The confidentiality and protection of your personal data is one of our commitments at 4ENVIGO SRL, a Romanian legal entity, with registered office located in the municipality of Bucharest, district 1, Rotașului street no. 14, building B3, entrance 2, 1^st floor 1, apartment 3212, room 1, registered in the Trade Register under no. J40/2208/2023, having unique registration code 47587859, hereinafter referred to as 4Envigo.

Therefore, we strive to process your personal data in accordance with the principles defined in the data protection legislation applicable in Romania, including Regulation (EU) 2016/679 on the protection of natural persons regarding the processing of personal data and on the free movement of such data (” GDPR „). Terms used in this privacy policy that are not defined shall have the meaning given by the GDPR.

Personal data is any information relating to an identified or identifiable natural person. An identifiable person is that person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more specific physical, psychological, mental, economic, cultural or social identity factors.

This privacy policy and protection of personal data concerns the data of our clients, business partners, other people who contact us, as well as their representatives, potential employees, collaborators, etc. and applies to data collected through our website, www.4Envigo.com, hereinafter referred to as the „Website „, as well as all other personal data collected by e-mail or other offline contacts.

The Privacy and Personal Data Protection Policy describes:

• the purposes for which we collect and use your personal data;
• the reasons for processing the data for these purposes;
• the categories of personal data we process;
• the duration of the processing of this data;
• your rights as data subjects and how you can exercise them;
• to whom we may disclose personal data,

information that we hope to convey to you in a transparent and easy-to-read manner so that you understand what we want to communicate to you.

You will also learn how to contact us if you have any questions about your personal data, which we will be happy to answer. Please also read our cookie policy, where you will find out how 4Envigo uses cookies and other similar technologies.

1.The purposes, grounds of processing and categories of processed personal data

In the context of the interaction with 4Envigo, we can subject you – as a natural person – to the data processing activities that we carry out. Therefore, we use your personal data in the following cases:

1.1.If you are the representative or contact person, employee or other collaborator of a customer or potential customer of 4Envigo or a business partner of 4Envigo

a.Provision of Services

We use your relevant personal data to prepare and provide the Services requested from us. We rely in this case on the legitimate interest in the provision of the Services and the execution of the contract.

b.Communication with you

We use the contact details you provide us to communicate with you in relation to your requests and any other relevant aspects of the business relationship. Also, in this case, we rely on the legitimate interest of providing our services in our field of activity and in managing the relationship with our customers as the basis of the processing of personal data.

c.Data processing as required by law in general and in relation to our obligations as a service provider in particular

We may process some of your personal data in the context of providing the Services based on the legal obligations that govern the activity of service providers. In this case, the reasons for the processing relate to the legal obligation we have.

d.Sending promotional offers and packages, news about 4Envigo services and products

We may also use your contact details to provide you in the form of your choice (electronically via e-mail, SMS, on paper) – our offers and other information or seasonal news about our services and products, its promotions 4Envigo, but only if you have expressly requested such a service and therefore expressed your explicit consent beforehand for such processing of your data. You can withdraw your consent at any time by opting out of receiving such information in the following ways:

1. Email to dpo@4Envigo.com 
2. Letter with confirmation of receipt sent to the address in Bucharest, sector 1, Anton Pavlovici Cehov no. 2, Tanora building, 3rd floor, office no. 8.

In all cases, the data is provided either directly by you or by the client/partner. The categories of data processed in the context of our relationship with you are your name, surname, e-mail address, telephone, fax, position within the company, as well as other personal data provided to 4Envigo, usually by you, as is necessary for the fulfillment of the above purposes.

1.2.If you are applying for a job/internship

We use the personal data contained in the CVs we receive to assess the qualifications of applicants for a position within 4Envigo, including for a position within our internship programs. We base the processing of personal data on your consent expressed once with the transmission of the CV and, subsequently, based on the conclusion and execution of the individual employment contract.

The categories of data processed in the context of our relationship with you are name, surname, e-mail address, telephone, fax, address, personal data included in CVs, details of education and training, professional qualifications, as well as other personal data on which you could provide directly to us.

1.3.Information we collect automatically. Cookies

By visiting the web page www. 4Envigo .com may automatically collect certain information through cookies. Please read the Cookie Policy

1.4.Information we collect from third parties

We may also receive your personal data through other sources, even if you do not provide it to us directly, from third parties who have the right or legal obligation to share your data with us. These may include business partners and public authorities. When you use or benefit from some of the 4Envigo Services, you provide details to our business partners, who forward your details to us.

1.5.Processing for other purposes

We do not process your personal data for secondary purposes other than those for which it was originally collected, without prior consent, without a legitimate interest or without a legal basis.

2.Do we disclose your personal data to third parties?

In certain circumstances, we will share personal data with third parties:

• Third party service providers – we may use service providers to process your personal data on our behalf. We assure you that we have signed personal data processing agreements and confidentiality clauses with all third party service providers in order to protect them and we do not allow them to use them for other purposes.
• Competent authorities – in the case of requests based on legal provisions, we provide your data to the competent authorities, when this is strictly necessary for the detection of fraud, criminal acts and, in general, when the legal provisions require us to comply with such a requirement.
• When you expressly ask us to do so or expressly authorize us to disclose your data.
• In case of urgent situations or cases of force majeure.
• If disclosure is necessary to resolve disputes, to ascertain or exercise a right in court.

We assure you that we do not transfer or sell your personal data to any other entity, natural or legal person.

3.HOW LONG DO WE KEEP PERSONAL DATA?

We limit the storage period of your personal data to what is necessary for the processing purposes that have been brought to your attention.

We are reviewing the need to continue to retain your personal data. Every 2 years we analyze the data collected and processed, in order to filter, sort and maintain the processing only for the data in which the purpose of the processing is current. If the periodic review shows that you have not used the Services in the last two years, 4Envigo will send you an email to reactivate the business connection. If you do not respond to 4Envigo’s request, we will proceed to delete both the processed personal data.

Regardless of your connection with 4Envigo or with our customers/suppliers/collaborators, we will delete your personal data immediately, as a result of a request sent by you, with the exception of data whose processing/supply is required by a legal provision, in which case the duration of retention will be that stipulated in the applicable mandatory legislation .

At the same time, it is possible to keep personal data in the case of establishing, exercising or defending a right in court.

If the retention of your personal data is required for purposes specified by law, we may continue to retain this data.

4.How do we ensure the security of personal data? Are these Safe?

We want to keep your personal data safe by implementing appropriate technical and organizational measures.

In accordance with applicable law, we have defined and use internal procedures to prevent unauthorized access and improper use of personal data.

We use appropriate systems and procedures to protect and secure personal data, in particular to prevent unauthorized/illegal processing, accidental or unlawful loss, accidental or unlawful destruction.

We have implemented measures to prevent and/or discover security breaches, document security incidents, data affected by such incidents, remediate security incidents, recover personal data.

We have also implemented measures and procedures to comply with our obligations under applicable law in the event of a security incident, including our obligations to notify the competent supervisory authority and to notify and inform you, as appropriate.

In the case of our employees, contractors, suppliers and 4Envigo collaborators, we limit and restrict their access to the personal data we process, to what is strictly necessary, on the one hand, and on the other, imposing strict confidentiality obligations.

We have also implemented and run a policy of continuous training of our staff in connection with the processing of personal data.

Annually, we conduct an audit of the management system in order to improve the protection and security of the personal data we process.

5.Do we transfer personal data outside the EU or EEA?

We do not transfer your personal data to countries outside the European Economic Area or to international organizations.

6.How can you control your personal data? What are your rights?

As a data subject, the GDPR offers you a number of rights, including:

1. To access the data : you can obtain information about the processing of your personal data and a copy of this personal data.
2. To rectify the data : if you consider that your personal data is inaccurate or incomplete, you can request the corresponding modification of this personal data.
3. To obtain data deletion : you can request the deletion of your personal data, to the extent provided by law.
4. To restrict processing : you can request the restriction of the processing of your personal data.
5. To object to the processing : you can contest the processing of your personal data, for reasons related to your particular situation.
6. Data portability : You have the right to request that the personal data you have provided to us be returned to you or, if possible, transferred to a third party.

We are happy to provide you with all our competition for the exercise of these rights.

You can exercise these aforementioned rights and learn more about them by submitting a written request to us, as a data controller, at: 4Envigo SRL, Bucharest, sector 1, Anton Pavlovici Cehov no. 2, Tanora building, 3rd floor, office no. 8, or by e-mail at dpo@ 4Envigo.com. You also have the right to file a complaint with the National Supervisory Authority for Personal Data Protection (ANSPDCP) [http://dataprotection.ro/].

All Requests will be treated seriously and will receive a response from 4Envigo, even if unfounded. The answer will be adapted according to the measures taken, and if the request cannot be complied with, the refusal will be motivated.

4Envigo will not charge any fee or other material benefit for the exercise of the rights conferred by the GDPR. The exception will be repetitive or excessive requests, in which case we may charge a reasonable amount, but we will inform you of this before resolving the request.

The response to requests will be sent within a maximum of 30 days from its receipt. If the complexity or volume of information requires more time, we will communicate this to you within 30 days, and the actual response will be communicated within a maximum of 60 days.

If the request concerns personal data for which 4Envigo has the capacity of authorized person, that request will be sent within 3 working days to the operator responsible for that processing. Under no circumstances will 4Envigo respond to the data subjects in situations where it acts as an authorized person, but it will assist in the formulation of the answer, if the operator requests it and will do all the diligence for the answer to reach the data subject.

Do not provide your personal data to 4Envigo through other communication channels, except as mentioned in this policy, namely by email to office@4Envigo.com, regardless of the person or company that would request it on our behalf, including employees or former employees of 4Envigo that you previously knew. Personal data transmitted through any other communication channels except those mentioned in the policy to any third party, for any purpose, do not fall under the responsibility of 4Envigo, the latter being unable to ensure their security. In this regard, we recommend that you carefully study the privacy policies of such third parties.

8.Who is responsible for processing personal data? Contact.

4Envigo controls the processing of personal data, being the data operator. For any kind of questions or ambiguities in connection with this policy or in connection with the processing of personal data, please write to us at: dpo@4Envigo.com

This privacy policy is effective as of [ 04/07/2023]. It may undergo further changes. Any kind of updates come into force on the date of their publication on the website www.4Envigo.com.

Through any subsequent changes and updates to this policy, we undertake not to affect in any way your rights mentioned in this version. If such changes could have a direct or indirect major impact on your rights in relation to your personal data, we undertake to explicitly inform you of this and request your consent, if necessary, in accordance with the applicable legal provisions.

In any case, all subsequent changes will be presented on this page, and if they are significant, we will highlight them. Also, all versions of this privacy policy are kept in the 4Envigo archive for reference.