1. Purpose of this privacy notice

This Privacy Notice explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal data. This Privacy Notice also sets out your rights in respect of our processing of your personal data.

When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specfic to them, such as their physical appearance.

This Privacy Notice informs you of the nature of the personal data about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it.

This Privacy Notice is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it. It should be read in conjunction with our Cookie Policy.

This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links to third party websites over which we have no control, or you purchase goods or services from those third parties).

2. About us

The Site and our Services are made available by ARQUERY (“ARUQERY”, “we”, “us, “our”). ARQUERY is the data controller responsible for your personal data.

ARQUERY is a Romanian company with its registered office at ADDRESS 28 Regina Elisabeta, A 31, 3rd Floor, Bucharest, Romania.

3. How to contact us

If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, you can contact us by:

• • sending an email to support@arquery.com

4. How we collect and receive personal data

We collect and receive personal data using different methods:

• • Personal data you provide to us

You may give us your personal data directly. This will be the case when, for example, you contact us with enquiries or complete forms on our Site, subscribe to receive our marketing communications or provide feedback to us.

• • Personal data we collect using cookies and other similar technologies

When you access and use our Site, we will collect certain technical information about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies (see the “Our use of cookies” section below).

5. Who we collect personal data about

We collect and process personal data from the following people:

• • Site visitors

If you browse our Site, register for updates on our Site, contact us with an enquiry through our Site, submit a complaint through our Site or use any Services available on our Site, we will collect and process your personal data in connection with your interaction with us and our Site.

• • Customers

If you buy products or services from us, we may collect and process your personal data in connection with the supply of goods or services to you.

6. Personal data we collect

We use your personal data for the following purposes:

• • Fulfilment of our Services

We collect and maintain personal data that you submit to us for the purpose of supplying Services that you have requested from us via our Site or where we contract with you to provide our Services. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organization you represent.

The personal data we process may include your name and contact information (such as email address) and your payment information (where applicable). We process this information so that we can fulfil the supply of Services, maintain our user databases and to keep a record of how our Services are being used.

• • Linking to social media sites and interacting with our social media pages

If you click on one of the social media links on our Site or otherwise interact with our social media pages such as on Facebook or Instagram (including interacting with any ‘like’ or similar embedded features on our Site or social media accounts) we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose. For more information about how we use this personal data, please see the Insight and Analysis section below.

Please note that we are a joint controller with the relevant social media platform in respect of the personal data we use which is collected via your use of our social media pages. Your personal data may be used by the relevant social media platform for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy policy of the relevant social media platform. 

• • Customer service and general enquiries

Our Site feature a “Contact us” page which invites you to submit general enquiries about our Site and our Services by email, telephone or post.

When you make an enquiry, we will collect and process your name, contact information (including email address and/or telephone number) and any other personal data that is relevant to your enquiry. We use this information to manage and respond to your enquiry.

• • Email marketing activities

We use your name and email address to send you (or the organization you represent) marketing communications by email. Our email marketing communications will include press releases, information, thought pieces, articles and details for events, as well as general information about our organization, our Site, our US offices, the Services we provide and the events and promotions we offer.

We may share your personal information with a variety of this party email or text message marketing providers (including MailChimp) who assist us in delivering our email marketing campaigns, newsletters and other mass emails.

• • Recruitment

We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you. We also use your personal data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.

We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us.

The personal data we process may include your name and contact information (including your email address, postal address and telephone number), details of your education, qualifications and employment history, any other personal data which appears in your curriculum vitae or application, any personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive.

We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.

• • Any other purposes for which we wish to use your personal data that are not listed above, or any other changes we propose to make to the existing purposes, will be notified to you using the contact details we hold for you.

7. If you fail to provide your personal data

Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.

8. How we obtain your consent

Where our use of your personal data requires consent, you can provide or withdraw such consent:

• • at the time we collect your personal data following the instructions provided; or
• • by informing us using the contact details set out in the “Contact us” section above.

9. Our use of cookies and similar technologies

Our Site may use certain cookies, web beacons, pixel tags, log files and other technologies. Please see our Cookie Policy to find out more about the cookies and other similar technologies we use, the purposes for which we use them and how to manage, block or delete them.

10. Third party links and services

This Privacy Notice does not apply to your interaction with services provided by third parties.

Our Site may contain links to third party websites and services.

When you use a link to go from our Site to another website (even if you don’t leave our Site) or you request a service from a third party, this Privacy Notice shall not apply to the processing of your personal data carried out by the relevant third party provider.

Your browsing and interactions on any other website party service provider, is subject to that website’s or third-party service provider’s own rules and policies. For example, our website invites you to view videos on platforms such as YouTube. When you click on the links we provide to such platforms, you will be transferred from our website to that platform, or your dealings with any other third ant platform and the privacy notice (and other terms and conditions) of that platform will apply to you.

We do not monitor, control or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you use in connection with your interaction with us and to contact them if you have any questions about their respective privacy notices and practices.

This Privacy Notice applies solely to personal data processed by us through your use of our Site, your receipt of our Services and/or in connection with our business operations. It does not apply to the processing of your personal data by these third-party websites and third-party service providers.

11. Sharing personal data

We will only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations. 

When processing your personal data, we may need to share it with third parties (including other entities within our group of companies) as follows:

• • Payment providers and banks: We share personal data with third parties who assist us with the processing of payments and refunds.
• • Law enforcement or other government and regulatory agencies and bodies: We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.

13. How long we keep your personal data

In respect of personal data that we process in connection with the supply of our Services, we may retain your personal data for up to six years from the date of supply of the relevant Services and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.

In respect of any other personal data that we process, we will retain relevant personal data for up to three years from the date of our last interaction with you and in compliance with our data protect obligations. We may then destroy such files without further notice or liability.

If any personal data is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we will not retain it for longer than the period for which it is used by us.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future.

14. Confidentiality and security of your personal data

We are committed to keeping the personal data you provide to us secure and we will take reasonable precautions to protect your personal data from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from:

• • unauthorized access;
• • improper use or disclosure;
• • unauthorized modification; and
• • unlawful destruction or accidental loss.

All our employees and data processors (i.e. those who process your personal data on our behalf, for the purposes listed above) who have access to and are associated with the processing of personal data are obliged to respect the confidentiality of the personal data of all users of our Site and our Services.

15. How to access your information and your other rights

You have the following rights in relation to the personal data we hold about you. If you would like to exercise any of these rights, please contact us using the details set out in on our Contact page.

• • Your right of access

If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.

• • Your right to rectification

If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them directly.

• • Your right to erasure

You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.

• • Your right to restrict processing

You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

• • Your right to data portability

You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.

• • Your right to object

You can ask us to stop processing your personal data, and we will do so, if we are:

• – relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or
• – processing your personal data for the purposes direct marketing.
• • Your rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.

• • Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “Contact” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.

• • Your right to lodge a complaint with the supervisory authority

If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “Contact us” section above. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. As we are incorporated in Romania, our regulatory authority is https://www.dataprotection.ro/.

16. Changes to this privacy notice

We may make changes to this Privacy Notice from time to time

To ensure that you are always aware of how we use your personal data, we will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data. We may also make changes to comply with changes in applicable law or regulatory requirements.

We will notify you by e-mail of any significant changes to this Privacy Policy. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal data.

Last updated 07.09.2020