Important Information
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The American Chamber of Commerce in Romania (hereinafter referred to as “AmCham”, “we” or other similar forms) is a non-profit, independent association, established in year 1993, with its registered office in Bucharest, 11 Ion Campineanu Street, Union International Centre, 4th floor, District 1, Tax code 6347859, having the capacity of personal data controller.
AmCham has been for 25 years one of the most representative associations of the Romanian business community, being recognized as a promoter of the public-private dialogue on topics related to business, public policies having an impact on economy, the competitiveness of Romania or the dynamics of the commercial relations between the U.S.A. and Romania.
The mission of AmCham is to provide its members with a professional platform of interaction, collaboration, exchange of good practices and promotion for the purpose of development of businesses and commercial relations, as well as to represent the priorities of the affiliated companies, on subjects of common interest, in its relation with the Romanian authorities.
amcham.ro is the portal of AmCham, which has a primary purpose the information of its members regarding the activity of the organization, its members and the benefits arising from the capacity of member. In order to reach this purpose, we come in contact with our members and readers, to whom we provide an interactive platform by means of which they can exchange opinions and information related to certain legal, economic or business-related issues.
The information given hereinafter is highly important since it explains why we need certain personal data to supply certain services and it requires a careful reading, since the concepts and principles we refer to are relevant both in the interaction with our website, as well as in the interaction with the online environment in general.
We shall also refer hereinafter to your rights in relation with your personal data that we process, as well as to the actions you may take to understand and control much better the volume of personal data which is processed in the online environment.
We shall explain as clearly as possibly, some concepts and ideas, actions and obligations, as well as many other elements meant to help you understand the purpose of our actions and the manner in which you can communicate to us what precisely bothers you or what should be changed.
According to the General Data Protection Regulation1 (GDPR), „personal data” means any information related to an identified or identifiable natural person (“data subject”). An identifiable natural person is a person who can be identified, directly or indirectly, especially by reference to an identifier, such as a name, an identification number, positioning data, an online identifier or to one or several specific elements, specific to their physical, physiological, genetic, mental, economic, cultural or social identity.
There is no list of personal data, and the GDPR does not impose the states to draw such a list, for the simple reason that a data can be in a certain context a personal data, and in another context, it can simply be an information without the value of a personal data2.
Further information to understand „what does personal data mean” can be obtained reading Opinion no. 4 from 2007 on the concept of personal data, delivered by the Working Group Article 29 for Data Protection.
Further information to understand „what does personal data mean” can be obtained reading Opinion no. 4 from 2007 on the concept of personal data, delivered by the Working Group Article 29 for Data Protection.
AmCham processes personal data of data subjects (former, current and potential members, partners, collaborators, office visitors and amcham.ro visitors, invitees and participants to all type of events and actions organized by AmCham Romania, journalists, opinion leaders and and media representatives, representatives of the authorities and public institutions that AmCham interacts with) mainly using the methods below:
AmCham processes personal data disclosed directly by you through the forms made available by AmCham (for example, following your registration as a member of the AmCham community, creating an user account on www.amcham.ro, requesting a service from our part or following the subscription to the AmCham newsletters).
All these include certain fields which must be filled in by You, therefore AmCham processes your following personal data, as the case may be: surname and name, surname and name of your legal representatives, the details of the contact persons of the company, gender, citizenship, e-mail address, mobile/ fax number, job, address of the place of work, profession/ position, bank details, photograph, signature, data regarding the participation in a certain event held by AmCham, cookies and access password.
Also, it is possible in certain situations for AmCham to process additional tax information, in case that we are forced by law to submit tax statements in relation with the services ordered by You. In this case, we shall refer to Your address also (necessary to be mentioned on the tax invoice), but also to other tax data that the law forces us process in relation with the transaction in question. In this situation, the legal ground for the processing will be the obligation to comply with the provisions of the relevant law (Article 6(1) letter c) of the GDPR).
AmCham does not process sensitive categories of personal data.
The purposes for which AmCham processes this personal data of Yours are: the fulfilment of the purposes and statutory missions for which AmCham was established, communication, statistics, organization of courses, seminars, other events (including receptions, workshops, delegations, conferences and fairs), for educational purposes (for the organization of the program of professional training), the issuance of any financial-accounting documents, the conclusion of contracts or other acts necessary in the activity of AmCham, the promotion of some of the services or products of certain members of AmCham that you have agreed with in prior.
Also, AmCham processes personal data to allow access to the website and to provide the services you have opted for (for example, newsletters, replies on the forum, comments on articles, etc.). The legal ground for this processing is the conclusion and implementation of a contract in which you are a party – Article 6(1) letter b) of the GDPR (each time you perform the operations mentioned above, you agree with the terms and conditions of these services).
The legal grounds based on which we process Your personal data are:
Personal data supplied by You after using the website amcham.ro amcham.ro collects automatically certain types of data that it stores in its traffic reports. This data may include the IP address of the device used to visit us, the region or the general location from where you access the website, as well as the browser used, the operation system or the device used to access the website and the history of the pages you access. Also, we process statistical demographic data that help us identify the preferences of amcham.ro readers. amcham.ro also uses cookies you may read on in the section below.
The legal ground based on which we process Your above indicated data is the vested interest of AmCham to observe the measure in which the pages of the website comply with the display needs of Your particular device, to detect any potential issues of our servers when delivering pages to certain types of devices, to analyse tendencies and observe the manner in which users could enjoy a better navigation on our web pages.
In the early days of internet, website did not have any memory. This is why, in the first variants of websites, it was not possible the authentication of visitors, nor the use of prompts, such as shopping baskets, in case of online stores or other mechanisms helping the user and the website to recognize other visits as well.
Cookies were invented precisely to fix this problem. They are small text files, placed on the device of the reader, that play the role of memory of the website.
Each time someone accesses a certain website, it can write or read from the cookie it placed on the device all kind of information that the reader has sent already to the website, directly or indirectly. Subsequently, other technologies were developed from here, concerning the same type of purpose. We have tried to describe every such technology below.
"Direct" cookies are established by the domains you visit at that time (e.g. amcham.ro). "Third" cookies are established by other domains than the ones of the websites you visit (e.g. other domains than amcham.ro, such as google analytics).
The mobile publicity code is a unique identifier (ID) set by the operation system of your mobile device. This ID helps applications you install on your device and which can contain advertisements to recognize you. Most of devices allow applications to access in a predefined manner the mobile publicity identifier. Nevertheless, you have the possibility to modify the settings of your device to prevent it from sharing this code with various applications. Check the section “Help” for operation systems to find out more on the administration of mobile publicity IDs. On Android devices, Publicity is the Android publicity ID, on iOS devices it is the publicity agent ID (IDFA).
Below we shall refer to cookies, local storage and mobile publicity ID, such as "cookies and similar technologies".
Below we shall refer to cookies, local storage and mobile publicity ID, such as "cookies and similar technologies".
Most cookies can be included in one of the categories below:
(a) Strictly necessary: These cookies are essential in the supply of services requested by readers. Without them, the website cannot be operated or it cannot deliver the supplied services.
Below is a detailed description of the cookies which are strictly necessary and used by amcham.ro:
Host (Family of cookies) |
Name (cookie ID) |
Domain placing the cookie |
Purpose of the cookie |
Duration of life of the cookie |
amcham.ro |
shAmChamSiteRoID |
It maintains the status of the session for requests for pages |
Browser session | 60 min from the setting/ resetting after the login |
(b) Performance: These cookies collect information on the manner in which readers use a website, such as most popular pages, which method of connection between pages is the most efficient and whether users come across any messages of error on the websites. These cookies allow us to offer a high-quality experience to our readers, as well as to measure the audience of the amcham.ro pages. The information collected by these cookies do not identify users. They are conceived to improve the operation of our website.
This website uses Google Analytics, an analysis program for internet traffic provided by Google, Inc. (“Google”). Google Analytics uses cookies to help amcham.ro analyse the manner in which users use the website. The information generated by cookies on the use of amcham.ro (including your IP address) will be sent to and stored by Google on the servers from Ireland.
Google shall use this information in order to evaluate your activity on amcham.ro, to compile the reports on the website activity and to supply other services related to the activity of amcham.ro. Google may also send this information to third parties, if this is required by law or if these third parties are empowered to process the information on behalf of Google. Google shall not associate your IP address with other data held by Google. You may refuse the use of cookies by selecting the corresponding settings from your browser. Nevertheless, retain that if you do this, you may not be able to use this website at its entirety
amcham.ro decided not to activate the remarketing functions, respectively the reports on advertisements, not to perturb your privacy. Also, for the same reason, amcham.ro did not activate the User-ID function, meant to ensure the association of the interaction data on different devices and from several sessions. Plus, amcham.ro activated the anonymization function of your IP addresses, not to be used by Google for other purposes than that which is necessary to analyse the traffic of amcham.ro.
A detailed description of performance cookies used by amcham.ro is given below:
Host (Family of cookies) |
Name (cookie ID) |
Domain placing the cookie |
Purpose of the cookie |
Duration of life of the cookie |
google analytics |
utma |
Google Analytics |
Used to distinguish users and sessions. The cookie is created when it executes the javascript library and there are no existing utma cookies. The cookie is updated each time data is sent to Google Analytics. |
2 years from the setting/ resetting |
google analytics |
utmb |
Google Analytics |
Used to determine new sessions/ visits. The cookie is created when it is executed the javascript library and there are no _utmb cookies. The cookie is updated each time data is sent to Google Analytics |
30 mins from the setting/ resetting |
google analytics |
utmc |
Google Analytics |
Not used in ga.js. Set for interoperability with urchin.js. From the point of view of history, this cookie module worked with the utmb cookie to determine whether the user is in a new session/ visit. |
browser session |
google analytics |
utmt |
Google Analytics |
Used for the rate of request for acceleration. |
10 mins |
google analytics |
utmz |
Google Analytics |
It stores the traffic source or the campaign which explains the manner in which the user has arrived on your website. The cookie is created when the javascript library is working and it is updated each time data is sent to Google Analytics. |
6 months from the setting/ resetting |
(c) Functional: These cookies recall your selections, to improve your experience. Below it is a detailed description of the functional cookies used by amcham.ro
Host (Family of cookies) |
Name (cookie ID) |
Domain placing the cookie |
Purpose of the cookie |
Duration of life of the cookie
|
---|
amcham.ro |
timex |
It stores the time when a promotion is displayed for the user, in case it exists. |
Possible values: session, 1 day/week/month, 2 days/weeks, 3 days, depending on the promotion |
|
amcham.ro |
skipPromo_promo_id |
It retains whether the user has viewed the promotion or not; it is displayed when the time interval is reached |
browser session |
|
amcham.ro |
mypanel |
It retains the state of the login form (expanded/ displayed or narrowed/ hidden) – button “Members Only click to expand” |
browser sessio |
Targeting and advertising cookies: These cookies collect information on your navigation habits to make advertisements relevant for you and your interests. They are also used to limit the number of views of an advertisement, as well as to help measuring the efficiency of publicity campaigns.
You have the possibility to adjust your privacy settings using the browser to block all cookies; nevertheless, this may seriously affect your navigation, since many websites might not operate properly. The browser can allow you to delete all cookies when you close the browser. This option though, leads to the removal of persistent cookies, which can store your preferences and customized settings for the websites you visit on a regular basis. Nevertheless, you are able to keep the desired cookies, since the browser allows you to indicate the website which are always or never authorized to use cookies.
Further details on the removal of cookies or the administration of cookies in different internet browsers can be found accessing the links below:
In order to opt for no more tracking by Google Analytics please visit: http://tools.google.com/dlpage/gaoptout. IAB has built the following website to offer specific information with regard to privacy issues related to internet advertising: http://www.youronlinechoices.com/ro/. Full information on the method in which organization use cookies is available at the address: www.allaboutcookies.org.
We shall disclose your personal data only for the purposes and to the third parties listed below. We shall take appropriate measures to ensure your personal data is processed, secured and transferred in accordance with the legislation in force.
We shall send your personal data, if strictly necessary, on a need-to-know basis, to the following categories of third parties:
Also, we shall disclose your personal data to third parties:
AmCham does not transfer personal data out of Romania.
Any third parties to whom we disclose your personal data in accordance with the above provisions are limited (for example, by law and under contract) in their capacity to use such personal data only for the purposes precisely identified by us.
We shall always make sure that all third parties to whom we disclose your personal data are subjected to the obligations of privacy and security, according to the contracts concluded with them and the applicable laws. Nevertheless, to avoid any doubts, this cannot be applied when the disclosure is not our decision.
Except for the situations detailed expressly above, we shall never disclose, sell or rent your personal information to any third party.
GDPR recognises to data subjects a series of 8 important rights that you are allowed to exert:
Period for reply: We will try to reply your request within 30 days and we can extend this term for specific reasons, related to the complexity of your request. In all cases, if this period is extended, we shall inform you about the extension term and the reasons that lead to it.
Limited access: in certain situations, we may not be able to grant you access to all or some of your personal data due to legal provisions. If we deny your access request, we shall inform you about the reason.
No identification: in certain cases, we may not be able to search for your personal data because of the identifiers you supply through your application. In such cases, if we cannot identify you as data subject, we are not able to comply with your request to implement your legal rights described in this section, except for the case in which you supply additional information that might allow your identification. We shall inform you and offer you the possibility to provide such additional details.
Exertion of legal rights: To exert your legal rights, please access your Account on amcham.ro, section My Rights according to the GDPR, from where you will be able to get an instantaneous answer to your requests. If you are not pleased with this answer, please write us (including by electronic means) using the contact details supplied in the sections Contact below.
AmCham complies with the terms of preservation of personal data, established for each category of data, according to the Archiving Register which can be consulted on the web page of AmCham here.
AmCham undertakes to protect your personal data against any loss, improper use, disclosure, modification, unavailability, unauthorized access and destruction and to take all reasonable measures to protect the privacy of this data, including by taking appropriate technical and organizational measures.
Organisational measures include the control of the physical access into our premises, the training of the personnel and the blocking of the physical files in storing lockers. Technical measures include encryption, passwords necessary to access our systems, certificates of security type SSL, for the encryption of data in transit etc.
During the supply of your personal data to you, the personal data can be transferred on the internet. Even though we make every effort to protect the personal data you provide us with, the transmission of information between you and us, online, is not completely safe (the device you use for writing to us might be monitored by third parties, for example, without having the possibility to take any measures in this respect).
Therefore, we cannot guarantee the security of your personal information send by means of the internet. So, you understand that any such transmission is made at your own risk. Once we receive your personal data, we shall use strict procedure and security characteristics to prevent any unauthorised access to it.
We reserve the right, at our discretion, to modify our privacy practices and to update and perform any changes in this information note anytime. For this reason, we encourage you to keep returning to this note
This document is actual from the date indicated in the upper part of the document. We shall treat your personal data in a manner which is compatible with the information form based on which it was collected, except for the case in which we have your consent to treat it differently.
Please address your queries on data protection and any requests under your legal rights at the following contact details:
gdpr@amcham.ro, amcham@amcham.ro.
We shall perform an investigation and try to settle any request or claim related to the use or disclosure of your personal information.