to the collection, recording, organization, structuring, storage, retrieval and use, disclosure by transmission, deletion or destruction.
The term "Website user" means any visitor who registers by filling in personal data in a registration form, which he will use when contacting us or applying for a job on the HUMANA ROMANIA website.
Who we are and how you can contact us
S.C HUMANA PEOPLE TO PEOPLE S.R.L hereinafter referred to as "HUMANA ROMANIA" is part of the Humana People to People Group - Central and Eastern Europe, associated with the Federation of Humana People to People Associations, a network of independent organizations for development, located in Europe, America North, Africa, Asia and South America. The main objective of Humana - People to People in Europe is to collect, sort and sell, through a chain of its own stores, quality second-hand clothing.
Unless otherwise specified in this Privacy Policy, HUMANA ROMANIA has the role of Personal Data Controller in compliance with the GDPR, which means that we decide the purpose and means of processing and the types of information we need for processing. This Policy covers the information collected by HUMANA ROMANIA through various means of communication, including but not limited to the website https://www.humana-romania.ro/
What kind of personal data we collect
In order to provide you with our products and services, we must collect personal data for the purposes stated below. We guarantee that the information we collect and use is indispensable for these purposes and does not aim to intrude on your personal space.
We generally collect your personal data directly from you, so you have control over the type of information you give us. During the course of our business processes we may have access to the following categories of data:
- Personal data related to the hiring process, execution and termination of the legal employment relationship: name, surname, photo, CNP, identity card, passport, driver's license, gender, date and place of birth, nationality, home address, telephone, e -mail, Skype address, information about family situation, information about marital status, children or other dependents, medical information about health, sick leave, maternity leave, accidents, tax information about payroll, premiums and compensation, fines and penalties, bank account, information about education, work experience, schools, degrees, qualifications and specialized courses, legal information about criminal records, sample signatures, GPS location information, etc.;
- Personal data about candidates obtained during the selection process for newly opened or existing vacancies: name, surname, facial image, date and place of birth, home address, telephone, email, Skype ID address, telephone, email, information about education, schools, qualifications, majors, past jobs and salaries;
- Images of employees and customers obtained through video recordings of surveillance systems;
- Personal data about HUMANA ROMANIA customers obtained as a result of sales activities, sales facilitation by promoting products and services, communication with customers and advertising.
We also collect other types of information from you or other sources, which may include, but are not limited to:
- Information collected through the online forms present on our website;
- Information from legal databases or public sources, such as business cards, Web pages, catalogues, company lists, recommendations as contact persons, social networks, etc.;
- Information about your use of our services, such as usage data;
- Information about the approximate physical location (ex, city or zip code) of a computer or device derived from the IP address of such computer or device.
We note with all responsibility that we do not collect or process sensitive data, included by the General Data Protection Regulation in special categories of personal data. We also do not collect or process personal data of minors under the age of 16.
What special categories of data we process
Medical information about employees working at the workplace - to the extent that the law requires this data to be collected, medical information about the employee's close relatives - to the extent that the law obliges HUMANA ROMANIA to deal with similar medical records. Previous information - as long as the law requires HUMANA ROMANIA to collect this information from its employees.
What are the purposes for which we collect personal data
As a personal data operator, HUMANA ROMANIA declares and assumes full responsibility that the personal data collected is used only for the following purposes:
- Administration of human resources;
- Recruitment process and candidate selection;
- Video surveillance systems to ensure optimal security conditions and personal protection of employees in the administration, warehouse and stores, as well as customers visiting commercial premises, as well as securing HUMANA ROMANIA assets and monitored premises;
- For commercial communication purposes with HUMANA ROMANIA customers who have given their consent for direct marketing communications or for goods return operations;
- For the purpose of the smooth development of commercial relations and logistics activities with HUMANA ROMANIA suppliers and partners.
What are the legal bases of personal data processing activities
According the provisions of Art. 6 (1) GDPR, the processing of personal data at HUMANA ROMANIA is carried out on the basis of the following legal grounds:
- the existence of a contract – such as the employment contract with employees, commercial relations based on a purchase contract, invoice, delivery note or other documents with contractual value or the existence of a contractual relationship for the provision of services;
- the existence of a legal obligation - of a commercial or legal nature, associated with certain types of activities, such as issuing or paying invoices or tax vouchers;
- the existence of a public interest - related to compliance with certain rules of conduct or anti-Covid prevention measures;
- the existence of a vital interest - related to protecting the physical integrity of HUMANA ROMANIA employees in the administration, warehouses and stores, as well as customers who are in the commercial areas of the stores;
- the existence of a legitimate interest - for the performance of business relationships of the seller-client type in the best conditions and the increase of the quality of services;
- the existence of a consent - freely given, specific, informed, clearly expressed and resulting from a clear affirmative action, requested in particular in the case of commercial relations with new customers or for the purpose of the smooth running of marketing activities.
How we collect your information.
We may collect or obtain information about you in the following ways:
- directly from you (for example, if you contact us by phone, email or social media channels);
- in the course of our interactions with you (interacting with marketing, sales or customer support or if you visit our stores);
- when you make your personal information public (for example, if you make a public post about us on social media);
- when you complete our online forums on the careers page or contact page;
- when you interact with any content owned by a third party.
- we may receive user information about you from third parties (for example, social networking sites).
- we may also retain information about you simply by keeping track of interactions with you, such as e.g. details about purchase history, record of service activities, acceptance of cookies when browsing the site, etc.
HUMANA ROMANIA is not responsible for the personal information you voluntarily provide about yourself on public pages of social networks or through offer requests addressed by phone, email or on the website. Also, this policy does not cover the practices of third parties who may provide information about you to HUMANA ROMANIA.
How long we keep your personal data
HUMANA ROMANIA keeps information for periods it considers useful or according to the contract, applicable laws or regulations. The information provided to HUMANA ROMANIA is stored within internal systems or outsourced service providers.
For the HUMANA ROMANIA website, as a general rule, we will store your personal data as long as you have customer status. You may ask us to delete certain information or withdraw consent at any time and we will comply with such requests, subject to the retention of certain information where applicable law or our legitimate interests require it, such as the law relating to the archiving of commercial documents, the prevention of legal action or special measures requested by the competent authorities in accordance with current legislation.
Data minimization
HUMANA ROMANIA takes reasonable steps to ensure that your personal information that we process is limited to what is absolutely strictly necessary in relation to the purposes set out in this policy or when it is necessary to provide services to you or to access and use our products and services.
Collection of data about minors
Because we care about the safety and privacy of children's personal data, we do not knowingly contact or collect information from anyone under the age of 16, either directly in stores or through the website.
How we manage the consent we receive from you.
HUMANA ROMANIA pays particular attention to the consent received from you regarding the processing of personal data. In this spirit, we have implemented a special consent administration procedure, which in the spirit of the GDPR must meet the 5 validity criteria:
- Freely granted - the data subject must not be pressured to give their consent or suffer any harm if they refuse;
- Specific - the consent of the person must be requested for each individual data processing activity;
- Informed - the person must be explained what is being asked of him and what he must agree to;
- Clearly expressed - the language must be clear and simple, and the answer clearly formulated, unambiguous, and unequivocal;
- Clear affirmative action - the person must expressly affirm by doing or saying something in the affirmative.
At the same time, HUMANA ROMANIA has adopted all the necessary technical and organizational measures for the administration in the best safe conditions of the databases associated with different forms of consent, as well as for ensuring the fundamental right of the data subject to withdraw the consent granted for a certain type of activity processing or for all of these. You can withdraw your consent at any time by sending an appropriate request to the contact addresses in this document.
How we share the collected personal data
As appropriate, we may transmit or provide access to certain personal data to the following categories of recipients/third parties:
- service providers associated with the human resources department
- logistics and courier service providers;
- providers of payment/banking services;
- IT service providers;
- other companies with whom we can develop joint programs for offering our goods and services on the market.
If we are under a legal obligation or if it is necessary to defend a legitimate interest, we may also disclose certain personal data to public authorities. All our relationships with these third-party companies are based on compliance with the principles of the GDPR, the legal bases associated with each type of processing, as well as the fundamental rights and freedoms of our customers.
We ensure that access to your data by third-party legal entities under private law is carried out in accordance with the legal provisions on data protection and information confidentiality, based on contracts concluded with them, which include the necessary confidentiality and data protection clauses personal. According to the legislation in force, personal data may be disclosed without the user's consent to the state institutions empowered in this regard, but only following an official and legal request addressed to the operator by them.
How we ensure the security of your personal data
HUMANA ROMANIA takes reasonable steps to ensure the security of personal data by implementing appropriate technical and organizational measures to secure your information and protect it against unauthorized or illegal use and accidental loss or destruction, including:
- sharing and providing access to your data to the minimum extent necessary, subject to confidentiality restrictions where appropriate and anonymously whenever possible;
- the personal data collected are stored on secure servers, located in protected rooms and with limited physical access;
- the transmission of your personal data is done using state-of-the-art encryption algorithms;
- verifying the identity of any person requesting access to information, before granting them access to information;
We follow generally accepted standards to store and protect the personal data we collect, both during transmission and once received and stored, including the use of encryption where appropriate.
Despite the measures taken to protect your personal data, we draw your attention to the fact that the transmission of information over the Internet in general or through other public networks is not completely secure, and there is a risk that the data may be seen and used by third parties unauthorized parties. We cannot be responsible for such vulnerabilities of systems that are not under our control.
International Data Transfer
For customers in Romania, HUMANA ROMANIA does not transfer personal information to other locations in other countries. Currently, we store and process your personal data only on the territory of Romania. For customers in EU countries and the EEA, personal data does not leave the area accepted by EU standards as appropriate. The only personal data that can be transferred through the usual communication channels (telephone, email, online platforms, and courier) represent contact data of the representatives of our external partners with whom there are commercial contracts and other special collaboration agreements, and the transfer is made with the agreement to all parties and persons involved, by signing the documents.
In its capacity as a member of an international business community, HUMANA ROMANIA can have a series of commercial relations with international producers and service providers, from the European Union or outside the EU, including in countries that the European Commission has not recognized a level adequate protection of personal data. The only international data transfers that are carried out with them are strictly of a commercial nature and with the consent of the parties and consist of the contact details of the persons who sign or endorse certain commercial documents such as contracts, product offers, invoices. In addition, data transfers of this type are punctual, and involve a small number of people.
We will always take steps to ensure that any international transfer of personal data is handled carefully. Transfers to service providers and other third parties will always be protected by contractual commitments and, where appropriate, other safeguards, such as standard contractual clauses issued by the European Commission or existing certification schemes.
- How we respect your rights of access to personal data
Under the conditions provided by the European Union Regulation 679 of 2016 for the protection of individuals with regard to the processing of personal data and the free movement of such data, as data subjects, you benefit from the following rights:
→ The right to information, respectively the right to receive details regarding the processing activities carried out by HUMANA ROMANIA as described in this document;
→ The right of access to data, respectively the right to obtain confirmation from HUMANA ROMANIA regarding the processing of personal data, the provision of copies of the data held, as well as details of the processing activities such as the manner in which the data are processed, the purpose in who is processing, the recipients or categories of recipients of the data, etc.;
→ The right to rectification, respectively the right to obtain the correction, without justified delay, by HUMANA ROMANIA of inaccurate/unjustified personal data, as well as the updating of incomplete data; The correction/completion will be communicated to each recipient to whom the data were sent, unless this proves impossible or involves disproportionate efforts.
→ The right to data deletion, ("the right to be forgotten"), without undue delay, if one of the following reasons applies:
- they are no longer necessary for the purposes for which they were collected or processed;
- if consent is withdrawn and there is no other legal basis for processing;
- if the data subject objects to the processing and there are no legitimate reasons to prevail;
- if the personal data were processed illegally;
- if personal data must be deleted to comply with a legal obligation;
It is possible that, following the data deletion request, HUMANA ROMANIA will anonymize these data (thus depriving them of their personal character) and continue processing for statistical purposes under these conditions;
→ The right to restrict processing, insofar as:
- the person contests the accuracy of the data, for a period that allows us to verify the correctness of the data;
- the processing is illegal, and the data subject opposes the deletion of personal data, requesting instead the restriction of their use;
- the operator no longer needs the personal data for the purpose of processing, but the data subject requests them for establishing, exercising or defending a right in court; or
- the data subject has objected to the processing (other than those for direct marketing), for the time interval in which it is checked whether the legitimate rights of the operator prevail over those of the data subject.
→ The right to data portability, respectively:
- the right to receive personal data in a structured way, commonly used and in an easy-to-read format;
- the right for these data to be transmitted by HUMANA ROMANIA to another data operator, to the extent that the conditions provided for by law are met.
→ The right to opposition can be exercised by submitting a request as indicated below;
- at any time, for reasons related to the particular situation in which the data subject is, that the data concerning him/her be processed on the basis of the legitimate interest of HUMANA ROMANIA or on the basis of the public interest, except in cases where HUMANA ROMANIA can demonstrate that it has legitimate and compelling reasons that justify the processing of the collected data and that prevail over the interests, rights and freedoms of the data subjects or that the purpose is to establish, exercise or defend a right in court;
- at any time, free of charge and without any justification, that the data concerning her be processed for direct marketing purposes.
→ The right not to be subject to an automated individual decision, i.e. the right not to be the subject of a decision taken solely on the basis of automated processing activities, including the creation of profiles, which produce legal effects that concern the data subject or affect him in a similar way to a significant extent.
→ The right to withdraw consent, respectively the withdrawal of permission to use personal data for any processing activity carried out by HUMANA ROMANIA for which you have given your consent. The withdrawal of consent for a certain type of personal data processing refers only to the processing carried out from the moment the withdrawal of consent is announced, not affecting the data processing carried out during the existence of the consent and will not affect the consent given for other activities or services. To benefit from this right, it is enough to contact us using the methods set out below and your request will be resolved in the shortest possible time.
→ The right to address the National Supervisory Authority for the Processing of Personal Data (ANSPDCP) in Romania, which can receive notifications from the persons concerned at: B-dul G-ral. Gheorghe Magheru no. 28-30, Sector 1, postal code 010336, Bucharest, Phone: +40.318.059.211, E-mail: anspdcp@dataprotection.ro or through the online platform www.dataprotection.ro
→ The right to address the Court, for the defense of any rights guaranteed by this law, which have been violated, as well as for situations in which you consider that the personal data operator or the Competent Authority did not pay the necessary attention to your request to exercise the stated rights.
Through this policy, HUMANA ROMANIA assures you that we will always give maximum importance to respecting your fundamental rights as a data subject. We are confident that any request you send us will be resolved as soon as possible, in accordance with the provisions of domestic and international legislation and the requirements of the GDPR. In this spirit, HUMANA ROMANIA has developed and implemented a special procedure for resolving data access requests from data subjects (clients and partners).
- How to contact us
