I. Introduction
At “Enterprise Business Solutions” SRL (doing business as EBS Integrator), the right to personal data protection is a paramount and fundamental commitment, therefore we dedicate any required resources and efforts to process your data in full compliance with the European and national Personal Data Protection law.
Since transparency is a key principle of the General Data Protection Regulation framework, we have developed this statement (and/or document) to inform you about how we collect, use, transfer and protect your personal data when you interact with EBS Integrator through its website (web: www.ebs.io).
This Privacy Policy’s purpose is also to inform you about any information we process about you, in relation to our business, when you use our website. In collecting this information, EBS Integrator acts as the controller of personal data and, by law, we are obliged to provide you with information about us, inform you about how we use your data and any rights you are entitled to, in regard to any of your personal data we have collected on our end.
1.Who are we and how can you reach us
Enterprise Business Solutions” SRL (doing business as EBS Integrator and/or EBS; further references to as “we”) is a privately held legal entity, based in the Republic of Moldova with its’ headquarters at Ion Inculeț 33 street, Chisinau, MD-2001, registered under fiscal code (IDNO) 1010607002906, that acts as a personal data operator for any information processed through: www.ebs.io
EBS Integrator complies with local law in regard to personal data operators and undertakes to protect personal data of any data subjects, processed through its website, in compliance with relevant European and national legislation, in particular, according to provisioning stipulated within “Law no. 133, from 8th of July 2011” regarding the protection of personal data, as well as EU Regulation 679/2016, also known as General Data Protection Regulation ( further as GDPR).
If you (or anyone for that matter) should require any additional information regarding to how we process data, do not hesitate to reach our dedicated Data Protection delegate, making use of the following contact means:
By post:
ÎM „Enterprise Business Solutions” SRL
ATTN: Data Protection Officer
Columna nr. 170 st, Suite C, 4th floor.
Chisinau, MD-2001, Republic of Moldova
Or via e-mail, at:
dpo@ebs-integrator.com
To ensure a secure processing of your data, we have implemented reasonable technical as well as organisational measures to protect any personal data and are dedicated to ensuring continuous efforts dedicated to instructing our team in regard to the importance of securing personal data.
2. Types of personal data we process
First, we must inform you that according to current legislation related to data protection, data processing resembles a series of actions that relate to: collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, disclosure via transmission or via any other means, aligning or combining, restricting, deleting or destroying such data.
Though its’ website, EBS shall deliver any public interest information that relates to products, services, and company activities; respectively, we’re collecting and processing personal data:
2.1 Directly from your behalf – whenever you are trying to reach us via any means of communication in instances such as: submitting a contact form or sending an e-mail to any e-mail address specified on our website or any e-mail address that ends in @ebs-integrator.com.
To address any of your inquiries, in the best way possible, we might require additional data (that can or cannot qualify as personal information). Either way, as a minimum, whenever you fill-in a contact form, we shall store, process, and secure the following types of personal data:
2.1.1 Identification Details: such as First and Last Names;
2.1.2 Contact Details: such as phone numbers, e-mail or post addresses;
2.1.3 Message/Form content: any information disclosed within a contact form, e-mail message or letter, addressed to EBS
2.2 Indirectly – whenever you are visiting our website via cookies and other similar technologies. Cookies are special text, often encoded, sent by a server to an internet browser. These are usually sent back (unmodified) by the browser, each time a user re-visits that server. Cookies are used for authentication, provided that the portal has this functionality, as well as for tracking user behaviour.
Typical cookie usage relates to user preferences storage as well as various other applications in regard to improving the user experience of a given portal.
Our website uses strictly necessary cookies which are essential for you to browse the website and use its features, such as accessing secure areas of the site. These cookies will generally be first-party session cookies. While it is not required to obtain consent for these cookies, what they do and why they are necessary we are obliged to inform you such exist and are used to enable the functionality of our portal.
However, for those cookies that are useful but are not strictly required for our websites’ functionality, your consent will always be required before we make use of them. In addition to the cookies we use, EBS works with third party ones, to provide you with a timely experience. These various cookies can be saved on your computer, but only in base of delivered consent.
To ensure the security of our website, but also to secure any data transmitted through it, we keep record of IP addresses of computers or IT systems that access our website, as well as minimal technical information such as: used web browser, operating system, location, etc.
For more details about the tools we use, cookies and data processed, please consult our Cookies Policy.
3. Data processing purposes
Personal data will be processed for the following purposes:
3.1 Communication Purposes – direct communication with you regarding any questions asked through the contact form (questions may be related to our products and services, complaints, information about events, campaigns, etc.);
3.2 Dialogue initiation – refers to any action that presumes initiating and sustaining a dialogue through electronic and/or telephone conversations, as the case may be, regarding commercial, contractual, or service provisioning relations between EBS and you.
3.3 Documentation Drafting – relates to the purpose of drafting documents related to the pre-contractual stages such as: Non-disclosure Agreements or Quotes related to any Information Technology Services Contracts we deliver.
3.4 Document Management and exchange – relates to any instance that serves the purpose of managing and issuing documents related to service delivery contract execution, such as invoices, receipt documents, acceptance statements, reports, etc.
3.5 Website security, maintenance and fraud prevention – relates to any information required for operating, maintaining, upgrading or securing the website, that allows us to diagnose connectivity problems and prevent fraud.
3.6 Custom Quote delivery – relates to the purpose of transmitting custom offers regarding Information Technology Services provided by EBS, with personalized content, according to your interests.
3.7 Promotional Purposes – relates to managing and sending information regarding promotions, latest news and personalized information, adapted to your client profile.
3.8 Service Performance Assessments – relates to any information referring to the analysis of visitors, their browsing preferences, locations and behaviour on our website, in order to create a personalized experience for target audiences, improve presentation and promotions of our service profile (otherwise summarised as marketing purposes).
3.9 Legal Provisioning – relates to the purpose of enforcing a legal obligation as well as defending rights and interests of EBS in its relations with you.
4. Legal Grounds
EBS can process your data in base of the following legal grounds:
4.1 Personal Data Processing is required in order to conclude-execute a contract with you or with the company you represent (for instance, any actions performed within the pre-contractual and contractual phases).
4.2 Personal Data Processing is performed in base of your consent – we carry out marketing communications and use cookies that are not strictly required, exclusively in base of your consent. By way of derogation, EBS in certain instances, bases it’s cookie usage on legitimate interests, in conducting direct marketing activities directed at business development, taking all required measures to ensure that your fundamental rights and freedoms are not affected. However, you can request, at any time, by any means described above, to stop processing of your personal data for any marketing purposes and we will submit to your request.
4.2 Personal Data Processing is carried out on the basis of our legitimate interest – for instance, this refers to any activities related to improving our services, direct marketing activities as explained above, defending our legitimate interests such as fraud prevention and detection measures, protection measures website, the management of various risks including legal defence of EBS interests within a legal relationship with you as our prospect (potential customer), Client, former Client or any visitor of our website.
4.3 Personal Data Processing is required to fulfil a legal obligation – for example, the execution of reporting obligations to state institutions and / or other public authorities accordingly.
5. How long will we keep your data?
EBS will retain your personal data for as long as is reasonably necessary, considering various stages of your interaction with us, the duration of your contractual relationship or its effects after its expiry, as follows:
5.1 Within the Pre-Contractual Period
The retention period of personal data related to any pre-contractual stages varies from case to case, depending on a number of circumstances (i.e., type of provided data, purpose of provision, specific purposes of processing, incidental legal obligations, etc.). For instance, to the extent that you have been a potential customer or a representative / employee of a potential customer of ours, your data will be permanently deleted within 3 years from the time when it becomes certain that there is no change of establishing a service delivery contract.
5.2 Within Contractual and Post-Contractual Periods
The retention period of personal data related to contractual and post-contractual stages varies from case to case, depending on a number of circumstances.
Your data will be stored by us for the entire contractual period, as well as after the termination of the contractual relations for a period of 5 years, based on our legitimate interest, to keep records and proof the content of legal relations with contractual partners. These terms are calculated from January 1st of the year following the one in which the contract ends.
To the extent that any legal provisions in force implies or requires the retention of this data and after the expiry of the term set out above, personal details will continue to be stored by us until the expiration of the legal period designated for data retention in the above set out circumstances.
On expiration, any personal data stored on our end, in base of contractual and post-contractual legal grounds, will be deleted or anonymised when used for analytical purposes.
6. RECIPIENTS OF PERSONAL DATA
6.1 Personal Data of data subjects may be transferred / communicated to the following recipients:
6.1.1 Persons acting under the careful guidance of EBS, who according to their functions, duties and responsibilities are obliged to intervene in the respective process.
6.1.2 Authorized persons or associated operators acting under the careful guidance of EBS;
6.1.3 Public authorities or institutions, if they so request, in accordance with the rules of taxation, labour protection, social security or any other applicable regulations.
6.2 The transmission of personal data to the persons named above will be carried out only to the extent that this transmission:
6.2.1 is either imposed by the need to achieve specific purposes for which we process your personal data;
6.2.2 or is imposed by the legislation in force.
6.3 In specific circumstances, EBS may carry out cross-border data processing, so whenever an international data transfer is required, we ensure usage of legitimate international data transfer mechanisms.
7. Security provisioning for Processed Personal Data
EBS ensures an adequate level of security of personal data, and reasonable physical, electronic and administrative procedures have been put in place to protect the information we collect. Our information security policies and procedures are closely aligned with widely accepted international standards and are regularly reviewed and updated as necessary to meet our business needs, technological changes, and regulated requirements. Access to personal data shall be granted only to authorised personnel and only to carry out their specific tasks within well defined scopes (see list 3 and 4 of this statement) ans such access delivery is subject to the obligation of ensuring and maintaining confidentiality of personal data. In the event of a personal data breach, the data operator(s) will comply with all applicable data breach laws.
8. YOUR RIGHTS RELATED TO PERSONAL DATA processing
In the following we inform you about your rights as a data subject, regarding personal data processing operations:
8.1 the right of access to your data:
You may ask us for information about the personal data we hold about you, including information about what categories of personal data we have in our possession or control, what they are used for, to whom they have been disclosed, and if any such records exist. You can request a copy of such data, from our behalf, free of charge. The data bundle shall contain any personal data we hold about you. We reserve the right to charge a reasonable fee for each additional copies of such bundles if you may require a second or third copy.
8.2 The right to update or rectify your data:
You have the right to request from EBS corrections or updated to personal data, when it is inaccurate or ask to supply additional details, if you consider such data as incomplete.
8.3 The right to delete data from EBS Integrators’ end:
You may request that personal data be deleted when, among other things, the data is no longer required to achieve the purposes for which it was collected (list 5 of this statement) or if you withdraw your consent, rendering any legal data processing basis null.
8.4 The right to restrict data processing regarding your personal details:
You have the right to request processing restriction in situations where:
8.4.1 you dispute their accuracy and require a grace period for verifying inconsistencies;
8.4.2 any personal data stored is no qualified as relevant and you are requiring a copy of that data to discover, exercise or defense of any legal grounds and/or rights;
8.4.3 checking (during personal data verification) if our legal grounds prevail over your exercised rights in case you have opposed to us processing your data.
8.5 The right to data portability:
You have the right to receive personal data in structured, general use and mechanically readable formats, and to transmit it to another responsible party(ies), when processing is based on consent or on a contract and is performed via automated means.
8.6 The right to oppose personal data processing:
You may object or oppose to our personal data processing activities, including profiling processing actions. As soon as we’re aware of your opposition, EBS will no longer process your data, unless there are legitimate and compelling reasons to justify such processing.
8.7 The right to automated personalized or individualized decisions:
You have the right to negate subjecting to a decision based solely on automated processing, including profiling, which has legal effects on you or significantly affects your person. However, this right cannot be exercised, if that specific subjection is required to conclude the performance of a contract between you and EBS, if that subjection is authorized by applicable international or local law, provided that appropriate measures are established to protect your rights, freedoms, and interests, be those legitimate or based on your explicit consent.
8.8 The right to file complaints:
You have the right submit complains to the supervisory authority for compliance with personal data processing, to:
The National Centre for Personal Data Protection of the Republic of Moldova,
Mun. Chisinau, str. Sergei Lazo nr. 48, Tel./Fax: +373-22.820.801,
E-Mail: centru@datepersonale.md
9. Exercising legal rights regarding personal data processing
In order to exercise the rights related to personal data processing, data subjects may contact EBS using the contact details presented in it policy. Ideally, our main contact must be a designated subject that represents your company in these situations, being responsible for Data Protection.
In support of data subjects, particularly to expedite their requests, EBS may will make available standard and easy-to-complete requests for all situations in which data subjects could manifest their rights – this provisioning are not mandatory, but rather a best practice deployed by EBS.
These requests, as well as their processing as a rule is delivered free of charge. As a controller of personal data, we have the legal obligation to respond to these requests within 30 days, and in certain exceptional cases, within 60 days of receipt of the request.
EBS will always verify the identity of any person, analyzing situations on a point-by-point basis for replying to any liability claims, enabling the exercise of any legal ground.
Contact details for the exercise of the rights of data subjects:
I.M. ENTERPRISE BUSINESS SOLUTIONS S.R.L.
ATTN: Data Protection Officer
Correspondence address:
Columna nr. 170 st, Suite C, 4th floor, Chisinau, MD-2001, Republic of Moldova
E-Mail: dpo@ebs-integrator.com
10. Amendments to this policy
Any change in the privacy rules related to our website, regarding our contact details, categories of personal data collected, purpose and legal grounds for processing, to the extent necessary will be published on this web page and can be consulted at any time.