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VoiceNews.ro is a project created by Europa FM

Europa FM, a registered trademark of Europe Developpement International-R S.A, a Romanian legal person, with head office in BUCHAREST, 46D-46E-48Sos. Pipera, Building B of Oregon Park | District 2, registered with the Trade Registry under no. J40 / 3402/1999, fiscal code RO 11717605, understands to update its personal data processing policy in order to comply with the new rules introduced by Regulation No. 679/2016.

1. What is this policy?

Through this Policy we inform you:

• Certain important concepts regarding personal data;

• What kind of personal data we process;

• How we use these data;

• Who can submit the data;

• What rights do you have regarding the data.

2. What are personal data?

Personal data” means any information that identifies or can identify you directly or indirectly. This means that personal information includes information such as name, surname, e-mail address, home address, phone number, username, profile photos, location data, etc. These could include unique numeric identifiers, such as your computer’s IP address or MAC address of your mobile device, as well as cookies.

3. What is the processing of personal data?

Processing” means any operation or set of operations performed on personal data or on personal data sets with or without the use of automated means such as collecting, recording, organizing, structuring, storing, adapting or modifying, extraction, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

4. How should data be processed?

1. Fair, legal and transparent;

2. Collected for specified, explicit and legitimate purposes;

3. Adequate, relevant and limited in relation to the purposes for which they are processed (“data minimization”);

4. Correct and up-to-date;

5. Stored in a form which does not allow the identification of the data subject for longer than necessary in relation to the purpose of the processing;

6. Processed in accordance with the rights of the data subject and in a manner that ensures adequate security and protection against unauthorized or unlawful processing and loss.

5. What does this Policy cover?

The policy we are implementing covers all the services of Europa FM (radio programs, contests, events, subscriptions, etc.) regardless of the way they are offered (radio, website, applications, phone, etc.).

The policy applies to the processing of personal data of:

• Our contractual partners such as suppliers, sellers, customers (“Business Partners”);

• Visitors and users of our sites that can be accessed at europafm.ro and omaga.ro (“Users”);

• Mobile Europe Mobile Users (“Application Users”)

• People interested in participating in our radio programs or competitions (“Candidates”);

• Participants in our radio programs or competitions (“Participants”).

 What categories of information do we collect about you?

• Information you provide us

We collect and process your personal data when you interact with us to access the services we provide (for example, the information you provide to us by filling out the forms on our websites listed in Section 1 (“Website “or by correspondence with us on radio, telephone, e-mail, WhatsApp or in any other way.

This includes information you provide when you register to use our Website when you subscribe to our services when you search for an audio-visual program of Europa FM, participate in discussion forums or other social communication activities on our Website when you sign up for participation in Europa FM broadcasts by completing an enrolment form or otherwise when you enrol in competitions, promotions or studies organized by Europa FM and / or its contractual partners and when you report a problem related to our websites.

The information you provide in this way can generally include identification and contact information (name, surname, address, e-mail address and phone number, personal description and photo, age, date of birth, and gender and other information, where applicable, if relevant to the service provided).

Information provided by the technology you are using

Every time you visit our websites, we collect the following categories of data according to the settings you can manage at any time from any page by clicking the “CONFIDENTIALITY” button:

• technical data, for example, this may include the Internet Protocol (IP) Address used to connect your computer to the Internet, connection information, browser type and version, time zone setting, browser plug-ins types and versions, system and operating platform, device type and brand of mobile device; these data may be collected and processed on our behalf through third-party cookies, and you can find more information about it at https://www.europafm.ro/despre-cookies-pe-europafm-en ;

• Data about how you use our services, for example this may include Complete Uniform Resource Locators (URL), a sequence of clicks to, through and from our Websites (including date and time), information or products that you viewed or searched for (including the top read articles, the top access categories, page response times, download errors, the duration of visits to specific pages (including the average time spent on certain pages, viewing certain content or videos) the average time spent in an app, and the number of views in such apps, the average number of articles viewed on our websites, page interaction information (such as scrolling, mouse clicks and crossings), methods used to navigate the page, user behaviour data, and any phone number used to call or any email address used in order to contact our customer service representatives.

• Sensitive data

We will not collect or process sensitive personal data related to you (e.g. information about racial or ethnic origin, political opinions, religious confession or philosophical beliefs, health, sexual life, or sexual orientation), unless

• these sensitive personal data are relevant for a particular purpose in which we process personal data such as your participation in Europa FM broadcasts, as detailed in Section 7 below (for example, if you participate in a politics show, we may ask you about political opinions);

• if you have given us your explicit consent separately.

If you voluntarily provide us with personal data (including sensitive personal data) through your interaction with our websites or by contacting us by phone, e-mail or in any other way, at your own will and not at our request, we will delete such personal data from our systems unless we consider that processing is necessary for a legitimate purpose of Europa FM, unless you have made this data public (for example, in a message forum that are visible to the public) …

 How and on what basis do we use personal data?

We must have a legal basis to process our personal data. It is called “the lawfulness of the processing”.

Sometimes we will require your consent, such as when communicating with you (for example, when you open an account on our site, when you want to participate in certain campaigns, competitions or for marketing purposes) or if we process sensitive data. In these cases, we will separately request your consent, in a transparent way, when providing your personal data. You will then be able to withdraw your consent at any time via the e-mail address dpo@europafm.ro or directly from the account created on europafm.ro if the consent and / or the data were provided through the website. However, withdrawal of consent will not affect the legality of any processing that occurred prior to its withdrawal.

In other cases, we do not require permission to use your personal data, but we use other legitimate processing grounds, that is, when the legal provisions allow us to do so and are appropriate to your rights.

Thus, we can process your personal data:

• to conclude or execute a contract that we have concluded with you (applicable in particular to Business Partners);

• to provide our services;

• to comply with a legal obligation (for example, the applicable accounting and tax laws when you win a prize in a contest);

• when it is necessary for our legitimate interests (or those of a third party) and your interests (for example, to detect and prevent fraud or to ensure IT security and networks), unless your fundamental rights prevail against these interests;

• for a variety of technical, administrative, and operational reasons, such as ensuring that content is presented in the most efficient way for you and your computer; to improve our websites, including its functionality; for the administration of our websites;

• for internal operations, including troubleshooting, data analysis, testing, statistics and research purposes;

• for advertising and marketing, including for specific marketing purposes, so that we offer content, including custom content, that may be of greater interest to you;

• to contact you (for example, responding to a request to keep you updated with our policies and practices to respond when you contact us)

• as part of our efforts to keep our Web sites safe, accurate and up-to-date.

If we require personal data to comply with legal or contractual obligations, the provision of such personal data by you is required. This means that if such personal data is not provided, we will not be able to manage contractual relationships or comply with our obligations. In all other cases, the provision of personal data is optional and you are not required to provide it.

We may also process your personal data, such as your identification, contact details, and residence address, for the purposes of the possible exercise of our rights or claims against you in the future. This processing is based on our legitimate interest, and we need to exercise our rights in case of possible litigation.

Most often, we will use your personal information in the following situations:

• Users and customers:

For the purpose of providing services, delivering goods and making payments based on relevant contracts (including subscriptions), we may process your personal data, such as identification data, contact details, banking data. This processing is based on the execution of a contract to which Users (especially subscribers) are party or a legal obligation imposed on us.

We may process your personal data so that we can provide you with information about goods or services that we believe you are interested in.

If you are an existing customer, we will only contact you via e-mail, SMS or push notifications via Mobile Applications (where applicable) with information about goods and services similar to those that were previously sold or negotiated with you for sale, unless you have opted previously.

If you are a new customer, we will contact you by electronic means only if we have your prior consent. If you do not want us to use your data in this way, check the appropriate box in the form by which we collect your data in the registration form. If you have installed a Mobile Application and you want to no longer receive push notifications, you can change the settings on your mobile device or the Mobile App settings.

We will not share your personal data with third parties for marketing purposes without your explicit consent (see also the cookie policy on europafm.ro).

We may also use your personal data to measure or understand the program’s preferred content and to provide content relevant to you; to let you participate in the interactive features of our service when you choose to do so; to measure or understand the effectiveness of advertising we offer you and others and to provide you with relevant advertising; and to make suggestions and recommendations to you and other Users of our Websites about products or services that may be of interest to you or them.

• Candidates and Participants:

In connection with your appearance and / or participation in the production or recording of a radio or other media production program, we may collect and process your personal data, including sensitive data as referred to in Section 6 above, for the purpose of your pre-selection, selection, recording, appearance or participation in such productions or recordings for that program or media production and other such programs or productions as well as communicating with you and others in connection with the above (references to all of these together take the form “for the purpose of participating in the Europa FM broadcasts”).

This processing may be based on the legitimate interest of Europa FM or on the performance of a contract to which you are a party (for example, when you fill out an entry form or sign an agreement / contract before such appearance / participation) or consent sensitive data.

In connection with our participation in the contests, we may collect and process your personal data based on your entry to the contest in accordance with the Competition Rules.

Under the same conditions as shown above, depending on the nature or character of a particular radio or other media production (video or audio), we may also broadcast or publish your photos, videos, your audio recordings or audio-visual recordings.

We may also process your personal data within and in connection with certain productions or recordings and with the public dissemination or communication of such productions or recordings for certain journalistic, artistic and / or literary purposes.

For the avoidance of any doubt, the provisions of this Policy do not affect copyright and other intellectual property rights relating to the production and recording of television programs or other media productions.

• Application Users:

In connection with your use of our mobile apps, we may collect and process your personal data, such as identification data, contact information, debit or credit card information, and geographic location data, when:

• sign up to use our Mobile Applications (including free trials) and provide us with information about you;

• provide a comment, rating, or other post using our Mobile Apps;

• interact with us using our Mobile Apps;

• interact with us by other means, such as by telephone, fax, SMS, e-mail, social communication, or posts related to a Mobile Application;

This processing can be based on

• executing a contract to which Application Users are party by registering in such Mobile Applications;

• our legitimate interests in verifying user account data for services provided in the territory in which you ordinarily reside and for detecting and preventing fraud;

• a legal obligation that has been imposed on us;

• your consent to information messages about the programs and services provided by Europa FM and / or our Affiliated Companies, newsletters, promotional campaigns and other marketing information sent by or on behalf of Europa FM and / or our affiliated companies.

8. How and with whom we disclose your personal data

We do not sell your personal data to third parties.

Within the Company, only a limited number of staff, such as Sales, Legal, Production, Marketing, News and IT departments, have access to your personal data according to the need to know (“on a need-to-know basis”). These staff members are subject to confidentiality obligations with respect to personal data. Appropriate technical and organizational measures are taken for the protection of personal data. Company staff members have the right to manage personal data only on Company’s instructions and, if necessary, on service responsibilities.

Personal data may be communicated to governmental authorities and / or law enforcement agencies if required by applicable law or if necessary for the exercise of our rights, including conditions of use, or for the protection of our legitimate interests (including legitimate interests of third parties) in accordance with the applicable laws.

Some of your personal data may also be disclosed to third parties, including:

(i) service providers providing administrative, professional, and technical support to the Company for IT, security and commercial resources support;

(ii) business partners (including partners for contests, sponsors, etc.), suppliers and subcontractors for the execution of all the contracts we conclude with you (including subscriptions to our services);

(iii) advertising agencies and advertising networks who request your information to select and deliver advertising relevant to you. We do not disclose personally identifiable information to advertisers, but we will provide aggregate and anonymous information about our users. We can also use aggregated information to help advertisers reach the type of audience they are targeting. We may use the personal information we have collected from you to respect the wishes of the advertisers by displaying their advertising messages to the target audience;

(iv) analytics and search engine providers that help us improve and optimize our Websites.

The company may also disclose personal data to external consultants (e.g. lawyers, accountants, auditors) if necessary.

We have implemented appropriate safeguards in dealing with our partners to secure this disclosure of personal data.

We may share personal data with our Affiliated Companies and other third parties in the context of certain types of transactions, including in the context of transactions involving a change of control over the Company, the substantial sale of all of its assets or trade restructurings.

The Company wishes to carry out an appropriate prior assessment of the selection of third party service providers and requires these service providers to maintain adequate technical and organizational security measures to protect personal data and process personal data only in accordance with the Company’s instructions. Service providers will be entitled to use subcontractors to provide services to the Company, provided that the subcontractor observes the same data protection obligations as service providers.

9. Storing your personal data and transfers abroad

Your personal data that we collect are stored in the European Union (“EU”) and in the European Economic Area (“EEA”). However, information collected by third parties through cookies (e.g. Google Double Click for Publishers) will generally serve traffic from a data center closest to where it originates traffic. This means that such information, including advertising traffic, can be managed by servers located in the EEA and can be transferred outside the EEA. For more information, see the Cookies Policy https://www.europafm.ro/despre-cookies-pe-europafm-ro.

We do not transfer your personal data outside the EEA unless there are adequate safeguards, including:

• a decision on the suitability of the European Commission with regard to the country or countries of destination;

• a “privacy shield” certification;

• appropriate corporate governance rules;

• an approved code of conduct, along with the binding and enforceable commitments of the data operator or the person empowered by the data operator in the country outside the EU and EEA;

• an approved certification mechanism, together with the binding and enforceable commitment of the data controller or the person empowered by the data controller in a non-EU country and the EEA to apply the appropriate safeguards;

• EU standard contractual clauses approved by the European Commission or standard clauses approved by the National Supervisory Authority (“ANSPDCP”).

10. Your rights

Your personal data is your property, so you have the following rights:

• you can ask us to confirm that your personal data is processed by us or not, to provide you with a copy of your personal data and / or to correct it.

• under certain circumstances, you have the right to ask us to delete your personal data or, under the right of portability, to ask us to transfer part of your personal data to you or to other entities.

• you also have the right to oppose or restrict your personal data processing (for example, the use of processing for direct marketing or certain automated processing (including profile creation)).

• if we have requested your consent to the processing of your personal data, you are entitled to withdraw this consent without any adverse effect on you and without prejudice to the lawfulness of your processing under consent prior to its withdrawal

Please note that your rights described above may be limited in some situations and subject to the applicable laws and regulations on the protection of personal data; for example, your right to oppose the processing of your personal data may be limited if we can demonstrate that we have compelling legitimate reasons to process your personal data that prevails over your interests or a legal provision in force imposes data processing.

When you exercise any of the above, you will need to prove your identity and give us further details to help us respond to your request.

We will not charge a fee to meet your request unless this is permitted by law and, if such a fee is levied, it will be reasonable and proportionate to your request.

If you wish to exercise these rights, please contact us through the contact persons listed below.

We hope we can respond satisfactorily to all your questions about how we process your personal data. However, you also have the right to lodge a complaint with the data protection supervisor. You can file a complaint in the Member State where you live, where you are working or where the alleged data protection violation occurred.

11. How long do we keep your personal data

We intend to retain your personal data only for as long as necessary, in accordance with our Privacy Policy, for a period not exceeding the period required to meet the purposes listed in this Privacy Policy and / or required by applicable law, in accordance with the legal minimum retention periods applicable and / or as necessary to exercise our legitimate rights (and legitimate rights of others).

For example, if you are a Commercial Partner, we will retain your personal information while exercising your contractual relationship with you. If we have a continuing commercial relationship with you as a Commercial Partner (for example, if we can use the same personal data in separate contractual relationships with you), we will continue to keep this personal data until termination our business relationship and the minimum retention period required by law, subject to our Data Retention Policy.

In the case of Application Users, we will retain your personal data for the period when the Mobile Application is downloaded or the period indicated by the relevant legislation, subject to our Data Retention Policy. If you want more information about how much time we keep your personal data, please contact us at office@europafm.ro.

Please be aware that we can process any of your personal data once it has become anonymous without first notifying you.

If we process your personal data under your consent, such personal data will be processed only for the period of your consent, unless you withdraw or limit your consent before the expiration of that period.

12. Data security

We want to keep your personal data safe! That’s why, when we create new services and technologies, we take this principle into account.

We keep your data on our servers and servers hosted by third parties (including cloud-based services). We use appropriate technical and organizational measures to protect your personal data and prevent unauthorized access. We have entered into contractual relationships with third parties providing hosting services and these contracts include obligations on the organizational and technical security of personal data.

You must be careful to keep the confidentiality of all means of authentication (e.g. passwords) used by you to access parts of our Websites, otherwise we will not be able to protect you.

Data transmission over the Internet is not completely secure. While we will do our best to protect your data, we cannot guarantee the security of your data transmitted to our Websites. Once we receive your data, we will use strict procedures and security features to try to prevent unauthorized access.

13. Confidentiality of minors’ data

The Company does not knowingly collect personal identification data on its Websites from people under the age of 16. If a parent or guardian is aware that his children have provided the Company with their personal data, they must immediately inform the Company. If the Company discovers that a person under the age of 16 has provided personal data, the Company will destroy this information on its servers immediately unless the parent or guardian explicitly gives its consent to the processing of to the company’s personal data of the child for the specified purposes.

14. Cookies and social communication widgets

Our Websites use cookies to distinguish you from other users of our Web sites. This helps us give you a good experience when browsing our Websites and also enables us to improve our Website. This processing is based on your consent expressed on our Websites or the settings in your browser. For detailed information about the cookie files we use, how long we use them, and the purposes for which we use them, please see our Cookies Policy https://www.europafm.ro/despre-cookies-pe-europafm-ro . Also, to set cookies, go to the “Privacy” window on your site. When accessing the site, only the cookies required for its operation are set.

Our websites can include social communication features, such as Facebook, Twitter, Instagram, LinkedIn or Youtube buttons. These features can collect information about you, such as the IP address and websites you visit, and set a cookie to allow it to function properly. The processing of this information through interactions with these features is governed by the information note / privacy policy of the company providing them.

15. Links to other Websites

A Website may provide links to websites that the Company does not control. After clicking on a third-party link, you will be directed to the third-party website. If you visit any of these linked websites, you need to review their privacy policies. We are not responsible for the policies and practices of other companies. Our company does not control and assumes no responsibility for the content, privacy policies and notices or practices of third-party websites or services.

16. Contact

For exercising any rights, but also if you have any questions or concerns regarding the processing of your personal data or if you wish to exercise your right, you can contact Europa FM at dpo@europafm.ro or send a letter to Europa FM – 46D-46E-48 Sos. Pipera, Building B of Oregon Park | Sector 2, Bucharest.

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We may update this Policy and notify you of any change by posting the new variant on our Websites listed in Section 1 above. Please consult this Policy periodically for any changes.

Last updated: 12/06/2019