Privacy Statement on Personal Data Processing

Introduction

Footprints for Retail SRL is a limited liability company specialized in Software as a Service technologies that uses offline shopping behavioral models generated by proprietary AI technologies to deliver digital advertising & digital marketing solutions for physical retailers (referred to as “Footprints for Retail”).

This Privacy Statement on Personal Data Processing (referred to as “Privacy Statement”) concern the personal data processing carried out by Footprints for Retail on our website. The Privacy Statement 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 Statement does not concern the processes performed due to our products or services which you can find here.

 

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 behavioral profiling and remarketing technologies for lead generation purposes and we are looking to synchronize the multi-channel environment of our marketing & sales ecosystem in order to boost traffic and conversions. In addition to our services, in order to further our current business relationships and develop future relationships, we produce personalized emails, digital ads, 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 processed for recruitment purposes

You may apply for a position within Footprints for Retail.

We shall use your personal data related to the recruitment process to:

– evaluate whether you are appropriate for a position at Footprints for Retail;

– contact you with regard to your application;

– manage the recruitment process;

– contact you with regard to subsequently vacant positions which we deem suitable for you, and

– keep records of prior recruitment processes of our company in which you participated and of the reasons why you have not been presented with an offer or why our offer has been rejected.

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. other CV related data, such as education, professional experience, competencies, your specialization, and the type of collaboration you want;
  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, if you are interested in becoming employed or 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 collect information necessary in the recruitment process, in order to be able to evaluate if you are appropriate for a position within Footprints for Retail and for the purposes given above in this section. The processing of personal data during the recruitment procedure is legally based on the entering into an employment agreement with you, this processing representing the pre-contractual phase of the performance of the employment agreement.

Also, we will keep records of the persons who have participated in the evaluation procedure and of the reasons for which they did not receive an offer or for which they rejected the offer, based on our legitimate interest, for the purpose of streamlining the recruitment procedure.

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.

For more information with respect to the use of cookies on our website, please visit our Cookie Policy available at https://footprintsforretail.com/cookie-usage-policy/

Personal data processed for testing the Retail Analytics tool purposes

Retail Analytics tool is an application developed by Footprints for Retail using Wi-Fi technology, triangulation and mobile device detection to create analytics built on shopping patterns.

More specifically, Retail Analytics tool is used for the monitoring of individuals which enter the range of a Wi-Fi network, or connect to a Wi-Fi network provided by Footprints for Retail, in order to provide anonymous reports including statistics which helps physical retailers in improving their commercial and marketing decisions (e.g. areas of interest, shoppers’ walking patterns etc.). In this specific case, your personal data is collected during your visits to our offices for purposes of testing the application and determining how it works for research and development purposes. This solution only collects data when you enter a Wi-Fi network area or connect to a Wi-Fi network, collect your data only incidentally, and however, data processing is accompanied by appropriate security measures.

According to art. 22 para. 1 of the GDPR, “the data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her”.

It should be outlined that this processing does not fall under art. 22 of the GDPR, since it does not have any legal effect on the data subjects or it not have does similarly significant affect the data subjects.

Personal data we process

The processed personal data collected during your visits to one of our offices by the means of Retail Analytics tool consist of your MAC address.

How we collect personal data

We collect your personal data through the Retail Analytics tool, as described above.

Legal grounds and purposes of processing

We collect your personal data in the specific case when you visit our offices, only for testing the application and determining how this application works for research and development purposes. Related to this processing, we have our legitimate interest to test the tool.

Personal data processed for the purpose of integrating our SaaS digital marketing solutions with third party applications/solutions

When implementing advertising campaigns in the name and on behalf of our clients, we act in our capacity as data processors. The purpose and means of processing of the personal data are solely determined by our client, and we only act within the limits of the documented instructions received in this respect under the service agreement and under the data processing agreement concluded with each individual client.

In this respect, this section 9 of our Privacy Statement does not constitute a privacy notice for any marketing activities performed by our clients in their capacity as data controllers, but it is only aimed to provide a general overview on the privacy related aspects that the integration of our tools with third party applications/solutions (such as Facebook, Google etc.) entails.

Footprints for Retail has developed its proprietary software for the purpose of providing our clients with an optimum framework to better promote and advertise their products and/or services. By integrating our tools with our clients’ accounts (such as Facebook account, Google account, LinkedIn account, Twitter account), we provide them with an integrated and centralized solution to manage and view all their advertising campaigns (irrespective of how they are implemented), automatize the advertising campaigns and increase the efficiency of each advertising campaign while decreasing the cost of implementation.

Specifically, the integration of our tools with third party applications/solutions enables us to:

  • Automatically synchronize data between an individual’s account (such as Facebook account, Google account etc.) and our tools (g. pixels, tracking codes, emails, telephone numbers etc.), without the need to manually save such data within our platforms. This automation enables us and our clients to create audiences for retargeting purposes, in a much more efficient manner.
  • Export statistical data on the targeted audience segments (classified by gender, age, location etc.) from our clients’ advertiser accounts (g. Facebook, Google etc.) directly into our own platform. By integrating our solutions, these statistical reports generated by such third-party applications/solutions may be saved automatically into our platforms, providing our clients with a centralized overview over all their advertising campaigns.
  • Automatically export statistical data on the performance of our clients’ marketing assets (such as, Facebook pages, websites, mobile apps etc.), as well as any statistical data related to the advertising campaigns implemented by our clients via third party solutions/applications (g. Facebook, Google etc.).
  • Utilize the shopping behavioral patterns as generated by our Retail Analytics technology to enrich the profile data of all contacts within our clients’ database and create predictions related to their future shopping interests which can be used of targeting purposes.
  • Provide centralized control for our clients with respect to each advertising campaign. In this respect, our clients may manage, activate or deactivate any advertising campaigns, in a centralized manner, directly from our tool, without the need to manage each advertising platform individually.

Personal data we process on behalf of our clients

When implementing the advertising campaigns, we may process the following categories of personal data, under the documented instructions of our clients:

  • Personal data which an individual has provided to third parties directly through his/her account (g. Facebook account, Google account), in accordance with their respective privacy policies. The following categories of personal data may be included: age, location, interests, preferences or other categories of personal data which are voluntarily provided by an individual to such third party.
  • Personal data which an individual has provided to our clients, in their capacity as data controllers. The personal data will be processed in accordance with our clients’ privacy policies and for the purposes described therein. At the sole discretion of our clients, the following categories of personal data may be included: name, gender, age, email address, residence, interests, preferences or any other categories of personal data which our client may decide to collect.

How the personal data is collected

The personal data that we process is collected directly from the individuals by our clients or by us at the documented instructions of our clients, via cookies, web-forms or any other means decided by our clients. Moreover, personal data may also be collected indirectly from other entities, such as Facebook or Google, when synchronizing our tools with such platforms, as described above.

Legal grounds and purpose of processing

The personal data collected directly by our clients will be processed on the legal grounds provided in their privacy notice and for the purposes provided therein.

The personal data which we collect from other entities, will be processed on the legal grounds provided in their privacy notices and for the purposes provided therein.

We do not process such personal data for our own purposes. We will only process such personal data in the name and on behalf of our clients, exclusively within the limits of the instructions received from our clients.

Storage duration

If you have chosen to receive communications from the Information Service, we will store your personal data to provide this service for 3 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.

Personal data collected in the recruitment process is stored and used for the purpose of keeping records on past recruitments for a period of 3 years from the date when you applied at Footprints for Retail, unless we concluded an employment agreement, when it will apply the retention period for employees’ file.

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 Statement 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), 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 personal 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:

  • you contest the accuracy of your personal data;
  • the processing of your personal data is unlawful;
  • 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
  • you have objected to processing of your personal data, pending the verification of our legitimate interest ground.

5. 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.

 

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 Statement

If we decide to amend this Privacy Statement, 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 Statement. Please feel free to contact us if you have any questions related to your personal data and our processing of your personal data.