Privacy Policy

Our Strategy and Privacy Policy

This document is protected by copyright. The rightful owner of the information, the company that provides the services of Responsible for the protection of personal data of RUA - ONLINE COUNTRY S.A. reserves all rights to information as a structured way of organizing the text.

This document has a complex legal nature:

The document regarding the structure and organization of the information - RUA - ONLINE COUNTRY S.A. has a right of indefinite use of the text of this version in Romanian, without the Header and Footer sections (“Header” and “Footer”) bearing the author's trademark or without making express reference to the author of this document, even using its own trademarks identification, for personal benefit in order to facilitate the interactions and contractual relations to which it is a party. RUA - ONLINE COUNTRY S.A. notifies you that he is not the owner of this document as a way of structuring the information. Viewed in this matter, the rightful owner of the information reserves all rights in relation to the information contained in this document. It is forbidden to transmit this document in a digital format other than the “.pdf” extension, or in a physical format other than the minimum number of A4 sheets.
Physical document held by the Contracting Parties - may be managed by the Contracting Parties as a physical document only for use in the contractual relationship and for the purpose of proving the contractual relationship with the other Contracting Party or with national or supranational authorities having a valid legal right and necessarily interpreted in the strictest possible objective way; for this purpose it may be copied or transmitted, in whole or in part, containing in any case the section “Copyright. © 2021 ARON SAMU PHD LLM ESQ OÜ. All rights reserved."It is forbidden to send this document in a format other than the “.pdf” extension or in a physical format other than the minimum number of A4 sheets. The information and personal data integrated in the physical document following the completion and signing of the final section requesting the identification of the parties will be managed in the activity flow of the Personal Data Protection Officer of RUA - ONLINE COUNTRY SA, and will be stored by him, on account of Google LLC Email aron.samu@aronsamu.com.

After the disappearance of any circumstances requiring the parties to retain the document in order to exercise their rights or fulfill their contractual obligations or to interact with national or supranational authorities that have a valid and necessary legal right interpreted in the strictest possible objective manner in relation to this document, the parties have the obligation to destroy the physical and / or electronic copies of this document, viewed in both senses, both as a structure and organization of information and as a physical document.

Any unauthorized use, reproduction, alteration, modification, addition or processing is prohibited. For any information or ambiguity regarding the rights relating to this document, the parties are obliged to contact the Owner of the right to information at Google LLC Email aron.samu@aronsamu.com.

The owner of the information and RUA - ONLINE COUNTRY S.A. as the holder of the right of use for an indefinite period of time of the text of this version reserves the right to use all legal means to mitigate and recover damages suffered by the violation of rights.

RUA - ONLINE COUNTRY S.A., a company headquartered in Târgu Mureș, Str. Vulcan Nr. 18, Ap. 1,Jud. Mureș, Postal Code 540074, registered in the Trade Register under number J26 / 513/2021, with fiscal code 43971210, ("RUA - ONLINE COUNTRY") has adopted and currently applies our Strategy and Privacy Policy ("Strategy and Policy") in order to ensure and maintain a level of security of privacy regarding Personal Data that complies with both EU-US Privacy Shield Frameworks and Swiss-US This Strategy and Policy refers to and is applied in connection with issues related to the operation and / or processing of Personal Data involving visitors, users and / or Trade Counterparties that are located within the European Union and / or the Swiss Confederation.

RUA - ONLINE COUNTRY S.A. complies with both EU-U.S. Privacy Shield Frameworks. and Swiss-U.S.A. as established and currently applied by the US Department of Commerce, the European Commission and the Swiss Administration regarding the management and transfer of personal data belonging to visitors, users and / or Trade Counterparties within the European Union, its Member States and Switzerland to the United States in support of transatlantic trade. RUA - ONLINE COUNTRY S.A. hereby certifies that it adheres to the Privacy Principles of both EU-U.S. Privacy Shield Frameworks. and Swiss-U.S.A. on notifications, choices, security issues, data integrity, access, limitations on purposes, applicability, appeals, transfer responsibilities and guilt. In the event of any conflict between the provisions of this Strategy and Privacy Policy and the Principles of Confidentiality established and applied by the EU-U.S.A. Shield Privacy Framework, and / or Swiss-U.S.A., the Privacy Policy of the latter category will prevail as applicable. For more information on both EU-U.S. Privacy Shield Frames, and Swiss-U.S.A. and / or the Privacy Shield Framework Program, and / or to consult our included and active Participation space located within it, you can visit the official .gov website of the Privacy Shield Framework Program.

RUA - ONLINE COUNTRY S.A. hereby formally recognizes the jurisdiction of the Federal Trade Commission (CFC) with respect to matters relating to compliance with both EU-U.S. Privacy Shield Frameworks, and Swiss-U.S.

The entire staff of RUA - ONLINE COUNTRY S.A. who are subject to employment contracts and are involved in personal data management activities deriving from Europe and / or the Swiss Confederation are informed and obliged to adhere to and comply with the provisions of this Strategy and Policy.

We define capitalized concepts under the name of Specific Terms in Section 4 of this Strategy and Policy.

1. APPLICABILITY

This Strategy and Policy extends to and regulates the management and transfer of Personal Data belonging to visitors, users and / or Trade Counterparties with which RUA - ONLINE COUNTRY S.A. gets in touch through its business operations (given that the main location of business activities and the official headquarters of the company are located in Romania, a member country of the European Union) regarding visitors, users and / or Commercial Counterparties resident in the European Union, any of its Member States and / or Switzerland. We make information, products and / or services available to consumers and / or businesses.

This Strategy and Policy also applies to data and / or information that cannot lead to situations in which individuals can be identified, including where pseudonymisation is used. Such pseudonymization may involve the replacement of any personal identifiers with fictitious alternatives in order to ensure the impossibility of identifying individuals.

2. IMPLEMENTATION, APPLICATION, MANAGEMENT AND SUPERVISION

RUA - ONLINE COUNTRY S.A. appointed our organization's executive leadership to implement, implement, manage and oversee our information and data security program, including the aspect of our compliance with both EU-U.S. Privacy Shield Frameworks, and Swiss-U.S.A. belonging to the Privacy Shield Framework Program, including but not limited to our Privacy Strategy and Policy. The executive management will recognize, review and approve any changes of a material nature that involve (even isolated aspects of) our program (s) as needed and / or their reasonableness. Any comments, questions, issues, concerns or complaints regarding our Privacy Strategy and Policy and / or our program may be addressed through any official channel provided for in Section 13 of this document.

We will implement, manage, monitor, test and / or challenge, and update our policies regarding our own information security and data program (including efforts, practices and systems) to ensure the protection of the Personal Data we enter in contact. Our staff who are subject to employment contracts and / or our entities legally involved in any connection with our organization in which we exercise significant control over their business will be prepared and trained, as reasonably appreciated, to adhere to, implement and / or apply our Privacy Strategy and Policy in the most efficient manner reasonably possible. You can learn more about the specific action plan we apply in our efforts to optimally protect personal data under the provisions of Section 8 of this document.

3. REVISIONS, CHECKS AND RENEWALS

RUA - ONLINE COUNTRY S.A. will update and restore both certifications in the EU-U.S. Privacy Shield Frameworks. and Swiss-U.S.A. belonging to the Privacy Shield Framework Program on an annual basis, unless maintaining these certifications becomes mandatory with increasing frequency (in which case we will adhere to stricter regulations) or in the case where our operations, business strategies and compliance requirements the whole regulatory framework requires that such certifications are no longer desirable or in the event that we adhere to, implement and apply a different compliance system with a higher level of strictness regarding the protection and observance of privacy and security standards in benefit the subjects of the USA, the EU and / or the Swiss Confederation.

Prior to applying for and / or obtaining (re) approval our participation in both EU-U.S. Confidentiality Shield Framework certifications. and Swiss-U.S.A. as part of the Privacy Shield Framework Program, we will implement and enforce our own audit to ensure that our statements and practices regarding the management of the Personal Data of Visitors, Users and Business Counterparties are as compliant, accurate and appropriate as possible, and of the fact that our company applies the aforementioned practices in full and consistently in the most appropriate manner reasonably appreciated. Specifically, in our own audit process and procedures, we will undertake the following actions:

Review, properly adapt and keep up to date the nature of our Privacy Strategy and Policy including the version of the document that we will continue to publish throughout our website in order to ensure continued compliance with both EU Privacy Shield Certifications. -US and Swiss-U.S.A. belonging to the Privacy Shield Framework Program regarding the management by us of Personal Data deriving from visitors, users and / or Trade Counterparties.
Ensuring that our Privacy Strategy and Policy is accessible to the public and that it informs and instructs our visitors, users and / or Business Counterparties clearly regarding the involvement of RUA - ONLINE COUNTRY S.A. under both certifications in the EU-U.S. Privacy Shield Framework, and Swiss-U.S.A. belonging to the Privacy Shield Framework Program, and also on the always available option to obtain a copy of the relevant data and / or information (for example to access and receive a transmission of our Privacy Strategy and Policy).
Maintaining the full compliance status of our Privacy Strategy and Policy in relation to the principles pertaining to the Privacy Shield Framework Program.
The guarantee that the visitors, users and / or Commercial Counterparties RUA - ONLINE COUNTRY S.A. have contacted the procedures available to them for initiating comments, questions, problems, concerns or disputes and also with any and all ways of escalating the matter to the attention of dispute resolution structures that present the guarantee covered by the independence (we can accomplish this by visibly displaying information on our public website, and / or any business interaction).
Review, properly adapt and keep up to date the strategies and means of implementation of our own regarding the training of our staff under our employment contracts or our legally involved entities in any connection with our organization in which we exercise significant control over their activity regarding our involvement in and adherence to the Privacy Shield Framework Program and also regarding the appropriate manner of managing the Personal Data of visitors, users and / or Counterparties.

RUA - ONLINE COUNTRY S.A. will implement, issue and apply its own audit document each year of our intentional perpetual participation in both EU-U.S. Privacy Shield Frameworks, and Swiss-U.S.A. belonging to the Privacy Shield Framework Program.

4. DEFINITIONS OF CERTAIN SPECIFIC TERMS

Terms that are presented in capital letters in our Strategy and Privacy Policy are defined below as Specific Terms:

“Commercial Counterparty” and “Commercial Counterparty” designate a client (s) and / or buyer (s) within the European Union or the Swiss Confederation who are involved in a business interaction with RUA - ONLINE COUNTRY SA, also any agents, representatives, or any personnel covered by employment contracts or entities that are in any legal relationship with their organizations or in respect of which they exercise significant control over their business, and also include all of our personnel. subject to employment contracts or entities that are in any legal relationship with our organization or in which case we exercise significant control over their activity in the event that we manage them Personal data in our business interaction with the Counterparty or Trade Counterparties..

“Our staff under employment contracts or entities that are in any legal relationship with our organization in which we exercise significant control over their business” also includes temporary, part-time or part-time employees, contract, independent collaborators, and / or applicants seeking employment within RUA - ONLINE COUNTRY SA or any of its affiliates or subsidiaries, which are at the same time legitimate residents of the countries of the European Economic Area (“EEA”).

“Personal data” means a concept currently delimited by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on free movement of this data and repealing Directive 95/46 / EC (General Data Protection Regulation, “RGPD”, published in the Official Journal of the European Union OJ L 119, 4.5.2016, in the range of pages 1-88) as representing any information relating to an identified or identifiable natural person (“data subject”);an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifying element, such as a name, an identification number, location data, an online identifier, or one or more many specific elements, specific to his physical, physiological, genetic, mental, economic, cultural or social identity or traits of that natural person (including but not limited to identifying information in the process of accessing personal spaces, geographical locations, device information, marital status, information Email, passwords and other identification data, telephone, address and / or contact information in case of emergency, collection of historical information on education or employment or qualifications of visitors, users and / or Business Counterparties). Personal data does not designate information that is anonymized or made public voluntarily by the person who legitimately holds it. It should be noted that with regard to the Swiss Confederation, the term “person” refers to both a natural person / persons and legal entities, without distinction as to the specific way of representing the legal entity in question).

“Sensitive Data” means Personal Data that reveals biometric data, regarding health and / or medical status, photographic or video captures, race or ethnicity, political, religious and / or philosophical affiliations and / or opinions, sexual preferences and / or orientation. , or membership in work-related groups (eg trade unions) of visitors, users and / or Trade Counterparties.

“Third Party Entity” and / or “Third Party Entities” means any legal entity or group of such entities that are outside the framework of RUA - ONLINE COUNTRY SA, personnel under employment contracts or entities that are in any legal relationship with our organization in which we exercise significant control over their activity.

5. PERSONAL DATA MANAGEMENT FRAMEWORK

RUA - ONLINE COUNTRY S.A. provides various final solutions to its visitors, users and / or Business Counterparties that interact with its own business strategy. RUA - ONLINE COUNTRY S.A. manages personal data from these visitors, users and / or Business Counterparties whenever necessary and to the extent necessary in the context of the most aggressive legitimate pursuit of its own business strategy, including but not limited to the circumstance of visitors accessing its website. , that of the users who register within any service and / or within all the services that we offer or parts of them or who access their allocated and secured spaces, that of any of them that transmit Personal Data through interactions our business (for example, they may voluntarily choose to involve our real-time support modules or transmit certain Personal Data in our private business interaction in the secure manner that we allow, make available and manage).

Any part and / or all of the Personal Data that we manage may be as diverse as the behavior of visitors, users and / or Business Counterparties in our business interactions. For general information that could be managed, the following categories are frequently included: information that could facilitate interactions (e.g., name information, email information, phone number information, employment data, and also information financial and / or payment, which may include credit card and / or bank account information). Users and / or Business Counterparties may be assigned personal spaces in our business interaction, including in a real-time support environment. They will be free to transfer any information that we reasonably request and that they deem reasonably appropriate in the context of our business interactions, any management of their Personal Data being deemed to be initiated through their consent, specific and freely expressed in this regard. We reserve the right to unilaterally refuse to provide specific information (or even all of it), products and / or services (or parts thereof) at any time in the event that no mutual agreement is reached on the need and opportunity, an aspect related to the management of information between us on the one hand and our visitors, users and / or our Business Counterparties on the other hand in the context of our own business strategy.

In any circumstance in which visitors, users and / or Commercial Counterparties interact with our business presence on the Internet, we will in almost any case be able to manage their information including the Internet Protocol address (“Internet Protocol”, “IP address”) and / or or features of the browser software. We may manage interactions between the latest categories of information and registered users and / or specifically registered Counterparties.

We will be able to manage data and / or information derived from visitors, users and / or Business Counterparties in order to pursue their most aggressive legitimate business strategy, for example to provide them with information tailored to their behavior and / or the predictability of their behavior. as determined by us managing such data and / or information, and / or for providing and / or securing sales of product (s) and / or services, managing interactions and / or transactions (including resumption respectively, even in a fully or partially automated manner), adherence to certain miscellaneous internal and / or external reporting, billing practices and / or other transactions related to the interactions of visitors, users and / or Counterparties with us.

In case of various information, products and / or services, RUA - ONLINE COUNTRY S.A. could act as a supplier, and in this role could be an operator (controller) and / or processor who manages (including but not limited to operations such as reception, storage and / or processing) Personal data (s) . In any and / or all (such) case (s), we may act as a processor of Personal Data and we will ensure that we process Personal Data legitimately in the interest and in accordance with the instructions of our partner entities and / or or our partner agents (including those belonging to the aforementioned entities). We may manage such Data and / or personal information collected, in order to provide and / or ensure the sale of product (s) and / or services, the management of interactions and / or transactions (including the resumption of such, even in an automated manner in whole or in part), adherence to certain miscellaneous internal and / or external reporting, billing practices and / or other transactions related to the interactions of visitors, users and / or Business Counterparties with us (including compliance with reasonable and legitimate requests, indications and / or the business strategies of our partner entities and / or our partner agents, including those belonging to the aforementioned entities).

RUA - ONLINE COUNTRY S.A. manages personal data that it receives directly from its own visitors, users and / or from its own Business Counterparties and / or from its partner entities and / or its partner agents (including those belonging to the aforementioned entities) directly and / or indirectly in its capacity as data processor and / or operator for the most aggressive pursuit of its business strategy, including (but not limited to) by:

identity checks (for example in connection with the personal digital spaces of users and / or Business Counterparties);
reactions to actions deriving from visitors, users and / or Trade Counterparties;
the maintenance, operation and / or processing of personal data in digital systems located in Romania (Member State of the European Union) and / or other locations (only if they provide adequate protection from the point of view of regulations and / or the business environment in the strictest sense of interpretation of the provisions of the General Regulation of the European Union on the Protection of Personal Data and of both EU-US and Swiss-US Privacy Shield Frameworks belonging to the Privacy Shield Framework Program, for the final purpose of total elimination or little minimization to the greatest extent of any or at least the most extensive liability of RUA - ONLINE COUNTRY SA in accordance with these regulatory frameworks);
management of information, products and / or services, and / or adherence to and compliance with our contractual liabilities with respect to them (including but not limited to transaction management, reporting, invoicing, resumption even in a fully or partially automated manner, and other operations and / or activities in connection with the provision of information, products and / or services to visitors, users and / or Business Counterparties);
related to other legitimate purposes related to its own business strategy (including but not limited to reporting and operations and / or cross-border tax and / or customs activities but not limited to customs duties) that are permitted or required under the framework local (Romanian), other supranational and / or international regulations applicable.

RUA - ONLINE COUNTRY S.A. it always has an opt-in mechanism in the context of its information management. We will not disclose Personal Data to Third Parties in the absence of specific or at least indirect consent from our visitors, users and / or our Business Counterparties provided to us in our business interactions with them and also in that of reasonable business practices interpreted in the most proactive and extensive way possible in any of the business environments in absolutely any kind of connection with our own business strategy.

6. EXTERNAL DISCLOSURES AND / OR TRANSFERS OF PERSONAL DATA

Unless otherwise provided in this framework, RUA - ONLINE COUNTRY S.A. will disclose Personal Data to Third Parties only if they reasonably need to become aware of such information and only to the extent that the scope of the business interaction with RUA - ONLINE COUNTRY S.A. is under discussion, in any case such disclosures will not take place for other reasons. Any and all such subsequent Third Party Entities receiving them must agree to comply with specific confidentiality charges, and at least all RUA - ONLINE COUNTRY S.A. documentation. applicable including indirect references to accession to the provisions of the General Regulation of the European Union on the Protection of Personal Data and of both EU-U.S. Privacy Shield Frameworks, and Swiss-U.S.A. belonging to the Privacy Shield Framework Program.

RUA - ONLINE COUNTRY S.A. could potentially provide information, including but not limited to Personal Data, to Third Party Entities that could act as consultants, contract staff and / or agents (even independent) for the provision, provision and / or management of operations from RUA - ONLINE COUNTRY SA and in accordance with our specific instructions, instructions and / or supervision. For example, RUA - ONLINE COUNTRY S.A. could potentially manage Personal Data in the operations (including systems) of such Third Party Entities. In any such case, Third Party Entities must consent to the management of Personal Data only within the limits of the specific purposes and / or reasons for which they have been involved and / or included by RUA - ONLINE COUNTRY SA, and must at the same time adhere all of the provisions included in this Section below:

to comply with both EU-U.S. Privacy Shield Frameworks. and Swiss-U.S.A. and the principles of the Privacy Shield Framework Program or at least the provisions and principles of another system or mechanism permitted alternatively by the laws and / or regulations in force of the United States of America, the European Union and the Swiss Confederation on data protection (in specific areas of transfers, exchanges, operators' activities and processing in connection with Personal Data);
to comply with the provisions of the framework of the General Regulation of the European Union on the Protection of Personal Data;
and agree to provide compliant protections regarding Personal Data that are at least as strict and provide at least as much protection as those that are established and / or defended through our Privacy Strategy and Policy.

RUA - ONLINE COUNTRY S.A. may also disclose Personal Data for any other reason and / or to other Third Party Entities in any circumstances where visitors, users and / or Business Counterparties have consented to and / or requested such disclosure. Any entity is hereby aware and agrees that RUA - ONLINE COUNTRY S.A. may potentially be required to disclose the Personal Data of visitors, users and / or Business Counterparties in order to legitimately comply with a legitimate mandatory request from the authorities, including but not limited to purposes related to compliance with the specifications, national security and / or defense of the regulatory order.

7. SENSITIVE DATA

RUA - ONLINE COUNTRY S.A. does not solicit and / or collect Sensitive Data from its visitors, users and / or its Counterparties.

8. DATA ACCURACY, INTEGRITY AND SECURITY

RUA - ONLINE COUNTRY S.A. implements a reasonable level of proactive attitude, diligence and efforts to ensure compliance with the integrity, integrity and security of the Personal Data it manages. We constantly adopt and implement updated information, physical and technical protections as they are considered reasonably appropriate to protect personal data in relation to incidents (even partial or tentative in this regard) such as loss, use in other purposes, management for other purposes or cases of unauthorized access, modification, disclosure or destruction. We implement secure network and firewall protection technologies when we manage personal data in electronic environments. In order to access our electronic data systems, we implement user authentication through access data that includes secure passwords or similar methods of secure authentication. We also implement access restrictions, restricting the category of personnel who must be allowed to access the Personal Data of Counterparties in the processes of our business operations (including by ensuring the security of the system that allows such business operations).

In addition, RUA - ONLINE COUNTRY S.A. implements secure encryption technologies in order to protect different types of personal data. With all reasonable precautions and reasonable efforts, we hereby notify visitors, users and Trade Counterparties that a full level of security could not be achieved at any time or at all times, and we strongly recommend them, to research, implement and apply appropriate personal security standards throughout our interactions.

9. OFFICIAL NOTIFICATION

RUA - ONLINE COUNTRY S.A. hereby notifies its Trade Counterparties of its adherence to and compliance with the principles established by the EU-U.S. Privacy Shield Frameworks. and Swiss-U.S.A. through the privacy policy at the level of the organization placed at the disposal of the public access, entitled “Our Strategy and Privacy Policy”, which it published on the Internet - https://www.rua.ro/politica-de-confidentialitate and that it ensures the absolute recognition, agreement and adherence of each Trade Counterparty to this current version of the strategy and policy at any time they initiate a formal interaction with our organization in the business process.

10. PROTECTION IN CONNECTION WITH THE ACCESS AND / OR USE OF PERSONAL DATAL

RUA - ONLINE COUNTRY S.A. staff subject to employment contracts or entities legally involved in any connection with our organization in which we exercise significant control over their activity may access and / or use Personal Data only if they are specifically authorized to act in such ways and only within the limits imposed by the specific authorizations, including those relating to the purpose for which they are authorized to act in those specific ways.

11. RIGHTS TO ACCESS, CORRECT, MODIFY AND / OR DELETE PERSONAL DATA

The Rights to Access, Correct, Modify and / or Delete Personal Data. Visitors, users and / or Business Counterparties enjoy the legal rights to Access, Correct, Modify and / or Delete Personal Data (including but not limited to the knowledge of the information included in the systems and to ensure the conformity and relevance of the information in relation to the purposes and / or the reasons why they were collected for management). Visitors, users and / or Business Counterparties may review their Personal Data that is managed within the systems (including but not limited to databases) and initiate procedures to rectify, delete or even block any part and / or all of it. Personal data, in a legitimate manner that is intrinsically consistent with all relevant RUA specific business policies and agreements - ONLINE COUNTRY SA which we apply at any time. Following contact with a reasonable request, and in accordance with the requirements of the principles of the Privacy Shield Framework Program and those of the regulatory framework of the General Regulation of the European Union on the Protection of Personal Data, RUA - ONLINE COUNTRY S.A. will provide appropriate Access to Personal Data for the purpose of rectifying or modifying information when it proves to be non-compliant. Users and / or Business Counterparties may also modify their Personal Data within the spaces allocated to them, although this will not always result in an automatic deletion of previous information (which we will keep until a specific request for disposal in accordance with the implicit consent or at least the implicit personal interest in the security of the insured space in the event of a potential breach). In any case, in order to exercise their rights to Access, Correct, Modify and / or Delete Personal Data, visitors, users and / or Counterparties must contact us through one of the official channels set out in Section 13 thereof document. The data subjects are legally obliged to provide only compliant, true and complete data and / or information in any interaction with us.
Requests to Access, Correct, Modify and / or Delete Personal Data. RUA - ONLINE COUNTRY S.A. manage each of the following typologies and notify visitors, users, Trade Counterparties and / or other entities legitimately in the following circumstances: (a) the presence of a legitimate request from the data subject; and / or (b) the presence of a legitimate mandatory request for the disclosure of personal data from a regulatory authority.
Compliant settlement of requests regarding Access, Rectification, Modification and / or Deletion of personal Data. RUA - ONLINE COUNTRY S.A. will endeavor to recognize and properly resolve each and all reasonable requests regarding access, rectification, modification and / or deletion or deactivation (including permanent anonymization of) Personal data in a manner and timely resolution interpreted in a manner proactive.

12. CHANGES IN OUR STRATEGY AND POLICY

Our Strategy and Policy may be adjusted from time to time to maintain its compliance with the Principles established by both EU-U.S. Privacy Shield Frameworks, and Swiss-U.S.A. belonging to the Privacy Shield Framework Program and also to the framework and principles of the General Regulation of the European Union on the Protection of Personal Data. We will also inform about and apply the recognition and observance of these Principles through any official communication channel within the entire grouping of our staff under employment contracts or entities legally involved in any connection with our organization in which we exercise a significant control over their activity. We will also make notifications to the attention of our visitors, users and / or our Business Counterparties regarding any updated information that may significantly affect our management of Personal Data (even in the event that management has previously started), while we will offer them the choice to submit their Personal Data to the management in any updated manner producing a relevant impact.

13. COMMENTS, QUESTIONS, PROBLEMS, CONCERNS OR COMPLAINTS

You and / or absolutely any entity can contact RUA - ONLINE COUNTRY S.A. with questions, raise issues or concerns, or file complaints regarding the Terms of Access, Use and / or Interaction in our Business Strategy and Policy and / or any provision or document referred to herein by contacting us:

Trade Counterparty Name:

ARON SAMU PHD LLM ESQ OÜ, by

Name Data Protection Officer in charge of personal data protection:

Dr. Áron Samu, LL.M., Esq.

Address:

Harju maakond, Lasnamäe linnaosa, Sepapaja tn 6, Tallinn, Eesti Vabariik (Estonia), postal code 15551

Cell Phone Number:

0040743773239

00407GDPREADY

Google LLC Email Address:

aron.samu@aronsamu.com

Availability of personnel invested with the protection of personal data: proactive 24/7 (24 hours a day, 7 days a week, in view of the obligations deriving from the legislative framework, the communication being considered to be made on the first national working day following the effective The actual communication of the communication took place on a national day off, the characteristics of working day and day off to be interpreted in accordance with the Romanian legislation applicable to this document in terms of interpretation).

14. CONTROL AND RESOLUTION OF ANY PROBLEMS, CONCERNS OR DISPUTES

In order to ensure our compliance with the EU-U.S. Privacy Shield Framework Principles, and Swiss-U.S., we are committed to resolving complaints regarding your privacy and the ways in which we collect or use your personal information. Visitors, customers and / or Trade Counterparties from the European Union and / or the Swiss Confederation and raise any concerns, concerns or disputes regarding the management of their Personal Data may feel free to contact us through any official channel presented in Section 13 of this document.

In the event that the issues, concerns and / or disputes of visitors, users and / or Business Counterparties in connection with us are not resolved in a satisfactory manner through our subsequent interactions, we hereby declare the action and confirm compliance with the transmission of such cases. unresolved issues relating to confidentiality and / or security that fall under either or both of the EU-US Privacy Shield Frameworks and Swiss-U.S.A. to the independent dispute settlement structures operating under the control of the European Union Supervisory Authorities with responsibilities for the protection of personal data, starting with our national authority which can be contacted through the following official communication channels:

Romanian National Authority: National Authority for the Supervision of Personal Data Processing
Address: 28-30 Magheru Blvd., Sector 1, Bucharest, postal code 010336
Phone: 0040 21 252 5599
Fax: 0040 21 252 5757
Email: anspdcp@dataprotection.ro
Internet page: http://www.dataprotection.ro/
Member Art. 29 WP: President of the National Authority for the Supervision of Personal Data Processing
Alternate Member Art. 29 WP: Representative of the International Relations Bureau

Any such issues, concerns and / or disputes will be brought to the attention of either the United States Department of Commerce and / or the United States Federal Trade Commission in order to provide assurance that any such circumstances of interest to visitors, users or Trade counterparties are processed and resolved accordingly. There is an appropriately assessed timeframe in which circumstances should be resolved. Whenever a circumstance (s) is addressed by the Supervisory Authority with responsibility for the protection of personal data to the attention of the United States of America, the United States Department of Commerce is required to meet a specific deadline for to react. In any case where the Federal Trade Commission of the United States of America is involved, it has assumed priority in the circumstances arising from individually assessed individual entities.

In any case where an appropriate settlement of the circumstances does not take place in accordance with the means listed above, the final remedy will be to refer them on appeal to the attention of an available arbitration body. This recourse in circumstances that are related to national security and involving any entity whose personal data falls within the United States of America will be handled by an Ombudsman independent of the intelligence structures of the United States of America. The specific modalities in which this Ombudsman operates and his independent status will be clarified, in particular issues concerning his independent status and his status in interactions with any other supervisory structures of the regulatory framework that are independent and have authority and jurisdiction over these matters. , throughout the initial phase of the appeal process.

Ultimately, which will be exercised only in special and limited cases, there will be an appeal that could be exercised by the entities of the European Union and the Swiss Confederation and subject to the mandatory arbitration structure of the Confidentiality Shield Panel.

RUA - ONLINE COUNTRY S.A. Finally hereby declares and undertakes in relation to the highest standards of openness, cooperation and compliance in relation to both the Supervisory Authorities with responsibilities for the protection of personal data of the European Union and the Swiss Confederation and to recognize, respect and apply the instructions issued by these Competent Authorities in relation to data and information relating to its staff covered by employment contracts or entities legally involved in any connection with our organization in which we exercise significant control over their activity which are transferred from the European Union and / or the Swiss Confederation in the relevant areas of employment relationships and / or other relevant legal links in which we exercise significant control over their activity.

Any data, information or parts thereof, transmitted through a voluntary interaction and in the absence of any coercion with RUA - ONLINE COUNTRY S.A. by a visitor, user and / or a Counterparty within the scope of our own business strategy, are considered to be transmitted with good intention, good faith, in an honest business manner and with full acceptance of the legal consequences of such actions, without the intention to make claims in relation to damages and / or to cause any kind of legal liability on us. Any time you begin to have any questions, concerns, concerns, objections or other attitudes or opinions that result from your unwillingness to continue our interactions in a predictable manner or if you wish to revert to previous conduct by removing any information or parts thereof within our management, contact us immediately through the official communication channels publicly presented in Section 13 of our Privacy Strategy and Policy in order to resolve our differences amicably.

We reserve the right to act in a manner consistent with our perfectly legitimate business strategy, including by limiting, denying or restricting your access to information, products and / or services (even in part) at least to the extent necessary, the occurrence of a change in your attitude, behavior and / or sovereign personal decisions regarding our management of your personal data, information and / or data.

Finally, we hereby declare and ensure the recognition, compliance and application of the entire regulatory framework in force of the General Regulation of the European Union on the Protection of Personal Data (including all the provisions referred to, which are related and which are connected to the regulatory framework, and also those that will apply to them beforehand or that will modify in any way any category of them, including even the General Regulation of the European Union on the Protection of Personal Data).

Our Strategy and Privacy Policy was published and enters into force today, March 26, 2021, and has 25 (twenty-five) pages, including 7188 words, 50430 characters, and 43455 characters excluding spaces, as specified by Google LLC Docs , presented below:

IN FORCE

Version 1.0 - March 26, 2021

PUBLISHED