Preamble

Integrate Investment (ININ) is providing consultancy services, training and sourcing activities, as well as ancillary procurement services.

We are registered with the Romanian National Trade Register Office under the no. J40/19827/2004 and ID Tax RO 16996322.

Our offices are located at 23, Petre S Aurelian Street, sector 1, Bucharest, Romania, 013837.

We can be contacted using the following coordinates: Tel: +40724.587.888, E-mail: office@in-in.ro

In accordance with 2016/679 EU Regulation of European Parliament and Council, on the protection of individuals in respect of personal data processing and the free movement of such data and the repeal of Directive no 95/46 / EC (GDPR), ININ, as data operator, informs when and why ININ processes personal data, how ININ uses it, the conditions under which ININ can divulge them to others, and how ININ stores them under safe conditions.

In this Privacy Statement:

• ‘We/Us’ means Integrate Investment (herein after, sometimes called ININ);
• ‘Third Party’ means someone who is not You or Us
• ‘You’ means any of our client reading this notice.

This Privacy Statement sets out how we use and protect any information that the clients give us and it applies to all IN-IN services. It covers the data shared online, stored in our computer system or in hard copy.

The personal data that We collect in any format and We hold is important to Us and is handled in accordance with this Statement.

We are committed to ensuring that your privacy is protected.

Where We ask you to provide information by which you can be identified when using our website or any of our services, You can be assured that it will only be used in accordance with this Statement.

We will only collect data we need to deliver and improve our services to You and to meet our responsibilities to You.

In this Privacy Statement, We explain how We collect, use, share and protect your personal information when You access our services and our website.

Personal information We collect about You 

The information We collect about You and how We collect it can vary depending on the services You use, how You use the services, and how You have interacted with Integrate Investment even if you aren’t a customer, or what We have obtained from a Third Party with permission to share it with us.

Integrate Investment will process your personal data based on

1. Integrate Investment’s legitimate business interests,for example
   • Direct marketing,
   • Sending suitable communications to you,
   • Monitoring and improving our services,
   • Enhancing the learning experience (for example, tailoring our events/training courses to the audiences attending or sharing information relevant to your studies)
   • Enhancing the networking opportunities that We offer,
   • Managing the data We hold.

Whenever We rely on this lawful basis to process your data, We assess our business interest to make sure they do not override your rights.

3. Compliance with a mandatory legal obligation, including for example accounting and tax requirements, which are subject to internal policies (such as retention periods), procedures.
4. Consent you provide. Consent may be withdrawn at any time by communicating this to office@in-in.ro or by filling the SAR FORM

When We will collect information on You 

We will collect information on you when:

• buy or use any of our services
• register for a specific service or apply for a professional development program
• subscribe to newsletters, alerts or other similar type of information from us
• contact us through various channels or ask for information about a service
• book onto an event/training course/exam
• visit or browse our website (see our cookies policy)
• have given permission to other companies, such as our business or joint-venture partners as well as our third-party suppliers or contractors, to share information about you;
• where your information is publicly available

We may also collect information about you from Third Parties, such as your employer (for instance, where you have been enrolled with educational programs arranged by your employer).

We also collect information from certain organisations, where appropriate and to the extent we have legal grounds to do so. These may include business directories or credit check reference.

The types of information we may have 

We may collect the following information from you when you join our services, place bookings, complete surveys or application forms, provide services and/or goods to us, or purchase r services from/via us:

• your name
• a contact addresses and a contact telephone number
• your bank details
• employment status
• career details – current job/description of role/employer
• employment/start & end dates
• qualifications (where relevant to qualifications, e.g. completion of accredited
• degrees)
• assessment information for qualifications
• examination marks and results and exemption details
• learning opportunities undertaken as part of continuous professional development
• online self-assessment tools use and scoring
• competency questionnaires use and scoring
• skills and interests
• membership status and grade (for cases when you belong to a professional development program (such as, but not limited to the ones developed by Chartered Institute of Procurement and Supply)
• photos and video footage (where captured at our events or video-recorded surveys during examination sessions).

What we do with the information we collect 

We require this information to understand your needs and to provide you with better services, and, for the following reasons:

• to respond to your enquiries
• to administer your trainee logger
• allow you access to the services
• to fulfil our obligations arising from any contracts we concluded with you and for their general management – this include providing the products and services that We or our Third Parties are offering under the contractual obligations
• to administer and manage the guided learning and examination processes, including the performance of the trained person
• to organize and deliver events and training courses, and fulfil any specific needs you may have
• process payments from you or to Third Parties related to the services requested by you
• maintain activities record
• evaluate your professional attributes, where necessary for certificates and diploma applications
• notify you when required for examination or other specific actions
• provide you with information relating to your studies
• provide you with news, products, services updates
• invite you to provide feedback on our services
• invite you to take part in research campaigns
• using photo and video footage in post-event publicity (please notify us when booking into an event if you object to this)
• monitor how you respond to our communications
• to allow us to monitor usage statistics as a basis for future improvements to relevant website processes
• to monitor and improve our services
• to meet security and safety requirements where you attend an event or training course
• to verify your identity
• to enable us to track system use by user
• internal record keeping
• to periodically conduct reviews and audits on the data we hold on you.

Your rights in controlling your personal information 

You can ask Us to make changes in how your data is handled and We will respond promptly should a request be made.

You have the following rights over the personal data about you that we are holding and processing:

Right to be informed

This provides you with information in relation to how your data is processed.  This ensures that we are transparent about what we will do with the information you supply to us.

Right of access 

You may request details of personal information which we hold about you under the General Data Protection Regulation (“Subject Access Request”). This is generally free of charge, however where a request is unfounded or excessive, or you ask for further copies of the same information, then we have the option to charge a reasonable fee based on the administrative cost of providing the information or, alternatively, we can refuse your request. Each request will be assessed on a case by case basis.

Before we provide the personal data to you, we must be satisfied that you are entitled to it. If someone is making a request on your behalf, then we will require a written authorization signed by you and evidence that it is a genuine request, e.g. proof of their relationship to you.

Right to request information held is accurate and how to update it 

If you believe that any information we are holding on you is incorrect or incomplete, please email us and we will respond as quickly as possible.

Right to erasure

In certain circumstances, you may ask us to delete information about you and stop processing or publishing it (“Right to be Forgotten”).

Right to object to the processing that is likely to cause you damage or distress

Where you challenge the accuracy or lawful processing of your information, we will consider this.

Right to object

We will ensure that we have the right consents in place for sending you information. You can unsubscribe from our mailings and remove your details at any time. If you wish to stop receiving communications from us, you will be able to do so by contacting us.

Rights related to automated decision making   

If there is additional profiling based on the information we hold, then you can object to us making decisions about you based on such processing.

Recipients whom We may share your data with

In performing our services We might be in the position to share your data with:

1. providers of Third Party application used for the purposes of delivering services to you
2. venues hosting events organized by Us (where necessary to fulfil any specific needs you may have or to meet security and safety requirements)
3. other attendees in our events (including specific networking events):
   • as a rule, we share your name and business contact details via an attendee list, and/or screen presentation. When so the case: please notify us when booking if you don’t want your data to be shared in this way.
4. regulatory bodies in Romania (where necessary for regulatory/audit requirements)
5. Chartered Institute of Procurement and Supply
6. Examination Centre
7. Your employer when You are enrolled into an educational program sponsored by your employer. If not the case and a request from your employer would be made in respect to access to your performance, We will only share information about you with your consent.

How long we hold your information for

We have a variety of obligations to keep the data that you provide us. These include ensuring that transactions are processed correctly, identifying fraud, and complying with any laws and rules that apply to Us, our partners and/or to our service providers.

We have a Data Retention Policy to ensure that your data is not held for longer than is necessary.

We will hold the information that you provide to Us while you are actively being part of our services. However, We may keep certain data to meet our obligations but for no longer than required or permitted by law.

Where your information is stored

Your information is held securely within the EU. However, for specific categories of services, the data are stored and processed also in UK, with consideration to CIPS Brands data protection standards.

Keeping your personal information secure

In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

ININ’s website are maintained on a secure server.

Restrictions are in place within ININ system so that users only have access to data that is required for them to do their job.

Checks are made regularly by our IT service provider to ensure data quality is maintained.

We also have in place multiple security systems scanning all incoming and outgoing email before being accepted or sent out. Where appropriate, senders will be informed that their message has been held by our systems and if held in error the message can be released and successfully sent.

The security systems will block and hold messages that contain viruses and malware, spam messages or other inappropriate content.

If you feel that the security of your interaction with us has been compromised, please contact us immediately. If such a disclosure does occur, we will contact you as soon as possible to explain what has happened and take all steps required of us to meet our obligations under the legislation.

We use cookies (small text files stored in your browser) and other techniques such as web beacons (small, clear picture files used to follow your movements on our website). For more details on this and how to opt out of these, please see the cookies section of this policy.

Further, We may publish or share anonymised statistics under the condition that no personally identifiable information can be derived from such statistics by third parties.

Complaints

If you wish to make a complaint about how we have processed your personal information, and we cannot resolve it, then you have the right to lodge a complaint to the “Autoritatea Nationala de Supraveghere a Prelucrarii Datelor cu Caracter Personal”, 28-30, G-ral. Gheorghe Magheru , Sector 1, 010336, Bucharest, Romania Tel: +40.318.059.211 or +40.318.059.212; E-mail:anspdcp@dataprotection.ro

Notification of changes 

We keep this privacy statement under regular review and will update the information on this notice. Please check this page from time to time to ensure that you are aware of any changes.