Data Privacy

The https://strix.solutions/ website, including the optimized version for mobile devices (smartphone, tablet), uses similar cookies and if the case, technologies assimilated to cookies (beacons, pixels, etc.) to manage sign-in sessions, to provide personalized web pages and adapt advertising and other relevant content to reflect the specific needs and interests of users. By accessing STRIX SOLUTIONS, Customer’s consent is absolutely necessary for the use of cookies and related technologies for the purposes we describe in this policy. Cookies can be used to store information such as user’s identifiers or the activity of users accessing the website. A website can install a cookie in the browser only if the browser settings allow such activity. A browser allows a website to access only the cookies installed by it, not those installed by other websites.

For the purposes of this policy, any person accessing the STRIX SOLUTIONS website or sections of the website is considered to be a user and will be hereinafter referred to in this document as “the user”. The Cookie Policy is complemented by the Terms and Conditions and the Privacy Policy provisions as well as the policies of our business partners, as is the case with Google.

  1. What are COOKIES?

Cookies will be understood as IT data in the form of small files installed in your laptop, smartphone, or tablet terminal, including but not limited to text files stored for the purpose of using the web page. Some of these files make it possible to recognize the user’s terminal and present the content in a relevant way, adapted to the user’s preferences. Other cookies extract certain information about user’s activity on a specific website. Typically, cookies contain the name of the originating web page, the storage date on the used terminal, and a unique number.

We may use “cookies” to personalize content and ads on the website, to give you access to company presentation pages in various social media networks and platforms and to analyze traffic on our website. We also offer our social media partners statistic information about your use of our website or our company’s social media pages.

  1. What type of cookies do we use?

We use the following types of cookies: of the site (session) and third party (Google analysis cookies only). Session cookies are temporary files that remain stored in the user’s terminal until the end of the respective session or closing the application (closing the web browser). The cookies used by our partners who own a webpage you can access from our website, if we offer this possibility, are the subject of our partners cookie policy, so we recommend that you read the cookie or privacy policy for which STRIX SOLUTIONS assumes no responsibility.

  1. What cookies are used for?

Cookies are used to adapt the content of our web pages to our users’ preferences and to optimize and use web pages. They are also used in the preparation of aggregated anonymous statistics that help with understand how a user may benefit from our web page, allowing us to improve the page structure and content, excluding personal identification of the user. Cookies provide a much faster and secure interaction with the STRIX SOLUTIONS website. Cookies may also help us advertise you both on and off the site on other websites you visit.

  1. Do Cookies process personal data?

Personal data collected through the use of cookies can only be collected to facilitate certain functionalities for the User. These data are encrypted, so unauthorized people’s access to it is not possible.

Ways of use
Description
Security
We use cookies in order to allow the installation and administration of security features implemented on the website and it helps us detect malicious activity and violations of the website’s conditions of use.
Preferences, features, and services
Cookies can tell us in which language you prefer to display the content of the website and what your communication preferences are. Cookies can also help you fill out the existing forms in the STRIX SOLUTIONS website more easily. They also provide you with features, information and personalized content along with our plug-ins, if we use any at a certain point in time.
Performance, Analysis and Research
Cookies help us understand how well the site works and how our plug-ins work in different locations. We also use cookies to understand, improve and research products, features, and services, including when you access STRIX SOLUTIONS from other applications or devices, such as your work computer or mobile device.
  1. STRIX SOLUTIONS website uses two types of cookies:

– Session cookies (of the website);

– Google analysis cookies.

 

  1. “Essential cookies”

Essential cookies are necessary files for a website to work properly. Generally, they allow the user to navigate through a website and perform certain functions, such as accessing secured areas, placing lists, depositing funds, or managing the customer account if necessary. Without these cookies, it would not be possible to provide specific online services and features.

 

These files do not interfere in any way with the user’s personal data, these cookies being part of the use and operation of the website, so they will be installed and then uninstalled upon completion of that session. These cookies are minimized, so the company will only use those “essential” cookies.

 

An example of an essential cookie may be a file installed to remember the option you have expressed for the use of cookies by STRIX SOLUTIONS. 

 

  1. We use the essential cookies to …

– connect you to the STRIX SOLUTIONS website;

– helps us provide the correct features of the site at the moment the website is being accessed.

 

  1. The cookies we have defined as “essential cookies” will not be used to …

– Collect information that could be used to present our services;

– Retain your preferences or username beyond your current visit.

 

STRIX SOLUTIONS uses the following session cookies:

  1. STRIX SOLUTIONS website uses two types of cookies:

– Session cookies (of the website);

– Google analysis cookies.

 

  1. “Essential cookies”

Essential cookies are necessary files for a website to work properly. Generally, they allow the user to navigate through a website and perform certain functions, such as accessing secured areas, placing lists, depositing funds, or managing the customer account if necessary. Without these cookies, it would not be possible to provide specific online services and features.

 

These files do not interfere in any way with the user’s personal data, these cookies being part of the use and operation of the website, so they will be installed and then uninstalled upon completion of that session. These cookies are minimized, so the company will only use those “essential” cookies.

 

An example of an essential cookie may be a file installed to remember the option you have expressed for the use of cookies by STRIX SOLUTIONS. 

 

  1. We use the essential cookies to …

– connect you to the STRIX SOLUTIONS website;

– helps us provide the correct features of the site at the moment the website is being accessed.

 

  1. The cookies we have defined as “essential cookies” will not be used to …

– Collect information that could be used to present our services;

– Retain your preferences or username beyond your current visit.

 

STRIX SOLUTIONS uses the following session cookies:

Cookie name
Cookie use
  1. Which third-parties’ cookies do we use?
Google Analytics The STRIX SOLUTIONS site uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies (text files installed on your computer) to help web site operators analyze how users are using a certain website. The information generated by cookies about the use of this site (including your IP address) will be transmitted and stored by Google on the servers in Ireland. Google will use this information to evaluate the use of the website, compile reports on website activity for site operators, and provide other services related to the activity of the website and the general use of the Internet. Google may also transmit this information to third parties, if so, required by law or if such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data owned by Google. By using STRIX SOLUTONS website, you agree that Google may process some information about you in the manner and for the purposes outlined above. We don’t identify and do not allow Google to identify or attempt to identify the users who visit our website. Google Analytics cookies are the following:
Cookie name
Cookie use
_ga
Duration 24 hours

To explain in detail how Google uses cookies and other related technologies, the purpose and what types of cookies are used, please access the Google Cookies Policy that we make available under the following link: https://policies.google.com/technologies/cookies?hl=ro

 

Facebook

STRIX SOLUTIONS uses Facebook specific cookies. To explain in detail how Facebook uses cookies and other similar technologies, for what purpose and what types of cookies are used, please visit the Facebook cookie policy that we make available under the following link: https://www.facebook.com/policies/cookies/

 

  1. How do we use Web Beacons, Pixels and/or Other Technologies?

Web beacons (also known as clear gifs or pixel tags) often work with cookies. We and our service providers (such as Facebook) can use them for similar purposes as cookies, such as understanding and improving the use of our services, improving site performance, monitoring traffic and visitor actions on our site and understand interactions with our third-party ads marketing).

 

We use other technologies that are similar to cookies, such as browser storage and browser plugins (jQuery, PHP, Elementor, MySQL and Google Font API). Like cookies, some of these technologies can store small amounts of data on the device. We can use these plugins and various other technologies for purposes similar to those for which we use cookies, such as implementing our business terms, preventing fraud and analyzing the use of our services. There are a number of ways to express your consensus for the usage conditions of these technologies. For example, many popular browsers offer the ability to clear the browser’s storage space, usually in the settings area; check out your browser’s help or assistance area to find out more. Other technologies can be removed from the website or application.

 

  1. Deleting cookies

An application used to access the STRIX SOLUTIONS web pages allows cookies to be saved on the device only to the extent that the user’s consent has been expressly granted for such processing. If you are a visitor, you can withdraw your consent to install third-party advertising cookies in the settings section provided under this paragraph.

 

To manage the use of STRIX SOLUTIONS cookies directly from the browser settings we use, we are about to send the link to the way, the instructions for each type of search engine used:

  • Cookie settings in Internet Explorer – Internet Explorer;
  • Cookie settings in Firefox – Firefox;
  • Cookie settings in Chrome – Chrome;
  • Cookie settings in Safari – Safari;
  • Cookie settings in Edge – Edge;
  • Cookie settings in Opera – Opera.

 

In the event that the use of cookies by STRIX SOLUTIONS is not accepted by the user, the settings can be changed in such a way that the automatic cookie administration is blocked by the web browser or the user is informed each time cookies are sent to its terminal. Detailed information about the possibilities and ways to manage cookies can be found in the application settings area (web browser). We inform you that limiting the use of cookies may affect certain essential features of the web page.

PRIVACY POLICY

This Privacy Policy sets out how personal data that STRIX SOLUTIONS collects from its contractual partners (legal persons) and from individuals (natural persons) through the functionality of the products offered, are being processed by STRIX SOLUTIONS.

By continuing to use the website, you understand that browsing the STRIX SOLUTIONS website/social media company pages and interacting with the company’s services implies your request for certain personal data, and the refusal to provide us with this data may result in the inability to provide the requested services. Our products functionality implies the processing of personal data of natural persons in the ways we describe herein.

Thus, we provide you with transparent information about the personal data we collect and the way we use these data, and we also inform you about the rights of the data subjects and how these rights can be exercised.

Before you provide us with personal data by accessing the site or by other means of communication and transfer, you will be required to consent to some of the processing of your personal data by STRIX SOLUTIONS in accordance with Article 3 of this Policy.

Insofar if you have requests or questions related to the processing of your personal data within the S.C. STRIX SOLUTIONS S.R.L., please contact us by using the following contact information:

Address (headquarters): Bucharest, 5th Heleșteului Street, postal code 011985, 1st District, Romania;

E-mail: dpo@strix.solutions

Telephone: +40 743 578 156​ (normal rate call)

Considering the data protection activity of STRIX SOLUTIONS, the company appointed a Data Protection Officer (DPO).

 

If you submit to STRIX SOLUTIONS a request to access your personal data processing activities to receive information, please keep in mind that due to the continuous processing of your personal data and taking into account the routine established in our IT systems for deletion of the information processed under the Data Retention Policy, we undertake to keep your up-to-date and accurate data at all times. Thus, this routine processing may involve modifying or deleting the personal information we process after you have submitted a request to us. In this case, STRIX SOLUTIONS will provide the information existing in our possession when we send the response to you, even if it differs from the information that was stored at the date when your request was sent. Please note that deleting your personal data is a procedure that STRIX SOLUTIONS would have performed even if you had not submitted the request.

 

  1. Contact details of the entity carrying out the described processing activities:

STRIX SOLUTIONS S.R.L. as Data Controller

Registered office address: Bucharest, 5th Heleșteului Street, 1st District, postal code 011985, Romania;

You can contact us through:

E-mail: dpo@strix.solutions

Telephone: +40 743 578 156​ (normal rate call);

By post-mail: Bucharest, 5th Heleșteului Street, 1st District, postal code 011985, Romania.

 

  1. Personal Data collection, storage and processing

 

For our website users and contractual partners representatives

We only store and process your personal data in cases when you have voluntarily provided us with such data, such as by telephone in direct contact with one of the company’s employees, or by e-mail to our corporate clients or our collaborators, or by filling in a printed form (paper), or storing such data on an electronic device (for example, a laptop, a tablet, etc.) in a campaign conducted by STRIX SOLUTIONS or by sending personal data by e-mail. If we collect any other personal data, you will be informed in this Policy or in the promotional campaigns or events, about the intended purpose of using this data, and if necessary, we will require your consent to the processing of personal data.

For personal data we collect directly from natural persons

All personal data of individuals obtained by STRIX SOLUTIONS directly from them on behalf of and for the STRIX SOLUTIONS customers (legal person) for which we conduct or organize a market research campaign or market research event will be forwarded to our client under the form of a statistical report without storing in any way this information and without transferring the image we record to any third party.

  1. What personal data we process, when and how?

3.1. STRIX SOLUTIONS collects personal data of the representatives of partner companies or individuals with whom STRIX SOLUTIONS employees or representatives come in direct contact according to the contract concluded with its client as follows:

 

– every time you access our services asking for offers, or information about the products we offer, we process your personal data to conclude and execute your request or/and the framework contract under which we provide our services;

– we process your personal data when we have obtained your consent to processing, such as the use of third-party cookies (Google Analytics for example), to verify the traffic generated on our website;

– keeping in touch with our partners (via SMS, e-mail or phone) for the performance of the contract;

– to respond to requests for the performance of the services rendered or in connection with the data processing activities;

– transfer of information to our contractual partners for the provision of contracted services;

– transmission of offers for the conclusion of a contract with STRIX SOLUTIONS;

– transfer of information requested by different public authorities according to legal requirements or to various internal or external audit firms or consultants;

– performing internal corporate operations of STRIX SOLUTIONS (example: drawing up lists);

– participating in a contest or promotional campaign sponsored or organized by STRIX SOLUTIONS or by a third party on our behalf.

3.2. STRIX SOLUTIONS collects personal data of the individuals by means of video cameras installed in the refrigerated showcases used in various shopping markets by STRIX SOLUTIONS’ clients, as follows:

  • the processing activity that STRIX SOLUTIONS carries out exclusively involves recording the physical person’s image that physically interacts with its product via a video camera installed on the product;
  • STRIX SOLUTIONS product has a motion detection service and a face detection feature that interacts with the face detection service. Thus, the refrigerated showcase detects through the video camera the presence of a person standing in front of the refrigerator’s door and opens it in order to pick a product form the shelve. It is also possible to record with the video camera the image of people who pass in front of the refrigerated showcase without interacting with it;
  • the image is stored in the device integrated memory for a 24-hour period;
  • the basic service (main function) of the camcorder is that of facial detection and image storage of the individual, not facial recognition. As a result of detecting a person’s image, the system does not identify the person whose image is detected, but only retains the image in order to interpret information about the approximate age and sex of people who interact with the purchaser’s products from the “smart shelves” of the cold store. The information is interpreted exclusively statistically according to the technically parameters integrated in the STRIX SOLUTIONS product and are transmitted to the client in an aggregated and encrypted form as a report, unable to identify the people whose image was processed;
  • the processed image is automatically and permanently deleted within the 24-hours retention term and is in no way transferred to the client;
  • STRIX SOLUTIONS doesn’t download personal data to its server, in other storage media except SBC for the above-mention time frame, doesn’t make copies or back-ups of the processed data, and it doesn’t transfer personal data or information recorded to third parties, whether contractual partners of the client or subcontractors.
  1. Personal data we use and the legal basis of the processing

 

  • Identification and contact details of our clients’ representatives – name and surname, business or personal email, phone number (mobile, landline or both), postal address of the company you are working in. The legal basis on which we carry out the processing of this personal data is our legitimate interest as provided by art. 6 par. (1) letter f), pursued by our commercial activity in our desire to sign a contract with our clients;
  • Identification and contact details of natural persons in the benefit of our client – image of natural persons is recorded by a video-camera installed in the refrigerated showcase as described in art. 3.2. and obtaining information in the benefit of a third-party which is always a STRIX SOLUTIONS client.

In relation to STRIX SOLUTIONS, we inform all parties about the way personal data is being collected and used and provide means to be contacted in case any interested party intents to send a request regarding our data protection activity.

  1. Principles of processing personal data

We respect the principles of processing and data protection so your personal data will be:

  • processed legally, fairly and transparently;
  • collected only for a valid purpose that we have clearly explained and not used in a way incompatible with this purpose;
  • relevant to the purpose we have communicated to you and limited only to those purposes;
  • accurate and up-to-date;
  • not be stored longer than necessary for the purposes described;
  • stored securely.

 

  1. How do we get this data:

Automatically:

  • By recording your presence and activity inside a store where STRIX SOLUTIONS product is placed;

Directly from you:

  • By using cookies to obtain information under theCookies Policy after receiving your express consent;
  • Via the website, after sending a message using our “Contact” information;
  • After interacting with you by phone or by e-mail to send requests, recommendations or suggestions;
  • Through your direct contact with our employees at a business meeting event.
  1. To whom we transmit your personal data and the results of our processing activities (reports, lists, etc.):

We don’t disclose/transfer personal data we collect directly from the natural persons to our contractual partners or clients. We share with our clients (legal persons) only non-personal information in an aggregated form (under the form or a report). Such information is automatically generated (approximated) through our technical algorithms integrated in our product (the video camera installed in the refrigerated showcase and we define such information as metadata (a set of data that describes and gives information about other data).

As for the personal data of our client’s representatives, we only process such data inside STRIX SOLUTIONS, unless mandatory legal requirements request that we transfer such data under certain conditions.

To the necessary extent and if STRIX SOLUTIONS still has the personal data, we will make such data available to third parties to comply with any laws, regulations, legal requests or requests received from public authorities (for example, under certain law enforcement measures as a result of controls, summons or court orders) or when we believe that we act in good faith (in order to implement our internal policies and rules), including in case of an investigation of possible violations or the detection, prevention or taking action in respect of illegal activities or other misconduct, suspicion of fraud or the occurrence of security incidents. In addition, we will only share your data insofar as we are required to exercise our legal rights to defend ourselves against claims with legal implications or to prevent the damage to our rights, property or safety, our partners, yours or any third party or for the purpose of collaborating with law enforcement authorities, or if we believe it is necessary to ensure compliance with the intellectual property of STRIX SOLUTIONS, data protection applicable laws or other rights.

Business transfers

We may share personal data of representatives we enclosed contracts with, in the case of a corporate transaction (purchases of the majority or wholly owned shares of the company such as by merger). In case of the aforementioned affiliated company or the company acquiring all shares will take-over and comply with the rights and obligations described in this policy or will integrate such responsibilities in its privacy policy.

Identifiers

We can share the identifiers we collect (by using cookies) in order to improve the relevance of our website as well as to detect potential security incidents or technical issues related to the operation of our website.

8. Legality of processing personal data

STRIX SOLUTIONS is responsible for the processing of your personal data for the entire duration of the data storage retention term. We comply with the principles of processing established under the General Data Protection Regulation (GDPR) and integrate these principles into our company’s internal processes and our commercial practices.

9. Where are we processing your data?

Personal data of the natural persons will be processed mainly in Romania and other European Union countries like Bulgaria and Hungary) where currently STRIX SOLUTIONS products are being used. In the future, as the business may be scaled to non-EU countries, we will only process personal data if appropriate technical and organizational measures are implemented in order to ensure the safety and confidentiality of the personal data we process or if such countries are considerate adequate by the relevant Data Protection Authority. We also consider implementing appropriate Corporate Binding Rules and only transfer information to companies who also implemented appropriate Corporate Biding Rules.

 

  1. Processing of job applicant’s data for jobs available within STRIX SOLUTIONS

 

Personal data means any information that identifies you or could be used to identify you. We process the data of the candidates applying to jobs available in the company for legitimate and voluntary purposes, in order to conclude an employment contract. We ensure that we process only the personal data that is strictly necessary for the stated purpose.

For the purposes of selection and recruitment, we can process the following categories of personal data:

Identification data – name, surname, address, national personal number (CNP) and series, photo, registration number and date of issue of various documents, etc..

Contact details – email address, phone number, address, etc.

Professional life data – employer, experience, position, salary, education, etc.

Please note that for certain positions involving the management of the company’s assets (especially related to money management), the company may request the submission of a criminal record without retaining this document and without processing any information from this document.

Digital data – cookies, IP addresses, and we can view websites that you own or are tracking and existing social networking activities as well as other public data available on the Internet without storing any data in any way;

Special categories of data (sensitive data) – personal data revealing racial or ethnic origin, membership of trade unions, health data for control of occupational health.

How do we collect the data?

Directly from you:

  • In the selection and recruitment process or through your submission of the resume following the careers section from our website, sending your CV directly to the existing information from our “Contact” section or through the recruitment platforms of our contract partners or following a recommendation.

From other sources:

  • By recommendation;
  • External company to assess the suitability of the candidate during the recruitment process;
  • Health and safety at work or other providers of safety services at work or in medical services;
  • From the former employer.

 

How long do we keep your data?

As a general rule, we keep your personal data for the period of time necessary to achieve the purpose of the processing, that is, during the recruitment and selection process, which is, in most cases, even if it does not materialize by signing an individual employment contract after 3 months. When we store your personal data for another specific purpose, the storage period will be specified in the Data Retention (storage) Policy . Your consent will be required if we consider it is necessary to extend the data storage period beyond the up-mentioned initial period.

11. The rights you have

  • Before exercising your rights, we must identify you to protect your personal data against any fraudulent attempts.
  • Your requests for accessing personal data processing by STRIX SOLUTIONS will be honored as soon as possible. With respect to our internal processes, we will endeavor to deliver any response in relation to your personal data processing activities, within a maximum of one month (mainly interpreted as 30 days period). Should you have such requests, we ask you to send an mail to dpo@strix.solutions or contact us by phone using the phone number displayed in the “Contact” section of the website;
  • You have the right to receive information at any time about the purposes of processing your personal data, categories and sources, recipients, periods of storage of your personal data and your rights.
  • You have the right not to be subject to an automatic decision, having the possibility of opposing an automatic decision-making process. STRIX SOLUTIONS does not engage in automated decision-making processes at this time;
  • You have the right to access your personal data, including the right to obtain a copy of the personal data we process;
  • Regarding the portability (transfer) of the data you have provided to us in relation to the precise purpose for which we process the data, the specific data we collect and the limited time for which we store such data (we store the image for a 24 hours period then it is automatically deleted) portability is not technically possible;
  • If you find that some data that we have or obtained from you is incorrect or inaccurate, you may request for the rectification and/or updating of incorrect data and the completion of all incomplete data;
  • You can rectify or complete your personal data by contacting us and providing us with the correct or additional data. You may request that you restrict your data processing if the accuracy of the data is challenged for a period that allows us to verify that accuracy.
  • You have the right to restrict processing, which means we store your personal data, but we do not use it for any other purpose. If you have obtained restriction on processing, you will be notified if and before the data processing restriction is lifted. However, given the specificity of the data processing activity and the limited period such data is retained in our systems, restriction of any processing activity requested by a natural person may be obsolete;
  • You have the right to request the deletion of your personal data. We will evaluate your deletion request from our internal legislation and procedures, taking into account, where applicable, our partner’s instructions and provide a written response within the agreed timeframe, which will not exceed one month from the receipt of the deletion request. However, given the specificity of the data processing activity and the limited period such data is retained in our systems, deletion of any processing activity requested by a natural person may be obsolete;
  • You have the right to contact us at any time if you believe that your rights stipulated by the legislation on the personal data protection have been breached by STRIX SOLUTIONS;
  • You have the right to appeal to the Data Surveillance Authority, namely The National Supervisory Authority for Personal Data Processing, having the address 28-30 General Gheorghe Magheru, 1st District, post code 010336, Bucharest, Romania, or at a competent court if you believe that your personal data processing rights have been violated.
  1. Cookies

Cookies are text files entered on your computer, smartphone or tablet, used to collect standard internet logging information and information about your conduct on our website. This information is used, for example, to analyze your use of the site and to generate statistics reports on the sections and other traffic existing on the website. You can set your browser not to accept cookies or you can disagree from the cookie consent pop-up. However, some internal cookies are required to allow the user to access the STRIX SOLUTIONS website.

For more information, visit the Cookie policy.

 

  1. Do we process data about minors?

 

As STRIX SOLUTIONS product processes personal data of individuals present in super-markets of various shops, by means of a video camera incorporated in the refrigerated showcase, children’s image can be also recorded. However, the purpose of the recording doesn’t change nor the retention period of the personal data and accessible information about the data processing activity is available on the refrigerator or next to it.

By using the STRIX SOLUTIONS website and interacting in any way with STRIX SOLUTIONS, you warrant that (i) if you are in Romania, you are at least 18 years of age, or if you are in any other country, you are over the age defined for “children” in accordance with the applicable laws of your jurisdiction and (ii) you have the full exercise capacity to become subject to this Privacy Policy and engage in commercials and legal relations with STRIX SOLUTIONS. If you are under 18, please read the terms of this Privacy Policy carefully with your parents or legal guardians. STRIX SOLUTIONS services are not directed or intended for children as defined by applicable law, and we do not collect or request information from children. If we get real knowledge of the fact that a user is considered a child in accordance with the applicable law, we will take steps to immediately delete the person’s personal information.

14. How do we protect your data?

In order to ensure that your rights and freedoms are not jeopardized and that compliance with relevant data protection laws and regulations is complied with, we implement appropriate technical and organizational measures to ensure a sufficient level of security for the processing of personal data. These measures consist of training and regular testing of our employees and, if applicable, our subcontractors in the introduction of relevant policies and processes, which are regularly reviewed and updated under the supervision of our existing data protection consultant. We also ensure that we carefully evaluate our service providers to provide you with an appropriate level of protection of your personal data and conclude personal data processing agreements to ensure that each subcontractor who comes in contact under our authority and your personal data, performs contracted processing activities in complete safety and comply with the provisions of the legislation in force in the field of personal data processing.

  1. Updates

Our Privacy Policy may be changed from time to time (in general, to comply with data protection laws and practices). Updated versions will be published on our website.

DATA RETENTION (STORAGE) POLICY

  1. Personal data operator

The operator of the personal data obtained from or granted by the company’s clients is: 

S.C. STRIX SOLUTIONS S.R.L.

Registered office address: Bucharest, 5th Heleșteului Street, postal code 011985, 1st District, Romania;

You can contact us through:

E-mail: dpo@strix.solutions  

Telephone: +40 743 578 156​ (normal rate call)  

  1. Requests regarding the Data Retention (Storage) Policy

The present policy is applicable to our clients (legal persons) and to individuals (natural persons) from which we directly obtain personal data in as specified in the articles 2, 3 and 4 from the Privacy Policy.

To the extent that you have requests or questions about the retention period of your personal data within STRIX SOLUTIONS, please contact us using the above-mentioned email address or phone number.

  1. Storage Policy

The STRIX SOLUTIONS retention policy is an internal guideline that includes the general and specific requirements regarding the accuracy and storage limitation principles of the personal data under the General Data Protection (GDPR), the relevant provisions and practices in respect of the personal data we collect and we strictly comply with these principles. This policy encompasses the principle of storage limitation, which requires retention of the personal data processed only for the time required in consideration of the purpose for which such data was obtained. The data retention (storage) policy is primarily intended as a favourable resource to the company’s activity that will allocate relevant retention periods in important business areas and in case the law doesn’t impose precise retention period, the company may be allowed to remove or delete in a consistent and controlled manner personal data that it no longer uses or is considered to be out of date.

  1. Retention (storage) periods

The personal data storage periods are specified in the table below and apply to all formats of storage, i.e. both paper and electronic files, unless otherwise specified in the present policy.

DEPARTMENT
PROCESSING ACTIVITIES
RETENTION PERIOD
NATURAL PERSONS (INDIVIDUALS) DATA PROCESSING
Image collected by means of the video camera incorporated in the STRIX SOLUTIONS product which records the image of the individual present in a super-market, a store, shop, etc.
24 hours form recording;
NOTIFICATIONS SENT BY STRIX SOLUTIONS
Notifications SENT by STRIX SOLUTIONS directly or through its contractual partners (invoices, notice of non-payment, etc.)
3 years from the date of transmission of each notification
RELATIONS WITH SUPPLIERS
Contracts concluded by the company with suppliers
10 years from the date of contract’s termination
RELATIONS WITH CONTRACTUAL PARTNERS
Service Supply Agreement
10 years from the date of contract’s termination
RELATIONS WITH THE REPRESENTATIVES OF THE CONTRACTUAL PARTNERS (CLIENTS)
Phone calls
We do not record / store phone calls
RELATIONS WITH THE REPRESENTATIVES OF THE CONTRACTUAL PARTNERS (CLIENTS)
Business cards collected at organized events
1 year from the date of receipt of the business card, if the contract is no longer valid
BUSINESS RELATIONS (B2B)
Personal data such as: name, position/function, and contact details of the representatives of our clients
Until we receive an official request for the deletion of the data or the at the date, we have learned that the personal data became inactive or outdated. We will not delete such personal data if it is part of a signed contract enclosed with our company.

For information on the storage periods of personal data processing activities within the company that are not covered by this Policy, please send your requests to the above-mentioned email address or by accessing other means of communication made available under art. 1 and having regard to the conditions stipulated in art. 2.

5.  Retention plan

The storage period is applied by default to all entries in that category and will be respected whenever possible, although we admit that there may be exceptional circumstances requiring the retention of documents for either shorter or longer periods. If entries or individual documents require a different retention period, STRIX SOLUTIONS should be contacted to discuss specific storage requirements.

6.Data deletion

You may request the deletion of personal data to the extent that we hold these data at the time of submitting the request by sending an email to dpo@strix.solutions in which you need to specify the following:

– Your contact details for sending our response/point of view;

– Your name;

– Processing activities through which data was collected or processed (data recorded by the video camera, the conclusion of a contract, the transmission of a written request by post, e-mail or by phone call, etc.);

– The type of collected or processed data that you want to delete;

– Total number of entries to be deleted if such information is available to you.

The deadline for replying to your request is one month (conventionally we will consider 30 days) from the receiving date of the request.

To the extent that your request will be solved by deleting your data, after we will make an assessment of the request, we will prepare a standardized document that will be sent to your attention through the agreed means of communication. The document shall include at least the following information:

– Purpose(s) for which the data were obtained (processed);

– Data that was transferred/deleted/removed/destroyed, and the processing activity performed by STRIX SOLUTIONS;

– Number of entries removed. 

The hardcopy of our point of view is signed STRIX SOLUTIONS’ representative and is stored and scanned in physical format for a period of 3 years from the sending date of the notification, after which the original document (paper format) will be destroyed and recycled. If our answer will be sent by email, it will be stored in the company’s servers for a period of 3 years from the submission date to the applicant at the email address provided, and then deleted.

If you submit a request to STRIX SOLUTIONS for access to the processing of your personal data in our company, please be aware that due to the processing of your personal data and taking into account the routine established in our systems for deleting the personal data according with the Retention Policy terms. Thus, this routine processing may involve modifying or deleting certain personal information we process at the date you submitted the request to us. In this case, STRIX SOLUTIONS will provide information about the personal data held at the time we send the response to you, even if the data is different from the personal data we stored at the submission date of the request. Please note that deleting or transmitting your personal data is a procedure that STRIX SOLUTIONS would have performed even if you had not submitted the request.

7.Continuous development 

The retention (storage) periods will be maintained by STRIX SOLUTIONS, which will make modifications, additions and updates, whenever the legislation, the guidelines or decisions of the National Supervisory Authority for Personal Data Processing or the organizational or structural modifications of STRIX SOLUTIONS impose these changes.

8.Updates

Our data retention policy may be changed from time to time (generally to comply with data protection and processing laws and practices). Updated versions will be published on our website.