Privacy Policy

This Privacy Policy explains how S.C. GLOBAL CONTRACT SOLUTIONS S.R.L. ("GCS", "we", "us" or "our") collects, uses, stores and protects personal data in connection with the website globalcontractsolutions.eu, business enquiries submitted through the website, and related business communications.

1. DATA CONTROLLER

The controller responsible for the processing of personal data described in this Privacy Policy is:

S.C. GLOBAL CONTRACT SOLUTIONS S.R.L.
Bucharest, Romania
VAT No.: RO47338475
Trade Register: J40/24682/2022
EUID: ROONRC.J40/24682/2022
Website: globalcontractsolutions.eu
General enquiries: office@globalcontractsolutions.eu
Privacy enquiries: gdpr@globalcontractsolutions.eu

The privacy email address above is provided for data protection enquiries and the exercise of data protection rights. It does not constitute the appointment of a Data Protection Officer unless expressly stated otherwise.

2. PERSONAL DATA WE MAY COLLECT

Depending on how you interact with us, we may process the following categories of personal data:

• your name and professional contact details;
• company or organisation name;
• business email address;
• telephone number, where provided;
• country or location information provided as part of an enquiry;
• company website, where provided;
• information concerning your business requirement, supply capability or proposed commercial opportunity;
• indicative quantities, destination, delivery requirements or timing information;
• correspondence exchanged with GCS;
• information voluntarily provided by you in connection with a business enquiry;
• technical information generated when accessing our website, which may include IP address, browser/device information, date and time of access, security information and server log data.

Please do not submit special-category personal data, sensitive personal information, passwords, payment credentials or confidential information that is not necessary for your business enquiry.

3. HOW WE COLLECT PERSONAL DATA

We may obtain personal data:

• directly from you when you submit a business enquiry through our website;
• when you communicate with us by email, telephone or other business communication channels;
• in the course of discussions concerning a potential or existing business relationship;
• automatically, to a limited extent, through the technical operation and security of our website and hosting infrastructure;
• from your organisation or its authorised representatives where this is necessary in connection with a business relationship.

Where personal data are obtained from sources other than directly from you, we will process them in accordance with applicable data protection law.

4. WHY WE PROCESS PERSONAL DATA

We may process personal data for the following purposes:

• receiving, reviewing and responding to business enquiries;
• assessing sourcing, procurement, wholesale, supply or commercial intermediation opportunities;
• communicating with prospective suppliers, manufacturers, buyers, corporate customers and other business partners;
• taking steps requested by you or your organisation before entering into a contract;
• administering existing commercial relationships;
• maintaining appropriate business records;
• protecting the security, integrity and availability of our website and communications;
• preventing fraud, misuse, unauthorised access and other security incidents;
• establishing, exercising or defending legal claims;
• complying with applicable legal, regulatory, accounting or other obligations.

5. LEGAL BASES FOR PROCESSING

Depending on the circumstances, we rely on one or more of the following legal bases under Regulation (EU) 2016/679 ("GDPR"):

Pre-contractual and contractual necessity — Article 6(1)(b) GDPR

Where you contact us in your individual capacity or where applicable to the relevant relationship, processing may be necessary to take steps at your request before entering into a contract or to perform a contract.

Legitimate interests — Article 6(1)(f) GDPR

We may process personal data where necessary for our legitimate interests or those of a third party, provided that those interests are not overridden by your fundamental rights and freedoms.

Such interests may include managing legitimate B2B communications, evaluating commercial opportunities, maintaining relationships with customers, suppliers and business partners, protecting our systems and communications, maintaining appropriate business records and establishing or defending legal claims.

Compliance with legal obligations — Article 6(1)(c) GDPR

We may process personal data where this is necessary to comply with legal obligations applicable to GCS.

Where another legal basis is required for a particular processing activity, we will identify and apply that basis as appropriate.

6. BUSINESS ENQUIRIES AND COMMUNICATIONS

Information submitted through our website enquiry form is used to evaluate and respond to the relevant business enquiry.

Submitting an enquiry does not oblige GCS to accept a commercial opportunity, provide a quotation, source or supply a product, enter into a contract or establish any form of agency, representation, partnership or exclusivity.

Where communication continues by email or another agreed business channel, information contained in that correspondence may form part of our business records.

7. DATA RETENTION

Personal data relating to business enquiries that do not result in a contractual or ongoing business relationship will generally be retained for up to 24 months from the last relevant interaction.

We may retain information for a longer period where necessary to:

• comply with a legal, accounting, tax or regulatory obligation;
• establish, exercise or defend legal claims;
• manage an ongoing contractual or commercial relationship;
• investigate fraud, misuse or security incidents.

Where an enquiry develops into a contractual or continuing commercial relationship, information may be retained for the periods required by applicable legal, contractual, accounting and regulatory requirements.

When personal data are no longer required for the purposes for which they were processed, we will take reasonable steps to delete or anonymise them, subject to applicable retention requirements.

8. SERVICE PROVIDERS AND RECIPIENTS

Access to personal data within GCS is limited to persons who require such access for legitimate business purposes.

We may also use third-party service providers that process information as necessary to provide services such as:

• website hosting and infrastructure;
• domain and technical services;
• email hosting and transmission;
• email access and management;
• website security and technical support.

Our current infrastructure includes services provided by Namecheap in connection with hosting, domain and email infrastructure.

Business correspondence received through our Namecheap email infrastructure may also be forwarded to and managed through Google Gmail according to our email configuration.

We may also disclose personal data where required by law, a competent authority, court order or where reasonably necessary to establish, exercise or defend legal rights.

We do not sell personal data.

9. INTERNATIONAL DATA TRANSFERS

Some of the service providers used by GCS may process personal data in countries outside the European Economic Area ("EEA").

Where such transfers are subject to GDPR requirements, we seek to rely on an applicable lawful transfer mechanism, such as an adequacy decision adopted by the European Commission, Standard Contractual Clauses or another mechanism permitted under applicable data protection law.

You may contact us at gdpr@globalcontractsolutions.eu if you require further information concerning safeguards applicable to relevant transfers.

10. DATA SECURITY

We take reasonable technical and organisational measures appropriate to the nature of the personal data and the risks associated with its processing.

These measures may include secure HTTPS connections, controlled access to systems and accounts, authentication mechanisms, secure email transmission, infrastructure security measures, backups and other appropriate technical and organisational safeguards.

However, no internet transmission or electronic storage system can be guaranteed to be completely secure.

11. YOUR DATA PROTECTION RIGHTS

Subject to the conditions and limitations provided by applicable law, you may have the right to:

• obtain information about the processing of your personal data;
• request access to your personal data;
• request correction of inaccurate or incomplete personal data;
• request erasure of personal data;
• request restriction of processing;
• object to certain processing based on legitimate interests;
• request data portability where the relevant legal conditions are met;
• withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal;
• lodge a complaint with a competent supervisory authority;
• not be subject to a decision based solely on automated processing where such decision produces legal or similarly significant effects and the relevant GDPR conditions apply.

Not all rights apply in every circumstance. Their applicability depends on factors including the legal basis and purpose of the relevant processing.

To exercise your rights, contact:

gdpr@globalcontractsolutions.eu

We may request information reasonably necessary to verify your identity before acting on a request.

12. SUPERVISORY AUTHORITY

You have the right to lodge a complaint with a competent data protection supervisory authority.

In Romania, the supervisory authority is:

Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP)
28–30 Gheorghe Magheru Boulevard
District 1, 010336 Bucharest, Romania
Website: dataprotection.ro

We encourage you to contact us at gdpr@globalcontractsolutions.eu if you have a privacy concern so that we have an opportunity to address it.

13. COOKIES AND SIMILAR TECHNOLOGIES

At the date of this Privacy Policy, GCS does not intentionally use Google Analytics, Meta Pixel, LinkedIn Insight Tag or similar advertising or behavioural analytics technologies on this website.

The website may use technical storage, server-side functionality or strictly necessary technologies required for security, communications or the proper operation of the website.

If we introduce analytics, advertising or other non-essential tracking technologies in the future, we will review this Privacy Policy and implement any consent or transparency mechanisms required by applicable law before such technologies are used where consent is required.

14. AUTOMATED DECISION-MAKING AND PROFILING

GCS does not use personal data collected through this website to make decisions based solely on automated processing that produce legal or similarly significant effects on individuals.

We do not use website enquiry data for behavioural profiling.

15. THIRD-PARTY WEBSITES

Our website may contain links to websites operated by third parties.

GCS is not responsible for the privacy practices, security or content of third-party websites. We recommend reviewing the applicable privacy information of any third-party website you visit.

16. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes to our website, business operations, service providers, processing activities or applicable law.

The current version will be published on this website together with its latest revision date.

17. CONTACT US

For questions about this Privacy Policy or the processing of personal data by GCS:

Privacy enquiries:
gdpr@globalcontractsolutions.eu

For general commercial enquiries:

office@globalcontractsolutions.eu