SmartSignature.ro is firmly committed to processing your personal data with the highest level of security.
The protection of your personal data is important to us because we want you to feel safe when visiting our website. We are committed to protecting the personal data we collect, process, and use during your visits to www.SmartSignature.ro.
This document outlines all our organizational practices regarding the processing of personal data and contains important information about your rights concerning the confidentiality of the data you provide. Please read it carefully to understand how we use your personal data. By accessing the website, you accept this Privacy Policy. If you do not agree with our privacy policy, you have the option to discontinue use.
Please note that SmartSignature.ro has the right to modify/update the privacy policy of this website, so we encourage you to consult it regularly!
"personal data" - any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
"processing" - any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction;
"operator" - the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of processing are determined by Union or national law, the operator or the specific criteria for its designation may be provided for by Union or national law;
"processor" - the natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller;
"recipient" - the natural or legal person, public authority, agency, or other body to which personal data is disclosed, whether or not it is a third party. However, public authorities which may receive personal data in the context of a particular investigation in accordance with Union or national law are not regarded as recipients; the processing of such data by these public authorities must comply with the applicable data protection rules in line with the purposes of the processing;
"consent" of the data subject - any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them;
"personal data breach" - a security breach that results, accidentally or unlawfully, in the destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed;
"GDPR" – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
GITS TAX S.R.L., a Romanian legal entity, headquartered in Sibiu, at 8 Bârsei Street, Sibiu County, registered under VAT number 23038470, and listed in the Trade Register of the Sibiu Court under no. J32/21/2008. Contact email: info@SmartSignature.ro, phone: +40 784 205 758, legally represented by the administrator Stefan Coarfă, hereinafter referred to as the Operator.
1.1. Clients and Potential Clients of SmartSignature.ro
If you are a Client of SmartSignature.ro, we may process your personal data for the following purposes:
For providing SmartSignature.ro services: This includes processing orders placed on the site, validating, shipping, and invoicing orders, informing you about the order status, organizing returns of ordered products, etc. The following personal data may be processed, but is not limited to: name and surname, email address, phone number.
Legal basis: The processing of your data for this purpose is based on the execution of the contract between you and SmartSignature.ro, as defined in the Terms and Conditions. Providing your personal data is necessary for the execution of this contract. Refusal to provide your data may result in the inability to carry out contractual relations between you and us.
For placing an order via the website: The following personal data may be processed, but is not limited to: name and surname, email address, phone number.
Legal basis: The processing of your data for this purpose is based on your consent.
For requesting an offer or testing the services for free: The following personal data may be processed, but is not limited to: name and surname, email address, phone number.
Legal basis: The processing of your data for this purpose is based on your consent.
For creating a user account: The following personal data may be processed, but is not limited to: name and surname, email address, phone number, and data entered by the client. If you use your Facebook or Google account to create your user account, SmartSignature.ro will process the following publicly available profile data displayed by those apps: username, email address, operating system, and IP address. If you choose to create an account only before completing an order, your email address will be used to automatically create an account. If you do not complete the order, the email address and other data provided will not be stored, and the created account will be automatically deleted.
Legal basis: The processing of your data for this purpose is based on your consent and the legitimate interest of the Operator.
For issuing payment documents: The following personal data may be processed, but is not limited to: name and surname, phone number, email address, bank account details.
Legal basis: The processing is based on the exercise of a legal obligation as well as the execution of the contract between the parties.
For marketing activities: This includes sending commercial communications regarding the products and services offered by SmartSignature.ro via remote communication means (email, SMS). The following personal data may be processed, but is not limited to: name and surname, phone number, email address.
Legal basis: The processing of your data for this purpose is based on your consent, which you may provide during account creation or afterward in the “My Account Information” section. You can withdraw your consent at any time. To unsubscribe from receiving such communications, you can use the option at the end of each commercial email/SMS. Additionally, you can unsubscribe by accessing the "My Account Information" section. Providing your data for this purpose is voluntary, and refusal to give consent will not have negative consequences.
For improving the user experience on the website: This includes conducting various analyses, generating reports regarding the site’s functionality, and creating user preference profiles. The following personal data may be processed, but is not limited to: email addresses, IP addresses, domain, browser type, and websites visited.
Legal basis: The processing of your data for this purpose is based on the legitimate interest of SmartSignature.ro to continuously improve the customer experience on the website. The data collected for this purpose does not allow for direct or indirect identification.
For handling complaints or requests submitted by you: The following personal data may be processed: name, surname, address, phone number, and any data provided in the message for managing your request.
Legal basis: The processing of your data for this purpose is based on your consent, the legitimate interest of the Operator, and the fulfillment of legal obligations by the Operator.
Source of the data: Generally, all data is provided voluntarily by you, but there may be situations where data can be provided indirectly.
1.2. Website Visitors
If you are a visitor to the SmartSignature.ro website, we may process your personal data for the following purposes:
Improving the user experience on the site: When you browse our website, our servers automatically collect information sent by your browser, which is contained in system logs. This information may include data such as email addresses, IP addresses, browser type, domain, the website visited immediately before entering our site or program, and other data. The data collected about website users does not allow for their direct or indirect identification.
SmartSignature.ro uses this data only to adjust the displayed content to ensure the highest quality of services provided, as well as for statistical, technical, advertising, and functional purposes. This allows us to tailor the site to your needs. Please note that providing your personal data is always voluntary. However, if you do not provide the requested personal data, we may not be able to adjust the content displayed for you, send you the desired information, or enter into contracts with you.
Legal basis: The processing of your data for this purpose is based on the legitimate interest of SmartSignature.ro to continuously improve the customer experience on the website.
For marketing activities: This includes sending commercial communications regarding the products and services offered by SmartSignature.ro via remote communication methods (email, SMS). The following personal data may be processed, but is not limited to: name and surname, phone number, email address.
Legal basis: The processing of your data for this purpose is based on your consent, if you choose to provide it. You can express your consent for processing your data for this purpose by completing and checking the corresponding box in the newsletter subscription form available on the website. To unsubscribe from receiving such communications, you can use the option at the end of each email/SMS containing commercial communications. Providing your data for this purpose is voluntary. Refusing to provide consent for processing your data will not have any negative consequences for you.
For resolving complaints or requests submitted by you: The following personal data may be processed: name, surname, address, phone number, and any data provided in your message for managing your request.
Legal basis: The processing of your data for this purpose is based on your consent, the legitimate interest of the Operator, and the fulfillment of legal obligations of the Operator.
Source of data: If you are a visitor to the SmartSignature.ro website, we will process your personal data that you provide directly when using the website, such as the data you provide in the contact/questions/complaints section, in case you contact us in this manner.
Are we processing sensitive personal information?
Applicable law recognizes certain categories of personal data as sensitive, which require additional protection, including data about health, sexual orientation, ethnicity, or political opinions.
We do not process sensitive data, except for personal identification numbers (CNP) when there is a legal basis for processing.
Furthermore, we do not process data belonging to minors. If we identify data entered by or about a minor, SmartSignature.ro will automatically delete such data.
We assure you that we will process your personal data by minimizing the processing of personal data in accordance with the principles of proportionality and necessity.
If you provide personal data belonging to other individuals, you must ensure that the individual is informed and that you obtain their consent. You are responsible for providing all information and obtaining consent for processing.
Consequences of Withdrawing Consent
When we process your personal data exclusively based on your consent, you have the right to withdraw your consent at any time by submitting a written request either by email to info@SmartSignature.ro or to our office at str. Bârsei nr.8, Sibiu. The withdrawal of consent will not affect the legality of the processing that occurred prior to the withdrawal.
Please note that in certain situations, if you do not provide the requested data, we may be unable to offer the services you requested. This includes being unable to respond to your requests, provide the requested offers, or send you information regarding services, products, or promotional offers, among others.
SmartSignature.ro will process your personal data for the duration necessary to fulfill the mentioned purposes. If you are a client, your data will be retained for the entire duration of the contractual relationship and subsequently, to fulfill legal obligations (e.g., to comply with the legal retention periods for financial and accounting documents).
If you choose to delete your user account, SmartSignature.ro will interpret this as your decision to unsubscribe from commercial communications via email and/or SMS. However, account deletion will not automatically delete all of your personal data. If you wish to delete your data, you have the option to request this, in accordance with the rights detailed in section V. If there are active orders on your account, the deletion request will be processed only after the last order is completed. Data associated with the account will be retained for 365 days, after which it will be deleted.
If you withdraw your consent for data processing for marketing purposes, SmartSignature.ro will stop processing your data for this purpose, but previous processing will not be affected.
After the legal retention periods have expired or following a deletion request, SmartSignature.ro will delete the data unless there are legal obligations to retain it further. Alternatively, the company may anonymize the data (removing its identifying characteristics) and continue processing the anonymized data for statistical purposes or to improve service quality.
We inform you that your personal data may be disclosed to third parties or public/private entities (e.g., courier companies, IT service providers, accounting firms, or public authorities) but only for the purpose for which the data was provided, such as, but not limited to:
• in cases where such communication is necessary for awarding prizes or other benefits to the data subjects, obtained as a result of their participation in various promotional campaigns organized by SmartSignature.ro through the Website;
• for managing, maintaining, personalizing, and improving the Website and services offered through it;
• for data analysis, testing and research, monitoring usage trends and activity, developing security features, and user authentication;
• for sending commercial marketing communications, under the conditions and within the limits set by law;
• when the disclosure of personal data is required by law, etc.
We inform you that there will be no disclosure of personal data to unauthorized persons, and access to it is limited to those directly involved in the data processing process. Your data is secure, and we ensure that the recipients of your personal data provide security and confidentiality in accordance with the purpose for which the data was transmitted and in compliance with your rights.
As a rule, your data will not be transferred to third countries outside the European Economic Area (EEA).
SmartSignature.ro may process personal data belonging to clients only in countries that ensure a level of protection for personal data in accordance with EU Regulation 2016/679 on data protection (“GDPR”), if necessary to provide the Services. In the event that SmartSignature.ro uses a third-party sub-processor to process personal data belonging to clients outside the European Economic Area, SmartSignature.ro will enter into the applicable EU Standard Contractual Clauses with this sub-processor, unless the European Commission has issued an adequacy decision for the country in which the sub-processor processes personal data belonging to clients.
SmartSignature.ro is responsible for facilitating the exercise of any of the rights mentioned below.
Any of these rights can be exercised by sending an email to info@SmartSignature.ro or by submitting a written request to our registered office at str. Bârsei nr. 8, Sibiu.
For the protection of your data and to prevent abuse by malicious individuals seeking access to your data, we may ask you to go through certain identification steps in advance to ensure that you are the person exercising the rights mentioned below. If we receive a request from you regarding the exercise of any of the above rights, we may request additional information to verify your identity before acting on the request.
If the data subject submits a request electronically to exercise their rights, the information will be provided by SmartSignature.ro in electronic format where possible, unless the data subject requests an alternative format.
We will make every effort to respond promptly to any request from you, and in any case, within the time limits specified by applicable legal provisions (usually within 30 days from the date the request is registered). In certain situations explicitly provided for by applicable legislation, we may charge a fee for an access request, taking into account the administrative costs necessary to fulfill the request.
In the event that, as a result of applying legal provisions, SmartSignature.ro is unable to fully or partially comply with a request from the data subject regarding data processing, the applicable exceptions will be communicated to the requester through the response provided by our organization concerning the respective request.
Right of Access
You have the right of access under Article 15 of the Regulation, which allows you to obtain confirmation from SmartSignature.ro as to whether or not personal data concerning you is being processed, and if so, the following information:(a) the purposes of the processing;(b) the categories of personal data concerned;(c) the recipients or categories of recipients to whom personal data have been or will be disclosed, especially recipients in third countries or international organizations;(d) where possible, the period for which the personal data will be stored or, if not possible, the criteria used to determine this period;(e) the existence of the right to request rectification or deletion of personal data or restriction of processing or the right to object to processing;(f) the right to lodge a complaint with a supervisory authority;(g) if the personal data were not collected from you, any available information about the source;(h) the existence of automated decision-making, including profiling, as referred to in Article 22, paragraphs (1) and (4) of the Regulation, and, at least in such cases, relevant information regarding the logic involved and the significance and consequences of such processing for the data subject.
In the event that personal data is transferred to a third country or an international organization, you have the right to be informed about the appropriate safeguards under Article 46 of the Regulation regarding the transfer.
Upon your request, SmartSignature.ro will provide a copy of the personal data being processed.
Right to Rectification of Data:
You have the right to obtain, without undue delay, the rectification of inaccurate personal data concerning you, in accordance with Article 16 of the Regulation. Considering the purposes for which the data were processed, you have the right to obtain the completion of incomplete personal data, including by providing an additional statement.
When possible or necessary, we will make corrections (as appropriate) based on updated information and will inform you about this if applicable.
Right to Erasure of Data
You have the right to obtain from SmartSignature.ro the erasure of personal data concerning you (in accordance with Article 17 of the Regulation), without undue delay, except in certain situations provided for by the Regulation, if one of the following reasons applies:
a) The personal data are no longer necessary for the purposes for which they were collected or processed.
b) You withdraw the consent on which the processing is based, to the extent that the processing is based solely on consent and there is no other legal basis for the processing.
c) You object to the processing carried out in the public interest or for the legitimate interests pursued by SmartSignature.ro or a third party, and there are no overriding legitimate grounds for the processing, or you object to the processing for direct marketing purposes.
d) The personal data have been processed unlawfully.
e) The personal data must be erased to comply with a legal obligation to which SmartSignature.ro is subject under Union law or the law of the member state to which it is subject.
f) Other situations provided for by the Regulation, to the extent that they are applicable.
Right to Restriction of Processing
You have the right to obtain the restriction of processing (according to Article 18 of the Regulation) in the following cases:
a) You contest the accuracy of the data, for a period allowing SmartSignature.ro to verify the accuracy of the data;
b) The processing is unlawful, and you oppose the deletion of the personal data, requesting instead the restriction of its use;
c) SmartSignature.ro no longer needs the personal data for processing purposes, but you request it for the establishment, exercise, or defense of a legal claim; or
d) You have objected to the processing in accordance with Article 21(1) of the Regulation, for the period during which it is verified whether the legitimate rights of the data controller override those of the data subject.
The right to data portability
You have the right to receive your personal data (according to Article 20 of the Regulation) that you have provided to SmartSignature.ro in a structured, commonly used, and machine-readable format, and to transmit it to another operator without hindrance from the Association, if:
(i) the processing is based on consent under Article 6(1)(a) or Article 9(2)(a) of the Regulation, or on a contract under Article 6(1)(b) of the Regulation; and
(ii) the processing is carried out by automated means.
When exercising the right to data portability, your data may be transferred directly from the Company to another operator you explicitly indicate, where technically feasible.
The right to object when processing is carried out in the pursuit of legitimate interests pursued by SmartSignature.ro or a third party
At any time, you have the right to object, for reasons related to your specific situation, to the processing carried out in the pursuit of a public interest or legitimate interests pursued by SmartSignature.ro or a third party, including profiling. In this case, SmartSignature.ro will no longer process your personal data, unless it demonstrates that it has legitimate and compelling reasons for the processing that override your interests, rights, and freedoms, or that the processing is necessary for the establishment, exercise, or defense of a legal claim.
The right to object to the processing of your personal data for direct marketing purposes at any time.
When the processing is carried out for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such purposes, including profiling, to the extent that it is related to direct marketing.
Right to Withdraw Consent
If the processing is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the legality of the processing carried out based on your consent before its withdrawal. The scenario of withdrawing consent does not apply in cases where the legal basis for processing is not consent.
We do not make decisions based solely on the automated processing of your data that would produce legal effects concerning you or significantly affect you in a similar way.
The security of your data is paramount to us, and therefore we apply high-level security systems and maintain the confidentiality of all information provided. We fulfill all of our obligations as a Data Controller, in accordance with legal requirements and guided by our experience.
To ensure the security of your data, SmartSignature.ro implements the following measures:
(i) We control the methods of collecting, storing, and processing information, including physical security measures, to protect against unauthorized access to the system;
(ii) We grant access to personal data only to employees, contractors, and representatives who need to access them to process the data for the operator’s needs. Additionally, by contract, they are required to maintain strict confidentiality, and failure to comply with these obligations may result in consequences, including termination of cooperation;
(iii) We do not share collected data with third parties, except when required by applicable law, such as a request from an authorized authority or court;
(iv) Your personal data is processed primarily for the execution of contracts concluded with you, strictly for the necessary duration to provide the contracted services. If the processing is based on consent, we will use this data until the consent is withdrawn. Additionally, based on legal obligations, we will process the data for as long as we are required to keep the data or documents containing it.
VIII. National Supervisory Authority for Data Processing
You have the option to file a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP) at its headquarters located at:
B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, 010336, Bucharest, Romania.
Alternatively, you can use the online complaint form available on the official website: www.dataprotection.ro.
