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Privacy Policy

Effective date: December 2023

How to Contact Us
 

Contact our Data Protection Office for privacy inquiries or concerns. We welcome your feedback and are happy to assist you.

 

Contact details are available below:

Data Protection Office
Legal Department
32-34 Drumul Bacriului St.,

Rosu 077042, Romania


Email Address: dpo@corebapp.com

1. Introduction

COREBAPP.COM (hereby “We”, "Us") is a brand and website owned and maintained by Core Business Solutions SRL, a Romanian-based limited liability company with headquarters in Ilfov, registered at The Chamber of Commerce and Industry of Romania with EUID ROONRCJ23/3732/2019 that can be contacted at hello@corebapp.com.

 

COREBAPP.COM has developed this Privacy Statement to explain how we may collect, retain, process, share and transfer your data when you visit our Site or use our Services. This Privacy Statement applies to your Data when you visit Sites or use Services and does not apply to online websites or services that we do not own or control.

 

This Privacy Statement is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our Sites and Services. Please note that our Service offerings may vary by region. Depending on the Sites and Services concerned, this Privacy Statement may be supplemented with additional notices. Supplementary information can be found in the Statement on Cookies and Tracking Technologies. If you feel that we have not fulfilled any of our legal obligation related to your data, be aware that you have the right to file a complaint at any time to the Romanian National Supervisory Authority For Personal Data Processing. It will be highly appreciated if you contact us with any questions about our privacy practices not addressed in this Privacy Statement.

1.1 Processing activities covered

 

This Privacy Statement applies to the processing of Personal Data collected by us when you:

 

  • Visit our websites that display or link to this Privacy Statement;

  • Visit our branded social media pages;

  • Receive communications from us or otherwise communicate with us, including but not limited to emails, phone calls, or texts.

  • Use our products and services where we act as a controller of your Personal Data;

  • Register for, attend, or take part in our events, webinars, programs, trainings, certifications, or contests;

  • Act as or work for a service provider or supplier to us to the extent we acts as a controller with respect to your Personal Data;

  • Are employed by a customer of our products and services where your information has been shared with us in our capacity as a controller (for example, during the contracting process); 

  • Participate in a corebapp communities; or

  • Participate in surveys, research, or other similar data collection facilitated by us.

2. What Personal Data Do We Collect?

The Personal Data we collect directly from you may include identifiers, professional or employment-related information, financial account information, commercial information, visual information, and internet activity information. We may collect such information in the following situations:

  • Registration and use information – When you register to use our Website and/or Services by creating an account, we will collect Personal Data as necessary to offer and fulfill the Services you request. Depending on the Services you choose, we may require you to provide us with your full name, postal code, telephone number, email address, and identification information to create your Account. We may require you to provide us with additional Personal Data as you use our Services, such as company name, full street address, city, state, and country.

  • Transaction and experience information - When you use our Services or access our Sites, for example, to make purchases from our web store (when it will be launched), we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, the amount paid for products or services, and additional information about any funding instruments used to complete the transaction, for example, but not limited to, Device Information, Technical Usage Data, and Geo-location Information.

  • Personal data that you choose to provide us to obtain additional Services or specific online Services – If you request or participate in an optional Site feature or request enhanced Services or other elective functionality, we may collect additional information from you. We will provide you with a separate notice at the time of collection if the use of that Personal Data differs from the uses disclosed in this Privacy Statement.

  • Personal Data about you from third-party sources – We obtain information from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law.

  • Other information we collect related to your use of our Sites or Services – We may collect additional information from or about you when you communicate with us, contact our customer support team, or respond to a survey.

 2.1 Personal Data we collect from other sources

We also collect information about you from other sources, including partners from whom we collect or purchase Personal Data or who provide us with publicly available information which may contain Personal Data. We may combine this information with Personal Data provided by you.

Provision of the services:

  • The Personal Data we collect to provide our products and services may include information you have made publicly available online (such as when using social media sites) or third parties publish that and contains information about you (such as news articles). For a select number of services, we collect this Personal Data from partners who may receive it when you visit or use their services or through the third parties they work with.

  • In addition, the Personal Data we collect to provide our products and services may include location information from third parties, which helps us offer features like identity management and multi-factor authentication.

2.2 Marketing and Advertising.

The Personal Data we collect from other sources for the purposes of tailored advertising includes identifiers, professional or employment-related information, education information, commercial information, visual information, internet activity information, and inferences about preferences and behaviors. We, collect this from third party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs and custom profiles for purposes of targeted advertising, delivering relevant email content, event promotion and profiling, determining eligibility and verifying contact information. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you.

Additional sources: In addition to the aforementioned, we collect Personal Data from the following sources:

  • Another individual at your organization who may provide us with your personal information, which may include Personal Data and special categories of Personal Data, to the extent you consent to providing it and sharing it, for the purposes of obtaining services and assessing our goals related to encouraging diversity within our vendors; and 

  • Only where necessary for security purposes, we may collect information that is publicly available online (such as accessible through search engines or public social media sites), as well as images, physical descriptions, and other pertinent information necessary to address a credible security threat to our employees, events or premises.

3. Why Do We Retain Personal Data?

We retain Personal Data in an identifiable format for the least time necessary to fulfill our legal or regulatory obligations and business purposes. We may retain Personal Data for extended periods than required by law if it is in our legitimate business interests and not prohibited by law. If your Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for as long as required to comply with applicable laws. We will continue to use and disclose such Personal data under this Privacy Statement.

The cookies we use have defined expiration times; unless you visit our Sites or use our Services within that time, the cookies are automatically disabled, and retained data is deleted. Supplementary information can be found in the Statement on Cookies and Tracking Technologies.

4. How Do We Use Personal Data?

corebapp.com uses the collected information in the following ways:

a. We will use your Contact and Billing Information to provide you with access to the Services you have ordered, as well as support services, technical updates, or updates on changes in our usage policies. We may also use your Contact Information to send you company updates and marketing offers when permitted by law or when you have agreed. If you are not a customer of Corebapp.com, we will use your Contact Information only for the purpose for which such information was provided. For example, if you have signed up to receive product information from us, we will use your Contact Information only to send you that information.

b. corebapp stores and uses Service Information to conduct business with you. Our use of the Service Information is also governed by the agreement you enter into with corebapp.com in connection with the Services (the "Terms of Services"). Refer to the Terms of Services for specific confidentiality and data protection provisions.

c. corebapp.com may use third-party service providers to serve advertisements on our behalf across the Internet. These service providers may collect your IP address and non-personally identifiable or de-identified information about your visits to the Site to serve corebapp.com advertisements while visiting other sites. Non-personally identifiable information is anonymous or de-identified and does not reflect your name, address, e-mail address, or other personal data; however, service providers may collect your IP address.

 

d. The Website may allow you to post comments and identifying information, such as the corebapp.com blog. When you post comments in a discussion, this information may appear publicly, such as through search engines or other publicly available platforms. It may be "crawled" or searched by third parties. Do not post any information that you are not comfortable revealing to the public at large.

 

e. We assure you that we use your data only on a legitimate basis, for example. your personal data is collected and processed only:

  • When you order our services – we use your personal data on a contract basis.

  • When you create a personal account on corebapp.com website, we process your personal data to take steps prior to entering into a contract.

  • When you give your consent to process your personal data.

  • When applicable, laws oblige us to process your personal data.

5. How Long Do We Retain Your Personal Data?

Your personal data are processed as long as it is necessary to provide Services to you but not less than we are obliged to process your personal data by applicable law. Your personal data, processed by us based on your consent, is processed and stored until you withdraw such consent. We may retain your information after it is no longer necessary to provide Services to comply with the law, prevent fraud, resolve disputes, troubleshoot problems, and comply with other legitimate obligations.

6. Do We Share Your Personal Data?

corebapp.com uses third-party vendors to perform certain business-related functions. Examples of such functions include data web development services, database maintenance services, and payment processing. When corebapp.com employs such third-party vendors to perform services on its behalf, corebapp.com will only provide them with access to personally identifiable information ("PII") that they need to perform their specific function. Each third-party vendor is required by contract to keep such PII confidential and not to use it for any purpose other than providing services to corebapp.com.

corebapp.com may share PII with entities that are controlled by or under common control with corebapp.com (each an "Affiliate") to assist corebapp.com in providing its Services to you. In that event, any such Affiliate will use PII solely as permitted under this Policy.

corebapp.com may disclose PII if required to do so by law or to comply with a legal obligation or if it believes in good faith that such action is necessary to:

  • if we need to do so to comply with a law, legal process, or regulations

  • to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to corebapp.com.

  • if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity

  • to protect the vital interests of a person

  • with credit agencies and data processors for credit reference checks and anti-fraud and compliance purposes

  • to investigate violations of or enforce a user agreement or other legal terms applicable to any Service

  • to protect our property, Services, and legal rights

  • to facilitate a purchase or sale of all or part of corebapp.com's business

  • In connection with shipping and related services for purchases made using a Service

  • to help assess and manage risk and prevent fraud against us, our Users, and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals and merchants

  • to banking partners as required by card association rules for inclusion on their list of terminated merchants

  • to credit reporting and collection agencies

  • to companies that we plan to merge with or be acquired by

  • to support our audit, compliance, and corporate governance functions

If we decide to engage advertisers to promote our products and services, the advertisers and their advertising networks may require anonymized personal data to serve relevant adverts to you and others. We will never disclose identifiable information about individuals to advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help our advertising partners provide a tailored and targeted campaign relevant to a subsection of our users. In some instances, we may use personal data we have collected from you to enable our advertising partners to display their advertisements to their target audience.

With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorize an account connection with a third-party account or platform. In addition, corebapp.com may provide aggregated statistical data to third parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services. This data will not personally identify you or provide information about using the Sites or Services. We do not share your Personal Data with third parties for their marketing purposes without your consent.

7. Security

corebapp.com maintains industry-standard physical, electronic, and procedural safeguards designed to protect data in our possession from loss, misuse, and unauthorized access. When we transmit highly confidential information (such as a credit card number) over the Internet, we protect it through encryption, such as the Secure Socket Layer (SSL) protocol. However, no transmission or electronic storage method is 100% secure. We regularly test and update our technology to help protect your data. However, such precautions do not guarantee that our Website or the data stored during your use of the Services is invulnerable to hacking and will not be subject to a security breach.corebapp.com makes no warranty, guarantee, or representation that the Website or the Services will be protected from all viruses, security threats or other vulnerabilities or that your information will always be secure. We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration.

 

The security measures include firewalls, data encryption, physical access controls to data centers, and information access authorization controls. While we are dedicated to securing our systems and Services, you are responsible for ensuring and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data we share with a third-party based on an account connection you have authorized.

8. International transfers

Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. The parties mentioned above may be established in a jurisdiction other than your own and outside the European Economic Area and Switzerland. These countries do not always afford an equivalent level of privacy protection. We have taken specific steps, in accordance with EEA data protection law, to protect your Personal Data. If you transact with parties outside the EEA or Switzerland or connect our Service with platforms, such as social media, outside the EEA or Switzerland, we are required to transfer your Personal Data with those parties to provide the requested Service to you.

9. How Do We Use Cookies and Tracking Technologies?

When you visit our Site, use our Services, or visit a third-party website for which we provide online services, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”) to recognize you as a User and to customize your online experiences, the Services you use, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Sites and Services. Certain aspects and features of our Services and Sites are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Sites and Services may be limited or not possible. Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not respond to DNT signals. Review our Statement on Cookies and Tracking Technologies to learn more about how we use Cookies.

10. What Privacy Choices Are Available To You?

You have choices regarding the privacy practices and communications described in this Privacy Statement. Many of your choices may be explained when you sign up for or use a Service or in the context of using a Site. You may receive instructions and prompts within the experiences as you navigate the Services.

Choices Relating to the Personal Data We Collect

  • Personal Data. You may decline to provide Personal Data when it is requested by corebapp.com, but certain, if not all, Services or all Services may be unavailable.

  • Location and other device-level information. The device you use to access the Sites or Services may collect information about you, including Geolocation Information and User usage data that corebapp.com may then collect and use. For information about your ability to restrict the collection and use of such information, use the settings available on the device.

Choices Relating to Our Use of Your Personal Data

  • Online Tracking and Interest-Based Marketing. We work with partners and third-party service providers to serve you advertising using ad-related cookies and web beacons. You can opt out of third-party advertising-related cookies and web beacons, in which case our advertising should not be targeted to you. You will continue to see our advertising on third-party websites. For more information on third-party advertising-related cookies and interest-based marketing and how to opt out of these practices with companies participating in industry self-regulation, visit Your Online Choices.

  • Finding and connecting with others. If available, you may manage your preferences for finding and connecting with others from your account of the Service you use.

Choices Relating to Account Connections

  • If you authorize an account connection to a third-party account or platform, such as a social media account, you may be able to manage your connection preferences from your Account or the third-party account or platform. Refer to the privacy notice that governs the third-party platform for more information on the choices you may have.

Choices Relating to Cookies

  • You may have options available to manage your cookies preferences. For example, your browser or internet device may allow you to delete, disable, or block certain cookies and other tracking technologies. You can learn more by visiting www.AboutCookies.org. You may choose to enable these options, but doing so may prevent you from using many of the core features and functions available on a Service or Site.

  • You may have an option regarding using cookies and other tracking technologies when you use a Service or visit parts of a Site. For example, you may be asked if you want the Service or Site to “remember” certain things about you, and we will use cookies and other tracking technologies to the extent that you permit them.

  • You can learn more about our cookies and tracking technologies by visiting the Statement on Cookies and Tracking Technologies page.

Choices Relating to your registration and account information

  • If you have an Account, you generally may review and edit Personal Data by logging in and updating the information directly or by contacting us. Contact us if you do not have an Account or have questions about your Account information or other Personal Data.

Choices Relating to Communication

  • Marketing: We may send you marketing content about our Sites, Services, products, and products we jointly offer with institutions, as well as the products and services of unaffiliated third parties and members of the corebapp.com corporate family through various communication channels, for example, email, text, pop-ups, push notifications, and messaging applications. You may opt out of these marketing communications we send by following the instructions in the communications you receive. If you have an account with us, you may adjust your communication preferences in your account settings.

  • Informational and Other: We will send communications that are required or necessary to send to Users of our Services, notifications containing important information, and other communications you request from us. You may not opt out of receiving these communications. However, you may be able to adjust the media and format through which you receive these notices.

11. What Are Your Rights?

Subject to limitations set out in EEA data protection laws, you have certain rights regarding your Personal Data. In particular, you have a right of access, rectification, restriction, opposition, erasure, and data portability. Contact us if you wish to exercise these rights.

 

If you wish to complete an access request to all personal data that corebapp.com holds on you, note that photo identity will be required to prove your identity. If you have an account with any of our Services, you can generally review and edit Personal Data in the Account by logging in and updating the information directly. Contact us if you require more information on automated-decision making by using legal@corebapp.com.

You may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws, these rights may include the right to:

 

  • Access your Personal Data held by us;

  • Know more about how we process your Personal Data;

  • Rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete;

  • Erase or delete your Personal Data;

  • Restrict our processing of your Personal Data;

  • Transfer your Personal Data to another controller to the extent possible;

  • Object to any processing of your Personal Data;

  • Opt out of certain disclosures of your Personal Data to third parties;

  • Know what categories of Personal Data are shared for delivering advertisements on non-corebapp.com websites, applications, and services and the types of recipients of such Personal Data;

  • Opt out of the sharing of your Personal Data for delivering advertisements on non-corebapp.com websites, applications, and services;

  • If you’re under the age of 16, or such other applicable age of consent for privacy purposes in relevant individual jurisdictions, opt into certain disclosures of your Personal Data to third parties; 

  • Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making");

  • Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal; and

  • Not be discriminated against for exercising your rights as described above.

 

Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection.

11.2 How to exercise your rights

To exercise your rights, please contact us using the information in Section 14 below. Your Personal Data may be processed in response to these rights. We try to respond to all legitimate requests within one month unless otherwise required by law. We will contact you if we need additional information to honor your request or verify your identity. Occasionally it may take us longer than a month. If you are an employee of a corebapp.com customer, we recommend that you contact your employer’s system administrator for assistance in correcting or updating your information.

Some registered users may update their user settings, profiles, organization settings, and event registrations by logging into their accounts and editing their settings or profiles. To update your billing information, discontinue your account, or request the return or deletion of your Personal Data and other information associated with your account, please contact us by using the information in Section 14 below.

11.3 Your rights relating to customer data

As described above, we may also process Personal Data submitted by or for a customer to our products and services. To this end, if not stated otherwise in this Privacy Statement or a separate disclosure, we process such Personal Data as a processor on behalf of our customer (and its affiliates), who is the controller of the Personal Data (see Section 1 above). We are not responsible for and have no control over our customers' privacy and data security practices, which may differ from those explained in this Privacy Statement. If your data has been submitted to us in our role as a processor by or on behalf of a corebapp.com customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with them directly. Because we may only access a customer’s data upon their instructions, if you wish to make your request directly to us, please provide us the name of the corebapp.com customer who submitted your data. We will refer your request to that customer and will support them as needed in responding to your request within a reasonable timeframe.

11.4 Your preferences for email and SMS marketing communications

If we process your Personal Data to send you marketing communications, you may manage your receipt of marketing and non-transactional communications from corebapp.com by clicking on the “unsubscribe” link located on the bottom of corebapp.com marketing emails, by replying or texting ‘STOP’ if you receive corebapp.com SMS communications. 

You may also turn off push notifications on corebapp.com apps on your device or unsubscribe by contacting us using the information in the “Contacting us” section below.

Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationships with us, such as communications about your subscriptions or event registrations, service announcements, or security information.

12. Can Children Use Our Services?

The Sites and Services are not directed to children under the age of 16. We do not knowingly collect information, including Personal Data, from children or other individuals who cannot legally use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 16, we will promptly delete it unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 16.

13. Changes to this Privacy Statement

We may revise this Privacy Statement occasionally to reflect changes to our business, the Sites or Services, or applicable laws. The revised Privacy Statement will be effective as of the published effective date. If the revised version includes a substantial change, we will give you 30 days prior notice by posting the change on our website. We also may notify Users of the change using email or other means.


14. Contacting Us

You may contact us if you have general questions or concerns about this Privacy Statement and supplemental notices or the way in which we handle your Personal Data. We want to make sure your questions go to the right place:

  • Click here to contact us about your corebapp.com account
    if you are not satisfied by the way in which we address your concerns, you have the right to lodge a complaint with the Supervisory Authority for data protection in Romania.

Our Data Protection Officer can be contacted at dpo@corebapp.com.

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