These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.
Media Kompass S.R.L. will only collect the minimum of information required for providing the respective service.
Why this policy exists:
This data protection policy ensures Media Kompass S.R.L.:
- Complies with data protection law and follows good practices
- Protects the rights of staff, customers and partners and other individuals
- Is open about how it stores and processes individuals’ data
- Protects itself from the risks of a data breach
We are committed to protecting your privacy online and offline and we explain below how we collect information, what we do with it and what controls you have over it.
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our services and the choices you have associated with that data.
We use your data to provide and improve our services. By using our services, you agree to the collection and use of information in accordance with this policy.
This policy applies to:
The head office of Media Kompass S.R.L.
All staff of Media Kompass S.R.L.
All contractors, suppliers and other people working on behalf of Media Kompass S.R.L.
It applies to all data that the company holds relating to identifiable individuals. This can include:
Names of individuals
and any other information relating to individuals
Everyone who works for or with Media Kompass S.R.L. has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
However, these people have key areas of responsibility:
The management is ultimately responsible for ensuring that Media Kompass S.R.L. meets its legal obligations.
Media Kompass S.R.L.’s clients may also process the personal data provided to them through our services for their own requirements. Where the client processes the personal data for its own purposes, such processing is carried out under the client’s sole responsibility and shall be governed by the privacy practices of that client. For any processing of this nature carried out by the client, the client shall be the data controller of such personal data and Media Kompass S.R.L. will be the processor. Media Kompass has data protection agreements in place with each client we provide personal data processing services to.
The data protection officer is responsible for:
Keeping the management updated about data protection responsibilities, risks and issues.
Reviewing all data protection procedures and related policies, in line with an agreed schedule.
Arranging data protection training and advice for the people covered by this policy.
Handling data protection questions from staff and anyone else covered by this policy.
Dealing with requests from individuals to see the data Media Kompass S.R.L. holds about them (also called ‘subject access requests’),
Checking any contracts or agreements with third parties that may handle the company’s sensitive data.
The IT manager is responsible for:
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards,
- Performing regular checks and scans to ensure security hardware and software is functioning properly,
- Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
The General Manager is responsible for:
- Approving any data protection statements attached to communications such as emails and letters,
- Addressing any data protection queries from journalists or media outlets like newspapers,
- Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
General staff guidelines
- The only people able to access data covered by this policy should be those who need it for their work.
- Data should not be shared informally. When access to confidential information is required, employees can request it from their managers.
- Media Kompass S.R.L. will provide training to all employees to help them understand their responsibilities when handling data.
Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
- In particular, strong passwords must be used and they should never be shared.
- Personal data should not be disclosed to unauthorised people, either within the company or externally.
- Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
- Employees should request help from their manager or the data protection officer if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager, data controller or data protection officer.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
- When not required, the paper or files should be kept in a locked drawer or filing cabinet.
- Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
- Data printouts should be shredded and disposed of securely when no longer required.
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
- Data should be protected by strong passwords that are changed regularly and never shared between employees.
- If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
- Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
- Servers containing personal data should be sited in a secure location, away from general office space.
- Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures. The use of cloud services and data centres will ensure automatic backups where possible.
- All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to Media Kompass S.R.L. unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
- When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
- Personal data should not be shared informally.
- Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
- Personal data should never be transferred outside of the European Economic Area, unless required by law.
Always access and update the central copy of any data.
Media Kompass S.R.L. will take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort Media Kompass S.R.L. should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
- Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
- Staff should take every opportunity to ensure data is updated.
- Media Kompass S.R.L. will make it easy for data subjects to update the information Media Kompass S.R.L. holds about them.
- Data should be updated as inaccuracies are discovered.
Subject access requests
All individuals who are the subject of personal data held by Media Kompass S.R.L. are entitled to:
- Ask what information the company holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed how the company is meeting its data protection obligations.
If an individual contacts the company requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the data controller at their email address. The data controller can supply a standard request form, although individuals do not have to use this.
Individuals will not be charged for the first subject access request. The data controller will aim to provide the relevant data within 30 days.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.
Disclosing data for other reasons
In certain circumstances, the General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Media Kompass S.R.L. will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the management and from the company’s legal advisers where necessary.
Media Kompass S.R.L. aims to ensure that individuals are aware that their data is being processed, and that they understand:
- How the data is being used
- How to exercise their rights
Information Collection and Use for the Media Kompass website
We collect several different types of information for various purposes to provide and improve our services to you.
Types of Data Collected:
Personal Data – when filling out the contact form or browsing
While using our services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
First name and last name
Cookies and Usage Data
We may also collect information how our services are accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking & Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our website.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website.
Examples of Cookies we use:
Session Cookies. We use Session Cookies to operate our website.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.
Use of Data
Media Kompass S.R.L. uses the collected data for various purposes:
To provide and maintain our services
To notify you about changes to our services
To allow you to participate in interactive features of our services when you choose to do so
To provide customer care and support
To provide analysis or valuable information so that we can improve our services
To monitor the usage of our services
To detect, prevent and address technical issues
Transfer of Data
Your information, including Personal Data, will not be transferred to a third party or outside Romania without your previous consent.
If you are located outside Romania and choose to provide information to us, please note that we transfer the data, including Personal Data, to Romania and process it here.
Disclosure of Data
Media Kompass S.R.L. may only disclose your Personal Data in the good faith belief that such action is necessary to:
To comply with a legal obligation
To protect and defend the rights or property of Media Kompass S.R.L.
To prevent or investigate possible wrongdoing in connection with our services
To protect the personal safety of users of our services or the public
To protect against legal liability
How can You access/correct/delete your personal data?
In accordance with the applicable Data Protection Laws, you have the right to request access to a copy of your personal data, or to request that your personal data be rectified, or updated, or entirely removed. You may also object to the processing of your personal data by us for legitimate reasons. On request, we will provide you with a copy of this information. Please contact us at the following address if you wish to receive a copy of your personal data held by us: firstname.lastname@example.org
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our services do not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.