Our Strategy and Privacy Policy
Copyright. © 2021 ARON SAMU PHD LLM ESQ OÜ. All rights reserved.
⧭ This document is protected by copyright. The rightful owner of the information, the company that provides the services of the Personal Data Protection Officer of Neotech Finance OÜ reserves all the rights regarding the information regarding it as a structured way of organizing the text.
⧭ This document has a complex legal nature:
The document regarding the structure and organization of the information – Neotech Finance OÜ has a right of limited use for an indefinite period of time of the text of this version in Romanian, without the Header and Footer sections (“Header” and “Footer”) bearing the author’s trademark or without express reference to the author of this document, even using his own identifying marks, for personal benefit in order to facilitate the interactions and contractual relations to which he is a party. Neotech Finance OÜ notifies you that it is not the owner of this document as a way of structuring the information. Viewed in this view, the rightful owner of the information reserves all rights in relation to the information contained in this document. It is forbidden to transmit this document in a digital format other than the “.pdf” extension, or in a physical format other than the minimum number of A4 sheets.
Physical document held by the Contracting Parties – may be managed by the Contracting Parties as a physical document only for use in the contractual relationship and for the purpose of proving the contractual relationship with the other Contracting Party or with national or supranational authorities having a valid legal right and necessarily interpreted in the strictest possible objective way; for this purpose it may be copied or transmitted, in whole or in part, containing in any case the mandatory section “Copyright. © 2021 ARON SAMU PHD LLM ESQ OÜ. All rights reserved.”. It is forbidden to send this document in a format other than “.pdf” or in a physical format other than the minimum number of A4 sheets. The information and personal data integrated in the physical document following the completion and signing of the final section requesting the identification of the parties will be managed in the workflow of the Personal Data Protection Officer of Neotech Finance OÜ, and will be stored by him in the account Google LLC Email aron.samu@aronsamu.com.
⧭ After the disappearance of any circumstances requiring the parties to retain the document in order to exercise their rights or fulfill their contractual obligations or to interact with national or supranational authorities having a valid and necessary legal right interpreted in the strictest possible objective manner in relation to this document, the parties have the obligation to destroy the physical and / or electronic copies of this document, considered in both senses, both as a structure and organization of the information and as a physical document.
⧭ Any unauthorized use, reproduction, alteration, modification, completion or processing is prohibited. For any information or ambiguity regarding the rights in this document, the parties are obliged to contact the rightful owner of the information at Google LLC Email aron.samu@aronsamu.com.
⧭ The owner of the information and Neotech Finance OÜ as the holder of the indefinite right of use of the text of this version reserves the right to use all legal means to mitigate and recover the damages suffered by the infringement.
Neotech Finance OÜ, a company headquartered in Harju County, Tallinn, Kesklinna District, mnt. Pärnu 139d, postal code 11317, Estonia, registered at the Trade Register from 15.02.2022 at 09:09, registration code 16442711 (“Neotech Finance OÜ”), with Trade Register Form no. 1, has adopted and is currently implementing our Strategy and Privacy Policy (“Strategy and Policy”) in order to ensure and maintain a level of security of personal data that complies with both EU Privacy Shield Frameworks. -US. and Swiss-U.S. This Strategy and Policy relates to and is applied in connection with matters relating to the operation and / or processing of Personal Data involving visitors, users and / or Trade Counterparties that are located within the European Union and / or or the Swiss Confederation.
Neotech Finance OÜ complies with both EU-U.S. Privacy Shield Executives. and Swiss-U.S.A. as established and currently applied by the U.S. Department of Commerce, the European Commission, and the Swiss Administration regarding the management and transfer of personal data to visitors, users, and / or counterparties within the European Union, its Member States, and Switzerland to the United States in support of transatlantic trade. Neotech Finance OÜ hereby certifies that it adheres to the Privacy Principles of both EU-U.S. Privacy Shield Frameworks. and Swiss-U.S.A. on notifications, choices, security issues, data integrity, access, limitations on purposes, applicability, remedies, transfer responsibilities and guilt. In the event of any conflict between the provisions of this Privacy Strategy and Policy and the Privacy Principles established and applied by the EU-U.S.A. Shield Privacy Framework. and / or Swiss-U.S., the latest Privacy Policy will prevail as applicable. For more information on both EU-U.S. Privacy Shield Frames. and Swiss-U.S.A. and / or the Privacy Shield Framework Program, and / or to view our Included and Active Participation space located within it, you may visit the official .gov Privacy Shield Program Program website.
Neotech Finance OÜ hereby formally recognizes the jurisdiction of the Federal Trade Commission (CFC) over matters relating to compliance with both EU-U.S. Privacy Shield Frameworks. and Swiss-U.S.
All Neotech Finance OÜ personnel who are covered by employment contracts and are involved in personal data management activities deriving from Europe and / or the Swiss Confederation are informed and obliged to adhere to and comply with the provisions of this Strategy. and Policies.
We define capitalized concepts under the name of Specific Terms in Section 4 of this Strategy and Policy.
1. APPLICABILITY
This Strategy and Policy extends to and governs the management and transfer of Personal Data belonging to visitors, users and / or Business Counterparties with which Neotech Finance OÜ comes into contact through its business operations (given that its principal location of the business activities and the official headquarters of the company are located in Romania, a member country of the European Union) regarding visitors, users and / or Trade Counterparties resident within the European Union, any of its member states and / or Switzerland. We make information, products and / or services available to consumers and / or businesses.
This Strategy and Policy also applies to data and / or information that cannot lead to situations in which individuals can be identified, including where pseudonymization is used. Such pseudonymization may involve the replacement of any personal identifiers with fictitious alternatives in order to ensure the impossibility of identifying individuals.
2. IMPLEMENTATION, APPLICATION, MANAGEMENT AND SUPERVISION
Neotech Finance OÜ has appointed our organization’s executive management to implement, implement, manage and oversee our information and data security program, including our compliance with both EU-US Privacy Shield Frameworks. and Swiss-U.S.A. belonging to the Privacy Shield Framework Program, including but not limited to our Privacy Strategy and Policy. Executive Management will acknowledge, review and approve any material changes that involve (even isolated aspects of) our program (s) as needed and / or their reasonableness. Any comments, questions, issues, concerns or complaints regarding our Privacy Strategy and Policy and / or our program may be addressed through any official channel provided for in Section 13 of this document.
We will implement, manage, monitor, test and / or challenge, and update our policies regarding our own information security and data security program (including efforts, practices and systems) to ensure the protection of the Personal Data we enter. in contact. Our staff under employment contracts and / or our legally involved entities in any connection with our organization in which we exercise significant control over their business will be trained and instructed, in a reasonably assessed manner, to join. to, implement and / or implement our Privacy Strategy and Policy in the most efficient and reasonably effective manner possible. You can learn more about the specific action plan we are pursuing in our efforts to optimally protect personal data under the provisions of Section 8 of this document.
3. REVISIONS, CHECKS AND RENEWALS
Neotech Finance OÜ will update and restore both certifications in the EU-U.S. Privacy Shield Framework. and Swiss-U.S.A. belonging to the Confidentiality Shield Framework Program on an annual basis, unless maintaining these certifications becomes mandatory with increasing frequency (in which case we will adhere to the regulations or our operations, business strategies and regulatory compliance requirements make such certifications no longer desirable, or whether we adhere to, implement and enforce a different compliance higher standards regarding the protection and observance of privacy and security standards for the benefit of the subjects of the U.S., the EU, and / or the Swiss Confederation.
Prior to applying for and / or obtaining (re) approval our participation in both EU-U.S. Privacy Shield Certifications. and Swiss-U.S.A. as part of the Privacy Shield Framework Program, we will implement and enforce our own audit to ensure that our statements and practices regarding the management of Personal Data of Visitors, Users and Business Counterparties are as compliant, accurate and appropriate as possible, and of the fact that our company applies the above practices in full and consistently in the most appropriate manner reasonably appreciated. Specifically, in our own audit process and procedures, we will undertake the following actions:
Review, properly adapt and keep up to date the nature of our Privacy Strategy and Policy including the version of the document that we will continue to publish throughout our website in order to ensure continued compliance with both EU Privacy Shield Certifications. -US. and Swiss-U.S.A. belong to the Privacy Shield Framework Program regarding our management of Personal Data arising from visitors, users and / or Trade Counterparties.
Ensuring that our Privacy Strategy and Policy is accessible to the public and that it informs and instructs visitors, users and / or Business Counterparties clearly about the involvement of Neotech Finance OÜ in both EU-U.S. Privacy Shield Certifications. and Swiss-U.S.A. belonging to the Privacy Shield Framework Program, and also regarding the always available option to obtain a copy of the relevant data and / or information (for example to access and receive a transmission of our Privacy Strategy and Policy).
Maintain the full compliance status of our Privacy Strategy and Policy in accordance with the principles of the Privacy Shield Framework Program.
Ensuring that visitors, users, and / or Neotech Finance OÜ Business Counterparties have contacted the procedures available to them for initiating comments, questions, concerns, concerns or disputes, as well as any and all ways to escalate. the issue to the attention of some dispute resolution structures that present the regulated guarantee of independence (we can accomplish this by visibly displaying the information in our public web page, and / or any business interaction).
Review, properly adapt and keep up to date the strategies and means of implementation of our own regarding the training of our staff under our employment contracts or our legally involved entities in any connection with our organization within which we exercise significant control over their activity with respect to our involvement in and adherence to the Privacy Shield Framework Program and also with respect to the appropriate manner in which we manage the Personal Data of Visitors, Users and / or Counterparties.
Neotech Finance OÜ will implement, issue and apply its own annual audit document of our intentional perpetual participation in both EU-U.S. Privacy Shield Frameworks. and Swiss-U.S.A. belonging to the Privacy Shield Framework Program.
4. DEFINITIONS OF CERTAIN SPECIFIC TERMS
Terms that are capitalized in our Privacy Strategy and Policy are defined below as Specific Terms:
“Commercial Counterparty” and “Commercial Counterparty” means a client (s) and / or buyer (s) within the European Union or the Swiss Confederation who are involved in a business interaction with Neotech Finance OÜ. Such appointments shall also include any agents, representatives, or staff under any contract of employment or entity who are in any legal relationship with their organizations or in respect of whom they exercise significant control over their business, and include as well as all our personnel under employment contracts or entities that are in any legal relationship with our organization or in which case we exercise significant control over their activity in the event that we manage their personal data in our interaction. business with the Commercial Counterparty or the Commercial Counterparties.
“Our staff under employment contracts or entities that are in any legal relationship with our organization in the event that we exercise significant control over their business” also includes temporary, part-time or part-time employees. contract, independent collaborators, and / or applicants seeking employment with Neotech Finance OÜ or any of its affiliates or subsidiaries, who are at the same time lawfully resident in European Economic Area (EEA) countries.
“Personal data” means a concept currently defined by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of persons of this data and repealing Directive 95/46 / EC (General Data Protection Regulation, “RGPD”, published in the Official Journal of the European Union OJ L 119, 4.5.2016, page 1-88) as representing any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifying element, such as a name, an identification number, location data, an online identifier, or one or more many specific elements, specific to his physical, physiological, genetic, mental, economic, cultural or social identity or traits of that natural person (including but not limited to identifying information in the process of accessing personal spaces, geographical locations, device information, marital status, information Email, passwords and other identification data, telephone, address and / or contact information in case of emergency, collection of historical information on education or employment or qualifications of visitors, users and / or Business Counterparties). Personal data does not designate information that is anonymized or made public voluntarily by the legitimate owner. It should be noted that in the case of the Swiss Confederation, the term “person” means both a natural person / persons and legal entities, without distinction as to the specific mode of representation of the legal entity in question).
“Sensitive Data” means personal data that reveal biometric data, health and / or medical status, photographic or video captures, race or ethnicity, political, religious and / or philosophical affiliations and / or opinions, sexual preferences and / or orientation. , or membership in work-related groups (e.g. trade unions) of visitors, users and / or Trade Counterparties.
“Third Party Entity” and / or “Third Party Entities” means any legal entity or group of such entities that are outside the scope of Neotech Finance OÜ, personnel under employment contracts or entities that are in any legal relationship with our organization. in which case we exercise significant control over their activity.
5. PERSONAL DATA MANAGEMENT FRAMEWORK
Neotech Finance OÜ provides various end-to-end solutions to its visitors, users and / or Business Counterparties that interact with its own business strategy. Neotech Finance OÜ manages personal data from such visitors, users and / or Business Counterparties whenever necessary and to the extent necessary in the context of the most aggressive legitimate pursuit of its own business strategy, including but not limited to the circumstance of visitors accessing it. the website, that of the users who register in any service and / or in all the services that we / we offer or parts of them or who access their allocated and secured spaces, that of any of them that transmit Personal Data through our business interactions (for example, they may voluntarily choose to involve our support modules in real time or to transmit certain personal data in our private business interaction in the secure manner that we allow, we provide and we manage).
Any part and / or all of the Personal Data that we manage may be as diverse as the behavior of visitors, users and / or Business Counterparties in our business interactions. Regarding the general information that could be managed, the following categories are frequently included: information that could facilitate interactions (e.g. name information, email information, phone number information, employment data, and also information financial and / or payment information, which may include credit card and / or bank account information). Users and / or Counterparties may be assigned personal space in our business interaction, including in a real-time support environment. They will be free to transfer any information that we reasonably request and that they deem reasonably appropriate in the context of our business interactions, any management of their Personal Data being deemed to be initiated by their consent. specific and freely expressed in this regard. We reserve the right to unilaterally refuse to provide specific information (or even all of it), products and / or services (or parts thereof) at any time in the event that no mutual agreement is reached on the need and opportunity. an aspect related to the management of information between us on the one hand and our visitors, users and / or our Business Counterparties on the other hand in the context of our own business strategy.
In any case where visitors, users and / or Business Counterparties interact with our business presence on the Internet, we may in any case manage their information, including Internet Protocol (IP), and / or IP address. or features of the browser software. We may manage interactions between the latest categories of information and registered users and / or specifically registered Counterparties.
We will be able to manage data and / or information derived from visitors, users and / or Business Counterparties in order to pursue our most aggressive legitimate business strategy, for example to provide them with information tailored to their behavior and / or the predictability of their behavior. as determined by us to manage such data and / or information, and / or to provide and / or provide sales of product (s) and / or services, to manage interactions and / or transactions (including resumption respectively, even in a fully or partially automated manner), adherence to various internal and / or external reporting, billing practices and / or other transactions related to the interactions of visitors, users and / or Counterparties with us.
In the case of various information, products and / or services, Neotech Finance OÜ could act as a supplier, and in this role could be an operator (controller) and / or processor who manages (including but not limited to operations such as reception, storage and / or processing) Personal data (s). In any and / or all (such) case (s), we may act as processor of Personal Data and we will ensure that we process Personal Data legitimately in the interest and in accordance with the instructions of our partner entities and / or our partner agents (including those belonging to the aforementioned entities). We may manage such Personal Data and / or Information collected in order to provide and / or ensure the sale of product (s) and / or services, the management of interactions and / or transactions (including the resumption thereof, even in an automated manner). in whole or in part), adherence to certain miscellaneous internal and / or external reporting, billing practices and / or other transactions related to the interactions of visitors, users and / or Business Counterparties with us (including by complying with reasonable and legitimate requests, indications and / or business strategies of our partner entities and / or our partner agents, including those belonging to the aforementioned entities).
Neotech Finance OÜ manages personal data that it receives directly from its visitors, users and / or from its own Business Counterparties and / or its partner entities and / or its partner agents (including those belonging to the aforementioned entities) in directly and / or indirectly in its capacity as data processor and / or operator for the most aggressive legitimate pursuit of its business strategy, including (but not limited to) by:
1. identity checks (for example in connection with the personal digital spaces of users and / or Business Counterparties);
2. reactions to actions arising from visitors, users and / or Counterparties;
3. the maintenance, operation and / or processing of personal data in digital systems located in Romania (Member State of the European Union) and / or other locations (only if they offer adequate protection from the point of view of regulations and / or the environment in the strictest sense of the interpretation of the provisions of the General Regulation of the European Union on the Protection of Personal Data and of both the EU-US and Swiss-US Privacy Shield Frames belonging to the Privacy Shield Framework Program, with the final aim of total elimination or at least minimize to the greatest extent any or at least the most extensive liability of Neotech Finance OÜ in accordance with these regulatory frameworks);
4. the management of information, products and / or services, and / or adherence to and compliance with our contractual liabilities with respect to them (including but not limited to transaction management, reporting, invoicing, resumes even in a fully or partially automated manner, and other operations and / or activities in connection with the provision of information, products and / or services to visitors, users and / or Trade Counterparties);
5. related to other legitimate purposes related to its own business strategy (including but not limited to reporting and operations and / or cross-border tax and / or cross-border activities but not limited to customs duties) which are permitted or required under applicable local (Romanian), supranational and / or international regulatory frameworks.
Neotech Finance OÜ always has an opt-in mechanism in the context of its information management. We will not disclose Personal Data to Third Parties in the absence of specific or at least indirect consent from our visitors, users and / or our Business Counterparties provided to us in the course of our business interactions with them and also in that of reasonable business practices interpreted in the most proactive and extensive manner possible in any of the business environments that are in absolutely any kind of connection with our own business strategy.
6. EXTERNAL DISCLOSURES AND / OR TRANSFERS OF PERSONAL DATA
Unless otherwise provided in this framework, Neotech Finance OÜ will disclose personal data to third parties only if they reasonably need to become aware of such information and only to the extent that the scope of the interaction business with Neotech Finance OÜ is under discussion, in any case no such disclosures will take place due to other reasons. Any and all such subsequent Third Party Entities receiving them must agree to comply with specific confidentiality charges, and at least all applicable Neotech Finance OÜ documentation including indirect references to accession to the provisions of the European Union General Data Protection Regulation. personal and both of the EU-U.S. Privacy Shield. and Swiss-U.S.A. belonging to the Privacy Shield Framework Program.
Neotech Finance OÜ could potentially provide information, including but not limited to Personal Data, to Third Party Entities who could act as consultants, contract staff and / or agents (even independent) for the provision, provision and and / or the management of operations by Neotech Finance OÜ and in accordance with our specific instructions, instructions and / or supervision. For example, Neotech Finance OÜ could potentially manage Personal Data in the operations (including systems) of such Third Party Entities. In any case, the Third Party Entities must consent to the management of the Personal Data only within the limits of the specific purposes and / or reasons for which they were involved and / or included by Neotech Finance OÜ, and must at the same time adhere to all provisions. further included in this Section:
1. comply with both EU-U.S. Privacy Shield Frames. and Swiss-U.S.A. and the principles of the Privacy Shield Framework Program or at least the provisions and principles of another system or mechanism permitted alternatively by the laws and / or regulations in force of the United States of America, the European Union and the Swiss Confederation on data protection (in specific areas of transfers, exchanges, operators’ activities and processing in connection with Personal Data);
2. to comply with the provisions of the framework of the General Regulation of the European Union on the Protection of Personal Data;
3. and agree to provide compliant protections regarding Personal Data that are at least as strict and provide at least as much protection as those established and / or defended through our Privacy Policy and Policy. Privacy.
Neotech Finance OÜ may also disclose Personal Data for any other reason and / or to other Third Party Entities in any circumstances where visitors, users and / or Business Counterparties have consented to and / or requested such disclosure. Any entity hereby acknowledges and agrees that Neotech Finance OÜ may potentially be required to disclose the Personal Data of its visitors, users and / or Business Counterparties in order to legitimately comply with a legitimate mandatory request from the authorities. , including but not limited to purposes of complying with national security and / or regulatory compliance specifications.
7. SENSITIVE DATA
Neotech Finance OÜ does not solicit and / or collect Sensitive Data from its visitors, users and / or Counterparties.
8. DATA ACCURACY, INTEGRITY AND SECURITY
Neotech Finance OÜ implements a reasonable level of proactive attitude, diligence and efforts to ensure compliance with the integrity, integrity and security of the personal data it manages. We constantly adopt and implement updated information, physical and technical protections as they are reasonably deemed appropriate to protect personal data in the event of incidents (even partial or attempted) such as loss, use in other purposes, management for other purposes or cases of unauthorized access, modification, disclosure or destruction. We implement secure network and firewall protection technologies when managing personal data in electronic media. In order to access our electronic data systems, we implement user authentication through access data that includes secure passwords or similar methods of secure authentication. We also implement access restrictions, restricting the category of personnel who must be allowed to access the Personal Data of Counterparties in the processes of our business operations (including by ensuring the security of the system that allows such business operations).
In addition, Neotech Finance OÜ implements secure encryption technologies to protect various types of personal data. With all reasonable precautions and reasonable efforts, we hereby notify visitors, users and Counterparties that a full level of security may not be reached at any time or at all times, and we strongly recommend them. to research, implement and enforce appropriate personal security standards throughout our interactions.
9. OFFICIAL NOTIFICATION
Neotech Finance OÜ hereby notifies its Trade Counterparties of its adherence to and compliance with the principles set out in the EU-U.S. Privacy Shield Framework. and Swiss-U.S.A. through the organization’s publicly available privacy policy, entitled “Our Privacy Strategy and Policy”, which it has published on the Internet – https://neotech.finance and on the fact that it ensures the recognition , the agreement and absolute adherence of each Trade Counterparty to this current version of the strategy and policy at any time they initiate a formal interaction with our organization in the business process.
10. PROTECTION IN CONNECTION WITH THE ACCESS AND / OR USE OF PERSONAL DATA
Neotech Finance OÜ personnel under employment contracts or entities legally involved in any connection with our organization in which we exercise significant control over their business may access and / or use Personal Data only if they are specifically authorized to act. in such ways and only within the limits imposed by the specific authorizations, including those relating to the purpose for which they are authorized to act in those specific ways.
11. RIGHTS TO ACCESS, CORRECT, MODIFY AND / OR DELETE PERSONAL DATA
Rights to Access, Correct, Modify and / or Delete Personal Data. Visitors, users and / or Business Counterparties enjoy the legal rights to Access, Correct, Modify and / or Delete Personal Data (including but not limited to the knowledge of the information included in the systems and to ensure the conformity and relevance of the information in relation to the purposes and / or the reasons why they were collected for management). Visitors, users and / or Business Counterparties may review their Personal Data that is managed within the systems (including but not limited to databases) and initiate procedures to rectify, delete or even block any part and / or all of it. Personal data in a legitimate manner that is intrinsically consistent with all relevant Neotech Finance OÜ specific business policies and agreements that we apply at all times. Following contact with a reasonable request, and in accordance with the requirements of the Privacy Shield Framework Program and the regulatory framework of the General Regulation of the European Union on the Protection of Personal Data, Neotech Finance OÜ will provide an appropriate Access to Personal Data. personally, for the purpose of rectifying or modifying information when it proves to be non-compliant. Users and / or Business Counterparties may also modify their Personal Data within the spaces allocated to them, although this will not always result in the automatic deletion of prior information (which we will keep until a specific request for disposal in accordance with the implied consent or at least the implicit personal interest in the security of the insured space in the event of a potential breach). In any case, in order to exercise their rights to Access, Correct, Modify and / or Delete Personal Data, visitors, users and / or Counterparties must contact us through one of the official channels set out in Section 13 there of. document. The data subjects are legally obliged to provide only compliant, true and complete data and / or information in any interaction with us.
Requests to Access, Correct, Modify and / or Delete Personal Data. Neotech Finance OÜ will manage each of the following typologies and will legitimately notify visitors, users, Counterparties and / or other entities in the following circumstances: (a) the presence of a legitimate request from the data subject; and / or (b) the presence of a legitimate request for the disclosure of personal data from a regulatory authority.
Complaint resolution of requests regarding Access, Rectification, Modification and / or Deletion of personal data. Neotech Finance OÜ will endeavor to recognize and properly resolve any and all reasonable requests regarding access, rectification, modification and / or deletion or deactivation (including permanent anonymization of) personal data in a timely manner and resolution. proactively interpreted.
12. CHANGES IN OUR STRATEGY AND POLICY
Our Strategy and Policy may be adjusted from time to time to maintain its compliance with the Principles established by both EU-U.S. Privacy Shield Frameworks. and Swiss-U.S.A. belonging to the Privacy Shield Framework Program and also to the framework and principles of the General Regulation of the European Union on the Protection of Personal Data. We will also inform about and apply the recognition and observance of these Principles through any official communication channel within the entire grouping of our staff under employment contracts or entities legally involved in any connection with our organization in which we exercise a significant control over their activity. We will also subject notices to visitors, our users and / or our Business Counterparties of any up-to-date information that may materially affect our handling of Personal Data (even in the event that management may have started earlier), while we will offer them the choice to submit their Personal Data to the management in any up-to-date manner producing a relevant impact.
13. COMMENTS, QUESTIONS, PROBLEMS, CONCERNS OR COMPLAINTS
You and / or any other entity may contact Neotech Finance OÜ with questions, raise issues or concerns, or file complaints regarding the Terms of Access, Use and / or Interaction in our Business Strategy and Policy and / or any provision or document referred to here by contacting us:
Trade Counterparty Name:
ARON SAMU PHD LLM ESQ OÜ, prin
Name Data Protection Officer in charge of personal data protection:
Dr. Aron Samu, LL.M., Esq.
Address:
Harju maakond, Lasnamäe linnaosa, Sepapaja tn 6, Tallinn, Eesti Vabariik (Estonia), postal code 15551
Cell Phone Number:
0040743773239
00407 GDPR READY
Google LLC Email Address:
aron.samu@aronsamu.com
Availability of staff protected by personal data protection: proactive 24/7 (24 hours a day, 7 days a week, in view of the obligations deriving from the legislative framework, the communication being considered to have been made on the first The actual communication of the communication was made on a national day off, the characteristics of working day and day off to be interpreted in accordance with the Romanian legislation applicable to this document in terms of interpretation).
14. CONTROL AND RESOLUTION OF ANY PROBLEMS, CONCERNS OR DISPUTES
In order to ensure our compliance with the EU-U.S. Privacy Shield Framework Principles. and Swiss-U.S., we are committed to resolving complaints regarding your privacy and the manner in which we collect or use your personal information. Visitors, customers and / or Trade Counterparties from the European Union and / or the Swiss Confederation and raise any concerns, concerns or disputes regarding the management of their Personal Data may feel free to contact us via any official channel presented in Section 13 of this document.
In the event that the issues, concerns and / or disputes of visitors, users and / or Counterparties about us are not resolved in a satisfactory manner through our subsequent interactions, we hereby declare the action and confirm compliance with the transmission of such cases. unresolved issues regarding confidentiality and / or security that fall under either or both of the EU-U.S. Privacy Shield Frameworks. and Swiss-U.S.A. to independent dispute resolution structures operating under the control of the European Union Supervisors with responsibility for the protection of personal data, starting with our national authority which can be contacted via the following official communication channels:
Romanian National Authority: National Authority for the Supervision of Personal Data Processing
Address: B-dul Magheru 28-30, Sector 1, Bucharest, postal code 010336
Phone: 0040 21 252 5599
Fax: 0040 21 252 5757
Email: anspdcp@dataprotection.ro
Internet page: http://www.dataprotection.ro/
Member Art. 29 WP: President of the National Authority for the Supervision of Personal Data Processing
Alternate Member Art. 29 WP: Representative of the International Relations Bureau
Any such issues, concerns and / or disputes will be brought to the attention of either the United States Department of Commerce and / or the United States Federal Trade Commission in order to provide assurance that any such circumstances of interest to visitors, users or Trade counterparties are processed and resolved accordingly. There is an appropriately assessed timeframe within which circumstances should be resolved. Whenever a circumstance (s) is addressed by the Supervisory Authority with responsibility for the protection of personal data to the attention of the United States of America, the United States Department of Commerce is required to meet a specific deadline to react. In any case where the Federal Trade Commission of the United States of America is involved, it has assumed priority in the circumstances arising from individual entities individually valued.
In any case where there is no proper settlement of the circumstances in accordance with the means listed above, the final remedy will be the transmission of the appeal to the attention of an available arbitration body. This recourse in circumstances related to national security and involving any entity whose personal data falls within the United States of America will be handled by an Ombudsman independent of the intelligence structures of the United States of America. The specific ways in which this Ombudsman operates and his independent status will be clarified, in particular issues concerning his independent status and status in his interactions with any other supervisory structures of the regulatory framework that are independent and have authority and jurisdiction over these matters. , throughout the initial phase of the appeal process.
Ultimately, which will be exercised only in special and limited cases, there will be an appeal that could be exercised by the entities of the European Union and the Swiss Confederation and subject to the mandatory arbitration structure of the Confidentiality Shield Panel.
Neotech Finance OÜ hereby declares and undertakes in accordance with the highest standards of openness, cooperation and compliance with both the Supervisory Authorities with responsibilities for the protection of personal data of the European Union and the Swiss Confederation and to acknowledges, complies with and enforces the instructions issued by these Competent Authorities in relation to data and information relating to its staff under employment contracts or entities legally involved in any connection with our organization in which we exercise significant control over the business which are transferred from the European Union and / or the Swiss Confederation within the relevant areas of employment relationships and / or other relevant legal links in which we exercise significant control over their activity.
Any data, information or parts thereof, transmitted through a voluntary interaction and in the absence of any absolute constraint with Neotech Finance OÜ by a visitor, user and / or a Counterparty as part of our own business strategy, are deemed to be transmitted with good faith, good faith, business conduct and full acceptance of the legal consequences of such actions, without the intent to make any claims for damages and / or to cause any legal liability to us. . Any time you begin to have any questions, concerns, concerns, objections, or other attitudes or opinions that result from your lack of desire to continue our interactions in a predictable manner or if you wish to revert to previous conduct by removing any information or parts thereof within our management, contact us immediately through the official communication channels publicly presented in Section 13 of our Privacy Strategy and Policy in order to resolve our differences amicably. We reserve the right to act in a manner consistent with our perfectly legitimate business strategy, including by limiting, denying or restricting your access to information, products and / or services (even in part) at least to the extent necessary. a change in your attitude, behavior and / or sovereign personal decisions regarding our handling of your personal data, information and / or data.
Finally, we hereby declare and ensure the recognition, compliance and enforcement of the entire regulatory framework in force of the General Regulation of the European Union on the Protection of Personal Data (including all related, related and related provisions). connected with the regulatory framework, and also those that will apply to them beforehand or that will modify in any way any category of them, including even the General Regulation of the European Union on the Protection of Personal Data).
