Introduction

Footprints for Retail SRL or its Affiliates (“Affiliated Company” shall mean any legal entity, which: (i) is Controlled by Footprints for Retail SRL; or (ii) Controls Footprints for Retail SRL; or (iii) is under common Control with Footprints for Retail SRL. For this purpose, “Control” means that more than fifty percent (50%) of the controlled entity’s shares or ownership interest representing the right to make decisions for such entity are owned or controlled, directly or indirectly, by the controlling entity. A legal entity is considered an Affiliated Company only for as long as such ownership or control exists.) is a limited liability company specialized in using the science of marketing automation with the power of indoor location intelligence. Footprints for Retail is the next generation Marketing Cloud that integrates all offline data-driven marketing needs into one platform (referred to as “Footprints for Retail”).

This Privacy Policy on Personal Data Processing (referred to as “Privacy Policy”) concern the personal data processing carried out by Footprints for Retail on our website. The Privacy Policy is applicable to personal data processing we carry out through our website, as well as to all interactions with our website hosted on the domain footprintsforretail.com. For the avoidance of doubt, it should be outlined that this Privacy Policy does not concern the processes performed due to our products or services.

Name of the data controller and of the website owner

Footprints for Retail is a personal data controller and the owner of the website accessible at the following web address: www.footprintsforretail.com.

Our business

At Footprints for Retail, we use creative technologies for engagement purposes and we are looking to synchronize the multi-channel environment in order to boost traffic and referrals. In addition to our services, in order to further our current business relationships and develop future relationships, we produce personalized emails, alerts, notifications and newsletters, reviews, and other information materials, both with respect to our areas of expertise and to our professional activity (jointly referred to as “Information Service”).

Personal data processed for the performance of the contractual relationships with our clients, suppliers and/or other business partners

Personal data we process

In order to conduct the performance of the contractual relationship, we collect the following personal data from you:

  1. basic data for identification purposes, such as surname, name, work place, industry and country of residence and relationship to another person with whom we have an established connection (e.g., with an employee, with another contact or client, with a person who facilitated our connection with you);
  2. contact data, such as the physical work address or email address and phone number;
  3. any data you make available to us during our interactions.

How we collect personal data

We collect the personal data that you provide voluntarily (in electronic format), as well as information and data available from public sources:

– when you contact us via contact forms or email, if you are interested in becoming our client, supplier or business partner.

Legal grounds and purposes of processing

You are entitled to know the purposes for which we process your personal data and we will inform you prior to processing your personal data for other purposes than that for which you disclosed your personal data to us.

Based on the agreement we concluded with you, as client, provider or business partner of Footprints for Retail, we will process all personal data you make available to us, as well as any other data necessary to the performance of our contractual and/or legal obligations. The legal ground of processing is performance of a contract with you or, in case you act as a legal representative or a contact person for a legal entity, on the basis of our legitimate interest.

Personal data processed for professional communication purposes

Personal data we process

The collection of your personal data is strictly limited to what is necessary to provide you with a professional communication. Personal data we process include:

  1. basic data for identification purposes, such as surname, name, work place, industry and country of residence;
  2. contact data, such as the physical work address or email address and phone number;
  3. any data you make available to us during our interactions.

How we collect personal data
We collect the personal data that you provide voluntarily, as well as information and data available from public sources:

– when you contact us via contact forms, if you are interested in our professional communications or express desire to cooperate with us.

Legal grounds and purposes of processing

You are entitled to know the purposes for which we process your personal data and we will inform you prior to processing your personal data for other purposes than that for which you disclosed your personal data to us.

When you subscribe to the Information Service directly, by means of the website, we will ask your consent for the processing of personal data in order to be able to supply those services for which you have requested the subscription. Thus, in such cases, the legal ground for processing of such data is your consent.

Personal data we process

When you apply via the dedicated section on the website, we will limit the processing of your data to what is strictly necessary for the purpose of recruiting.

Personal data we process include:

  1. basic data for identification purposes, such as your full name, email address, phone number and mail address, country of origin, any other data you make available to us by the application documents, which you provide by applying directly on the website;
  2. any data you make available to us during our interactions.

How we collect personal data

We collect the personal data that you provide voluntarily (in electronic format), as well as information and data available from public sources:

– when you contact us via contact forms, if you are interested to be contracted by our company.

Legal grounds and purposes of processing

You are entitled to know the purpose for which we process your personal data and we will inform you prior to processing your personal data for other purposes than that for which you disclosed your personal data to us.

We use personal data only to respond to user inquiries and to schedule possible appointments pertaining to the Footprints for Retail product. 

Use of Cookies

Personal data we process

Our website contains cookies, which collect personal data. The collection of your personal data is strictly limited to what is necessary to provide you with an experience of the highest quality with regard to the use of our website. We collect technical data (including the IP address), such as information on your visits on our website or by accessing materials and communications we send you electronically, your online identifiers, behavior on our website and profiling data.

How we collect personal data

We collect your personal data through our website by cookies tools. The details on the processing of personal data though such tools are available in our Cookie Policy.

Purposes of processing

We use such cookies for the purpose of providing you with a better user-experience when navigating on our website, for analytical purpose in order to better improve our services, as well as for the purpose of providing you with relevant content and advertisements, in accordance with your interests.

Storage duration

If you have chosen to receive communications from the Information Service, we will store your personal data to provide this service for 2 years from your last interaction with our communications. Afterwards, following this period, we will ask again for your consent in order for you to keep benefiting from the Information Service.

If at any moment in time, you decide you do not want to benefit from the Information Service and you withdraw your consent, we will respect your decision and we will stop processing your personal data for this purpose.

We shall delete your other personal data when it is no longer necessary for the purposes for which they have been collected or when you withdraw your consent (if the processing of your data is based on consent), provided that we are not legally required or otherwise permitted to continue to hold such data. We may retain your personal data for an additional period to the extent deletion would require us to overwrite our automated disaster recovery backup systems.

Recipients

As a general rule, we do not share with or transfer your personal data to third parties. If the disclosure or transfer is required or if we are obliged by law, we shall inform you in the shortest possible time with regard to such transfer, unless the applicable law, including the rules of governance for the obligation to maintain professional secrecy, prevents us from sending such notification.

If we disclose or transfer your personal data to third parties, we shall do so according to the applicable laws and take the necessary measures to ensure their integrity and protection.

We transfer your personal data to all entities in our group. The companies in our group are: Fullscreen Digital SRL, Footprints for Retail SRL and Surround IPS SRL. In such cases, these entities will process your personal data for the same purposes and under the same conditions as outlined in this Privacy Policy based on our legitimate interest.

For performing our activity, we use data processors, i.e., Google (for the Drive platform, and for lookalike marketing campaigns), Facebook (for Pixel, excluding custom audiences and custom conversions), Account Capital SRL (for payroll services), HR Consultant (for recruitment services), on our behalf and strictly based on our instructions. We will maintain the control over your personal data and will use appropriate safeguards, as provided under the applicable law, to ensure the integrity and security of your personal data in relation with those processors. We shall conclude agreements for the processing of personal data with all data processors, which will include adequate clauses to ensure that data processors undertake obligations to process personal data (including to delete it) in full agreement with applicable laws and which provide an adequate level of protection to your personal data.

Certain recipients of your personal data, such as Google and Facebook are located in countries for which the European Commission has not issued a decision regarding the provision of an adequate level of data protection, namely: the United States of America. These recipients are certified under the privacy agreement concluded between Europe and USA called “EU-US Privacy Shield”.

Security of personal data

Personal data is secured against threats and we make sure they are protected by appropriate IT infrastructure and security measures. Moreover, we have implemented internal measures that allow us to discover, notify, and document persona data breaches in the shortest possible time.

If we discover any personal data breach that poses a risk for your rights and freedoms, we shall notify the National Supervisory Authority for Personal Data Processing. You will be informed with regard to your personal data breach if it leads to a high risk for your rights and freedoms.

Your rights regarding the processing of personal data

If you expressed your consent with respect to the processing activities, you might withdraw such consent at any time with future effects. Such withdrawal will not affect the legality of the processing prior to the withdrawal of your consent. As a general rule, if you withdraw your consent, we will no longer allow the processing of your personal data and will take any appropriate actions to erase any records containing your personal data. However, if the processing is mandatory for the provision of our services and the processing may be performed on other legal bases stipulated by the applicable legal provisions, we will proceed to such processing and will notify you in this respect.

You have the following rights regarding the processing of your personal data:

  1. The right to access your personal data. You have the right to be informed, upon request, as to whether or not your personal data are being processed, and, where that is the case, to request access to the personal data. The access information includes, inter alia, the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom your personal data have been or will be disclosed. You have the right to obtain a copy of your personal data processed. For any additional copies, we may charge a reasonable fee based on administrative costs.
  2. The right to rectification your personal data. You have the right to have your inaccurate Personal data rectified. Depending on the purposes of the processing, you have the right to have your incomplete Personal data completed, including by means of providing a supplementary statement.
  3. The right to erasure your personal data. You have the right to ask us to erase your personal data.
  4. The right to restriction of processing of personal data. This right is available to you when:
  5. you contest the accuracy of your personal data;
  6. the processing of your personal data is unlawful;
  7. we no longer need your personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims; or
  8. you have objected to processing of your personal data, pending the verification of our legitimate interest ground.
  9. The right to data portability. You have the right to receive your personal data provided to us in a structured, commonly used and machine-readable format and you have the right to transmit those personal data to another entity without hindrance from us.

6. The right to object to the processing of your personal data. You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data. If you have a right to object and you exercise this right, your personal data will no longer be processed for such purposes by us. Exercising this right will not incur any costs.

How can you contact us regarding personal data processing

Should you have any questions related to the processing of your personal data or if you would like to submit a request, as well as to exercise any of the rights on the processing of personal data, please contact us at:

– email address: dpo@footprintsforretail.com

– head office: 114-116 Știrbei Vodă Street, District 1, Bucharest, Romania.

We will review each request and notify you with regard to the undertaken actions in the shortest possible time, but no later than one month since the registration of your request. Should we require more information from you or experience difficulties in the settlement of your request, we shall notify you without delay with regard to the fact that we need additional time to perform a proper review of your request.

Should you consider that we have failed to settle all your requests or are discontent with our answers, you may file a petition with the National Supervisory Authority for Personal Data Processing. You may also refer to the courts of law.

Amendments of the Privacy Policy

If we decide to amend this Privacy Policy, we will publish the new version on our website, which will supersede the current version.

Thank you for trusting us with your personal data and for finding the necessary time to read our Privacy Policy. Please feel free to contact us if you have any questions related to your personal data and our processing of your personal data.