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PERSONAL DATA USEAGE POLICY

 

European Regulation 679/2016 repeals and replaces Directive no. 95/46 / EC on the protection of individuals with regard to the processing of personal data and on the free movement of such data (Article 94 of the Regulation).

The Regulation is directly applicable in all Member States under the Treaty on the Functioning of the European Union. Consequently, as of May 25, 2018, the Regulation also replaces the internal regulatory framework normative act of this particular field, Law no. 677/2001 on the protection of individuals with regard to the processing of personal data and the free movement of such data.

The General Data Protection Regulation (RGPD) creates consistent data protection rules in Europe. This applies to companies based in the EU and to global companies processing personal data in the EU.

Freeways Global SRL, a Romanian legal person, is a personal data operator that carries out commercial activities, including MLM ("multi level marketing"), consisting of: sales of specific products or packages, network partners with the aim of improving marketing, obtaining prizes and income in the form of commissions resulting from the sale of products, conducting product presentation training, informing, guiding new partners, etc.

Data protection is important to us, so for your safety and our services, we respect the current legislation on the protection of your personal data and we inform you accordingly. We are responsible when it comes to our practices and we have data privacy principles that explain how we perceive security and protection. We are constantly meeting with decision makers, policy, security, and privacy of personal data to establish our practices, get feedback and adapt as needed. This policy describes the information we process to provide and support our products, collaborations and related services (marketing, advertising, courier, banking, accounting, IT, legal, ITM, ANAF, Ministry of Finance, etc.) and how which can be accessed and deleted information we collect from you.

  1. What types of information do we collect?

The information we are required to ask from you depends on how our collaboration is possible: about the products - which you can buy directly from our headquarters or request by courier; with your position - an employee, consumer, partner or founder member; with the services we provide to our employees, clients and partners (presentation training, advertising, advertising of any kind, information, participation in events, sales commissions, information, relations with travel agencies, conclusion and execution of contracts (including work) as well as our technical capabilities, such as diagnosing our server problems.

Considering the specificity of MLM activity, for you to benefit from our products and services as well as for a good collaboration with us, it is necessary to collect from you the following data: name and surname, address, delivery date, birthday, contact phone, e-mail, or special dates such as personal identification number, biometric data (facial images, video or audio recordings during the various events you choose to join with us, or for us) that are subject to special protection measures and will help us to offer you products according to your requirements.

We will keep any personal information you wish to provide to us, contained in the consent (registration) form attached to this policy or displayed on the site in the „My Profile” section or in another document addressed to us, considering that we have your express agreement.

  1. How do we use this information?

We need your consent to use this data in order to ship your products by courier, to give you access to certain product promotions, to register you as a new partner, to prepare sales invoices, to provide information - by phone, by e-mail (newsletter) or sms - to guide you when you need it, to facilitate your commissions and to respond to any requests or complaints you make, as well as other purposes in or arising out of them.

We use the presentation materials of the company and the products we offer to inform the public in the country and abroad.

Our systems automatically process the content and communications you provide and conduct surveys on our products in order to improve the quality of our marketing.

We record the frequency with which you view the images or content of our products, buy from us, how you use them, what you do about them, how you find them on the market (advertisements, etc.), the people you interact with related information, such as credit or debit card number and other card information, if applicable, other account and authentication information, billing information, delivery, and contact information.

We also use special information as we use biometric or health-related data in advertisements, recorded or recorded audio events, online conferencing, etc. to promote products. Thus, our partners have the possibility, with the express written consent of the persons to whom they belong, to take specific contact with them and to convince themselves of the qualities of our products as well as to benefit from the information they need directly from them.  

The partners who have recommended you to join the system are important to keep in touch with you in order to provide guidance on request. To that end, if you do not decide otherwise and do not inform us in this respect, we can provide your data to the partners who are most proficient (those who have recommended you or those previously registered in the uplink system that form the team guidance). They have the role of supporting, on request, the collaboration, with the effect of optimal system operation, so that all partners get benefits (eg commissions) and help you run your business. When enrolling in the system, we ask each new partner to keep confidential the personal data of current and future partners with whom they come into contact and use them only for the purposes for which they were entrusted to the company. We do not collect personal data, for whatever purpose, from minors over 13 years of age, except with the express agreement of legal representatives.

We collect, record and retain the information you provide to us, based on your free consent, through the registration form displayed on the site and the "Partner / Contract Registration Form" for the purposes of this document. The two documents (forms) complement each other, together constituting the agreement for the processing of personal data.

We process, modify, correct, delete your data whenever you request us.

To create personalized, unique and relevant products for you, we use information about your preferences and interests, the way you use and interact with our products.

We use location information such as your current location to provide you with our products, including advertisements, leaflets, and for use by courier services that provide information protection based on specific contracts.

We use the information we have to provide you with a more fluid experience, to promote our marketing and to communicate information about our products and our policies and conditions of use. We also use your information to respond when you contact us.

We also use your personal data to automatically evaluate product-related issues based on your choices, the characteristics of the products you have already purchased, the circumstances of your situation and the predictions about your behavior. This automation process will not affects in any way, it is very useful to the extent that we can offer you for sale products similar to those you have bought or not yet found.

Your data can also be used in situations where we have a legitimate interest in the contexts created by and in connection with you, such as, for example, defending the rights we have in your relationship with you.

Audience can not access your data.

Freeways Global S.R.L. assume no responsibility towards partners who own other partners' personal data in other ways and uses them for purposes other than those agreed upon by them described in this document.

  1. How and to whom is this information distributed?

We allow the distribution of your data only to partners who support us to work safely and perfectly legally: courier services, accounting, human resources, legal, IT, banks, ITM, occupational medicine, ANAF, Ministry of Finance (eg payment of commissions outside the country and taxes to the partners' countries of origin), printers for printing leaflets or diplomas, travel agencies, hotels and other spaces used for accommodation, conferences or other events, as well as interested authorities, upon request, in the purpose of protecting public interests (health, public safety, etc.) and our employees. Based on our legal obligation, we communicate information and law enforcement bodies or respond to legal requests in the situations described below.

If ownership or partial or total control of ownership of our products and associated assets changes, we may transfer your information to the new owner.

Partners in our group of companies, in your interest and your consent, can take advantage of your data as it helps us deliver and improve our products, and this allows the operation of our companies and enables us to offer quality services.

We do not alienate anyone and in any way what you communicate to us, and we will never do this. We also subject severe restrictions and controls to the ways in which our partners can use the data we provide with your consent.

We use, as our partners, secured data storage systems that will guarantee their security against any unlawful or unauthorized accidents, loss, modification, access, disclosure or use. For details, read our data security policy.

  1. Cookie policy.

When you browse the internet, you have probably encountered the term "cookie". Some websites have informed you about their use, or your internet browser has provided some settings for them.

In general, a cookie is a small amount of data that is transmitted between a sender and a recipient. A cookie is created and interpreted by the sender, while the recipient just keeps it and sends it back if the sender asks for it.

When browsing the internet, the sender is the server hosting a website and the recipient is the user's internet browser who visits that site. Their purpose is to identify the user, verify their past activity on that site, and provide specific content based on these data.

When a user visits a site for the first time, the server stores a certain cookie in their web browser. For all successive visits to this first visit, the server will ask for a cookie to read and load a particular web site configuration that is most appropriate for that user. You can see a cookie as a label that servers apply to each user, then read them to identify users.

This identification is especially useful on websites where real-time user data is critical. For example, when you use an online sales site, you could not buy anything without the cookie. Stores can not identify you and give you a shopping cart without them because every time you upload a new page, the store would look like a new user and create a new basket.

Cookies are widely used on the internet, including by our company and its group of companies, because they allow websites to be more powerful, providing dynamic and user-friendly content. In some cases, websites can not work without using a cookie. They also allow websites to collect data about their users and the pages they visit.

We do not allow third parties to place a cookie on your device.

We use cookies on our site without affecting in any way the security of any kind of information we have, because we benefit from high-security technical systems. However, if you want to disable them or delete them, use the.... But remember that disabling certain cookies reduces system operating features.

5.What is the legal basis on which we process the data?

We collect, use and distribute the data we have in the ways described above in accordance with your consent, which you may revoke at any time through the settings we provide to you under the following conditions:

• as necessary to meet our legal obligations;

• to protect your vital interests or others;

• as necessary in the public interest

• as necessary in our legitimate interest (or others), unless these interests harm your interests or the fundamental rights and freedoms that require the protection of your personal data.

6.How can you exercise your rights under the General Data Protection Regulation (GDPR)?

In accordance with the General Data Protection Regulations, you have the right to information and access, rectification, porting and deleting your data.

You can withdraw your consent at any time.

You also have the right to oppose and restrict certain automated processing of your data.

Because we use personal data in accordance with the Regulation (EU), this policy may be supplemented by any provision of this policy.

Learn more about your rights and how to exercise them by visiting the link: https://eur-lex.europa.eu/legal-content/RO/TXT/?uri=CELEX%3A32016R0679

7. Storing, disabling and deleting data

We store your data as long as you are our partner, as the retention of your data is required for the purposes specified in the contract with us, on the basis of which periodic sales commissions, as well as for periods determined by law (for example, for accounting, statistical purposes, etc.).

The right to be forgotten / delete your data is accomplished by deleting your account, which also includes the waiver / loss of your commissions. It is in your advantage to keep your data in the system, as by registering we can provide the benefits that our partners normally have (commissions, prizes, promotions, attendance at trainings, etc.) to which, by deleting the data, willingly.

If you want to be forgotten, send a message to us or contact the contact person responsible for data protection on the phone: 0040761.217.771 and your data will be deleted immediately, without delay and you will be notified accordingly.

The information we receive about you may be accessed and stored for a longer period of time including after deleting the data by disabling your dsv account when it is the subject of a legal or legal request or solution or of a criminal investigation or of some investigations into possible violations of our terms or policies, or in other cases to prevent damage. We also keep information from accounts deactivated for at least one year's violation to prevent repeated abuse or other violations of the terms, but this will not affect you in any way.

8.How do we respond to requests, including legal and how do we prevent injury?

We access, retain and provide your information to regulatory authorities, law enforcement or other entities:

• In response to a legal request, when we believe in good faith that the law requires us to do so. It is also possible to respond to legal requests when we consider in good faith that the response is required by law, affects buyers in the jurisdiction and is in line with nationally and internationally recognized standards.

• When we believe in good faith that it is necessary to: detect, prevent and respond to acts of fraud, unauthorized use of our products, violations of our terms or policies, or other harmful or unlawful activities to protect us (including our rights, goods or products) to you and others, including investigations or investigations by regulatory authorities. For example, if relevant, we provide information to and receive third-party partner information about your data to prevent fraud, abuse, and other harmful activities inside and outside of our products.

We've delegated people in charge of your data who can handle the requests you are addressing and who can respond to them in time.

We have written forms of exercising your specific rights.

We have determined, in case your requests are received by mail, that your reply is also provided by mail, for more rapidity, in case you do not want to receive it in a different way.

We have implemented specific security procedures for situations that relate to your data (data security, response to your requests, resolution of any request, etc.).

We keep the record of your requests and response addresses for any need.

We identified the risks early and we have secured, through specific protection systems, in collaboration with industry specialists with whom we have firm agreements, that your data will be protected at all times and that there is no risk for you.

The information we receive from you may be accessed and stored for a longer period when subject to a legal, legal or criminal request, criminal investigation or investigation of possible violations of our terms or policies; or in other cases to prevent damage.

We do not transfer databases to other countries, within or outside the EU, for any purpose other than law, accounting, tax, banking, or similar. If we also transfer for other purposes, we will inform you before being transferred for the purpose of obtaining your consent.

9. How will we let you know about changes to this policy?

If the changes will be dictated by the company's interests, we will notify you before making any changes to this policy and give you the opportunity to review the revised policy before choosing to continue using our products.

If the changes will be dictated by the change of the legislation in force regarding the protection of personal data, the content of this document will be updated. At the end of the document, we will show the date until which the legislative changes were considered.

10. How to contact us if you have any questions

If you have any questions about this policy, you can contact us online via the contact section posted on the site, or by calling the data protection officer on the phone: 004061.217.771

Contact the Data Protection Officer

You also have the right to file a complaint with the data supervisor in Romania.

Continuing accessing the site by completing and activating the consent form that makes reference to this document means that you have become aware of our privacy and security policies that you are fully aware of as agreeing to it and that we have your consent to use the data for the purposes stated in the form.

A. The form in section 9

Questions on the Data Usage Policy

- Deleting your data with the consequence of closing your account and losing your partner's right, as well as your commissions

- Requesting data deletion only

- Requesting a copy of your personal information

- Reporting a security incident related to your data

- Reporting your rights violation

- Suspend the use of your data

- Restrict the use of your data (for a period of time)

- To ask a question about your data

- To submit a referral, any information

B. Contact form with data manager

Contact the Data Protection Officer (DPO)

To submit a request to the Data Protection Officer (DPO), please complete this form. Please note that the form is only for requests sent to the DPO regarding our products / services – link: „Request Form”

C. Consent Form

I want to be a customer of Freeways Global S.R.L, a personal data operator. For this, I understand to give my consent, as a legal basis, to the processing by Freeways Global S.R.L. and the companies with which it collaborates, having similar products, activities and purposes, of the following data:

  • Name and surname
  • Personal identification number
  • Stable home address
  • Delivery address (other than stable residence)
  • Online identifier
  • Phone
  • E-mail
  • Date of birth
  • Home country
  • Processing of genetic data

I agree that the data specified in the form be used for:

  • selling products
  • promotion of offers
  • automatic profiling to identify future offers, create ads, ... ..
  • acceptance of cookies use
  • sending sms and newsletters
  • phone contact and mail for various purposes (product presentation, response to requests, invitations to events, etc.)
  • Transfer to partner companies
  • Transmission to our partners, including those in the guidance team
  • Transfer to the courier, in order to ship the products
  • Preparation of accounting documents and internal records,
  • Concluding and executing contracts
  • Identification of the person representing the legal partner
  • Recharging periodic fees, awards, etc.

throughout my entire life as a partner of Freeways Global S.R.L.

I have been informed that in the event of a change in the stated purposes I will be notified about this before the processing in order to supplement the consent and that in case of any option made by me regarding the data I will be notified or will be answered in this sense.

I have read the policies posted on the site regarding the use and security of my personal data (link to them) and I know that, according to the law, I have the right of option regarding:

• Information and access to existing data on your base

• Correcting data

• Deleting data with the consequence of closing your account and losing your partner's right as well as the commissions

• Restrict data

• Suspension of processing

• Automatic processing (profiling) of data

• Opposition to processing

• Data portability

• Withdrawal of consent

• Submitting a complaint to the supervisory authority

• Contacting the Data Protection Officer

I would like to point out that I was informed that the Data Protection Officer can be contacted for any issue related to them at no. by phone: 0040761.217.771

The completion of this form is my express consent to processing in the specified ways by ticking my personal data by Freeways Global S.R.L. in accordance with Personal Data Protection Regulation 679/2016